Regulatory information

Your Relationship with National Bank Financial [PDF]

Securities regulations in Canada require all investment dealers to comply with rules about conflicts of interest. It is important for you to know how we identify and respond to conflicts of interest, as well as how we minimize their impact.

We consider a potential conflict of interest to be any circumstance in which our interests, or the interests of our Wealth Advisors or employees, could be inconsistent with or divergent from the interests of our clients or others who use our services.

We take reasonable steps to identify all existing material conflicts of interest, as well as those that are reasonably foreseeable. We then assess the level of risk associated with each conflict.

We avoid any situation that would create a serious conflict of interest or represent too high a risk for you or for the integrity of financial markets. In any other situation, we take appropriate measures to address the conflict in your best interest. Where it cannot be avoided, we will notify you of any existing or reasonably foreseeable material conflict of interest situation as they arise.

We could potentially be in a conflict of interest in our dealings with:

• Issuers of securities 
• Related dealers and advisors
• Other related companies 
• Our employees 
• Our clients 

The following sections describe each of these potential conflicts, the effects they might have on you and how we deal with them.

Sometimes we deal in the shares of companies or people that are related or connected to us. Here is how we define those terms.

A company or person is a “related issuer” if: 

• the person or company is an influential holder of NBF; 
• we are an influential holder of the person or company; or 
• both we and the person or company are related issuers of the same third-party securities.

A company or person is a “connected issuer” if the issuer has a relationship with us that may lead a reasonable prospective purchaser to question whether we are independent from the issuer and believe that we will benefit from it. This includes the issuer’s relationship with us, with one of our related issuers, with our directors, officers or partners or those of our related issuer.

The following are considered our related issuers under Canadian securities legislation.

National Bank of Canada: National Bank of Canada is a bank incorporated under the Bank Act (Canada) and is a reporting issuer that holds indirectly 100% of the voting and equity shares of the National Bank Financial inc.

 

Canadian Credit Card Trust II: This trust is a trust whose administrator is National Bank of Canada and whose securities are publicly distributed. Consequently, Canadian Credit Card Trust is deemed to be a related issuer.

 

NBI ETFs: National Bank Investments Inc. (“NBI”), a wholly-owned subsidiary of National Bank of Canada, is the investment fund manager of the NBI ETFs. National Bank Trust Inc. is the portfolio manager of the NBI ETFs. National Bank Financial Inc. acts as designated broker and broker of the NBI ETFs.

 

NBI Funds: National Bank Investments Inc., a wholly-owned subsidiary of National Bank of Canada, is the investment fund manager of all NBI Funds (including, without limitation, the Meritage Portfolios, as listed in the NBI Funds prospectus, dated May 13, 2022 and updated annually).

 

When we deal with securities issued by our related or connected issuers, we may: 

• Act as an underwriter or selling group member in the distribution of the securities. 
• Sell the securities to, or on behalf of, our clients. 
• Purchase the securities from, or on behalf of, our clients. 
• Exercise discretionary authority to buy or sell the securities, with the written consent of the client. 
• Act as an advisor regarding the securities. 
• Make recommendations to buy or sell the securities. 
• Offer for sale securities, goods and services issued or provided by National Bank of Canada or another related issuer. 
• Work with National Bank of Canada or another related issuer to jointly offer the sale or purchase of securities, goods or services. 

It is our policy to comply fully with all securities legislation. We make all required disclosures when acting as advisor, dealer or underwriter of the securities of National Bank of Canada and our other related or connected issuers.

Before advising you on the securities of a related issuer or taking part in the distribution of securities of a related issuer, we will inform you, verbally or in writing, about the relationship between the advisor and the issuer of the securities.

Before we exercise discretionary authority over securities of a related or connected issuer, we give you the issuer’s current Statement of Policies. If necessary, we also obtain your specific and informed written consent to exercise the discretionary authority.

When we buy or sell securities with a subsidiary or affiliate, we ensure that the transaction price, along with any brokerage commission, is as good as or better than the price offered by an unaffiliated third-party broker in an arms-length transaction.

In addition, when we deal in securities of related or connected issuers, we take your investment objectives and your best interests into account.

As part of our business as an investment dealer, we may act as “agent” or “principal” while buying or selling on your behalf. In such instances, we will provide services in accordance with our normal practices and procedures, and follow all relevant legislations or regulations.

Because of our affiliation with National Bank of Canada and its subsidiaries, we have put policies in place to deal with any potential conflict of interest, and to ensure we act in your best interests.

