Regulatory Disclosure

Revision Date: November 5, 2024

At AimStar Capital Group Inc. (“AimStar”), our clients’ interests always come first, and we’re providing this disclosure to you, our client, because we want you to understand the material facts about your relationship with us, including:

  • The capacity in which we will act;
  • Details and resources about the material fees and costs you will incur in your account;
  • The type and scope of the services we will provide, including any material limitations related to products, our investment philosophy, and general risks; and
  • Material facts related to conflicts of interest associated with our recommendations.

In this document, we have included links to more detailed information that we believe would be of value to you. Please review the referenced links and disclosures on, as well as any applicable statements, trade confirmations, prospectuses, statements of additional information, offering statements, and any other relevant documents. Your advisor will discuss and explain this document with you. If you have any questions, please speak with your advisor.

AimStar Capital Group Inc (CIRO Member Firm) wants to inform you that our main office is a shared location with AimStar Insurance. All Investment dealer files and systems are independent and removed from insurance documentation; and investment advisors do not have access to insurance documentation, and visa-versa.

Accounts, Products and Services

AimStar is registered as an investment dealer under provincial securities laws and is a member of the Canadian Investment Regulatory Organization (“CIRO”), as such, we offer our clients a broad range of products and services to meet your financial needs, including:

Accounts (commission based): Your advisor can make recommendations but cannot make investment decisions for you. When making recommendations, your advisor provides an appropriate standard of care, provides suitable investment recommendations, and provides unbiased investment advice. These accounts are non-discretionary in nature and are considered to be traditional brokerage accounts. Traditional brokerage accounts are commission- based so you pay a commission when you buy or sell investments (see Investment Expenses section below for expenses related to each investment type), as well, investments such as Mutual Funds may earn a trailer fee based on the assets under administration in the account. The accounts can be either registered or non-registered. The terms for traditional brokerage accounts are set out in your AimStar Client Account Agreement (the “Client Account Agreement”).

Accounts (Fee-Based): In a ‘fee-based’ account at AimStar, the client will pay a monthly or quarterly fee based on the value of their account, there are no commissions to trade (within set limits). It is non-discretionary account, and with the exception of the fee structure, operates just like a traditional full-service cash or RRSP account.

If you switch from one series Mutual Funds into another series Mutual Funds within the same fund family, any gains realized on the sale transaction will be taxable unless held in a registered or non-taxable account.

Your Investment Instructions

Any instructions by you on account transactions in your Accounts must be made by telephone or orally to your advisor or other authorized representative of AimStar. AimStar does not accept trade instructions via electronic mail, text message, voice mail, or any other electronic medium.

Account Type

Accounts can be cash investment accounts, advisory accounts (commission-based) or advisory accounts (Fee-based). Other account types are:

  • S. dollar accounts;
  • Retirement plan accounts (RRSPs, RRIFs);
  • Tax-free savings accounts (TFSA);

Note: AimStar does not accept cash deposits.

Investment Products

Accounts can hold a variety of investment products:

  • Listed equities (stocks);
  • Mutual funds;
  • Exchange trade funds (ETF’s); and
  • Fixed Income Securities / Products.

We offer only mutual funds and ETFs for purchase that have undergone an extensive and thorough internal review process. These investment products have been approved by AimStar only after careful review and consideration. To limit conflicts of interests, we do not offer any proprietary products, including investment products that are managed by an affiliate or subsidiary of ours.

Typically, the securities that we recommend to you for investment or allow your account to invest in will be able to be readily liquidated or resold. Any exceptions will be explained to you by your advisor prior to purchase, and either noted in your account statement or in the applicable disclosure document which would be provided to you.

In addition to the above, AimStar offers the following services:

  • Investment recommendations;
  • Portfolio reviews;
  • Electronic delivery of statements, trade confirmations, and tax documents.

Please discuss with your advisor which products and services are appropriate for you. Products and services offered by AimStar to its clients may be added or deleted from time to time.

