As of July 2, 2025

How has the Relationship Disclosure Information changed?

We updated the documents to provide clients with clarity and transparency around our complaint handling process. This update aligns with the AMF’s new Complaint Handling Rule and our ongoing commitment to support clients fairly, resolve issues efficiently, and ensure compliance.

Below is a high-level summary of the changes:

We updated information about:

• How to submit a complaint: Clients are encouraged to submit complaints to our Complaints and Regulatory Investigations team by mail or email. Clear contact information is now provided.
• Our complaint resolution process: We outline how complaints are acknowledged, reviewed, and responded to, generally within 90 days (or 60 days for Québec residents).
• Compensation options: We explain how to seek compensation through independent third parties like the Ombudsman for Banking Services and Investments (OBSI), including how to contact them.
• Your legal rights: Clients are informed about the option to consult a lawyer, including the importance of respecting legal time limits to preserve their rights.
• Jurisdiction-specific recourse: We have added details for clients in Québec, Manitoba, New Brunswick, and Saskatchewan about additional provincial avenues for complaint resolution or compensation.

Historical Changes

As of April 30, 2024

How has the Relationship Disclosure Information changed?

We updated the documents to reflect our updated business practices. We believe transparency and education are crucial for fostering a strong relationship with our clients. By providing this information, our goal is to ensure a clear understanding of our products and services, and how we uphold our commitment to working in your best interests.

For your convenience, here’s a brief summary of the recent changes to our relationship disclosure information. Feel free to reach out if you have any questions.

We've made some updates about how we recommend portfolios based on your answers to our KYC Questionnaire (your KYC Information):

• We’ll no longer offer specialized portfolios that are only available to clients of referral partners and our conflicts of interest disclosure has also been updated to reflect this change.
• All of the portfolios that we provide to clients will be considered for all clients, regardless of how they’re introduced to CI Direct Investing.
• If you're investing less than $50,000 in your CI Direct Investing account, we'll recommend a portfolio typically consisting of a single diversified investment fund that we consider suitable for you.
• If you’re investing more than $50,000 in your account, we'll recommend a portfolio which might include two or more investment funds that we consider suitable for you.
• It's required to meet the portfolio minimums before your money is invested in the recommended portfolio.
• If you're interested in portfolios that involve leverage or short selling, we'll reach out to you by email or phone to discuss if they're suitable for you, given their specific risks. Your deposits won't be invested in these portfolios until we've had this conversation and you've provided any additional KYC information we need. We'll only proceed with these investments if we believe they're right for you.

As of September 22, 2023

How has the Relationship Disclosure Information changed?

We updated the documents to ensure that they accurately reflect our current business practices and regulatory requirements. We believe transparency and education are essential to building a strong relationship with our clients, and by providing you with this information, we aim to give you a clear understanding of our products and services and commitment to work in your best interests.

For ease of reference, here we have provided you with a high level summary of the recent changes made to our disclosure. Please contact us if you have any questions.

We updated information about:

• How we consider the curated model portfolios created for our referral partners, along with the other relevant and applicable model portfolios, when assessing which model portfolio will be suitable for you. Our portfolio managers will consider a reasonable range of alternatives for all accounts.
• How clients who work with an external representative will be required to confirm annually that you are receiving services from the representative.
• Conflicts of interest related to employee personal trading on the conflicts of interest disclosure.

As of April 21, 2023

How has the Relationship Disclosure Information changed?

We updated the documents to ensure that they accurately reflect our current business practices and regulatory requirements. We believe transparency and education are essential to building a strong relationship with our clients, and by providing you with this information, we aim to give you a clear understanding of our products and services and commitment to work in your best interests.

For ease of reference, here we have provided you with a high level summary of the recent changes made to our disclosure. Please contact us if you have any questions.

We added information about:

• clients who open an account with CI Direct Investing through our referral partners, who may be invested in model portfolios created specifically for clients referred by those partners
• our referral partner relationships, which are considered to be "referral arrangements" under applicable securities laws that apply to us, even though we do not generally pay our partners or their representatives any fees or incentives for these referrals
• how for some of our referral partner relationships, we may facilitate the collection and remittance of a services fee you may agree to pay your representative in respect of their financial planning and other on-going support services they provide to you (separate from the management fee you pay to us)
• how if you invest with CI Direct Investing through one of our referral partners as described above, you may pay a different management fee to us than if you invest directly through us

As of September 19, 2022

How has the Relationship Disclosure Information changed?

We have enhanced our disclosure in order to provide you with greater transparency about our services, policies and material conflicts of interest. 

For ease of reference, here we have provided you with a high level summary of the recent changes made to our disclosure. Please contact us if you have any questions.

