The purpose of this disclosure is to outline iA Private Wealth’s order execution approach and its framework for delivering “best execution” to clients, in accordance with the Universal Market Integrity Rules (UMIR), the “best execution of client orders and transactions” requirements under the CIRO Corporation Investment Dealer and Partially Consolidated Rules (the “IDPC Rules”), and applicable Canadian securities legislation.
This policy applies to services provided to both institutional and retail clients (as defined in the IDPC Rules) of the iA Private Wealth trading desk. It covers transactions in listed securities, derivatives, foreign-exchange traded securities and transaction in OTC securities.
Best execution refers to the obligation to take all reasonable steps to achieve the most favourable result for clients. This assessment considers various factors, including price, cost, execution speed, likelihood of execution and settlement, order size, order characteristics, and any other relevant considerations (collectively, the “Execution Factors”).
In fulfilling best execution obligations for both retail and institutional clients, iA Private Wealth evaluates the following Execution Factors:
In addition, prevailing market conditions are taken into account, including:
For institutional clients, the relative importance of Execution Factors is determined based on the characteristics of:
When routing listed securities to foreign intermediaries or executing on foreign markets, additional considerations include:
iA Private Wealth is obligated to take all reasonable steps to achieve best execution when acting on behalf of clients. This obligation applies in circumstances where clients reasonably rely on the firm to protect their interests in relation to the Execution Factors.
This includes, but is not limited to, situations where iA Private Wealth:
Where clients provide specific instructions relating to one or more Execution Factors, iA Private Wealth will follow those instructions to the extent reasonably practicable, while continuing to comply with applicable regulatory requirements.
Clients should be aware that providing specific instructions may limit the firm’s ability to apply certain measures designed to achieve best execution.
When routing interlisted securities to U.S. marketplaces, the firm considers:
In certain situations, such as system disruptions or abnormal market conditions, it may be necessary to execute orders in a manner that differs from this policy. In such cases, iA Private Wealth will continue to pursue the best possible outcome given the circumstances.
iA Private Wealth reviews this policy and its order execution arrangements at least annually. The purpose of this review is to assess whether improvements can be made to execution quality, including:
More frequent reviews are conducted where material changes arise that may affect the firm’s ability to consistently achieve best execution.
Client orders in listed securities may be executed across multiple Canadian trading marketplaces. iA Private Wealth is committed to making reasonable efforts to achieve best execution across all Canadian marketplaces.
The firm accesses all protected marketplaces, as well as unprotected marketplaces where doing so may benefit the client.
Unless otherwise communicated, the default marketplace for securities listed on the Toronto Stock Exchange (TSX) is the TSX, regardless of whether the security is available on alternative marketplaces.
Orders for Canadian-listed securities may be executed on the Toronto Stock Exchange (“TSX”), the TSX Venture Exchange (“TSXV”), the Canadian Securities Exchange (“CSE”), a number of alternative Canadian electronic marketplaces, or on a foreign organized regulated market.
The alternative Canadian electronic marketplaces which iA Private Wealth accesses, or may access, in accordance with the Order Protection Rule (both protected and unprotected) are as follows:
NOTE – * protected as of the date of this policy.
iA Private Wealth directs orders for securities traded on U.S. markets to Citadel Securities LLC (“Citadel”). U.S. market orders may also be executed through Virtu and StoneX. Orders for securities traded on marketplaces outside of Canada and the United States are directed to NBIN and Virtu for execution on those markets through its affiliated entities.
These institutions maintain comprehensive best execution policies, procedures, and disclosures governing the handling of orders routed by iA Private Wealth. iA Private Wealth obtains annual attestations from each of these parties to support its oversight of best execution obligations.
iA Private Wealth uses third-party smart order routing (SOR) technology to obtain optimal pricing and execution outcomes.