AimStar and your advisor will not provide any of the following services:

  • Legal advice (including advice as to the drafting of wills, designation of beneficiaries and creditor protection) – You are encouraged to consult with a lawyer for such advice.
  • Tax advice – AimStar and your advisor can provide general information with respect to the tax treatment of products and services provided but will not provide you with specific advice as to the impact of federal or provincial income tax laws and regulations on your personal situation, the structuring of your affairs, or the tax implications of your investment decisions. You are encouraged to consult with a tax professional for such advice.
  • Tax return preparation – AimStar and your advisor will not prepare your tax returns.

Suitability Determination

Before we can open an account and provide you with financial services, your advisor will ask you a series of questions to understand how best to meet your particular needs. This “Know-Your-Client” (or “KYC”) process ensures your advisor is familiar with various factors before making investment recommendations. Your advisor is also required to have a strong understanding of investment products recommended to you, known as “Know-Your-Product” (or “KYP”). In determining suitability of the investments in your account, we will consider various factors including your personal and financial circumstances, investment knowledge, investment needs and objectives, investment time horizon and risk profile (your “KYC Information”), as well as the current portfolio composition and risk level of your account.

As a result, we reserve the right to decline to accept orders to purchase securities if, in our opinion, they are not suitable based on your KYC Information. Upon opening your account, your advisor will request information from you related to your KYC Information, which will be used to assess the suitability of investments recommended and orders accepted. When we provide you with a recommendation, we act in your best interest and put your interests first, and ensure that any investment action taken, or recommendation made to you, is suitable for your investment portfolio, including when:

  • securities are received into or delivered out of your account by way of deposit, withdrawal, or transfer;
  • your advisor becomes aware of a change in your KYC Information that could result in your account not meeting the suitability determination requirements;
  • we become aware of a significant change in a security in your account that could result in your account not meeting the suitability determination requirements;
  • we conduct our periodic review of your KYC Information; and
  • there is a change of the advisor responsible for your account.

Your advisor will review your KYC Information for your accounts from time to time, and no less frequently than once every 36 months. Other events, such as significant market fluctuations and other trigger events, will result in a review of the suitability of your existing investments. Please contact your advisor if you wish to review the suitability of your investments at any time.

You will be provided with a copy of your KYC Information. Please review carefully to ensure that all of the KYC Information recorded is accurate before signing the form. Please advise us promptly if any of the KYC Information is not accurate.

If there is a significant change to your KYC Information – such as your employment status, income or financial resources, investment objectives, investment time horizon or risk profile – at any time after you open your account, please tell your advisor about these changes so that we can update our records and continue to provide suitable advice. If you do not tell your advisor about these changes, we cannot ensure that any further recommendations made to you, or orders accepted from you will be appropriate for you. If there is a significant change in your KYC Information that results in a change to the information that we have on record, we will update your KYC information accordingly and will send you a copy of the updated KYC. Please review and advise us promptly if any of the information is not accurate.

It is important to know that the value of individual securities (unless specified) is not guaranteed, the value of securities and your investment portfolio as a whole can fluctuate, and you could lose part or all of the value of any investment.

Similar to your bank accounts, your stocks, mutual funds, and ETFs are covered by the Canadian Investor Protection Fund (“CIPF”). The CIPF covers losses of clients of IIROC member firms resulting from the insolvency of a member firm, within specified limits, but the CIPF does not insure against investment losses resulting from loss of value of securities.

Trusted Contact Person and Temporary Transaction Holds

When you open an account (other than a corporate account) with us, we will ask you for the name and contact information for a trusted contact person and your consent to contact the trusted contact person in certain circumstances. A trusted contact person is someone we can contact to confirm or make inquiries about possible financial exploitation, or if we have concerns about your mental capacity as it relates to your ability to make financial decisions (“Trusted Contact Person”). Financial exploitation means the use or control of, or deprivation of the use or control of, a financial asset through undue influence, unlawful conduct, or another wrongful act. We may also contact your Trusted Contact Person to confirm your current contact information if we cannot reach you after multiple attempts, or to confirm the name and contact information of a legal guardian, if any. You can replace or revoke your Trusted Contact Person at any time.

