Liberty Gold Corp. (LGD:TSX; LGDTF:OTCQX) announced findings from a 24-hole, 1,400-meter sonic drilling program on the legacy heap leach pad at its Black Pine Oxide Gold Project in Idaho, Paradigm Capital Senior Analyst Lauren McConnell in and updated research note on August 27.
The drilling confirmed the presence of residual cyanide-soluble gold in the heap, presenting an opportunity for economic reprocessing and additional benefits for mine planning, the analyst wrote.
The drilling covered the approximately 31-million-ton (Mt) legacy heap, revealing residual grades between 0.06 and 1.18 grams per tonne gold (g/t Au), with higher concentrations near the surface.
Cyanide solubility ratios averaged between 40% and 60%, indicating that the material remains leachable and could provide incremental recoveries, McConnell noted. Relocating the legacy heap leach pad could allow its use as construction material (over-liner) for the new heap leach pad, reducing initial capital expenditures.
In the 2024 PFS, the Rangefront pit design required a 50-meter setback from the L-HLP's base, limiting access to approximately 250,000 ounces of oxide gold currently classified as a resource on the pit’s northern edge.
"Relocating the heap eliminates this restriction, enabling potential reserve conversion of these ounces," McConnell wrote.
Additionally, historical drilling suggests that oxide mineralization continues beneath the L-HLP, offering a new exploration target near the pit.
Next Steps
A resource estimate for the L-HLP is in progress and metallurgical and geotechnical testing will confirm leach characteristics and over-liner suitability, McConnell wrote. The Rangefront pit optimization will be updated to include both the reprocessed heap material and newly accessible ounces.
Permitting discussions are also ongoing with state and federal agencies, the analyst said.
The announcement is "incremental but positive," according to McConnell.
"Liberty has demonstrated an opportunity to extract additional gold at minimal cost, reduce capital requirements by re-using material, and unlock access to ~250 Koz (thousand ounces) of constrained resources in the Rangefront pit," she wrote. "Importantly, this is not a standalone development but a strategic enhancement to the feasibility program, with the potential to improve NAV, reserve conversion and payback metrics versus the 2024 PFS."
For investors, this update underscores Black Pine’s status as a large, adaptable oxide system in the Great Basin, McConnell said.
Near-term catalysts include metallurgical results from the heap material and updated mine optimization studies. Success in these areas could modestly increase the project’s NPV while also strengthening the investment case for potential M&A interest, given the district-scale profile and oxide heap-leach flexibility.
"Liberty trades at a deep valuation disconnect — at US$32/oz based on our minable estimate versus the Takeover Twenty peer median of US$47/oz, and at 0.05x P/NAV, compared to the peer median of 0.12x," the research note said. "It currently ranks #2 in our Takeover Twenty screen."
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Important Disclosures:
- Liberty Gold Corp. is a billboard sponsor of Streetwise Reports and pays SWR a monthly sponsorship fee between US$3,000 and US$5,000.
- Steve Sobek wrote this article for Streetwise Reports LLC and provides services to Streetwise Reports as an employee.
- This article does not constitute investment advice and is not a solicitation for any investment. Streetwise Reports does not render general or specific investment advice and the information on Streetwise Reports should not be considered a recommendation to buy or sell any security. Each reader is encouraged to consult with his or her personal financial adviser and perform their own comprehensive investment research. By opening this page, each reader accepts and agrees to Streetwise Reports' terms of use and full legal disclaimer. Streetwise Reports does not endorse or recommend the business, products, services or securities of any company.
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Disclosures for Paradigm Capital, Liberty Gold Corp., August 27, 2025:
Purpose
This Relationship Disclosure Information (“RDI”) is designed to help retail investors of Paradigm Capital Inc. (“Paradigm”) clearly understand the nature of the services that can be provided by their Paradigm advisor, and the necessary elements to ensure a satisfactory ongoing relationship. This document reflects the Client Focused Reforms (“CFR”)1 that came into effect in 2021 (Link).
