The Company:
BluMont Capital (“BluMont”) is one of Canada’s leading providers of alternative investment solutions.
BluMont is a wholly-owned subsidiary of Toronto-based Integrated Asset Management Corporations (TSX:IAM), a leading Canadian alternative investment management company with approximately C$3 billion in assets and committed capital under management as of June 30, 2007 (www.iamgroup.ca).
At BluMont we take careful and controlled measures to ensure that we are compliant will all legal and regulatory requirements and strive for transparency in all our documented processes and practices. In addition to working with Citigroup Fund Services Canada Inc., an independent third party administrative services provider, we work closely with legal counsel, trust companies, custodians, auditors and our strategic partners to ensure that investors’ rights and purchases are safeguarded. We feel it is crucial to disclose any potential investment risks – including potential conflicts of interest – with the same level of clarity and conciseness that we describe our products, their structure, fees and performance record.
Potential Conflicts of Interest:
Both Advisor and Dealer:
BluMont is registered as an advisor in the categories of investment counsel and portfolio manager (“IC/PM”) and as a mutual fund dealer. As such, we maintain reasonable policies and procedures to minimize the potential for conflict of interest from our activities as both an advisor and a dealer.
Although we are dually licensed as both an IC/PM and a mutual fund dealer, we primarily operate as a manager and distributor of alternative investment products sold via offering memorandum or information statement through financial advisors of brokerages and financial planning firms in Canada. The financial advisor, therefore, has the responsibility for Know Your Client (KYC), account opening and other required disclosure and reporting requirements. As an independent third party, the financial advisor can objectively assess the merits of our products and other alternative investment products to determine what would be the most suitable to the investor.
As a mutual fund dealer, BluMont can, in its sole discretion, accept direct client purchases. In those situations, BluMont accepts the responsibility for the KYC, account opening documents, required disclosure and suitability requirements. The direct client activity is incidental to our business and wherever possible, we encourage investors to seek independent advice from a financial advisor. BluMont will assess the suitability of a potential investment in our own products but cannot assess, or hold on behalf of the investor, products not managed or advised by BluMont.
Fees and Commissions:
BluMont follows standard industry practices relating to the payment of fees and commissions and, therefore does not accept direct referral arrangements from individual financial advisors of brokerages, dealers and financial planning firms. This allows us to avoid potential conflict of interests between clients and their registered dealers, concerns around the suitability assessment of our products for individual clients, and other such compliance obligations.
Relationship of Related Registrants:
In July 2005, Integrated Managed Futures Corp. (“IMFC”) became a related registrant of BluMont. IMFC is registered in Ontario as an advisor in the category of commodity trading manager and limited market dealer and is currently an advisor to the BluMont Canadian Opportunities Fund. BluMont has a 32.5% equity interest in IMFC. The nature of the relationship between BluMont and IMFC is extends to that of manager / sub-advisor only. Each entity maintains it own distinct policies and procedures. IAMC is the parent company of both BluMont and IMFC.
BluMont acts as fund manager and advisor to the BluMont Canadian Opportunities Fund, the BluMont Hirsch Long/Short Fund, and the BluMont Hirsch Performance Fund which are considered to be connected issuers.
MFDA Exemption:
BluMont is not currently a member, and does not intend to become a member of the Mutual Fund Dealers Association (MFDA); consequently, clients of BluMont will not have available to them investor protection benefits that would otherwise derive from membership of BluMont in the MFDA, including coverage under any investor protection plan for clients of members of the MFDA.
Privacy Plan:
At BluMont we recognize that all personal information is private and confidential. BluMont’s Privacy Plan (“Privacy Plan”) governs BluMont’s collection, use and disclosure of personal information. It is the intention of BluMont, by way of this Privacy Plan, to comply with privacy legislation and, in particular, with the requirements of the federal Personal Information Protection and Electronic Document Act (PIPEDA). BluMont recognizes the following key principles of PIPEDA: accountability, purpose; consent; collection; use, disclosure and retention; accuracy; safeguards; directness; access; and complaints and recourse. The measures outlined in the Privacy Plan are intended to provide clients with comfort that we regard personal information with the utmost importance. The Privacy Plan is also created to provide the right of access to personal information and an avenue to address any concerns individuals may have about the use of their information. For more information or for a copy of our Privacy Plan, please contact BluMont’s Privacy Officer.
Money Laundering and Terrorist Financing:
As outlined by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, BluMont is obligated to implement specific measures to detect and deter money laundering and the financing of terrorist activity. As such, all investments into our open-ended funds require completed documentation including confirmation of investor identification or financial entity information. If BluMont becomes aware or suspects that an investor is engaged in money laundering, it is our duty to report to the Financial Transactions and Reports Analysis Centre of Canada. This reporting will not be deemed a breach of information disclosure restrictions imposed by law or otherwise.
Please do not hesitate to contact us should you have any questions in regards to BluMont’s Statement of Policies or should you require further details on any BluMont practices and policies.