If we reasonably believe that you are in a vulnerable position and are being financially exploited or that you are experiencing diminished mental capacity which may affect your ability to make financial decisions relating to your account(s) with us, we may place a temporary hold on a particular transaction. A vulnerable position includes where an illness, impairment, disability, or aging-process limitation places you at risk of financial exploitation. If we place a temporary hold on a particular transaction, we will provide you with notice, either written or verbal, explaining our reasons for the temporary hold, and at least every 30 days thereafter until the temporary hold is revoked. We may also contact your Trusted Contact Person about a temporary hold.

Investment Expenses

In the course of making, holding, and disposing of investments in securities, you may incur the following expenses:

Equities (Stocks): When buying or selling stocks that trade on a marketplace, you will normally be charged a commission for our services as agent in the transaction. Your advisor can provide you with our current equity commission schedule upon request and can also provide you with an estimate of the commission that will be applicable on any specific trade. Commissions applied to trades will be confirmed at the time of the trade and included on your trade confirmation.

Mutual funds and exchange traded funds: Mutual funds and ETFs (whose securities are listed on an exchange) carry built-in operating expenses and ongoing management fees. These are described as being the “management expense ratio” or MER of the fund. The built-in management fees and operating expenses are not charged directly to you but are important because they will be deducted from the returns of the fund and therefore will affect your returns on your investment for so long as you own the fund. For mutual funds, fund managers pay us a portion of their management fee called a trailing commission for the ongoing services we provide to you. As an example, if you have invested $10,000 in a fund, a trailing commission of 1% would pay us $100 annually. ETFs generally do not have a trailing commission (similar to stocks) but have upfront commissions and ongoing fees, and all future transactions to rebalance or liquidate an investment are charged a commission.

Details of these charges are outlined in a fund’s prospectus and in the Fund Facts or ETF Facts document, as applicable. You will receive the Fund Facts or ETF Facts, as applicable, before a purchase of a fund. Both of these documents are available from your advisor, from the fund company’s website or on the SEDAR website (www.sedar.com). When you get information about the value of your investment in a fund, the fees and expenses of the fund have already been taken into consideration. Your advisor can help you evaluate internal costs and fees and their impact on what you earn from mutual fund and ETF investments.

Account Service Fees and Charges

Please refer to the Schedule of Fees in your Account Agreement for a description of service fees and charges that may apply to your account.

Impact of Investment Expenses, Fees, and Charges on Your Returns

The fees and charges described above under the headings “Investment Expenses” and “Account Service Fees and Charges” reflect the value of our advice and services and will affect the returns on the investments in your account by reducing such returns in proportion to such fees and charges. Over time, similar to the compounding effect of performance returns, the compounding effect of these fees and charges will affect how your portfolio grows.

 

 

Advisor Compensation

Your advisor is an employee of AimStar, and all compensation to the advisor will be paid, directly or indirectly, through AimStar. The advisor will not bill clients directly for any services. All payments for investments to be purchased must be made payable to AimStar and not to the advisor. The compensation received by your advisor may include one or more of the following:

  • A base salary;
  • A share of trailing commissions earned on certain products such as mutual funds;

Account Documentation

Upon opening your account, you will receive copies of the following documents from your advisor:

  • Client Account Agreement and Other Disclosures, which includes this Relationship Disclosure document. If you have opened a retirement account, you will receive the beneficiary designation information, if applicable, and the Declaration of Trust for such plans; and
  • If you purchase strip bonds, a strip bond disclosure statement; and
  • An IIROC-approved brochure describing the complaint handling process.

Account and Activity Reporting

You will receive an account statement from us after the end of each month when there has been any activity in your account (other than interest or dividend entries) during the month. You will receive an account statement after the end of each quarter, whether or not there has been any activity in your account, if you have held any cash or investments in your account during the quarter. You will also receive a trade confirmation each time you purchase or sell a security, other than transactions resulting from systematic plans such as dividend reinvestment or pre-authorized purchases or sales of securities on a systematic basis. If you enroll in our electronic account access, you may view your statements, trade confirmations and tax documents though our website. If you enroll in electronic account access, you may also elect to receive monthly statements, trade confirmations and tax reporting documents through electronic delivery, if you prefer. Please review all statements and trade confirmations carefully and advise us promptly if you believe there are errors or if you did not authorize any of the transactions reported.

