This bulletin is being issued to provide guidance on the policies and procedures’ regarding the referral program HUB Capital Inc. has in place with VirtualWealth™ offered by Qtrade Securities Inc. (“Qtrade”).

The purpose of this referral program is to allow HCI Representatives the opportunity to provide clients with access to Qtrade’s Online Managed Account Services through VirtualWealth™ via dedicated website functionality and linking. Under your mutual fund registration you are not licensed to offer Managed Accounts or Exchange Traded Funds (ETFs”). This referral arrangement allows you to maintain the integrity of your client relationship, should a client wish to invest in an online managed account “Robo-Advice” solution.

Referral Process:

The Client Disclosure Document. This form explains the relationship between HUB Capital and VirtualWealth™ and Qtrade to your client, discloses that a referral fee will be paid to HCI and that it will be paid to you through the normal compensation grid. The signed copy of this form should be uploaded into the client documents in RepVision and the original saved in the client’s file.

Responsibilities of HUB Capital Representatives:

  1. You may provide basic description of services to clients in a form approved by Qtrade.
  2. The referral agreement does not allow you to act in the furtherance or in unauthorized trading of securities.
  3. You may only provide clients with the link to the website or the contact information for VirtualWealth™.
  4. You are required to provide your client with a Client Disclosure document and request it be signed by your client.
  5. You are required to maintain a copy of the Client Disclosure document(s) in the client’s file.
  6. You may not complete, or assist the client in completing forms, online account opening or trading documents with respect to the account the client holds with VirtualWealth™ and Qtrade.

Responsibilities of Qtrade - VirtualWealth™:

  1. Completing New Account obligations.
  2. Provide managed online accounts and ETF investment portfolios to clients.
  3. Provide all forms to clients.
  4. Provide information and statements to clients.
  5. May provide copy of client statements to Rep if the client agrees.
  6. Pay a referral fee to HCI.

Please contact your Regional Compliance Officer or Branch manager if you have any questions in this regard.