We are registered as an investment dealer and an indirect wholly owned subsidiary of National Bank of Canada. National Bank of Canada is also an important shareholder of many dealers and advisors, meaning it directly or indirectly holds more than 20% of any class or series of voting securities.

• National Bank Investments Inc.
• National Bank of Canada Financial Inc. 
• NBC Financial Markets Asia Limited - in Hong Kong only
• NBC Global Finance Limited - in Ireland
• Natcan Trust Company
• National Bank Trust Inc.
• NatWealth Management Inc.
• Nest Wealth Asset Management Inc.

We are therefore related to these dealers and advisors. Although there may be overlaps among the directors and officers of these companies, all of them operate as separate legal entities.

Both we and the related dealers or advisors named on our website may provide services to each other, including management and administrative services, as well as client referrals.

These relationships are subject to certain legislation and industry regulations. We have also adopted internal policies and procedures to supplement these requirements, including our policies on confidentiality of information.

National Bank of Canada, NBF and their affiliated companies may hold an interest or participation in certain companies.

TMX Group Limited

National Bank Acquisition Holding Inc., one of our affiliates, owns or controls an equity interest in TMX Group Limited in excess of 5% of the issued and outstanding equity securities thereof, and has a nominee director serving on the board. In addition, NBF is a wholly-owned subsidiary of National Bank of Canada. From time to time, National Bank of Canada may enter into lending or financial arrangements with companies that are the subject of research reports or that are recommended by related entities. At the present date, National Bank of Canada is a lender to TMX Group Limited under its credit facilities. As such, NBF may be considered to have an economic interest in TMX Group Limited. No person or company is required to obtain products or services from TMX Group Limited or its affiliates as a condition of doing business with TMX Group Limited or its affiliates.

TMX Group Limited is also the owner of Alpha Trading Systems Limited Partnership. Alpha Trading Systems Limited Partnership owns Alpha Exchange Inc., a stock exchange in Canada for the trading of securities.

We can execute transactions on your behalf on Alpha Exchange Inc. and enter orders into Alpha Exchange Inc.’s order book which cannot be immediately completed. In that role, we are subject to a number of regulatory obligations, including the requirement to diligently pursue the best price and best execution of each client order on the marketplace. Those obligations override the direct or indirect interest NBF has in the above companies.

In the normal course of their activities, our directors, officers, employees, representatives and agents may find their personal interests are in potential conflict with those of a client.

We have developed a Code of Conduct and Ethics, a Compliance Manual and internal policies. Among other things, these documents state that our employees must never put their own interests ahead of their responsibilities toward clients or NBF and that they should not under any circumstances exert undue pressure on clients to acquire a product or service. They also reinforce the fact that any existing or reasonably foreseeable material conflict of interest must be addressed in a manner that is fair, equitable, transparent, and in the clients’ best interests.

Here are some highlights from these documents:

 

Confidential information: Our employees are prohibited from using confidential information gained in the course of their duties for their personal benefit or for the benefit of a third party. This includes information related to clients, transactions or client accounts. Our employees may not exploit any situation for the purpose of obtaining an advantage of any kind that would compromise confidential client information.

Gifts, entertainment and compensation: Employees are prohibited from accepting gifts, entertainment or compensation that could influence the decisions they make in the course of performing their duties and to compromise or give the impression of compromising their independence.

All decisions must remain objective and impartial, in the best interests of clients. Unless they have our prior approval, our employees may not receive any form of compensation other than what we pay them. We ensure that our employee compensation practices do not conflict with employees’ obligations toward our clients.

 

Other business activities: Employees are prohibited from engaging in activities that could interfere or be in conflict with their duties. We will not permit any employee to engage in business activities outside the scope of their duties without our prior approval and without ensuring that these activities do not compromise our clients’ interests or harm our own reputation or that of the industry. We would also consider an employee to be in a potential conflict of interest if he/she were designated as a beneficiary of a client’s estate or otherwise inherit from a client’s estate.

 

Client best interests: The interests of clients must always be given priority over those of NBF and its employees. When we receive two orders for the same security at the same or better price, we always execute the client’s order before our or our employee’s order. This also means that the Wealth Advisor has an obligation to choose the best investment for a given client, even if it is an investment that directly competes with our offerings. No Wealth Advisor is authorized to make recommendations solely for the purpose of generating revenue or promoting in-house investments if there is no benefit to the client and the recommendations do not constitute the best execution and the best investment for the client.