Natioanl Bank Independent Network (“NBIN”) will be providing custody, clearing, settlement and record-keeping services, such as transaction records, to our clients. We also execute, settle and report all of your trading activity to you. Investment industry regulations require that all fully paid securities held by us on your behalf must be kept separate and easily identified (or segregated) from the total assets of AimStar.

 

Best Execution of Client Orders.

AimStar has established policies and procedures designed for achieving best execution when executing client orders. AimStar has prepared policies to help clients understand how AimStar executes debt market and equity security orders, so that clients can make an informed investment decision based on their personal circumstances. These policies can be found on NBIN website. https://info.nbin.ca/

Cost and Performance Reporting

Your monthly or quarterly statement will show the adjusted cost base of securities held in your account. If the securities were purchased elsewhere and transferred into your account, the cost base shown will be based on the information, if any, provided when the securities were received by us, and we cannot guarantee the accuracy of that information.

You will receive annual performance reports with respect to the performance of your account, including account percentage return information, together with your quarterly account statements. In addition, you will receive an Annual Report on Charges and Other Compensation and an Annual Investment Performance Report which includes annual account percentage return information.

You may assess the performance of your investments by comparing them to an investment performance benchmark. Benchmarks show the performance over time of a select group of securities. There are many different benchmarks. When choosing a benchmark, it is important to select one that reflects your actual investments. For example, the S&P/TSX 60 Index follows the share prices of the largest companies listed on the Toronto Stock Exchange. This index would be a good benchmark for assessing the performance of a Canadian equity fund that invests only in large Canadian companies. It would be a poor benchmark if your investments are diversified in other products, sectors, or geographic areas.

We do not provide benchmark comparisons in our client account reporting, as each client account is unique, and many clients do not hold a combination of investments that are directly comparable to a benchmark. Also, clients often deposit money to, or withdraw money from, their accounts over the course of a year, making comparison to a benchmark, which does not account for those changes, less meaningful.

If you invest in a mutual fund, the managers of those funds may measure the performance of those funds against one or more benchmarks based on the specific investment mandates of the funds. However, the performance of your account may vary from the performance of the manager as a result of deposits to or withdrawals from your account over the course of a year.

Please speak with your advisor if you have questions about the performance of your portfolio or which benchmark(s) might be appropriate for you.

Conflicts of Interest Disclosure Statement

This conflicts of interest disclosure statement describes the material conflicts of interest that arise or may arise between AimStar and our clients, and

between our registered representatives and our clients. Canadian securities laws require us to take reasonable steps to identify and respond to existing and reasonably foreseeable material conflicts of interest in a client’s best interest and tell clients about them, including how the conflicts might impact clients and how we address them in a client’s best interest.

What is a Conflict of Interest?

A conflict of interest may arise where (a) the interests of AimStar or those of its representatives and those of a client may be inconsistent or different, (b) AimStar or its representatives may be influenced to put AimStar ‘ or our representatives’ interests ahead of those of a client, or (c) monetary or non- monetary benefits available to AimStar, or potential negative consequences for AimStar, may affect the trust a client has in AimStar.

How does AimStar address Conflicts of Interest?

At AimStar, our clients’ interests come first, as such, AimStar and its representatives always seek to resolve all material conflicts of interest in the client’s best interest. Where it is determined that AimStar cannot address a material conflict of interest in the client’s best interest, AimStar and its representatives will avoid that conflict.

AimStar has adopted policies and procedures to assist it in identifying and controlling any conflicts of interest that AimStar and its representatives may face.

Material Conflicts of Interest

A description of the material conflicts of interest that AimStar has identified, the potential impact and risk that each conflict of interest could pose, and how each conflict of interest has been or will be addressed, is set out below.