Delivery
Paradigm uses its website www.paradigmcap.com as its repository for its RDI. All new and existing customers of Paradigm who have accepted electronic delivery method of materials, including RDI, can rely on its delivery via the Paradigm website, as per Section 14.2 of National Instrument 31-103. Effective June 30, 2021.
Compliance Contact Information
This document will explain the nature of the roles and responsibilities that both the client and advisor should follow to maintain a successful relationship. Please direct any questions about this document to Paradigm’s Chief Compliance Officer at [email protected]. Information Contained Within Document
• Know Your Client (KYC)
• Services
• Account types
• Products
• Investment risks
• Investment Suitability
• Client Focused Reforms (“CFR”)
• Conflict of interest management
• Account fees and charges
• Client transaction and account reporting
• Complaint Handling Procedures
• Agreements & Disclosures
Paradigm predominantly has institutional customers. The few retail customer accounts are either Paradigm employee accounts or accredited investors who were introduced to Paradigm by corporate clients with whom Paradigm has an investment banking relationship. Consequently, the Paradigm retail accounts usually do not reflect the entire portfolio of the client, and the clients are not looking to Paradigm to provide investment or portfolio advice. Typically, these clients are accredited investors with sufficient capital, risk tolerance and time horizon to invest in new issues offered by Paradigm.
It is paramount that the information provided by clients be accurate and kept up to date to ensure that all investments made in their accounts are suitable. As such, clients must immediately keep Paradigm apprised of any significant changes that could impact the operation of their account(s), including changes to marital status, employment income, or other changes. Paradigm will contact clients on a periodic basis to ensure that any changes are noted on file, and any relevant changes are made, if necessary.
Services
Paradigm only offers advisory accounts to retail investors. In an advisory account the client is ultimately responsible for investment decisions, although the client can rely on advice given by the advisor. The advisor is responsible for any advice given. In providing this advice, an advisor must meet an appropriate standard of care, give suitable investment recommendations, and present unbiased investment advice, consistent with the KYC information provided by the client.
Account Types
Depending on which of the accounts below is right for a particular retail client, the client may be able to open one or more of the following: Cash Accounts: involve standard cash settlement of transactions, where cash or securities must be delivered two trading days after the day of trade execution. Margin Accounts: offer some level of borrowing capacity, secured by the prescribed loan value of the securities held in the account; this loan value is prescribed by the more stringent of either both the Canadian Investment Regulatory Organization (“CIRO”) or by the credit policies of Paradigm and its Carrying Broker, National Bank Independent Network (“NBIN”). Cash-On-Delivery (“COD”) Accounts: the settlement of these trades takes place between Paradigm and the client’s designated custodian on a Delivery Versus Payment (“DVP”) basis.
Registered Retirement Savings Plan (“RRSP”) accounts are intended to hold eligible retirement savings investments and assets, with appropriate contributions, in accordance with the regulations and restrictions on their operation, as prescribed in the Canadian Income Tax Act.
Registered Retirement Income Fund (“RRIF”) accounts are intended to hold eligible retirement savings investments and assets, with appropriate withdrawals, in accordance with the regulations and restrictions on their operation, as prescribed in the Canadian Income Tax Act.
Registered Education Savings Plan (“RESP”) accounts are intended to hold eligible savings investments and assets, with appropriate contributions and withdrawals, intended to help a family member pay for post-secondary education, in accordance with the regulations and restrictions on their operation, as prescribed in the Canadian Income Tax Act.
Tax-Free Savings Accounts (“TFSA”) allow clients to hold eligible savings investments and assets where the related income and capital gains are earned on a tax-free basis, in accordance with the regulations and restrictions on their operation, as prescribed in the Canadian Income Tax Act.
First Home Savings Accounts (“FHSA”) allow clients to hold eligible savings investments and assets, with appropriate contributions and withdrawals, intended to help first-time home buyers pay for their first home, in accordance with the regulations and restrictions on their operation, as prescribed in the Canadian Income Tax Act.
For more information on how the various account types operate, the client should consult an advisor. For more information on tax matters, the client should consult a licensed tax advisor.
