We are excited to be a part of your wealthcreation journey. Before we start, we want to make sure that you have all theinformation you need to make well-informed financial decisions. ThisRelationship Disclosure document is something that we are required to provideto all new clients under applicable securities laws. Besides meeting ourobligations under the law, we see it as a good opportunity to explain how wecan work together in the best possible way. It is important that you:
When you open your account(s) with us weask you a series of questions about your personal circumstances. We will alsoask you to update this information from time to time, and you can update yourinformation at any time in App. It is important that you provide us with fulland accurate information, and that you tell us whenever there is a significantchange to this information.
You should understand the potential risksand returns of your investments. IISI does not provide advice. If you think youmight need advice, you should consult professionals, such as a financialadvisor, lawyer or accountant. You should also familiarize yourself with anycommunications we provide to you, as there might be important information foryou to consider.
Any concerns? Reach out to us at any timeby clicking the in-App chat icon.
Make sure you know what’s going on. Reviewyour statements and confirms to be certain everything is as it should be. If itlooks like something is off, please let us know as soon as possible.
Self-Directed Accounts are offered byIntelligentInvesting Securities Inc. (“IISI”), a member of the CanadianInvestment Regulatory Organization (“CIRO”) and the Canadian InvestorProtection Fund (“CIPF”). IISI is an Order Execution Only broker. That meansthat we are not able to provide recommendations or advice, and we don’t checkto make sure that your trades are suitable for you. When you give usinstructions, we enter your orders without considering your personal andfinancial circumstances, investment needs and objectives, investment knowledge,investment time horizon or risk profile. Youare responsible for making your own investment decisions. We do notdetermine that the investments and account type are appropriate for you. Forexample, we do not provide advice about whether you would benefit from aregistered or a non-registered account. Want to do things on your own? You’rein the right place.
The trading and investment services areprovided by IISI through the IntelligentInvesting App (the “App”).
IISI offers cash accounts and registeredaccounts like RRSPs and TFSAs. We offer a selection of individual stocks andETFs that trade on major North American exchanges, including the Toronto StockExchange, the New York Stock Exchange, the Nasdaq, and more. Right now, IISIdoes not offer mutual funds, individual bonds, or options, among other things.We do not offer in house products such as investment funds managed by IISI or arelated company. We are always considering what to offer you, and as we expand thelist of securities and services we offer we will let you know.
In the investment management industry, many“introducing brokers” use “carrying brokers” to provide certain services. CIInvestment Services Inc. (“CIIS”)acts as Carrying Broker for IISI and is its agent for clearing, settlement,record keeping and as required, custodial services provided to your account.
As IISI’s agent, CIIS will accept andsettle trades in compliance with instructions IISI provides on your behalf.CIIS will be responsible for issuing confirmation slips, statements of accountand tax reporting information. IISI is responsible for delivering securities toCIIS who then assumes custodial and safe keeping responsibilities.
As an Introducing Broker, IISI isresponsible for the execution, control and supervision of your transactions.IISI is also responsible for the opening and approval of client accounts. IISIand CIIS are both responsible for adherence to all applicable bylaws andregulations of our applicable Self Regulatory Organization(s).
IISI self-directed investment services areaccessible via your smartphone or other connected device. All reporting to youby IISI, including account statements, confirms, and any additional statementswill be provided in-App.
In addition, in accordance with regulatoryrequirements, CIIS must deliver custodial documents including investmentstatements directly to you, which they will do via the FutureVault platform.
Trade confirmations (sometimes called“confirms”) provide a record of buying or selling a security. Confirms containimportant information like the name of the security, the price, and any fee,charge, commission or spread charged in connection with a transaction. Youshould check your trade confirmations to ensure that they properly reflect yourtransaction. Confirms will be provided to you within one business day of yourtrade date.
Account statements, showing all activity inyour account(s), will be provided on a monthly basis. These monthly statementswill also show the original cost of the securities held in your account(s).
Once per year, IISI will provide you with areport showing the performance of your account(s), expressed in percentageterms.
Once per year, IISI will provide you with areport showing the fees and charges that were applied to your account(s).
Some investors like to compare theperformance in their account(s) against a standard, known as a “benchmark” inthe investment industry. Common benchmarks include the performance of an index,such as the S&P 500 (to use a common USD-based benchmark) or theperformance of the S&P/TSX Composite Index. While benchmarks can be useful,they also have inherent limitations, as they don’t take into account thingslike taxes and exchange rates, and don’t necessarily reflect what you might ownin your account(s). If you decide to use a benchmark, it’s important that youunderstand the advantages and limitations of benchmarks and carefully selectthe right benchmark for your needs.