 

Referrals: On occasion, third parties may refer clients to us for our products and services. We or our Wealth Advisors may also refer clients to third parties. In all cases, referrals should prioritize clients’ interests. When these referrals involve a commission, the commission must comply with existing regulations, and we notify the referred client about the commission and other relevant information. This allows the client to make an informed decision about the referral and to consider any potential conflict of interest. Any agreement must be made in the best interests of clients and not for the purpose of receiving a commission.

Corporate financing, advisory, and research activities: We offer corporate financing, research, and investment advisory services for a fee. We have established procedures and policies to avoid conflicts of interest and to protect the confidentiality of privileged information. In addition, our departments involved in advisory and research activities are physically isolated from all our trading activities thus preventing the unauthorized transmission of privileged information.

Underwriting and market-maker activities: In some cases, we may act as an underwriter, meaning we administer the public issue and distribution of securities. We may also be a market maker, which means we hold an inventory of securities and use it to quickly complete buy and sell orders. In some cases, the interests of the parties we work for can differ from the interests of our clients. Regulations govern the various roles we play. In a case of conflict, we are duty-bound to abide by the applicable legislations and regulations. We will always give the client’s best interest priority over our own interest so that any recommendation constitutes the best execution and the best investment for the client.

Policy respecting the allocation of securities: We have a policy that deals with the allocation of securities among our clients when there are not enough securities to meet the demand. This policy is intended to ensure fair distribution of securities and thus avoid that a client entitled to a quantity of securities does not receive his fair share.

 

Brokerage commissions: We charge brokerage fees when a Wealth Advisor exercises discretionary power by trading investments on behalf of a third party. Examples include transactions carried out for an investment fund or for an account under discretionary management. We adhere to requirements intended to ensure that the brokerage fees are proportionate to the services the client receives. Also, we ensure that the client receives fair and reasonable benefits considering both the use of services and the amount of client brokerage commissions paid.

Private placements and personal investments: Employees who wish to participate in a private placement, as a buyer or promoter, must first go through our authorization and verification procedure to avoid or supervise conflicts of interest. Our employees’ personal investments are also subject to our policies and supervision. Employees should not make personal investments based on confidential information held by NBF. We must always put clients’ interests first over those of employees.

Discretionary management: We provide discretionary management services to our clients. At times, certain securities in the managed accounts may also be held by our employees, officers or managers, or may be issued by our related or connected issuers. We may also offer, as part of our discretionary management programs, public and private investment funds (also known as “Private Pools” or “Private Portfolios”) managed by National Bank Investments Inc. or by National Bank Trust Inc., both affiliates of NBF (collectively the “Related Funds”) and for which NBF or related entities:
› act as investment fund manager, portfolio manager, or trustee, or
› provide other services to the funds.

We may also recommend that you invest in Related Funds even if you do not use our discretionary management services.

Some of these Related Funds may, in turn, invest a part of their assets in other underlying funds that are Related Funds. NBF and its divisions may receive fees or other compensation from these Related Funds, such as management fees, administrative fees, custody fees, securities lending fees and trading fees. The managers of the Related Funds will ensure that investments by a Related Fund in another Related Fund will not result in any duplication of management fees for the same service and that the services are provided, at a minimum, on market standard terms.

The decision to invest a Related Fund in underlying Related Funds is made based on different criteria. Faced with comparable products, but offered by competitors, the manager may prefer to invest in Related Funds. We must always put clients’ interests first over those of NBF and its employees.

Compensation and other benefits: We are compensated for the business we perform for our clients. The level of compensation varies depending on the product and the type of remuneration. At all times, recommendations to clients are appropriate and are intended to give precedence to clients’ interests, regardless of the compensation associated with the recommended product or service. There is no undue pressure on clients to acquire a product or service. In order to oversee these practices and ensure the absence of conflicts of interest, several controls are in place. Here are some examples of how compensation could lead to a conflict of interest, and how we avoid such conflicts:

− Compensation and benefits from issuers: Issuers of securities or other related parties may compensate us based on the sale of their securities to our clients. An example is trailing commissions we receive for selling mutual funds. Securities regulations require issuers to include details in their offering documents about such arrangements and the compensation involved. Issuers can also pay or reimburse us for certain costs (registration for educational events, sales communications, conferences, seminars, etc.), allow us to attend conferences or seminars, and provide us with promotional items of minimal value. Regulations surrounding these sales practices are very strict and only benefits that meet the conditions must be accepted.

− Currency and interest rates: On occasion, we may be compensated indirectly. For example, in a foreign currency exchange, we may receive compensation based on the difference between the price our clients pay for the currency and the price we pay for the same currency. We could also be compensated based on the difference between the interest rate we receive on invested funds and the interest rate actually paid to our clients.