The firm also utilizes third-party algorithmic tools offering a range of execution strategies tailored to different trading objectives. For interlisted securities, orders may be executed in either Canadian or U.S. markets, depending on:
Routing decisions are influenced by both:
SOR may divide orders into smaller orders, distributing them across one or multiple marketplaces, either simultaneously or sequentially. The system determines execution details such as size, timing, and limit price while respecting client instructions. Best execution obligations apply at both the parent order and smaller order levels.
iA Private Wealth may route client orders resting on a marketplace to an alternative marketplace if the firm feels such actions will increase the likelihood of obtaining best execution on our client orders.
Unless otherwise specified, client orders are valid between 9:30 a.m. and 4:00 p.m. ET.
Unfilled day orders expire at 4:00 p.m. ET or at the close of the applicable after-hours session.
Orders containing conditions that prevent execution in the regular market are classified as special terms orders. These are posted to the special terms market of the primary listing exchange, unless immediately executable on another marketplace at entry.
Clients are encouraged to contact their Investment Advisor or Portfolio Manager for further guidance regarding such orders.
iA Private Wealth does not receive payment for order flow from any marketplace to which the firm routes its client orders in listed securities. iA Private Wealth may pay fees and receive rebates from various marketplaces for passive or active order flow in accordance with the marketplace’s fee schedule. iA Private Wealth will not pass along any fees or rebates associated with order execution directly to clients.
iA Private Wealth does not have any ownership interest in any exchange or marketplace in Canada and as such, iA Private Wealth does not have any conflict of interest regarding order handling and order routing practices.
In order to achieve best execution, iA Private Wealth relies on the third-party vendor systems and data and marketplace systems. In the ordinary course of business, all third parties and the systems they provide can be subject to various failures. When these failures occur, iA Private Wealth policies are exposed to compromise and failures are immediately reported to Compliance.
When notified of a technical or systemic problem, the iA Private Wealth trading desk will immediately verify that the systemic problem is not internal to iA Private Wealth. If another market participant is isolated as the source of a potential problem, Compliance will take steps to ascertain if best execution is compromised and client executions are affected. When dealing with a marketplace that is experiencing technical difficulties, iA Private Wealth may rely on self-help in these circumstances. If self-help is invoked, the affected marketplace may be removed from the iA Private Wealth SOR system until it has been determined there are reasonable grounds to believe that the identified issues have been resolved.
If best execution is compromised, Compliance will inform the regulators and take necessary steps to declare self-help.
An order executed on one or more marketplaces may be reported to the client with the following disclosure: "Traded on one or more marketplaces of markets, may be an average price; details available upon request". This disclosure will be made on the client’s trade confirmation.
Should the client receive such a trade confirmation, they may contact their Investment Advisor/Portfolio Manager to secure full details of the trade executed.
For unlisted securities, trading and fair price verification is completed through iA Private Wealth grey market policy and procedures.
iA Private Wealth is committed to providing clients’ orders in over-the-counter securities at the most favourable terms available under prevailing market conditions. iA Private Wealth fixed income desk acts as principal and facilitates all client transactions. iA Private Wealth is required to make reasonable efforts to provide a fair price for each client order including any markup or markdown, commission and service charges. Markup/markdown charges are the amount added/subtracted from the price of the security. Transactions and prices are reviewed and verified as being within the context of the market.
All iA Private Wealth debt transactions are reported to the Canadian Investment Regulatory Organization daily. This enables the Canadian Investment Regulatory Organization to enhance the integrity of Canada’s debt market through more timely surveillance, enhanced oversight and increased regulatory transparency.
The iA Private Wealth Best Execution Committee meets on a minimum, annual, or ad hoc basis when necessary. The purpose of the committee is to ensure the ongoing integrity of iA Private Wealth trading policies, procedures and rules. The marketplace landscape and regulatory environment are re-evaluated in order to ensure iA Private Wealth best execution policy and procedures remain up to date. Trading technology is also reviewed to ensure client orders receive optimal order execution.
iA Private Wealth reviews this disclosure at least annually and updates it as necessary to reflect current practices.