Compensation and incentive-related conflicts – we earn compensation by selling you products and services.

The potential risk to the client is that a recommended action, such as an account type or particular trade, is motivated by the compensation that the advisor or the firm might receive rather than what we believe is right for the client.

How the Conflicts is addressed,

  • We make it our priority to understand our client’s goals, objectives, needs and investment profile;
  • We make sure that any recommendation or action is in the client’s best interest;
  • We do not manufacture our own proprietary products, nor do we trade in, or advise on, any securities that are related or connected to us;
  • Our compensation structure does not incentivize one product or service over another;
  • The giving and accepting gifts and entertainment is deemed appropriate only if it does not improperly influence the recipient and/or improperly influence objectivity; and it is within a reasonable limit and ethical industry standard.
  • All client and account activity is supervised by qualified individuals who do not receive the commissions generated from the transactions.

Compensation and incentive-related conflicts – we earn third party compensation, such as trailing commissions, by selling you products such as mutual funds.

The potential risk to the client is that a recommended trade is motivated by the additional compensation that the advisor or the firm might receive rather than what we believe is right for the client.

How the Conflicts is addressed,

  • We make it our priority to understand our client’s goals, objectives, needs and investment profile;
  • We make sure that any recommendation or action is in the client’s best interest
  • We do not manufacture our own proprietary products, nor do trade in, or advise on, any securities that are related or connected to us;
  • Our compensation structure does not incentivize one product or service over another;
  • The giving and accepting gifts and entertainment is deemed appropriate only if it does not improperly influence the recipient and/or improperly influence objectivity; and it is within a reasonable limit and ethical industry standard.
  • We encourage and incent our advisors to increase assets rather than solely incenting on commissions;
  • All client and account activity is supervised by qualified individuals who do not receive commissions generated.

Personal financial dealings between staff of AimStar and clients.

The potential risk to the client is that the staff puts their own interests over the interests of the client.

How the Conflicts is addressed,

  • Personal financial dealings between staff and clients is strictly prohibited at AimStar;
  • We prohibit personal loans between clients and staff except between immediate family members on an exceptional basis;
  • We prohibit staff from being a power of attorney, trading authority, executor, or trustee for a client, except where the client is an immediate family member;
  • We generally do not permit staff to be beneficiaries on client accounts except where the client is an immediate family member;
  • We have gifts and entertainment limits between staff and clients;
  • Personal financial dealings requests for scenarios involving family members are reviewed and supervised by qualified Individuals.

Personal trading by staff or an associate of AimStar.

The potential risk to the client is that our employees could use non-public information about you, and the securities in your account, for their direct or indirect personal benefit.

How the Conflicts is addressed,

  • Our policies and procedures ensure that our employees act in accordance with applicable laws and that they do not engage in personal securities transactions that are prohibited, such as insider trading;
  • Our employees are restricted from accessing non-public information of our clients;
  • We place securities on a “restricted list” to prevent trading when we have non-public information;
  • We review on a regular basis securities transactions made in our employees’ personal securities accounts.

Outside activities – where an advisor is involved in a non-AimStar business activity or association.

The potential risk to the client is that the outside business activity negatively impedes the advisor’s ability to service clients or incents the advisor to recommend certain products over others.

How the Conflicts is addressed,

  • We limit the types of outside activities in which advisors are able to engage;
  • All permissible outside activities must be approved by a qualified supervisor;
  • All approved activities are reviewed and reassessed annually.

Referral arrangements – where AimStar and/or an associate of AimStar receives a referral fee for referring a client to another company or a non-AimStar person or where AimStar and/or an associate of AimStar gives a referral fee for receiving a potential client referral from another company or a non- AimStar person.

The potential risk to the client is that the referral is given or received based on the referral fee and not because of a benefit to the client.

How the Conflicts is addressed,

  • Generally speaking, referral fees are prohibited at AimStar;
  • Should one be approved, it would be reviewed and approved at the head office to ensure clients’ interests are the primary reason for the arrangement and that the referral fee is appropriate and does not encourage undue incentives;
  • The details of any referral arrangement would be disclosed to the client;
  • We will ensure that the other party has the appropriate qualifications to provide applicable services to you under the referral arrangement.

