Compliance Memo

Compliance Memorandum 2013-11; Change of fund risk rankings: CI Investments

For more information, contact:

Compliance Team

Date Issued:

November 14, 2013

We have been advised by CI Investments that they have recently made changes to the risk ranking of the Harbour Growth & Income Fund, moving from a “Low - Medium” to a “Medium” risk ranking.

As a best practice, review each client’s portfolio holding any of these funds for suitability. At a minimum, a review of the clients KYC and portfolio must occur prior to any new purchase in the affected plan.

Where the risk ranking of the existing holdings now exceed the client’s stated “Plan Risk Tolerance”, a recommendation must be made to rebalance the client’s portfolio to bring it into compliance.

We must caution financial advisors that updating a client’s risk tolerance to simply match a new risk ranking with existing holdings in an effort to maintain the affected plans onside with KYC may be inappropriate. At minimum, when faced with this circumstance, advisor notes must be maintained documenting a discussion on the amended client risk tolerance.

As always, if you have any questions or comments, contact the Compliance Department by email at