ENHANCED CONFLICTS OF INTEREST DISCLOSURE – effective June 30, 2021
A conflict of interest includes situations where:
- The interests of the client and of Pathfinder are not consistent or in opposition;
- Pathfinder may be influenced to put its interests before the interests of the client; or
- A reasonable client would lose his/her trust in Pathfinder due to benefits available to or detriments subject to Pathfinder.
A material conflict of interest involves situations where the conflict may reasonably affect the decisions of the client and/or the recommendations of Pathfinder.
While Pathfinder has already provided its clients conflicts of interest disclosure during account opening, our policies and disclosure around conflicts of interest are being enhanced to ensure that any such conflicts will be adequately identified and addressed in the best interest of our clients as mandated by our regulator. That is, Pathfinder will be putting our client’s interest ahead of its own in all circumstances.
Pathfinder pooled funds are proprietary products because we are the portfolio managers of these funds. Clients are provided with the following disclosure in our Managed Account Agreement:
The suitability determination conducted by PAML and its representatives will not consider the larger market of non-proprietary products or whether those non-proprietary products would be better, worse, or equal in meeting the client’s investment needs and objectives.
Your Investment Policy Statement addresses this conflict in your best interest.
Pathfinder has policies and procedures covering the following:
- Clients’ product mix;
- Employee trading;
- Outside business activities;
- Intrynsyc Capital Corporation; and
- Employee bonuses.
Please refer to your Managed Account Agreement for details or ask your portfolio manager or investment counsellor for a copy.
Pathfinder has adopted policies and procedures to identify conflicts in a timely way taking reasonable steps to identify existing and reasonably foreseeable material conflicts of interest.
This disclosure is to ensure clients are aware all material conflicts of interest must be either avoided or addressed in the best interest of the client.