Know Your Product
Products Available through Paradigm
Paradigm predominantly trades Canadian and US listed equities on behalf of its clients. Paradigm does not currently offer fixed income products, bonds, government debt, money market or securities traded outside the US or Canada to its retail clients. For a comprehensive list of the various products the firm offers a client should speak to their advisor.
Products may change from time to time. Clients should talk to their advisor or visit the firm's website.
Risks
Investment Risks Understanding risk and knowing an individual's comfort with risk is an important part of investing. Risk may be defined as the measurable possibility of a future investment loss or gain, including the prospect of losing some or all of the original investment in addition to any funds borrowed on margin and the associated interest costs. Risk is a common indicator of the volatility of the value of a security or market. Volatility is a measure of the rate or degree that the price of a security or investment fluctuates over time. Risk Profile:
An individual’s risk profile encompasses both risk tolerance, willingness to accept risk, and risk capacity, ability to sustain a loss.
Risk Versus Return:
It is unrealistic to expect to receive a high return without incurring any risk. In reality, risk and return are related. To seek higher returns, investors can choose investments with higher risk profiles, but must understand they can lose all their capital. The amount of risk that a client is comfortable with is their risk tolerance. How a client feels about risking their capital will drive many of the investment decisions. The risk comfort scale extends from very conservative low risk, where the client does not want to risk losing a penny regardless of how little their investment earns, to the very aggressive high-risk client who is willing to risk all of their investment for the possibility that it will grow considerably.
Risk Tolerance:
An individual's risk tolerance may be affected by a number of factors including:
• Age
• Family situation
o marital status
o number and ages of dependants
o education
• Net worth
o Assets
o Liabilities
• Investment Income needs and expectations
• Income sources and amounts
• Investment time horizon
• Insurance coverage and cash reserves
Risk Capacity:
A person’s financial situation including their assets, debt, and the amount and stability of their income are all important when determining how much risk they can take with their investments. In addition, the larger the portion of a client’s total assets they are investing, the more conservative they may wish to be with this portion of their portfolio.
Paradigm assigns a risk capacity score at account opening based on a client’s answers to various questions regarding their ability to sustain loss. This helps determine which investments are suitable for the account, based on a client’s unique situation.
Careful discussions with one’s advisor to identify their own personal risk tolerance and capacity is essential.
Common Risks
Generally speaking, risks can be classified as market-related or security-specific.
Market-Related Risks
Risk factors that every investor is subject to irrespective of specific investment holdings include:
Market risk -- Most investments are subject to the risk of a general market decline in response to changing conditions in the domestic or global economy. These market-wide changes can be unpredictable and beyond anyone's ability to forecast.
Inflation risk -- Inflation reduces an individual's future purchasing power and their real investment returns.
Interest rate risk -- Interest rates changes affect the value of fixed income securities. An increase in interest rates will result in a drop in the market value of a fixed income security.
Foreign exchange risk -- Foreign exchange rate changes affect the value of investments that are traded in a foreign currency.
Security-Specific Risks
Risk factors which can affect the value of a specific investment holding include:
Product risk -- Stocks generally carry a higher level of risk than bonds. Short-term government debt securities are essentially risk-free, with the degree of risk increasing with longer-term government
bonds, investment grade corporate bonds and other corporate bonds.
Concentration risk – a high concentration of assets in a single or small number of issuers may reduce diversification and liquidity within a portfolio and increase its volatility.
Liquidity Risk – some securities may be illiquid because of legal restrictions, the nature of the investment itself, settlement terms, a shortage of buyers, or other reasons. In general, investments with lower liquidity tend to have more dramatic price changes and may subject the investor to losses or additional costs.
Business risk -- Business specific risk factors can affect a company's profitability. The failure of a new product, labour difficulties, high debt levels and the performance of competing firms are some of the specific risk factors which may contribute to a particular company's level of business risk.
Sector risk – certain sectors might be more volatile, or speculative, and thus have differing risk profiles.
Credit Risk – the riskiness of an issuer due to its debt obligations and ability to repay outstanding debt.
Foreign exchange risk -- Foreign exchange rate changes affect the value of investments in companies that buy and sell products / services in foreign countries.