We added information about:

• our investment strategy which permits us to invest your money in cash equivalents or other securities that we deem appropriate
• high interest savings accounts offered by CI Direct Investing operated by third party financial institutions
• offering portfolios managed directly by CI Direct Investing or by sub advisors, including our affiliate, CI Investments Inc. (“CI GAM”)
• which portfolios are managed by CI Direct Investing and which are managed by CI GAM or other sub advisors, including disclosures during account opening and on a new Portfolio Disclosure page
• the portfolio construction process of portfolios managed by CI Direct Investing, which considers all available securities unless otherwise disclosed during account opening and may use CI GAM funds when we consider them to be in the best interest of our clients
• the portfolio construction process of portfolios managed by CI GAM, which considers funds managed by CI GAM and will generally only include other funds when CI GAM does not have a suitable fund for that portfolio
• how we address the inherent conflict of interest that results from providing portfolios and investment funds managed by our affiliate CI GAM in our Conflicts of Interest Disclosure
• CI Direct Investing’s responsibility for determining the appropriate portfolio for your account
• how we work with affiliates and address related conflicts of interest which is described in our Conflicts of Interest Disclosure
• the costs of holding investment funds, including MERs and TERs
• the Fair Trade Allocation Policy which was moved from your Managed Investment Account Agreement to our Relationship Disclosure Information to align with the presentation of other policies and allow us to provide you with more timely updates, should the policy change

As of December 31, 2021

How has the Relationship Disclosure Information changed?

We have enhanced our disclosure in order to provide you with greater transparency about our services, policies and material conflicts of interest. 

As these are the material changes that may impact how we work with you, please contact us if you have any questions.

We added information about:

• our no fee high interest saving account
• the liquidity of securities in our portfolios
• the construction of our portfolios is not limited to proprietary products
• the details we collect from you as part of the “Know Your Client” process
• how we put your interests first in determining a suitable investment for you
• encouraging you to provide us with a trusted contact person
• our ability to place temporary holds on your accounts where we reasonably believe that you might have an illness, impairment, disability or aging-process limitation that places you at risk of financial exploitation, and we believe that you are, or may be exploited financially, or if we believe you do not have the mental capacity to make decisions involving financial matters
• material conflicts of interest that we have identified and addressed in your best interest. Please read this section carefully as it has had the most substantial changes in the document.

We removed or changed some details:

• removed the Fair Trade Allocation Policy since it is already available to you in your Managed Investment Account Agreement.
• removed references to our insurance business
• additional details on how the management expense ratio (MER) fees charged by third parties can impact your account
• added to our Leverage Disclosure Statement that we do not adjust our recommendation based on your use of borrowed funds for the purpose of investing
• moved our Personal Trading Policy, Outside Business Activities, Referral Arrangements, Soft Dollar Arrangements and Brokerage Arrangements to the Conflicts of Interest Disclosure.

As of June 28, 2021

How has the Relationship Disclosure Information changed?

We reformatted the disclosure to make it easier to read and understand in order to provide you with greater transparency about our policies. We also added some new disclosures, and made a few changes to our policies.

These are the material changes that may impact how we work with you.

We added information about:

• the financial planning services we provide you
• our team approach to providing you with advice and service
• how often we invest cash in your account
• how we calculate and charge our management fees
• the impact of fees on your return, specifically that “the management fee we charge reduces the return of your account over time”
• added a link to a new page with our most recent fee schedule
• management expense ratio (MER) fees charged by third parties
• foreign exchange fees charged when we convert foreign currency in your account
• monitoring our employees’ outside business activities to ensure they don’t “impair our ability to serve you and is consistent with our duty to deal fairly, honestly, and in good faith with you.”

We removed or changed some details:

• changed “no-load mutual funds” to “commission-free mutual funds” for greater clarity
• removed references to “cashflow” and “tax-efficient” from our investment strategy and replaced them with a more detailed explanation that we “offer a variety of portfolios tailored to your needs and preferences, including low-cost portfolios of ETFs, portfolios with access to private investments, socially responsible impact investing portfolios, and more.”
• changed the “Clean Tech” optional add-on to “thematic investment exposure” to better reflect current and future add-ons that may be available
• moved information about the Risks of Investing to their own page
• updated our explanation of a conflict of interest as “any circumstance where the interests of a client and those of CI Direct Investing or individuals acting on our behalf are inconsistent or divergent.” 
• updated our Conflict of Interest policy to clarify that “we take reasonable steps to identify and respond to material conflicts of interest and conflicts that are reasonably foreseeable.”
• moved our Personal Trading Policy to its own section
• updated the list of CI Direct Investing affiliates to “CI Global Asset Management, CI Private Counsel LP, Assante Financial Management Ltd., CI Direct Investing Inc., CI Investment Services Inc., Assante Connect Inc., One Capital Management LLC, Aligned Capital Partners Inc., Lawrence Park Asset Management Ltd. and Marret Asset Management Inc.”
• moved some details about our privacy policy to a new Privacy Notice available at https://app.cidirectinvesting.com/privacy

As of August 5, 2020

How has the Relationship Disclosure document changed?

We’ve recently updated our Relationship Disclosure document to provide you with

greater transparency on our policies.

The following includes material changes and their implications to investors as a

result of this update:

• Deposits to your CI Direct Investing account may be held for up to 30 days before they can be withdrawn in order to prevent fraud and identity theft. Since we are an investment management firm not meant for short term trading, our clients do not typically withdraw funds within this window.
• WealthBar Financial Services Inc. now does business as CI Direct Investing ("CI Direct Investing").