Learn the best practices as a Wealth Planner
Understanding your Role in the Wealth Management Private Client Program
It's important to follow the outlined guidelines for interacting with clients in a service-oriented and compliant basis.
Employees and/or Optimize representatives such as Wealth Planners, who are not securities licensed, are not allowed to conduct any registrable activities such as providing investment advice or facilitating securities related transaction activities.
The below activities however are permitted by such employees:
Registration Triggers
The table below depicts some of the main activities which require securities licensing and are registrable.
Accordingly, unless you are a licensed representative under Optimize, please do not communicate verbally and/or via written correspondence on any services that fall under the scope of registrable activities.
Important: Non-licensed employees are required to immediately direct all questions/inquiries which pertain to the duties outlined below to their assigned Associate Portfolio Manager (AAR) or Portfolio Manager (AR).
Understanding our Communications and Social Media Policies
Please note that any content you wish to post online (e.g. your social media accounts) related to your role as a Wealth Planner for Optimize must be reviewed and pre-approved in writing by compliance.
- If there is any such content, please send an email to compliance@optimize.ca with the proposed advertising content or social media content you are looking to use and allow four to five days for compliance to review and either approve the content or require changes be made.
Important: Please understand that all content must be approved by compliance in writing prior to publishing. All content where registrable activity is discussed without the appropriate registrations will not be allowed.
Optimize's Marketing Policies
In any instance where you provide or a client requests to receive additional information regarding Optimize, please follow the protocols outlined below:
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If the discussion could potentially lead to registrable activities occurring, please ensure that a licensed Optimize representative conducts those discussions with the client that involve the provision of investment advice or recommendations.
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All outside websites are not permitted.
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It is not permitted to provide clients with documents which could be interpreted as solicitations for investments or conducting registrable activities (e.g. Morningstar Reports).
Important: As an important reminder, any discussions with clients regarding their portfolios, performance, or any other registrable activity must be conducted by a licensed Optimize representative. If you are not licensed with Optimize, you must request your assigned APM or PM to conduct such discussions.
Using your Optimize Email and Approved Signature Format
Kindly ensure that all email communication is done so through your Optimize email address. This allows for ongoing efficient monitoring of any client communication from a compliance and legal perspective. In addition, your email signature must be in the pre-approved format and content so that it contains the necessary legal and regulatory content.
Conflicts of Interest
Canadian securities laws require registrants, such as Optimize, to take reasonable steps to identify existing material conflicts of interest, as well as material conflicts of interest that the registrant in its reasonable opinion would expect to arise, between the firm, including each individual acting on its behalf, and a client.
A conflict of interest includes any circumstance where:
- the interests of different parties, such as the interests of a client and those of Optimize or a representative, are inconsistent or divergent;
- Optimize or a representative may be influenced to put their interests ahead of their client’s interests; or
- monetary or non-monetary benefits available to Optimize or a representative, or potential detriments to which Optimize or a representative may be subject, may compromise the trust that a reasonable client has in Optimize or a representative.
If there are instances where you believe there is an explicit or implied conflict of interest between yourself and the client, please notify the compliance team immediately through compliance@optimize.ca. The team will take the necessary time to review and assess the potential conflict of interest and act accordingly. Please refer to the Ethics Program for a full explanation of the review process to identify what constitutes potential conflicts of interest.
The Optimize Seniors and Vulnerable Clients Code
Optimize is committed to protecting the best interests and well-being of all clients, including clients who are seniors or with diminished capacity, severe long term illness, mental or physical impairment or language barriers, and may be vulnerable to potential financial exploitation, abuse or fraud (“vulnerable client”).
- If there are any clients who you become aware of that may be considered a vulnerable client, please notify their PM as soon as possible – so that additional monitoring can be completed on their accounts.
Optimize asks all clients to identify and provide the contact details for a “trusted contact”. This information will be asked to each client as part of the account opening process. If that information is not readily available when the account is being opened, it can be submitted through a service request within the portal.
A trusted contact is typically a reliable friend, family member or other individual who a client believes has their best interest in mind and who can speak to Optimize and its representatives about the client’s health, mental capacity and financial circumstances in instances where financial exploitation, abuse or fraud is suspected or there are concerns about the client’s decision-making capacity.
The Optimize Policies and Procedures Manual
- To help you and your team remain fully compliant and build your ongoing processes in line with our required policies, please take the time to regularly review and internalize our Policy and Procedures Manual.
Once a year we will ask you to confirm and commit to these policies, which helps everyone to ensure that your actions are always in line with the firm’s values, mission, and our current regulatory environment. This in turn, helps to build trust with clients and contributes to them receiving the highest level of service possible.
Client Complaint Process
It is important to understand how to identify a complaint along with how to appropriately handle it and when to notify the Compliance department at Head Office.
A complaint is any verbal or written statement from a client, or person acting on behalf of a Complainant, alleging a grievance or dissatisfaction with any product or service offered by Optimize or a representative of Optimize.
All Complaints are to be forwarded to compliance@optimize.ca as soon as they are received.
Important: It is important to emphasize that once a complaint is received, please forward to Compliance immediately, please do not attempt to resolve the complaint independently, and please do not communicate with the client while compliance is reviewing the complaint.