Proprietary products – products manufactured by the dealer or manufactured by a company related to the dealer.

The potential risk is that the proprietary product is recommended or sold because of the additional benefits to the dealer.

How the Conflicts is addressed,

  • We do not manufacture our own proprietary products, nor do we trade in, or advise on, any securities that are related or connected to us.

Supervisory personnel – the designated Supervisor has responsibility for supervising the activity of advisors.

The potential risk is that the Supervisor’s compensation is tied to the sales or revenue generation of the firm or the advisor they supervise.

How the Conflicts is addressed,

  • Supervisors do not receive commissions on the activity they are reviewing;

We will notify you of any significant changes to this Conflicts of Interest Disclosure Statement by notifying you and posting an updated version on our website or mailing them to you. You can also obtain a current version of the Conflicts of Interest Disclosure Statement at any time from your advisor. If you have any questions about this Conflicts of Interest Disclosure Statement, please speak with your advisor.

Complaint Handling Procedures

If you have a problem or concern regarding the handling of your account, there are several options available to resolve such issues.

  • In the first instance, please contact your advisor to discuss any problems or concerns regarding your account. We will generally be able to review and resolve any service-related issues regarding your account.
  • If your complaint involves possible misconduct or violation of industry rules, the Compliance Department will investigate these matters immediately.

Any complaints to be investigated by our Compliance Department will be acknowledged in writing, and you will be advised of the name and contact information of the individual reviewing the complaint. We will endeavour to provide you with a substantive response to the complaint within 90 calendar days from the date that we receive it, along with details of alternative courses of action available if you are not satisfied with that response. If we are unable to provide you with a substantive response within that time, we will advise you of that and provide you with an estimate of the time for completion.

Risks of Borrowing Money to Invest

Borrowing money to finance the investments in your account involves greater risks than an investment using your cash resources at hand. If you borrow money to make an investment in your account, your responsibility to repay the loan and pay interest as required by its terms remains the same even if the value of your investments in your account declines. You can discuss your intention to borrow money to invest with your Advisor, however AimStar will consider whether you have used borrowed funds to determine the suitability of your investments and your investment strategy.

Investment Risks

All investing has risks and the investments in your account will continuously be reviewed by your advisor so that they align with your objectives and risk profile. Different types of investments have different risks associated with them. The value of equity securities changes with the financial condition of the issuer of the security and can be affected by general market conditions and the state of the economy as a whole. The value of equity securities of certain companies or companies within a particular industry may fluctuate differently than the value of the overall stock market because of changes in the outlook for those individual companies or the particular industry. Your advisor will discuss the risks associated with the investments in your account with you on your request or as part of the annual review of your account with you. You can also refer to your applicable disclosure documents for more information about risks, such as the Fund Facts document for mutual fund purchases. During your account opening process and/or review of your account with you, the advisor will also discuss: a) Your Risk Tolerance, b) Your Risk Capacity, and c) Your Risk Profile which will be the lesser of the two and provided to you by the advisor.

Changes to Relationship Disclosure

If there are significant changes to this Relationship Disclosure, we will notify you and we will post them on our website or we will mail them to you. You can also obtain a current version of the Relationship Disclosure Information at any time from your advisor.

Your Relationship with Us

It is important that you actively participate in your relationship with AimStar and your advisor. In particular, we encourage you to:

  • Keep us fully and accurately informed regarding your personal circumstances, and promptly advise us of any change to information that could reasonably result in a change to the types of investments appropriate for you, such as a change to your employment status, income or financial resources, investment objectives, investment time or risk profile.
  • Review the documentation and other information we provide to you regarding your account, transactions conducted on your behalf and the holdings in your portfolio.
  • Ask questions of and request information from us to address any questions you have about your account, transactions conducted on your behalf, the holdings in your portfolio, or your relationship with us or anyone acting on our behalf.
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