Reducing security specific risk
Security specific risks can be reduced by holding a well diversified portfolio of investments. A diversified portfolio starts by allocating a client's investments between debt and equity products. It can also factor in diversification across sectors, and specifically to avoid over concentration in any security or sector.
The debt portion of the portfolio can be further diversified by purchasing debt of different terms and of different issuers, although all issuers should have an acceptable credit rating. The equity portion of the portfolio can be further diversified by buying shares of companies in different business sectors or based in different countries. If the client does not have a large amount of money to invest, they can diversify by investing in a pooled investment like mutual funds or exchange traded funds. Paradigm clients must decide their own asset allocation and specific security concentration. If they need full-service advice, such clients should seek a full-service retail representative at another firm.
CIPF Protection from firm insolvency risk
The cash and security assets in the client's account are covered by the Canadian Investor Protection Fund (“CIPF”), details of these limits can be found at www.cipf.ca. Should the firm become insolvent. CIPF provides coverage up to CAD $1 million in cash per customer for securities in the account in the event a firm becomes insolvent. Note that registered accounts are treated as separate accounts.
6CIPF coverage does not insure against market losses due to volatile markets, product suitability, or insolvency of an actual security in an account.
Your Personal Investor Risk Profile
An advisor can help a client determine their comfort level with risk based on the information the client provides.
• For a LOW RISK investor -The firm will recommend investments that generally display a lower volatility and risk profile. Although returns generated by such products are generally lower, they may be more certain.
• For a MEDIUM RISK investor --In addition to lower risk products, the firm may propose investments that include securities that may exhibit moderate volatility and a medium risk profile. While potential returns are higher, return volatility and risk also increase.
• For a HIGH-RISK investor --In addition to lower and medium risk products, the firm may suggest investments that may be unpredictable and speculative in nature. Such products may be subject to a greater risk of loss with a greater potential for returns.
• For a COMBINATION OF RISK LEVELS - A client may have a combination of the risk levels depending on the types of accounts they have. For example, a client may be high risk investor in their margin account and a low risk investor in their RRSP account. Given the product offering at Paradigm, all retail clients must be high risk investors. Investment Suitability
Suitability assessment
CIRO member firms are required to use due diligence to evaluate the suitability of any order the firm accepts or recommendation the firm makes based on factors including a client's financial circumstances, investment knowledge, investment objectives, risk tolerance and time horizon. The firm will conduct a suitability assessment whenever:
• A trade is proposed by a client;
• A trade is recommended by a client;
• Securities are received or delivered into a client account by way of deposit or transfer;
• We become aware of a significant change in a security in a client account that could result
in the account not meeting suitability requirements;
• There is a change to the Investment Advisor on the account
• There is a material change in a client’s KYC information
The suitability of the investments held in a client’s account will not be reviewed in the case of triggering events not described above and, in particular, in the event of significant market fluctuations. While an Investment Advisor may make recommendations with respect to suitable investments, the responsibility for all investment decisions lie with the client.
Client Focused Reforms (“CFR”)
The Canadian Securities Administrators (“CSA”) mandated the CFR which supplement the Registration Requirements, Exemptions and Ongoing Registrant Obligations found in National Instrument 31-103. Paradigm recognizes that most, if not all, retail accounts will not form the whole portfolio of holdings by its clients.
Client must provide Paradigm with updates:
Paradigm will ask clients to provide at account opening and to be updated on the total Assets Under Management (“AUM”) and sector breakdown of their entire portfolio. However, as the CSA recognizes, sometimes clients may not provide a full picture, or keep Paradigm informed of all portfolio changes.
Unsolicited Orders:
Paradigm will use its business judgment whether an order, even if unsolicited, as per section 13.3(2.1) of NI 31-103, is suitable for the customer. If the registrant deems the order to be unsuitable, it may ask the client to provide updated information to substantiate the suitability of the unsolicited order.
If the advisor determines that a transaction proposed by the client is unsuitable, they will advise the client of their assessment prior to executing the trade. Moreover, a firm will reserve the right not to accept an order to purchase a security if it is not in keeping with the client's investment or risk objectives.