− Marketplaces: We may receive compensation based on the marketplace we use to carry out our clients’ transactions. Regulations control the conditions under which we carry out our client transactions.

− Over-the-counter securities: We may receive compensation for the purchase or sale of some over-the-counter securities. These investments are traded outside of the formal exchanges. We mark up the final price clients pay when they buy these securities, and mark down the final price clients receive when they sell these securities.

− Compensation for Wealth Advisors:  Wealth Advisors qualify for different types of incentives, such as trips or bonuses, when the revenue they generate crosses a certain threshold. We prohibit Wealth Advisors from making recommendations solely for the purpose of generating revenue without any benefit to the client. We have a comprehensive supervision program in place to monitor Wealth Advisors and ensure that any recommendation they make is suited to the client’s investment objectives, time horizon, risk profile, investment knowledge, and overall financial situation.

− Fee-based or commission accounts: There may be periods when it would be cheaper for clients to pay a commission per trade instead of a fee based on the assets they hold. Wealth Advisors must always ensure that clients are using the billing method most suitable to their needs.

 

Proxy voting: Your Wealth Advisor may ask whether you intend to vote on a specific matter or question pertaining to the securities you hold. Your Wealth Advisor may even recommend you vote in a specific manner. Our employees are prohibited from accepting payment from the issuer or any other party that relates to any request for your vote or a proxy in their favour. Our policy is that any recommendation the Wealth Advisor makes must be in the best interests of the client.

Transaction between two clients: In some circumstances, we may have one client who wants to buy a security through us and another client who wants to sell the same security through us. Our policy is to ensure that we make such transactions at fair market value. Neither we nor our Wealth Advisors are authorized to favour one client over another. Regulations and our policies require Wealth Advisors to make only suitable investment recommendations to clients in their best interests.

 

Margin accounts and investment loans: A margin account or an investment loan generates debit interest and additional fees or commissions when we invest the amount borrowed. This benefits the Wealth Advisor, as well as us or one of our related companies that make the loan. Any investment recommendation made by the Wealth Advisor must be suitable for the client and puts his interests first. Our employees cannot recommend a product solely on the basis of the amount it will bring us. 

Other existing or reasonably foreseeable conflicts of interest may arise. We will continue to take the necessary steps to identify and respond to such situations fairly and reasonably, and update our policies as required. Where not avoided, any material conflicts of interest will be disclosed to you as they arise.

NBF and other members of the National Bank group of companies refer clients to each other according to the needs of the client provided the client has given us his/her consent. At all times, referrals made must prioritize clients’ interests, regardless of the commission or benefits received. To ensure this, a referral program is in place to oversee these practices. If one member of the National Bank group of companies does not offer services that a client needs, that member will refer the client to another member of the group that does. An example of a common referral is when National Bank refers a client to us to establish a brokerage account.

 

Some business units in the National Bank group of companies, including NBF, are registered under securities legislation. If you are referred to a business unit for a product or service that requires securities registration, that business unit is responsible to you for the activities that require registration. An example would be if you were referred to NBF by National Bank for an investment transaction; NBF would be responsible for everything related to that transaction.

We enter into referral arrangements with the members of the National Bank group of companies listed below. We and these other members are completely separate from each other, but are all direct or indirect wholly owned subsidiaries of National Bank. Each member holds the appropriate registrations for the services they offer.

 

National Bank is a federally regulated bank, which offers a full array of banking services, including corporate and investment banking. It is an active player on international markets and, through its subsidiaries, is involved in securities brokerage, insurance and wealth management, as well as mutual fund and retirement plan management.

National Bank Financial Inc. (“NBF”) is registered as investment dealer in all Canadian jurisdictions. NBF is a truly integrated, full-service securities dealer offering retail advisory and brokerage services with institutional brokerage, investment banking, corporate finance and securities clearing services for third parties. As well, its discount brokerage services (execution orders only) are provided under its trademark National Bank Direct Brokerage (NBDB), and other administrative and trading services (custody, clearing, account statement production, account opening management) are provided under its National Bank Independent Network (NBIN) trademark.

Private Banking 1859 is a trademark NBF and other members of the National Bank group of companies use. It has been created for individuals and families with substantial financial assets who wish to ease the burden of managing their wealth on a day-to-day basis. These clients understand the benefits of entrusting this task to professionals. The business model is designed as a complete, integrated offering.

