Information on Conflicts of Interest
Desjardins Financial Security Investments Inc., which also operates under the business name SFL Investments, a financial services firm (hereinafter, the “Dealer”), is a mutual fund dealer registered in all Canadian provinces and territories and is also reg istered as a restricted dealer in Quebec. Represent atives of the Dealer may offer products from a select list of mutual funds.
This summary provides you with information on the nature and scope of certain conflicts of interest that could affect the prod ucts and services provided to you by the Dealer.
1. Conflicts of Interest Our Responsibilities
Our mutual fund representatives must deal fairly, honestly and in good faith with clients, observe high standards of ethics and conduct in the transaction of business, and refrain from engaging in any business conduct or practice which is unbecoming or detrimental to the public interest.
It is important that you are informed of existing or potential conflicts of interest which could arise in the course of the Dealer’s activities. A conflict of interest arises when the interests of different persons, for example those of a client and those of the Dealer or one of its representatives, are incompatible or divergent.
The Dealer takes reasonable measures to identify any material conflicts of interest that exist or that it can reasonably expect to arise. A material conflict of interest is one where the conflict may be reasonably expected to affect either of the following, or both: One, the decisions of the client in the relationship; or two, the recommendations or decisions of the representative in the relationship.
The Dealer assesses the level of risk associated with each conflict and avoids any circumstances that involve a serious conflict of interest or that present an important risk for its clients. In any other situation involving a conflict of interest, the Dealer ensures that appropriate measures are put in place to effectively control the conflict.
2. Relationships with Related or Connected Issuers
The following section lists relationship and product information to help you make an informed choice by describing any affiliation between the Dealer and the following issuers which may be recommended by your representative. When there is a connection between the Dealer and an issuer, a potential conflict of interest exists. The Dealer mitigates this risk by putting in place policies and procedures to ensure that there are no incentives, financial or otherwise, to sell related issuers’ products over the products of another issuer.
The Dealer is a wholly owned subsidiary of Desjardins Financial Security Life Assurance Company, a provider of life and health insurance and retirement savings products and is therefore an indirect subsidiary of the Fédération des Caisses Desjardins du Québec. Desjardins Funds is an entity that may be considered an issuer related or connected to the Dealer.
3. Outside Activities
Where permitted and approved by the Dealer, your representative may engage in certain activities outside of their mutual fund registration. We require that these activities be disclosed to the Dealer and approved prior to the representative engaging in them and require the representative to monitor and fully disclose certain activities to clients so that clients are aware these activities are not conducted through or supervised by the Dealer. In addition, representatives are required to disclose to clients in writing, any outside activity which may give rise to a potential or actual conflict of interest.
Representatives registered with the Dealer are also licensed to distribute automobile, property, life and health insurance through Desjardins Insurance, a separate legal entity. In addition, in some cases, your Representative may offer other products and services. Where and when required, a dual occupation disclosure form will be provided by your Representative. To find out which products your Representative is able to offer through the Dealer, please consult your Representative.
4. Information on Compensation and Fees and Charges
The following section lists fee and compensation structure information to help you make an informed choice by explaining charges, fees, commissions, and comp-ensation received by your representative and the Dealer related to sales and the servicing of your account. The Dealer mitigates the risk of an representative selling you a product that does not meet your needs by ensuring that account transactions flow through the Dealer and are reviewed for suitability, including the fee structure selected. For more information regarding suitability, please contact your representative or refer to the Relationship Disclosure document provided to you by your representative with your account opening. You can request a copy of the Relationship Disclosure document through your representative, at any time.
The Dealer and its representatives receive a commission from the fund company or fees agreed to by clients when they purchase investment products. The amount of comm-ission earned depends on which type of asset class is purchased and on whether the investment products the clients purchased were bought on a front-end load fee basis or deferred sales charge basis.
Front-End Load Fees
Front-end load (FEL) fees are deducted from the original investment. A corresponding commission is then paid to the Dealer and to the representative. The exact amount of the FEL fee which may be charged is described in the mutual fund prospectus or Fund Facts document. For a client who chooses a FEL fee structure, the exact amount of the fee charged is negotiated with his/her representative on a per transaction basis.
Deferred Sales Charges
Deferred sales charges (DSC) have a declining fixed rate over a specific number of years. In this fee structure, the client will not pay any commission up front; however, should the client redeem any units from the investment fund during the DSC period, the applicable fee will apply. The exact number of years where DSC charges may apply to a redemption and the amount of the fee is described in the mutual fund prospectus or the Fund Facts document. Every year, a client may redeem up to a certain percentage of the units fee free (generally 10%), even during the DSC period. After the DSC period, the client may redeem unlimited units without penalty. The Dealer and its representatives earn a commission paid directly by the mutual fund company when a client purchases a mutual fund on a DSC basis.
The fund company continues to pay the Dealer and your representative a commission for as long as you hold fund units. The commission, commonly referred to as a trailer fee, is intended to recognize the ongoing service and advice provided by your representative. The trailer fee is included in the management fee, and the rate depends on which of the above-mentioned sales charge options you choose.
Your representative may qualify for additional compensation, such as bonuses and non-monetary benefits like travel incentives. This compensation is based upon the gross revenue earned by your representative, and not specific investments. Investments through the Dealer are supervised to ensure that they are suitable for you, in respect of your personal information, including your Know Your Client (KYC) information. For more information regarding KYC, please contact your representative or refer to the Relationship Disclosure document provided to you by your representative with your account opening. You can request a copy of the Relationship Disclosure document through your representative, at any time.