IISI doesn't charge commissions for trades.Our clients pay a monthly fee (the “MonthlyFee”) for the brokerage, trading and investment management servicesprovided by IISI and its affiliate IntelligentInvesting Wealth Management Inc.(“IIWMI”).
The Monthly Fee is collected by IIWMI fromyour funding account in accordance with your PAD agreement with IIWMI, aportion of which IIWMI allocates to IISI.
If a linked funding source lacks sufficientfunds to cover the full Monthly Fee, or a funding source has otherwise beendisconnected, IISI reserves the right to sell shares in the client’s Accounts,to pay such Monthly Fee.
Like all brokerages, IISI charges a“spread” on foreign currency transactions. More details are available in yourSelf-Directed Account Agreement. In certain circumstances, and for certaintypes of things you might ask us to do for you, there may be an additionalcharge. A list of these fees and charges can be found at this link. IISI will provide you with atleast 60 days’ advance notice before increasing or adding any new fee orcharge.
Some products, like investment funds,charge fees that are not charged to you directly but which erode yourinvestment performance. IISI does not offer mutual funds, but you can buy ETFsthrough IISI which do charge these types of fees. IISI never receives any ofthese fees, which are retained by the fund companies themselves. All fees andcharges affect investment performance because of the effect of “compoundinterest”. Every dollar taken out to cover fees is one less dollar left toinvest in your portfolio to compound and grow over time.
We may support multiple funding optionsfrom time to time. Our current funding options include Interac e-Transferrequests, which are provided in partnership with Peoples Trust Company. We, orany of our processing or financial institution partners, may impose limits onthe amount of money that you are allowed to send, receive, or request throughany of our funding methods.
Funds added by Interac e-Transfer requestare generally confirmed in minutes, however processing times for fund movementmay vary and may take significantly longer depending on a number of variables,including the time it takes to pass through any applicable counterparties,partners and/or affiliates. As with all payment methods, intermediary banks andfinancial institutions may be involved in the money movement process, and theymay from time to time experience outages, insolvency or other issues. You shouldinform yourself about payment methods, their associated risks, and theprotections available to you. We do not anticipate that any issues experiencedby these intermediaries should impact you as a client, though in rare cases itmay be possible. Nevertheless, you should be aware that disruptions and serviceissues are possible where a provider experiences such an occurrence.
When you created your IntelligentInvestingProfile and open your account with IISI we ask you to provide us with contactinformation for a trusted contact person (a “TCP”). There are two circumstances when IISI might contact yourTCP: if we are concerned that you are the victim of financial exploitation, orif we are concerned about your mental capacity as it relates to your ability tomake decisions involving financial matters. In other words, we will onlycontact your TCP for your protection. In that case we might have to discloseinformation about you or your account. If that happens, IISI would be requiredby law to carefully follow a defined process to balance your individual rightswith our obligation to ensure you are protected.
Similarly, in circumstances where IISIbelieves that you are vulnerable to financial exploitation (because of anillness, impairment, disability or aging-process limitation that places you atrisk of financial exploitation) and such financial exploitation has occurred,is occurring, has been attempted or will be attempted, IISI is required by lawto place a temporary hold on your account, which would temporarily prevent anywithdrawals or transactions in your account.
In that case, IISI would provide notice ofthe temporary hold and the reasons for the temporary hold to you as soon aspossible after placing the temporary hold, and, within 30 days of placing thetemporary hold and, until the hold is revoked, within every subsequent 30-dayperiod, either revoke the temporary hold, or provide you with notice of ourdecision to continue the temporary hold and the reasons for that decision.
If you need to update your TCP, pleasecontact our Customer Support team using the in-App chat.
IISI’s parent company is Orion DigitalCorp. (“Orion Digital”), a publiccompany (NASDAQ:ORIO) (TSX:ORIO) whose shares can be purchased in the App.Under securities law there are certain rules regarding trading in securities ofcompanies that are “related” or “connected”. A person or company is a “relatedissuer” to IISI if, through the ownership of, or direction or control over,voting securities or otherwise, (i) the person or company is an influentialsecurityholder of IISI, (ii) IISI is an influential securityholder of theperson or company, or (iii) if each of them is a related issuer of the samethird person or company. Because IISI is a wholly-owned subsidiary of OrionDigital, it is a related issuer of IISI.
Similarly, a person or company distributingsecurities is a “connected issuer” to IISI if there is a relationship betweenthe person or company and IISI, another related issuer of IISI, or a directoror officer of IISI, or the related issuer of IISI, that might lead a reasonableprospective purchaser of the securities of the connected issuer to questionwhether IISI and the issuer are independent of each other for the distributionof the issuer’s securities.
