Assante Capital Management Ltd. hours of trading

Order Handling Policy

The Canadian marketplace is constantly evolving. We would like to take this opportunity to outline Assante Capital Management Ltd.’s policies with respect to trading equities.

This policy disclosure is for your information only.  Please keep in mind that it does not apply to your mutual fund transactions.

Assante Capital Management Ltd. (“ACM”) has a carrying broker arrangement with National Bank Independent Network (“NBIN”), which acts as an agent on behalf of ACM for all equity trading on the Toronto Stock Exchange (“TSX”) and other marketplaces.

 

Trade Desk Hours of Operation

Through our carrying broker, NBIN, ACM’s Trade Desk will provide to you and your financial advisor full order execution services between the hours of 9:30 AM and 4:00 PM, Eastern Standard Time (“EST”), during days on which the TSX is open for business (excluding statutory holidays).

While some marketplaces will provide order execution services outside the hours currently available on the TSX, the ACM Trade Desk nor NBIN, as a standard, expand its hours of operation.  This is due to concerns that in the absence of adequate market liquidity, the best execution of your orders may be compromised. As such, we cannot guarantee order acceptance or execution outside of our standard hours of operation.

 

Primary Marketplace and Routing of Orders

For securities listed on the TSX, which may also trade on one or more ATS (Alternative Trading System), the TSX will be designated as the principal marketplace at the time of order entry.

Unless otherwise agreed to by you and your financial advisor, the following policies will apply:

  • All orders received by ACM prior to 9:30 AM EST will be released by ACM to NBIN to be entered onto the pre-opening of the TSX.
  • Orders entered after 4:00PM will not be released by ACM to NBIN until the pre-opening on the next business day.
  • All orders received by ACM between the hours of 9:30 AM and 4:00 PM EST which are immediately executable (including market orders or limit orders within the bid/ask spread on a trading facility or marketplace) will immediately be forwarded to NBIN to be executed on the trading facility or marketplace which offers the best price for that order. During regular market hours NBIN achieves best price execution by using automated systems that will source the best price for the execution of a client order from the multiple Canadian marketplaces. All available markets are considered during the sourcing process, including both visible markets and markets that offer no pre-trade transparency (Dark Pools).
  • All orders received by ACM between the hours of 9:30 AM and 4:00 PM EST which are not immediately executable (including limit orders outside the bid/ask spread) will be forwarded to NBIN to be entered on a transparent trading facility or marketplace in accordance with ACM’s and NBIN’s policies as updated from time to time.
  • ACM’s financial advisors or the ACM Trade Desk may delay entering all or part of a client order on a trading facility or marketplace to achieve best execution if specifically requested by the client. This procedure will not be affected by the introduction of new trading facilities or marketplaces.
  • For overseas trades, NBIN will facilitate buys in overseas markets as long as they have a relationship with a registered dealer on that exchange. NBIN will sell securities in overseas markets on condition that (a) the securities must be sold on the market where the client bought it and (b) a physical certificate has been fully deposited.

 

Best Execution

Best Execution represents the obligation on marketplace participants to diligently pursue the execution of each client order on the most advantageous execution terms reasonably available under market conditions at the time of execution. Best Execution includes, but is not limited to the best price available at the time of execution. It also includes optimizing liquidity, minimizing order signaling effects, speed and certainty of execution.

Our carrying broker NBIN is committed to using all reasonable efforts to ensure that Assante clients achieve “best execution” of their orders in respect to Canadian listed securities that are quoted or traded on Canadian marketplaces.

NBIN uses the following Best Execution Criteria Considerations:

  • Price at which the trade would occur
  • Speed of execution
  • Certainty of execution / % Fill Criteria
  • Overall cost of execution
  • Market disclosure/signaling
  • Prices and volumes of the last sale and previous trades
  • Direction of the market for the security
  • Posted size on the bid and offer
  • Size of the spread
  • Liquidity of the security
  • Execution quality over the order duration – determines the price at which the order was executed relative to the time of entry and average execution price over the time in which the order was actively traded in the market

NBIN meets its best execution obligations for client orders through:

  • Use of Smart Order Routing technology: NBIN endeavors to employ the most technological advanced smart order routing (SOR) technology available relevant to the trading application and execution venue. NBIN is responsible for adjusting their Smart Order Routing Strategies, using a Third-Party SOR and typically uses a spray strategy.
  • Provision of client liquidity: In order to minimize price, certainty of execution and adverse market signaling impacts of large client order types NBIN may at its discretion enhance visible market liquidity though the provision of proprietary liquidity facilitation.
  • Marketplace Access: NBIN is a member of all Canadian protected marketplaces.
  • Access dark liquidity: NBIN will access dark liquidity facilities when market factors indicate a reasonable likelihood of material liquidity for a security in these trading venues.
  • Access foreign markets: NBIN will sometimes access foreign market liquidity in a security when market factors indicate this can be accomplished on terms advantageous to the client in the context of both price and other execution considerations.
  • Monitoring order execution quality: NBIN performs periodic, systemic reviews of order routing criteria to ensure optimum routing for client orders and by order execution performance against relevant quantitative metrics.
  • Personnel: NBIN is committed to employing professional, experienced trading personnel capable of evaluating market characteristics and suitable execution strategies in the context of market conditions.

 

Best Execution Governance

NBIN’s Best Execution Committee meets at least quarterly to ensure ongoing integrity of its best execution regime.