National Bank Insurance Firm Inc. is an indirect wholly owned subsidiary of National Bank. National Bank Insurance Firm Inc. offers a variety of insurance products and services, such as life insurance, disability insurance, critical illness insurance and other insurance products for individuals and businesses.

NBF Financial Services Inc. and NBF Financial Services Ltd. (together, “NBFFS”) are wholly owned subsidiaries of NBF. NBFFS offers a variety of insurance products and services, such as life insurance, disability insurance, critical illness insurance and other insurance products for individuals and businesses. 

National Bank Trust Inc. is a wholly owned subsidiary of National Bank of Canada and offers fiduciary, asset management, custody and discretionary portfolio management services.

When we refer a client to another member of the National Bank group of companies or when another member of the group refers a client to us, one company generally pays the other a commission. A portion of the commission may be shared with your Wealth Advisor.

It is important to note that these referral arrangements will not increase the costs or fees of services provided to the client. Therefore, the client will not pay more as a result of any referral arrangement between us and other members of the National Bank group of companies.

The commissions give us and other members of the National Bank group of companies incentive to refer clients to each other. Despite these commissions, clients’ interests must always come first. The commissions will vary depending on which member of the National Bank group of companies is involved and whether the client is referred to or by us.

We and the other members of the National Bank group of companies have adopted policies and procedures to help identify any material conflict of interest which may arise from these referral arrangements. We will not be involved in or made aware of your specific dealings with the other member(s) of the National Bank group of companies, other than in reference to any referral fees generated, as well as any specific authorization you may grant the member(s) of the National Bank group of companies in your account opening form.

The referral commissions we and the members of the National Bank group of companies share may be modified from time to time, in accordance with the referral arrangements we and other members of the National Bank group of companies may enter into with one another. In such cases, the list of referral arrangements and the information pertaining to the referral commissions will be updated and made available for consultation on the website.

 

Last update: January 2023

Best Execution Public Disclosure Statement (PDF)

NBF and members of National Bank Financial Group will, from time to time, refer clients to each other. The members of National Bank Financial Group promote the referral of clients between each other in accordance with the needs of the client. A referral may arise for example where a specific member of National Bank Financial Group does not offer certain services that a client needs but another member of National Bank Financial Group does and the client is referred to that other member of National Bank Financial Group for those services. An example of a common referral is when National Bank refers a client to NBF for purposes of establishing a brokerage account.

If a client is referred to a member of National Bank Financial Group that is registered under securities legislation, such as NBF, the referred member of National Bank Financial Group is responsible to the client for the activities that require registration such as the know-your-client and suitability obligations.

A brief description of the members of National Bank Financial Group that NBF enters into referral arrangements with from time to time, and the general nature of the services each provides is set out below. Each of NBF and the other members of National Bank Financial Group listed below are completely separate from each other, but are all wholly owned, direct or indirect, subsidiaries of National Bank. Each member of National Bank Financial Group offers its clients a different range of services, such as discretionary portfolio management services, high networth client services, direct brokerage services and insurance services for which each hold the appropriate registrations under the applicable legislations including, if required, the applicable securities laws.

National Bank is a federally regulated bank that offers a full array of banking services, including corporate and investment banking. It is an active player on international markets and, through its subsidiaries, is involved in securities brokerage, insurance, wealth management, as well as mutual fund and retirement plan management.

National Bank Financial Inc. is registered as an investment dealer in all Canadian jurisdictions. NBF is a full service securities dealer that is a truly integrated firm, combining retail advisory, brokerage services and discount securities brokerage services with institutional brokerage, investment banking, corporate finance and securities clearing services for third parties.

Private Wealth 1859, is a trademark used by NBF and other members of National Bank Financial Group and has been created for individuals and families with substantial financial assets who wish to free themselves from the burden of managing their wealth on a daily basis and understand the benefits that can be derived by entrusting this task to professionals. Its business model is designed as a complete, integrated offering.

National Bank Insurance Firm Inc. is an indirect wholly-owned subsidiary of National Bank. National Bank Insurance Firm Inc. offers a variety of insurance products and services such as life insurance, disability insurance, critical illness insurance and other insurance products for individuals and businesses.

National Bank Financial Financial Services Inc. and National Bank Financial Financial Services Ltd. (“NBFFS”) are wholly-owned subsidiaries of NBF. NBFFS offer a variety of insurance products and services such as life insurance, disability insurance, critical illness insurance and other insurance products for individuals and businesses.

National Bank Trust Inc. is a wholly owned subsidiary of National Bank of Canada and offers fiduciary, asset management, custody and discretionary portfolio management services.