Certain IISI officers and directors, and adirector of Orion Digital, are officers and directors of companies that issueand/or provide management services to non-prospectus qualified investmentfunds. However, as IISI does not offer non-prospectus qualified securities,currently there are no connected issuers whose securities could be tradedthrough IISI.
When you create your IntelligentInvestingProfile, your personal information is collected by IntelligentInvestingFinancial Technologies Inc. (“IIFTI”)and shared with IISI to facilitate the opening and servicing of yourself-directed account. If you also hold an account with IIWMI, your personalinformation may be shared between IISI and IIWMI to manage your relationshipacross IntelligentInvesting products, maintain accurate and consistentinformation about you, and service your accounts.
In accordance with our Privacy Policy, onoccasion services may be provided to you by other companies related to IISIincluding customer service, anti-money laundering controls, cybersecurity, andcompliance, among others. Sharing information and these services amongaffiliated companies allows IISI to draw on a deeper pool of resources and tooffer you the best possible protection and client experience. For moreinformation about how your personal information is collected, used, and shared,please refer to our Privacy Policy.
When you open an account with IISI weprovide you with a variety of documents. These documents are always accessiblein app. These documents include:
If you open a registered account, such asan RRSP or TFSA, we will also provide you with the applicable declaration oftrust documents.
Securities regulations in Canada requireall securities brokers to comply with certain rules in relation to conflicts ofinterest (“COIs”). While IISI seeksto avoid COIs whenever possible, COIs are an aspect of all relationships, bothpersonal and business. As a part of our COI management process, we provide youwith information about the nature and extent of the COIs that may affect ourrelationship, and about how IISI addresses them in order to resolve them inyour best interests.
A COI is a situation in which anorganization or a person is involved in multiple interests, financial orotherwise, and serving one interest could involve working against another.Typically, this relates to situations in which the interest of an individual ororganization might adversely affect a duty owed to make decisions for thebenefit of another. IISI has a special responsibility to identify, disclose,and address COIs and potential COIs in its clients’ best interests. Where IISIis unable to address a COI in its clients’ best interests, it is required toavoid the COI altogether.
This COI disclosure is intended to provideyou with the information necessary for you to make an informed decision aboutyour relationship with IISI. If a new COI emerges in the course of ourrelationship we will disclose that to you and address it in your bestinterests. If that is impossible for any reason (if addressing it anddisclosing it would violate the law, for example) then we are required to avoidit altogether. We encourage you to ask us questions if you have any concerns.
Below is an alphabetical list of IISI’sidentified COIs. This list will be reviewed regularly and updated as necessary.
IISI could be incentivized to choose anexecuting broker based on a benefit it gains rather than the broker’s abilityto provide best execution and other services for its clients. To control thisCOI, ISII reviews the best execution policies of its executing brokers on anannual basis to ensure they always offer best execution.
In some instances, IISI may be compensatedindirectly, e.g., for transactions involving a foreign currency exchange, inwhich IISI receives compensation based on the difference between the priceclients pay for the currency and the price IISI pays for the same currency.This is a standard practice in the securities industry which IISI discloses toits clients.
If IISI participates in an offering that islimited (such as a “hot” new issue) it may have incentive to allocate sharesunevenly. To control this potential COI IISI has a Fair Allocation policy. TheFair Allocation Policy is enforced by the Compliance Department.
IISI and its agents can be influenced bygifts received from third parties. To control this potential COI, IISI requiresthat all gifts be reported to the Compliance Department for assessment. Giftsexceeding a materiality threshold are forbidden.
The interests of IISI’s clients must alwaysbe given priority over those of IISI and its employees. For this reason, whenIISI receives two orders for the same security at the same price (or a betterprice), the order coming from a client is always executed prior to the one fromIISI or one of its employees.
IISI employees sometimes engage in businessactivities outside of their core responsibilities at IISI. Such activities maypresent a COI in terms of time commitment, potential for confusion on behalf ofclients, or competing duties. IISI closely monitors and controls its registeredemployees’ outside business activities and requires pre-approval of suchactivities.
IISI will occasionally offer you productsand services that are provided by related companies. IISI neither pays norreceives compensation for these referrals. These products and services mayinclude the Intelligent Investing Wealth Management services, Mogo mortgage andline of credit products and more.
You may opt out of these marketingofferings at any time. This may constitute a conflict of interest because IISIhas an incentive to promote products and services provided by related companiesover similar products and services offered by unrelated third parties. IISIperiodically reviews these offerings against those offered in the broadermarketplace to ensure that they are competitive.