Paradigm mostly covers speculative investments, and thus its retail clients should have a high tolerance for risk, as well as the ability to absorb any resultant losses.
Paradigm corporate-related accounts typically hold a higher-than-normal concentration of the issuer for whom the customer is an employee. This can result from a stock-option plan and / or an issuer financial transaction in which this issuer-related employee participated. In either event, the account will likely be over-concentrated in the issuer, and the customer will have account(s) elsewhere which overall provide for a more balanced portfolio.
Referral Arrangements:
Occasionally customers will be referred to Paradigm. Should there be any referral fee attached to this referral, as per Section 13 of NI 31-103, there shall be both a referral arrangement made between Paradigm and the referring party, and a referral disclosure document sent to the underlying client who was referred to Paradigm.
Best Interests Standard:
The CSA has guided that Best Interest is dependent upon facts and circumstances, in which the materiality of a potential conflict must consider materiality, reasonability and professional judgment.
Management of Conflicts of Interest
Conflicts of interest may arise at account opening or while a client's account is held at the firm. Management of conflicts is carried out through disclosure.
Introduction
CFR requires Paradigm to take reasonable steps to identify and respond to actual and potential material conflicts of interest, and to provide clients with information about these conflicts; and where appropriate obtain prior client consent before engaging in certain types of transactions. This document contains important information clients should read carefully about the key conflicts of interest we have identified.
In situations where Paradigm is providing services in which a conflict of interest might occur between the interests of Paradigm and the client, Paradigm will fully inform clients of these conflicts in a fair, equitable and transparent manner, consistent with the best interest of our clients.
Paradigm is an employee-owned commercial enterprise that has a responsibility to maximize the returns for its shareholders and customers alike. Paradigm earns compensation for investment banking services and trading commissions, in return for investment banking work, research services, and trade execution. Customers should be aware of these fees, which are outlined below in this document.
Paradigm provides these fee/trade-based services to meet the interests and needs of customers, as expected under corporate and securities laws. Paradigm provides trusted advice and seeks to protect client and investor interests by addressing conflicts of interest.
Regulators:
The Canadian Securities Administrators (“CSA”) and the Canadian Investment Regulatory Organization (“CIRO”) stipulate that material conflicts of interest must be identified, addressed and disclosed appropriately.
Description of Paradigm
Paradigm is an independent, research-driven investment dealer, and a member of CIRO. Paradigm sales and trading focuses on companies that Paradigm covers via research services. Our investment banking team provides advisory and corporate finance services, mainly to Canadian corporate issuers. Paradigm espouses teamwork and long-term relationships that are the key to exceptional success and growth.
Paradigm believes in a dynamic work culture, and a high standard of ethics.
Paradigm’s principal clients are institutional money managers and corporate issuers; the Firm has limited number of retail client accounts, which are usually employees of either Paradigm or corporate issuers. Importantly, Paradigm does not provide the full range of services of a traditional retail member. The Firm will often act as an agent between both buyers and sellers or issuers and try to act in the best interests of all parties. Occasionally, we may also act as a principal in a Bought Deal financing or a trade in the marketplace to facilitate a client order. Consequently, some of our business activities may lead to conflicts of interest, should we represent both sides of a transaction.
National Bank Investment Network (“NBIN”)
Paradigm is a Type 2 Introducing Broker that uses NBIN as its Carrying Broker. NBIN provides many administrative services for Paradigm and its clients, which are outlined in the NBIN Account and Services Agreements and Disclosures found at www.paradigmcap.com
Managing Conflicts of Interest
Under CIRO's rules, all existing or potential material conflicts of interest between a Dealer Member and a client must be addressed "in a fair, equitable and transparent manner, and considering the best interest of the client or clients". In applying this requirement, it is recognized that it is not always possible or practical for us to address all conflicts of interest in the best interests of each client when the conflict of interest involves multiple clients and competing interests. The most common types of conflicts of interest that can occur are:
• Conflicts of interest between Paradigm and a client;
• Conflicts of interest between clients; and
• Conflicts of interest between Paradigm and our related or associated companies
Paradigm manages material conflicts of interest in three ways:
• Avoidance: Paradigm avoids conflicts of interest that are prohibited by law, as well as any conflicts that cannot be effectively addressed other than by not engaging in the activity that would give rise to the conflict.
