Hello,

We take this opportunity to provide important reminders on your obligations, and HUB Capital’s (“HCI’s”) policies and procedures, regarding the delivery of the Fund Facts documents to clients. This Bulletin also highlights the tools available in RepVision to assist you with accessing Fund Facts documents for your clients, documenting the delivery of Fund Facts documents to your clients, and showing your compliance with these obligations as part of your client file.

Advisors are required by regulations and HCI Policies and Procedures to provide clients with a copy of the Fund Facts document before acceptance of a trade. This requirement also applies to subsequent trades into a fund. Therefore, if an updated version of the Fund Facts document is available, it must be delivered to the client before the subsequent trade is submitted. 

Fund Facts documents, like a Simplified Prospectus, must be updated on an annual basis or more frequently if there has been a material change to the fund, to ensure current information/disclosure for new and existing unitholders. If a new version of the Fund Facts document is available at the time of a subsequent trade, an updated version must be provided to the client.

The delivery of a current version of the Fund Facts document is required for all purchases, switches, conversions, initial PACs, and changes to funds in existing PACs, however, it is not required for subsequent PACs, distributions, adjustments or in-kind transfers. 

Fund Facts can be delivered to clients in person, by email or through other means (e.g. printed and mailed to the client). Representatives must evidence the method of delivery and have proof that the Fund Facts document was provided to the client prior to the acceptance of the trade.

To assist with meeting these obligations, HCI requires all representatives to use RepVision to provide Fund Facts document(s) to their clients. This ensures that the most recent version of the Fund Facts has been given to the client. 

In addition to tracking the delivery of the most current version, other benefits to the representative in using Fund Facts delivery in RepVision include:

• Quick access to Fund Facts documents for all mutual funds approved for sale through HCI.
• Easy delivery of Fund Facts to clients via email, directly from RepVision.
• Option to print a copy of Fund Facts to deliver to clients, either in person for via mail, and print a separate page for clients to sign acknowledging receipt of the printed copy.
• Keeps a record under the client in RepVision, showing each Fund Facts document that has been delivered, including Fund Code, Fund Name, Date the Fund Facts was Requested, Delivery Method (Email or Print), Delivery Details, and whether there is an up-to-date version of the Fund Facts available. This functionality allows Representatives to easily demonstrate the Fund Facts document was delivered to the client prior to the trade.

‘Up To Date’ Column on the Fund Facts Delivery Section in RepVision

The information provided in this column is important for a Representative to consider when a client is making a subsequent purchase to determine whether the last Fund Facts document delivered is still current, or if an updated version of the Fund Facts document is available and should be provided to the client before the additional purchase is made.

Under the “Up to Date” column if it indicates:

• “Yes” next to the fund, the client has the most current version of the Fund Facts document and they do not need to be provided with a copy before the subsequent purchase is made.
• “No” next to the fund, it means that the Fund Facts previously delivered to the client is now out of date, and the client will have to be sent a current copy of the Fund Facts document before the additional purchase is made in the fund.

Creating New Clients and Delivering Fund Facts before the KYC Form is Completed

• Representatives can create new clients on the system, by entering only their name and email address, to deliver Fund Facts to the client prior to opening an account and be able to document the delivery electronically on the system. A KYC is not required to create the client record and deliver the Fund Facts document.
• Once the KYC Form has been fully completed and signed by the client, the balance of the KYC information must be entered into RepVision (e.g., address, employment information, plan information, etc.) as per HCI’s normal procedures.

If you have any questions or would like to learn more about the Fund Facts delivery tools in RepVision, please reach out to your Investment Product Specialist. 

If you have any questions regarding your Fund Facts delivery requirements, please reach out to your Regional Compliance Officer.

Thanks,

Cheryl Hamilton
Vice President Risk Management and Chief Compliance Officer