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Relationship Disclosure

Services and Investments

Rothenberg Wealth Management (“RWM”) is a Level II full-service stock broker. We provide investments for RRSP, RRIF, TFSA, RESP, RDSP, LIRA and LIF and non-registered accounts as described below: 

  • Cash and cash equivalents such as T-bills and money market instruments
  • Fixed income or debt securities such as bonds and debentures 
  • Guaranteed Investment Certificates (GICs) 
  • Equities 
  • Investment funds including Mutual Funds and Exchange Traded Funds (ETFs)
  • Alternative investments such as Principal Protected Notes and Principal at Risk Notes 
  • Options trading

Account Type and How Your Account Will Operate

Your account will either be Advisory, or Managed. For advisory accounts, orders are entered after your discussion in person, over the phone, or by video call with one of our Wealth Management Advisors.

RWM uses National Bank Independent Network (NBIN) to execute the orders.

RWM gives you comprehensive support, tools and resources to help you make informed investment decisions. We provide you with investment advice based on your investment objectives, risk tolerance and investment goals.

Alternatively, your account transactions may be supervised by our Wealth Management Advisors based on your investment goals if you open a managed account.

The Fees You Will Be Paying and How They Will Be Calculated

The commissions you will pay for trades and the fees related to the operation of your account are included in the enclosed FEE Schedule. These fees will have an impact on the investment returns you will experience, and the overall impact of those fees will compound over time.

 
ANNUAL COST FOR REGISTERED ACCOUNTS
Balance is over $200,000 $0
Below $200,000 $100
Tax- Free Savings Account $100
Registered Education Savings Plan $100
 
TRADING – Stocks and ETFs
Up to $ 25,000 1.35% or $85 minimum
$ 25,000 – $ 50,000 1.10%
$ 50,000 – $ 100,000 0.85%
$ 100,000 and over 0.60%
 
BONDS
Purchase 0.4% per year of term to a maximum of 3%
Sell 0.3% per year of term to a maximum of 1%
 
COST-BASED ACCOUNTS
$1 – $1 million in assets 1.20% per annum deducted monthly
Next $1,000,000 0.75% per annum deducted monthly
Next $1,000,000 0.50% per annum deducted monthly
Above costs are blended
   
MUTUAL FUNDS No cost to purchase or switch. Costs if sold before a determined time frame.
   
OTHER  
Partial account transfer-out $75
Full account transfer-out $175
Certificate registration $100
Partial registered plan de-registration $75
Full plan de-registration $100
Swap fee (per security) $50
Unscheduled RRIF withdrawal $50
Wire transfer $50
Certified cheque $50
Cheque – not sufficient funds/stop payment $50
DAP charge (per transaction) $75
Ineligible mutual fund (per month/per fund) $35
Drip enrollment (initial fee) $35
Securities held in safekeeping (minimum per month) $35
Research fee (per hour) $75
Estate settlements $175
Any fees for services provided by other financial institutions will be charged through at cost.

 

Pre-Trade Disclosure of Charges

Before accepting an instruction from a client to purchase or sell a security, in an account other than a managed account, the Wealth Management Advisor will disclose to the client: 

  • An exact or estimate amount of the charges paid directly or indirectly, in respect to the purchase or sale.
  • In the case of certain products, any deferred charges that may apply at the time of sale.
  • Whether there are trailing commissions with respect to the product.

Suitability Assessment

Your Wealth Management Advisor is responsible for making investment suitability determinations. By completing a Pocket Risk Questionnaire and a New Client Account Form (NCAF), your client profile is created, which will assist your Wealth Management Advisor in determining a suitable investment portfolio. This process will also determine your:

  • Overall financial situation
  • Investment objectives
  • Risk tolerance
  • Primary purpose of the account(s)
  • Time horizon
  • Investment knowledge
  • Additional Information you may providee

Furthermore, suitability will be reevaluated whenever placing an order, securities are transferred or deposited into the account, a recommendation is made and in the case of material change to your financial situation. Suitability will also be conducted in regular reviews (by phone, video call or in person), if any significant event occurs in the market or with a specific holding, or if there is a change in the Wealth Management Advisor responsible for your account(s). All investment actions must put the client’s interests first.

How we monitor portfolio risk

All portfolios have a numerical risk limit based on the risk tolerance and risk capacity of the client, ranging from 1.0 for the lowest risk to 5.0 for the highest risk. Each security in the portfolio also has a risk number assigned using the same scale. We then calculate the weighted average risk score for your portfolio. We monitor your portfolio to ensure that the calculated risk score remains at or below your risk limit. In order to make allowances for market value fluctuations, we generally permit a risk score to go a maximum of 0.5 points higher than the risk limit before portfolio changes are required.

Content and Frequency of Our Reporting to You 

Trade Confirmations

When you buy or sell securities, a trade confirmation will be sent to you using your preferred communication method (electronically if you are signed up for e-services or by physical mail), generally within one business day of the trade date. The confirmation will contain the following information:

  • The name of the security that was traded, the total amount paid by you for a purchase or paid to you on a sale.

You will be provided with a copy of the NCAF that is completed at time of the opening of the account and any “Client Update” forms which will be completed on a regular basis or when there is a material change to your information.