• Control: When, in the Firm’s judgment, the conflict of interest can be successfully managed Paradigm will do so by restricting access to information and/or separating business functions.
Clients may also be provided with alternative solutions to best manage the conflict.
• Disclosure: When the Firm is unable to avoid or control the conflict, Paradigm will disclose the conflict to clients appropriately. Clients can then independently assess the significance of the conflict in light of the services offered by Paradigm, and determine with Paradigm whether and how to proceed accordingly. Outlined below are the various services offered by Paradigm, the potential conflicts to consider, and how the Firm addresses these conflicts.
Paradigm Services and Relationships:
Research:
Potential Conflict of Interest How Conflicts Will Be Addressed Paradigm provides investment research on securities of issuer companies that it may recommend to paying customers. These issuers may also have other business relationships with us, including investment banking activity.
Our Research is subject to extensive and detailed regulatory requirements and internal standards. This includes the controls over communications between the investment banking department and the research department.
Paradigm is also required to disclose within our research reports conflicts that a client should review in assessing whether these conflicts are important. These include:
• Compensation received related to both investment banking and non- investment banking services
• Ownership by the firm or analyst,
• Compensation of analysts,
• Rating systems and distributions, including where corporate finance services have been provided
• Site visits conducted by research analysts as part of the due diligence for their investment report
Sales & Trade Execution:
Potential Conflict of Interest How Conflicts Will Be Addressed
Paradigm earns compensation by selling products and services to paying clients Paradigm will inform clients of fees, commissions and other compensation so clients are aware of what they will be paying in advance of any transaction. Paradigm earns brokerage commissions on trades executed for clients which are negotiated directly between the client and the investment advisor.
All commissions are disclosed on trade confirmations. Fees for other services is documented in a fee schedule provided to retail clients at the time of account opening, as well as any time there is a change in the fees related to any services.
This includes service fees as offered by NBIN, the Carrying Broker for Paradigm. Paradigm is required to make “suitable” investment recommendations, in line with client’s investment objectives and risk tolerances, as well as the information available to investment advisors about the recommended investment. Paradigm may need to select which clients will be offered certain securities if availability is limited in the event of a New Issue being over-subscribed.
The syndication group will make a fair determination of the appropriate allocation of securities based on individual client relationships and other trade-related considerations including suitability, timing, and order size. Due to investment banking business relationships with issuers of securities, certain employees may know confidential or Material Non-Public Information (“MNPI”). As per the Tipping Provisions of Section 5 of the Securities Act (Ontario), Paradigm cannot disclose such Paradigm’s investment banking department operates as a separate business unit from both the sales and trading department and the research department. Any information obtained from issuer clients is kept confidential and not divulged to other information to clients, even if the information might lead us to not recommend a trade in those securities departments. Paradigm’s internal information barriers are designed to ensure compliance with securities regulations to ensure MNPI does not go beyond investment banking and compliance.
While the majority of trades executed are ‘Agency’ trades, Paradigm may occasionally act as ‘Principal’, trading with its own capital or securities against client orders which may result in a profit to the Firm Paradigm will obtain client consent when required and disclose on the client trade confirmation whether the Firm acted as Agent or as Principal for each transaction.
Notwithstanding the Agent/Principal nature, Paradigm will always seek to achieve Best Execution, as is found in Paradigm’s Best Execution and Order Handling Document found at www.paradigmcap.com. Paradigm may sell sedscurities of companies that are related or connected to the Firm.
Paradigm will disclose this fact to the customer at the time of the trade.
Investment Banking:
Potential Conflict of Interest How Conflicts Will Be Addressed Paradigm is paid by issuers of securities when we advise on or underwrite a new issue which we may recommend to clients. In these instances, Paradigm is acting for the issuer that wants to obtain the highest reasonable price to raise funds for the Issuer’s enterprise, while recommending the investment to purchasers who are interested in obtaining the lowest reasonable price.
