NEW CONFLICT OF INTEREST Disclosure Requirements under the Client Focused Reforms are coming into effect June 30th, 2021. Both HUB Capital and its Advisors must provide updated disclosures to clients, including outside activities and referral programs, before the June 30th, 2021 deadline. Please note that HUB Capital will be sending a copy of the updated HUB Capital Conflicts of Interest disclosure with the Q2 client statements.

The advisor conflicts of interest requirements were covered in detail on the May 25th, 2021 webinar. We have summarized your requirements below and are providing the Advisor version of the Conflicts of Interest Disclosure which is mandatory for HUB Capital advisors. You can conveniently meet both your investment and insurance disclosure obligations using this one document that includes the disclosures you are required to make as an MFDA/AMF dealer advisor as well as a life insurance agent.

If you were not able to attend the May 25th, 2021 webinar, it is mandatory that you attend the recorded version and complete the quiz by clicking here. 

There are two versions of the Conflicts of Interest advisor disclosure form.

1. The Conflicts of Interest (general disclosure) is to be used for the general email/mail communication to your clients that must be distributed on or before June 30th, 2021. Click here to download.

2. The Conflicts of Interest (client acknowledgement) requires client acknowledgement and is to be reviewed in detail with the client at your next in-person, telephone, or virtual meeting. A copy of the original or e-signed version is to be maintained in the client file for future reference. Click here to download.

Click here for steps on how to send the document as a PDF.

Procedures:

1. Confirm your outside business activities to the listing provided to you from compliance, which you will receive via a separate email. Please contact your Regional Compliance Officer or Branch Manager immediately if the listing needs to be amended.

2. Complete the sections of the Conflicts of Interest Disclosures (general disclosure and client acknowledgement versions) that require additional input about your business relationships, licensing jurisdictions, etc. Please note that as a mutual fund advisor you are registered as a Dealing Representative with the provincial securities regulators, so please reference that as your registration.

3. Distribute the Conflicts of Interest (general disclosure) to your mutual fund clients via email or by post by June 30th, 2021. Maintain evidence of the distribution i.e. email, postage receipt. If sending an email to multiple clients, please ensure that you indicate Conflict of Interest Disclosure in the subject line, use your @hubcapital email address, and enter the client email addresses in the Bcc section that you can access by selecting the "To" box to ensure the privacy of individual email addresses.

Email wording:

Please see the updated Conflict of Interest disclosure that I am sending as a result of new Client Focused Reform regulations that are coming into effect on June 30th, 2021 with regard to how I disclose and manage conflicts in the interest of my HUB Capital Inc. Mutual Fund clients. I have conveniently included these new disclosures along with my updated Insurance disclosure.

I will review this document in detail at our next meeting, however, I encourage you reach out to me if you have any questions or concerns in the meantime.

I look forward to discussing this at our next meeting and thank you for the opportunity to provide financial, retirement and/or estate planning advice and solutions to you.

4. At next client meeting, review the Conflict of Interest (client acknowledgement version) in detail, address any client questions, have the client acknowledgement signed, sign as the advisor and maintain a copy in the client file for future reference.

5. The Conflicts of Interest disclosure document you provide to clients should be reviewed regularly to ensure that it accurately reflects your insurance contracts and outside activities. Clients should be notified of any material changes to your disclosure.

Please contact your Reginal Compliance Officer if you have any question regarding your disclosure and/or recordkeeping requirements.

Cheryl Hamilton
Vice President Risk Management and Chief Compliance Officer