Account Statements

During months where there is trading activity in your account (exclusive of interest or dividend payments), you will receive a statement of account shortly after the end of the month. If no trans-actions have occurred, statements of account will be provided to you after each Calendar quarter: Calendar quarters are March 31, June 30, October 31 and December 31. Each statement will contain the following:

  • Your name, address and account number
  • The type of account
  • Period covered by the statement
  • Name and telephone number of the location where the account is maintained
  • Details of each trade, the name of the security and the dollar value of the trade
  • Details of all non-trade transactions such as dividends interest earned and paid, transfers and any other transactions that occurred in your account over the previous period
  • Total holdings, including name, number of units and representative market value of all securities held at the end of each reporting period

Investment Benchmarks

Investment benchmarks generally provide a broad measure of the return generated by specific asset classes over a given period. Some common broad-based market benchmarks include the S&P/TSX Composite Index, and the S&P 500. Measuring the return of your portfolio against appropriate benchmarks can be an effective way of assessing the relative performance of your investments.

Complaint Handling 

Occasionally a RWM client may express concern relating to the performance, trading or a regulatory contravention on the brokerage account(s). Any concern should be promptly addressed to Christopher Mack, the Designated Complaints Officer. Within five business days, an acknowledgment letter providing a summary of the matter will be sent to you. Included in that letter will be a brochure provided by the Canadian Investment Regulatory Organization (CIRO) specifically addressing the com-plaint process, CIRO enforcement as well as Ombudsman and independent arbitration options. RWM will continue to maintain regular contact with you by phone or electronically until the issue is resolved.

If you are not satisfied with the response or resolution we have provided, you have other options available to you:

  • Submit a complaint to CIRO(note that you may file a complaint with CIRO at any time during this complaint process). If CIRO opens an investigation file they will notify you within 90 days and every 60 days thereafter until the conflict is resolved.
  • Free mediation services
  • Arbitration 
  • The Ombudsman for banking services and investments if a request is made within 180 days of initial conflict acknowledgment letter

Avoiding, Managing, and Disclosing Conflicts

RWM has policies and procedures in place to assist in identifying and minimizing any conflicts of interest. If there is a potential of a conflict of interest, we inform our clients or potential clients. For full details on our conflict of interest policies, please speak to your Wealth Management Advisor.

Checklist of Documents

We have provided you with copies of the following documents relating to your account: 

  • RWM Account Forms 
  • Relationship Disclosure 
  • Commission and Fee Schedule 
  • Strip Bond Disclosure Document 
  • Canadian Investor Protection Fund (CIPF) 
  • An Investor Guide to Making a Complaint (CIRO) 
  • Conflicts of Interest Disclosure 

Shared Premises Disclosure

RWM shares offices with its sister company, Rothenberg & Rothenberg (“R&R”), a company that acts as a Life Insurance and GIC broker. RWM follows CIRO rules regarding Outside Business Activities and Conflicts of Interest.

Privacy Agreement

  1. Collection and Use of Personal Information by RWM

When you open an account with RWM, we will obtain personal in-formation about you which will be kept on file in accordance with industry regulations. Only authorized individuals and entities have access to this information. The information that we collect allows us to identify you, to protect you against possible fraud, and to assess your potential investment needs so that we may suggest products and services to you which are appropriate for you and to comply with legal and regulatory requirements.

While RWM does not normally record its telephone conversations with clients, it may be the case that we could obtain personal information from you by phone, if you should happen to call us on one of our taped lines (trade desk, compliance). We record these lines in order to ensure that we have an accurate record of conversations.

  1. Social Insurance Number

If you are an individual, RWM may collect, use and disclose your SIN for income tax reporting purposes.

  1. Disclosure of Personal Information to External Sources

RWM may from time to time disclose your personal information to external sources such as credit agencies, other financial institutions and other parties who provide services to RWM, and may also rely on external sources to collect personal information about you.

  1. Affiliated Companies

RWM does not disclose your personal information to affiliated companies for non-essential services. Employees of related companies may have access to your personal information in that they provide certain services such as trade execution for RWM accounts.

  1. Consent

Your consent is required before we may provide your information to any third parties. The consent that you provide to RWM with regards to the collection use and disclosure of your personal information may be cancelled by you at any time by providing written notice. RWM does not require your consent to collect, use and disclose your personal information where such collection, use and disclosure is reasonably required in the normal course of providing service to your account, or for the collection of a debt owed to RWM by you, or to a law enforcement agency, securities regulatory authority, Self-Regulatory Organization or to legal counsel for the purpose of obtaining advice.

By opening an account at RWM, you are providing consent to RWM to collect, use and disclose your personal information as set out in this agreement.

  1. Corrections to Personal Information

You may review the information you have provided to RWM and make corrections to it. We may request that you provide corrections in writing. You may address corrections, questions or privacy-related complaints to Christopher Mack, the Chief Compliance Officer at RWM.

  1. Retention of Personal Information

RWM may retain your personal information on file after you cease to be a client of RWM for as long as RWM requires such information or as long as required by our regulatory requirements.

BY OPENING AN ACCOUNT AT ROTHENBERG WEALTH MANAGEMENT, YOU ARE PROVIDING CONSENT TO ROTHENBERG WEALTH MANAGEMENT TO COLLECT, USE AND DISCLOSE YOUR PERSONAL INFORMATION AS SET OUT IN THIS AGREEMENT.

Protection for Vulnerable Clients

RWM prioritizes the protection of our clients against financial exploitation. RWM may place a temporary hold on an account if there is reasonable belief that:

  • The client is a vulnerable client
  • Financial exploitation of the client has occurred, is occurring, has been attempted or will be attempted
  • The client does not have the mental capacity to make decisions involving financial matters

If a temporary hold is placed on an account, RWM must provide notice to the client as soon as possible. Within 30 days of placing the temporary hold, and every subsequent 30 days thereafter, RWM must either revoke the hold, or provide the client with notice of the decision to continue the hold and the reasons for that decision.