Paradigm has structurally segregated the investment banking department from the rest of the advisory business. This prevents the sharing of non-public information.
The Firm’s investment banking department appropriately evaluates the reasonableness of pricing new issues and takes into consideration factors such as market conditions, market value, and the specific securities being offered. This evaluation is performed separately from the considerations of the equity sales group. In all instances, investments must be suitable for the client and in line with the client’s stated investment objectives and risk tolerance.
While institutional customers are suitability exempt, Paradigm reserves the right to not sell certain new issue securities to retail customers if it is determined that the investment is unsuitable.
The offering documents provide full disclosure of all relationships Paradigm may have with the issuer, including compensation arrangements related to the transaction.
Related or Associated Companies
Potential Conflict of Interest How Conflicts Will Be Addressed Merchant Banking Activities:
From time to time one or more companies affiliated with Paradigm may undertake merchant banking activities. Individuals involved with Paradigm in various capacities may also be involved in such merchant banking activities. Such merchant banking activity may involve an issuer to which, or about which, Paradigm provides one or more of the above listed Paradigm services. These merchant banking activities may be, or may reasonably be perceived to be, of direct or indirect benefit to Paradigm. These types of potential conflicts are covered in Paradigm’s internal policies, and the activities are supervised and monitored internally. Appropriate disclosure will be provided to clients as determined in the context of each conflict of interest.
Other Potential Conflicts of Interest
As well as the potential conflicts of interest we have set out above there are a number of other potentially relevant conflicts that may arise: Potential Conflict of Interest How Conflicts Will Be Addressed Individuals may serve on the board of directors of issuer companies or other organizations Employees may act as directors or officers of public companies in rare instances. Any employee looking to serve on the board of directors of a public company must first seek the approval of both compliance, as well as the Board of Directors to ensure all conflicts of interest are accounted for.
For employees looking to serve on the board of private companies, compliance pre-approval is required.
Employees may receive or give gifts, gratuities, or entertainment opportunities due to their relationship with clients
Paradigm has strict Policies and Procedures to limit what are acceptable gift and entertainment practices. All gifts are reviewed.
Other Outside Activities by employees of the firm All employees must disclose upon hiring and at least annually, whether they engage in outside activities for which they expect to receive compensation (including indirect payment), consideration or other benefit received or expected. If required, these activities may be added to the National Registration Database (NRD).
These activities must be preapproved by the compliance department to mitigate the risk of client confusion and/or conflicts of interest in advance, consider the best interests of the client, and approval will only be granted in cases where effective controls, and qualified supervisory personnel are in place. Employees are prohibited from engaging in outside activities that would interfere or create conflict with their duties.
Fees and Services Charges
Commissions
Commissions are transaction related fees paid to the firm at the time of sale or shortly thereafter and which are shared by the dealer with the advisor. Paradigm charges a minimum of $25 per trade for retail accounts and may negotiate a mutually agreeable fee with the client based on the number of shares purchased and/or the value of each share.
Fees
As part of the account opening process, all retail clients are provided with a Fee Schedule which details the fees Paradigm charges, including costs to:
• Trade
• Hold accounts at the Firm
• Send money via wire transfers
• Transfer accounts out of the firm
Account Reporting
Transaction and Statement Reporting
The client will receive written confirmation of all transactions in their account. The client will also receive account statements when there is a transaction during the month and on a quarterly basis regardless of account activity. We do not currently provide clients with the percentage return of their accounts on account statements.
Paradigm does not offer Portfolio Management services.
These client account statements are provided by our carrying broker NBIN and are in accordance with regulatory requirements.
Annual Portfolio Review
We are responsible for sending each client an annual account report for the previous calendar year which will be provided by our carrying broker NBIN. The report will provide information regarding how client’s investments performed over the last year and a list of charges and payments paid by the client over the same time period.
If the client chooses to have an annual portfolio review with their advisor, the client can discuss the performance of the account holdings and investment strategy.