The referral arrangements that NBF enters into from time to time with other members of National Bank Financial Group under which NBF may refer its clients to or may receive a referral from the members of National Bank Financial Group are in exchange for the sharing of commissions. It is important to note that these referral arrangements will not increase the costs or fees pertaining to the services provided to a client. Therefore, the client will not pay higher fees as a result of any referral arrangements that are entered into by NBF with another member of National Bank Financial Group. However, the commissions shared by NBF with another member of National Bank Financial Group give NBF and such other member of National Bank Financial Group incentive to refer a client to each other. The commissions will vary depending on the other member of National Bank Financial Group involved and whether the client is referred to or by NBF.

The referral commissions that could be earned or paid by NBF through referral arrangements with other members of National Bank Financial Group are as follows. For information purposes only, one basis point is equivalent to 0.01% (1/100th of a percent).

Private Wealth 1859 pays to National Bank 30% of the total gross revenue generated by the referred account during the first year

National Bank pays to NBF 20 basis points of the amount referred, subject to a maximum of $15,000.00 for referrals made to Commercial Banking.

NBF pays to National Bank 16.5 Basis Points of the amount referred annually for 5 years.

National Bank Insurance Firm Inc. or NBFFS pays to NBF, as the case may be, 50% of the total revenue received by it from the insurance company with respect to the transaction, including a renewal amount which will vary based on the product and the insurance company involved.

National Bank of Canada pays to NBF the following basis points based on the product and the amount involved.

NBF and the members of National Bank Financial Group have adopted policies and procedures to assist them in identifying and responding to any material conflicts of interest that may arise from these referral arrangements. NBF will not be involved in or aware of your specific dealings with the other member of National Bank Financial Group, other than in reference to any referral fees generated as well as any specific authorizations that you may grant the member of National Bank Financial Group in your account opening form or otherwise to enable it to continue to offer you its services.

The referral commissions NBF and the members of National Bank Financial Group are sharing may be modified from time to time in accordance with the referral arrangements NBF and the members of National Bank Financial Group may enter into with one another. In such cases, the list of referral arrangements and the information respecting the referral commissions will be updated and available for consultation on the NBF Internet site.

Comparing the return on your portfolio to an appropriate benchmark can be very useful in tracking the performance of your investments. Such comparisons can help you understand if your investment strategy is having the desired results or if you need to make some changes. Investment benchmarks also help establish reasonable expectations concerning your portfolio's long-term returns.

Such benchmarks generally measure returns generated by specific asset classes over a given period. The most common method used to measure the performance of an investment is to benchmark returns with broad indexes, such as stock or bond indexes. To ensure the comparison is meaningful, a benchmark index should be as close as possible to the security or portfolio you want to track. Benchmarks include the S&P/TSX for Canadian equities, the DEX Universe for Canadian bonds and the S&P 500 for U.S. equities. For a portfolio made up of several asset classes, the appropriate benchmark would be a combination of indexes weighted based on the portfolio's asset allocation.

For more information on comparing your portfolio's return to a benchmark, feel free to contact your Wealth Advisor.

Minimum interest: $5,00 (credit and debit)

1 The Prime rate refers to National Bank of Canada Prime Rate.

2 The U.S. Prime rate refers to Federal Reserve Rate.

A currency conversion is required when, for instance, a transaction involves a security denominated in a currency other than that of the account in which the operation is settled, a transfer of funds is made between accounts denominated in different currencies, or an amount (such as a deposit) in a currency is paid in an account denominated in another currency. 

Each time a currency conversion is required, NBF acts as principal in converting the currency and is remunerated on the basis of the spread between the price you pay for the currency and the price obtained by NBF or parties related to NBF for that same currency. The exchange rate applicable to the operation is established by NBF or persons related to NBF and includes spread. The applicable exchange rate, which appears notably on the trade confirmation and the statement of account, varies according to a number of factors, including market fluctuations, the amount, date and nature of the operation. 

The Spread NBF applies to operations is indicated in the table below.¹ 

1. Spread is subject to change without notice. 
2. Calculated for demonstration purposes only and rounded to the nearest tenth. We use basis points for foreign currency exchange conversions. The figures shown are based on the trailing 12 month USD/CAD Bank of Canada Daily exchange rate (as of Feb 1st, 2023).

Pursuant to the regulations in effect, National Bank Financial Inc. must notify you of the following:

The head office of National Bank Financial Inc.(NBF Inc.) is located in the province of Quebec.