 

Market Orders

All client orders which will result in immediate execution will be executed by NBIN on behalf of ACM on the trading facility or marketplace which displays the best price (or prices) available to our client. All such market orders received outside of the TSX’s trading hours (or on a day when TSX is not open for trading) will be released by ACM to NBIN during the pre-opening of the next trading session of the TSX for that security.

 

Limit Orders

A client limit order will be considered to be any order that includes a minimum sale price or maximum purchase price set by the client. Where such an order is received between the hours of 9:30 AM and 4:00 PM EST but is not immediately executable (the minimum sale price is below the best bid or the maximum purchase price is above the best offer), the order will be entered in accordance with ACM’s and NBIN’s policies in effect at the time. Where a limit order is received outside of the hours of 9:30 AM and 4:00 PM EST or on a day when TSX is not open for trading, the order will not be released by ACM to NBIN until the TSX opens its regular trading (regardless of which trading facility or marketplace’s order book will be utilized).

 

Special Terms Orders

Special terms orders have specific, non-standard terms attached to them which are not executable on a regular trading facility or marketplace (i.e. orders with a non-standard settlement period). Unless otherwise agreed to by you and your financial advisor, ACM will communicate to NBIN to enter all such orders on the TSX. NBIN will make the determination if such orders are immediately executable on another trading facility or marketplace at the time the order is entered.

 

Day Orders

Unless otherwise agreed to by you and your financial advisor, an unfilled day order on the TSX that has not priced at the last trade price on the TSX will expire at the close of trading of the TSX which is currently 4:00 pm EST. However, if an order is priced at the last trade price on the TSX, the order will remain eligible for trading on the TSX until the extended trading session is over at 5:00 pm EST unless you have instructed your financial advisor to cancel the order. If, however, your order was initially booked on another trading facility or marketplace, the day order will expire at the close of trading for that facility or marketplace.

 

“Good ‘til Cancelled” Orders

Client orders specified as “good ‘til cancelled” (“GTC”) will be entered and will remain on a trading facility or marketplace until they are executed or expire. Our carrying broker will only allow the entry of orders with a 30 calendar-day maximum GTC. It is your responsibility as the client to ensure what the date of expiry will be on an outstanding order and to contact your financial advisor on or before the order’s expiry date should you wish to have the order re-instated.

 

Stop-Loss Orders

Stop-Loss orders will be entered in the order book of a transparent trading facility or marketplace in accordance with ACM’s and NBIN’s policies in effect at the time the order is received. The stop-loss order will become an active market order once the trigger price is achieved on the trading facility or marketplace on which the order is housed. Once triggered, NBIN will undertake, on a best efforts basis, to ensure that the best possible fill price is obtained taking all available trading facilities and marketplaces into consideration at the time.

 

“Fill or Kill” Orders

NBIN will accept from ACM “fill or kill” orders but will only execute these orders on the understanding that they will execute the fills on the trading facility or marketplace which will provide the best price for our client. All trading facilities and marketplaces will be reviewed for “fill” opportunities before the order will be “killed.”

 

Market-on-Close Orders

Currently the TSX is the only marketplace which offers a market-on-close (“MOC”) facility. All orders must be entered on the TSX’s MOC facility prior to 3:40 pm EST and will be executed at the calculated closing price for that security on the TSX. It should be noted that trading on the MOC facility will be executed at the same time as other trading facilities or marketplaces will be offering quotes on their visible order book and therefore ACM and NBIN cannot guarantee that the order will be executed at the best price.

 

Disclosure of Marketplaces on Trade Confirmations

If a trade has been executed on more than one marketplace or an alternative marketplace, the trade confirmation will reflect the following disclosure “Traded on one or more marketplaces or markets, details available upon request. May be an average price, details available upon request.” You may contact your financial advisor to obtain the full details of your order execution.

 

Trading on a Specified Marketplace

ACM and NBIN are subject to certain obligations to the Canadian equities market. NBIN is obliged to consider execution opportunities on all Canadian trading facilities and marketplaces for our clients and cannot accept instructions from ACM to trade on a specific trading facility or marketplace. NBIN is obliged to execute on behalf of ACM all trades at the best available price regardless of where such a price may be quoted.

 

Relationship with Alpha Trading Systems Limited Partnership

Alpha Trading Systems Limited Partnership (Alpha) is an ATS operating in Canada offering a broad range of trading services and options. As part of NBIN’s regulatory obligations to secure best execution for all client orders, its parent corporation, National Bank Financial (NBF), is a subscriber to Alpha. Its automated trading systems probe Alpha’s available liquidity on all orders. NBF is a limited partner of Alpha and a shareholder of Alpha Trading Systems Inc., the general partner of Alpha, and also has representation on the Board of Directors of Alpha.

 

Relationship with Aequitas Innovations Inc.

The Ontario Securities Commission has given approval to Aequitas Innovations Inc. to launch a new stock exchange in Canada, Aequitas NEO Exchange (Aequitas), effective March 2015. Aequitas Innovations Inc. was founded by a group of Canadian corporations, representing a diverse range of market participants, working together to create the new user-focused stock exchange and a private securities platform. CI Investments, which is a related issuer to Assante Capital Management Ltd., is an investor in Aequitas. For more information, please visit: www.aequitasneoexchange.com.

 

Questions

Your financial advisor with Assante Capital Management Ltd's will gladly provide you with more details should you have any questions or require further clarification regarding ACM order handling procedures and hours of operation for equity trading.