Performance Benchmarks
Investment benchmarks are a standard against which the performance of a security, mutual fund or portfolio can be measured. Generally, broad market stock and bond indices are used for this purpose. There are dozens of indices that be used to gauge the performance of any given investment including the S&P/TSX Composite, the S&P 500 and the Dow Jones Industrial Average.
When evaluating the performance of investments, it is important for customers to compare returns against a pre-selected and appropriate benchmark.
Given the importance of having the correct comparison and the diverse nature of its client portfolios, Paradigm will not include benchmarks on the monthly client statements.
Client Responsibilities
A firm needs the client's help to ensure that the relationship with their advisor is positive and results in the services that the client needs and wants. The client has a responsibility to help achieve this outcome. To this effect, the client should:
• Provide a full and accurate description of their financial situation, investment objectives risk tolerance, risk capacity and time horizon to their advisor to assist him/her in meeting the client's investment goals.
• Promptly inform their advisor of any material changes to their life circumstances or investment objectives. A "material change" is a change to any information that could reasonably result in changes to the types of investments appropriate for a client, such as income level, investment objectives, risk tolerance, time horizon or net worth. Examples of such changes would include changes in employment, marital status or retirement plans.
• Review all account documentation, sales literature, trade confirmations, statements and other documents provided by the advisor or Firm.
• Understand all costs and fees associated with the services a client will be provided.
• Be proactive - ask questions and request information to resolve any questions about the account, specific transactions or investments or the client's relationship with their advisor.
• Be cognizant of potential risks and returns on investments.
• Communicate in writing expectations for the advisor and/or firm.
• Contact the Chief Compliance Officer if displeased with answers or explanations from the advisor: [email protected]
• Ensure payment for transactions is made by the settlement date.
• Review account/portfolio holdings on a regular basis and discuss them with the advisor.
• Consult a professional such as a tax accountant or a lawyer for professional advice.
Complaint Handling Procedures
Written client complaints can be submitted either via email to [email protected] or via mail to the Designated Complaints Officer (“DCO”) of Paradigm Capital Inc.
General Counsel
95 Wellington Street West, Suite 2101
Toronto, Ontario M5J 2N7
The DCO may also be reached by phone at 416 361 9892.
Within five (5) business days of the receipt of a complaint, the client will be sent an acknowledgment letter. In this acknowledgement letter, Paradigm may request additional information in order to investigate the complaint. Paradigm will also send the client the following CIRO brochures: How To Make a Complaint (Link to brochure) and How CIRO Protects Investors (Link to brochure).
The client will also receive these brochures at the time of account opening. Within ninety (90) calendar days of the receipt of a complaint, Paradigm will provide the client with a substantive response. If Paradigm is unable to respond to the complaint within the above time frame, the client will be provided a written explanation as to why.
In the final decision letter, Paradigm will provide the client with a summary of their complaint, the results of the investigation, an explanation of the final decision, and the other options available for seeking compensation, should the client not be satisfied with the response.
If any client is dissatisfied with Paradigm’s final response, they may contact the following organizations: Ombudsman for Banking Services and Investment (“OBSI”), Canadian Investment Regulatory Organization (“CIRO”), or they may choose to go to arbitration or pursue legal action.
Agreements and Disclosures:
The following agreements, some of which may be found at www.paradigmcap.com, may be entered into depending on the type of account(s) the client opens:
• Joint Account Agreement
• Margin Agreement, to be obtained before a margin account is opened
• Consent to electronic delivery of documents
• Trading Authority Agreements
The following disclosures are provided via www.paradigmcap.com to the client by Paradigm:
• Research Rating System
• Research Distribution Policy
• Best Execution and Order Handling
• Privacy Policy and Agreement
• Relationship Disclosure Information
• NBIN Account & Services Agreements & Disclosures
• NI 24-101 Trade Matching Statement
• CIRO Know Your Advisor: Advisor Report
The remaining disclosures below are provided to the client via email at the time of account opening:
• Introducing/Carrying Broker Disclosure Statement
• Paradigm’s Fee Schedule
• CIPF Brochure
• OBSI Brochure
• How CIRO Protects Investors Brochure
• CIRO Complaints Brochure
• Paradigm’s Business Continuity Plan