Herein below you will find the names and addresses of the NBF Inc. agents for service of process in the provinces and territories where NBF Inc. does not have business locations:

Nunavut
Chandler & Cooper
C/O Susan Cooper
203 - 626 Tuniit Plaza
P.O. Box 2021
Iqualuit (Nunavut) X0A 0H0

Newfoundland
Stewart McKelvey Striling Scales
C/O Lewis B. Andrews
Cabot Place
1100 – 100 New Govers Street
St-John's, NFLD, A1C 5V3

Northwest Territories
Lawson Lundell, LLP
C/O Keith Bergner
200 – 4915, 48th Street
P.O. Box 818
Yellowknife, NT, X1A 2N6

Yukon
MacDonald & Company
C/O Grant MacDonald
200 - 204 Lambert Street
Whitehorse, YT, Y1A 3T2

Prince Edward Island
Stewart McKelvey Stirling Scales
65 Grafton Street
P.O. Box 2140
Charlottetown, PEI, CIA 8B9

To protect your assets, you need to do business with a solid and reliable financial institution. Clients of National Bank Financial Wealth Management can count on our vast investment experience, as well as our long-standing reputation for financial strength, credibility and reliability.

As a member of the Canadian Investment Regulatory Organization (CIRO), National Bank Financial Wealth Management is covered by the Canadian Investor Protection Fund (CIPF). The CIPF protects you in the unlikely event that National Bank Financial Wealth Management should become insolvent. It offers coverage up to:

• $1 million for all general accounts
• $1 million for all retirement accounts combined (RSPs, RIFs, LIFs and locked-in RIFs)
• $1 million for all education savings plans

To learn more about this coverage, contact the Canadian Investor Protection Fund at:

79 Wellington West
Suite 610, P.O. Box 75
Toronto, Ontario M5K 1E7
Toll Free: 1 866 243-6981
E-mail: info@cipf.ca
Internet: www.cipf.ca

That's not all! Fixed-income securities, such as bonds, stripped coupons and T-bills, guarantee a minimum return and value at maturity. For securities issued by a government or government agency, this guarantee is unconditional and unlimited.

In addition to this coverage, one of the best ways to safeguard your assets is by choosing a solid financial institution. National Bank Financial Wealth Management is a subsidiary of National Bank of Canada, one of Canada's strongest institutions, which has been serving investors for over 150 years.

On July 1, 2014, the Government of Canada added provisions to the Income Tax Act  to prevent tax evasion by U.S. persons. Under these provisions, Canadian financial institutions are required to identify and disclose information on accounts held by "U.S. persons" to tax authorities, annually.

Learn more

What is CRS-FATCA?

CRS-FATCA refers to the Foreign Account Tax Compliance Act (« FATCA »), an American law, and to the Common Reporting Standard (« CRS »), an international standard, whose principles have been integrated into the Canadian Income Tax Act.

The objective of these regulatory obligations is to fight tax evasion. To do this, financial institutions, including the National Bank, its subsidiaries and foreign centers (“the Bank”) must collect and report to the Canada Revenue Agency (“CRA”) certain information with respect to accounts they hold where the account holders are foreign residents for tax purposes. This reporting is done on an annual basis and the information collected must be constantly kept up to date in case of changes.

Since May 1, 2016, your wealth advisor has had to give you a Fund Facts document before your purchase of mutual funds. Your transaction cannot be completed until your wealth advisor gives you this document. There are some exceptions, which your wealth advisor can discuss with you. These changes are not exclusive to National Bank Financial - Wealth Management; they've applied to the entire industry since the end of May 2016.

Why the change?

Receiving the Fund Facts document before completing the transaction gives you adequate time to read about the fund you want to purchase.

How are Fund Facts sent?

The Fund Facts document will be given to you in person or sent by email, mail, or fax, as chosen by you and your wealth advisor. Don't hesitate to contact them for more information on this topic.

What's the Fund Facts document?

The Fund Facts document contains important information on the mutual fund you would like to invest in. There's a specific Fund Facts document for each mutual fund with information on the securities it includes, returns, risks, and fees. You should always read the Fund Facts document when you invest in a mutual fund so you're familiar with its main features.

To learn more about this change, please contact your wealth advisor.

UK Tax Startegy - 2021

This risk disclosure statement does not disclose all of the risks and other significant considerations associated with trading in derivatives. In light of the variety of risks involved, you should undertake such transactions only if you understand the nature of the contracts, the contractual relationships into which you are entering and the extent of your exposure to risk. Trading in derivatives is not suitable for everyone and often entails a high level of risk. Trading in derivatives should be made with caution and you should carefully consider whether such transactions are appropriate for you in light of your personal and financial circumstances, investment needs and objectives, investment knowledge, risk profile, investment time horizon, and other relevant circumstances. You should consult with your own business, legal, tax and account advisers before engaging into such transactions.