IISI is a wholly owned indirect subsidiaryof Orion Digital, a public company listed on the TSX and the Nasdaq. If youinvest in Orion Digital securities, the relationship between Orion Digital andIISI will be indicated on your trade confirmations and statements.
While IISI always strives for excellence,on occasion we don’t meet the high expectations we set for ourselves. If youare dissatisfied with IISI we invite you to let us know so that we can addressthe situation. We want you to have a great experience with IISI, so don’thesitate to contact us if you have questions or comments. If you want toregister a formal complaint, you can send it to the following address:
IntelligentInvestingSecurities Inc.
1010 Rue Sainte-Catherine Ouest, Suite 200,
Montréal QC H3B 5L1
Email: compliance.selfdirected@intelligentinvesting.ai
Please provide the following informationwhen you make your complaint:
Once your complaint has been filed, IISIwill send you a written acknowledgement within five business days, specifyingthe name and contact information of the person who will be analyzing it. Pleasecontact this person directly if you have any questions on developments with thefile.
Your complaint will be dealt with quicklyand fairly. We may ask you to provide us with additional information as weinvestigate your complaint. Then, no later than 60 days after we have begun ouranalysis, we will send you a letter detailing our results and conclusions, aswell as your options if you are not satisfied with these findings. Ifnecessary, we may ask for additional time. In that case we will explain why weneed additional time to complete our analysis.
If you are still unsatisfied after we haveaddressed your complaint you may contact one of the following agencies:
Canadian InvestmentRegulatory Organization
Telephone: 1-877-442-4322
Email: info@ciro.ca
Web: www.ciro.ca
Ombudsman for BankingServices and Investments (OBSI)
Telephone: 416-237-2877
Toll-free: 1-888-451-4519
Toll-free fax: 1-888-422-2865
Email: ombudsman@obsi.ca
Web: www.obsi.ca
If you reside in Quebec, and if you aredissatisfied with our response to your concerns, you may request that yourcomplaint file be transferred to the Autorité des marchés financiers (the“AMF”). Transferring your file to the AMF does not interrupt the prescriptiveperiod for civil remedies. The Chief Compliance Officer shall act as therespondent to the AMF.
Following the transfer of your file, theAMF will proceed with its review and may offer you mediation services if deemedappropriate and the interested parties agree. Mediation is intended to be aconflict settlement process in which a mediator intercedes to assist theparties in reaching a satisfactory settlement.
The AMF may be contacted as follows:
Autorité des marchésfinanciers
Québec City: 418-525-0337
Montréal: 514-395-0337
Toll-free: 1-877-525-0337
Fax: 418-525-9512 or 514-873-3090
Web: www.lautorite.qc.ca/grand-public/nous-joindre/
Escalation to the OBSI or AMF does notaffect your rights for taking legal action in the civil courts.
We want to make you aware of our businesscontinuity plan (“BCP”) in case ofemergency. IISI’s BCP is designed to ensure that our business will continue tofunction with minimal disruption, that your assets will be secure andaccessible, and that you will be able to communicate with us. Since the timingand impact of disasters and disruptions is unpredictable, IISI has to beflexible in responding to actual events as they occur.
IISI Services are offered through anapp-based experience. IISI has engaged world class partners that help to ensuremaximum uptime and functionality. If the App is unavailable, you will be ableto provide liquidating trades at IISI’s backup website, which will send yourinstructions to a licensed trader who will execute your trades in accordancewith your instructions. The backup website link will be communicated to youin-App where possible, or through our website.
IISI plans to quickly recover and resumebusiness operations after a significant business disruption and respond bysafeguarding our employees and property, making a financial and operationalassessment, protecting the firm’s books and records, and allowing our customersto transact business. In short, our BCP is designed to permit our firm toresume operations as quickly as possible, depending on the scope and severityof the significant business disruption.
Our BCP addresses: data backup andrecovery; all mission critical systems; financial and operational assessments;alternative communications with customers, employees, and regulators; alternatephysical location of employees; critical supplier impact; regulatory reporting;and providing IISI clients with prompt access to their funds and securities ifwe are unable to operate our business.
Our clearing firm, CIIS, backs up ourimportant records in a geographically separate area. While every emergencysituation poses unique problems based on external factors, such as time of dayand the severity of the disruption, we have been advised by CIIS that itsobjective is to restore its own operations and be able to complete existingtransactions and accept new transactions and payments within a matter of hours.Please note that your orders and requests for funds and securities may bedelayed during this period.