You may lose more than the amount of funds deposited

A characteristic of many derivatives is that you are only required to deposit funds that correspond to a portion of your total potential obligations and yet your profits or losses are based on changes in the total value of the derivative. This inherent leverage characteristic means that losses incurred can greatly exceed the amount of funds deposited. A relatively small market movement will have a proportionately larger impact on the funds you have deposited or will have to deposit. Your dealer may require you to deposit additional funds on short notice to maintain your position as the value of the derivative changes. If you fail to deposit these funds, your dealer may close out your position at a loss without warning and you will be liable for any resulting deficit in your account.

Using borrowed funds carries greater risk 

Using borrowed funds to finance a derivatives transaction involves greater risk than using cash resources only. If you borrow money, your responsibility to repay the loan and pay interest as required by its terms remains the same even if the value of the derivative declines. 

Deposited cash and property

You should familiarize yourself with the protections accorded to money or other property you deposit for domestic and foreign transactions, particularly in the event of a firm insolvency or bankruptcy. The extent to which you may recover your money or property may be governed by specific legislation or local rules.

Commission and other charges

Before you begin to trade, you should obtain a clear explanation of all commission, fees and other charges for which you will be liable. These charges will affect your net profit (if any) or increase your loss.

Fluctuations in price or value

The price and value of derivatives can be adversely affected by volatile market conditions and such occurrences may significantly increase your risk exposure. There are a variety of market factors and conditions which can directly or indirectly affect derivatives such as market demand and supply, interest rate, foreign currency exchange rate, indices, commodity prices, equity prices, investor perception and other political or economic factors. Since derivatives are linked to one or multiple underlying interests, the price or value of the derivatives may also be subject to considerable fluctuations due to the risks associated with the underlying interest. The level of sensitivity of an underlying interest with specific market conditions can have wide implications on the value of derivatives linked to that underlying interest. For example, when two or more factors are affecting one or more underlying interests of a derivative, its value may become unpredictable. A small movement in the price of one underlying interest can cause a sudden and large fluctuation in a derivative’s value.

Hedging and risk management strategies

Hedging transactions may require constant monitoring. A failure to adjust your hedging transaction in light of changing market conditions may result in the position becoming either under-hedged or over-hedged and losses can ensue.

The placing of certain orders (e.g. "stop-loss" or "stop- limit" orders) which are intended to limit losses to certain amounts may not be effective because market conditions may make it impossible to execute such orders. Strategies using combinations of positions, such as "spread" and "straddle" positions may be as risky as taking simple "long" or "short" positions.

Listed derivatives

Under certain market conditions, you may find it difficult or impossible to liquidate or offset an existing position on a marketplace (e.g. buy-to-close or sell-to-close order). This can occur, for example, when the market reaches a daily price fluctuation limit (“daily price limit” or "circuit breakers").

You should ask your dealer about the terms and conditions of the specific derivatives which you are trading and associated obligations. Under certain circumstances the specifications of outstanding contracts may be modified by the marketplace or clearing house to reflect changes in the underlying interest.

Over-the-counter derivatives

Over-the-counter derivatives (OTC derivatives) trading is not done on a marketplace. Your dealer is your trading counterparty. When you sell, your dealer is the buyer and when you buy, your dealer is the seller. As a result, when you lose money trading, your dealer may be making money on such trades, in addition to any fees, commissions, or spreads it may charge.

An electronic trading platform for trading OTC derivatives such as contracts for difference and foreign exchange contracts is not a marketplace. It is an electronic connection for accessing your dealer. You are accessing that trading platform only to transact with your dealer. You are not trading with any other entities or clients of the dealer by accessing such platform. The availability and operation of any such platform, including the consequences of the unavailability of the trading platform for any reason, is governed only by the terms of your account agreement with the dealer.

You are limited to your dealer to offset or liquidate any trading positions since the transactions are not made on a marketplace. As such, it may be difficult or impossible to liquidate an existing position. The customized nature of certain OTC derivatives may also add to illiquidity.

The terms of OTC derivative contracts are generally not standardized, and the prices and characteristics are often individually negotiated with your dealer. A central source to obtain or compare prices may not exist. It may be difficult to assess the value, to determine a fair price or to assess the exposure to risk. You should ask your dealer about the terms and conditions of the OTC derivative contracts you are trading and understand the related rights and obligations.