Order Handling Procedures
on Multiple Markets

Best Price, Best executions & Hours of Operation
Under Canadian regulation, we are obligated to provide best price and best execution for all client orders. For equities that trade on multiple marketplaces, Fidelity Clearing Canada (“FCC”) who act as All Group’s carrying broker, execute the trades for us. In accordance with SRO and exchange rules, when executing client orders FCC will take all reasonable steps to achieve Best Execution for these orders, taking into consideration the kind of security to be traded, the nature of the order, the execution venue as well as any other additional special instructions provided by the customer in relation to the execution of his order.

 Regular hours are between the hours of 9:30 a.m. and 4:00 p.m., Eastern Standard Time (“EST”), Monday through Friday, not including statutory Canadian holidays (“Regular Trading Hours”). All available markets are considered including both visible markets and markets that offer non pre-trade transparency (Dark Pools). FCC’s trading staff and systems will be available for order execution during Regular Trading Hours. All Group staff may be available outside of this time; however, All Group will not guarantee the ability to take client orders and/or effect trade execution outside of the Regular Trading Hours.

Order Handling and Execution
Day Orders
A Day Order is an order to trade that expires if it is not executed the day that it is booked to the marketplace. All Day Orders expire, if not filled in full, upon the close of the default marketplace where the last portion of the order remains effective.

Good Til Cancelled (Open) Orders
Open orders are orders that will remain valid until a specified date of expiry. These orders will be entered in the Default Marketplace if they are not immediately executable on an alternative marketplace at the time of entry. The order will remain in the Default Marketplace until executed or expiry, whichever comes first.

Market Orders

A Market Order is an order to buy or sell a security at whatever prices are available in the marketplace to help ensure a complete and full fill. Market Orders will be handled in accordance with this policy. These orders will expire, if not filled in full, on the marketplace where the last portion of the order remains live, at the close of the marketplace.

Limit Orders
A Limit Order is an order for a security at a specific minimum sale price or maximum purchase price that is not to be exceeded. Limit Orders will be handled in accordance with this policy.  The order will expire, if not filled in full, upon the close of the marketplace where the last portion of the order remains live.
Special Terms Orders
Special Terms Orders are orders with specific terms that are not executable in the regular marketplace. Special Terms Orders will be executed on a best-efforts basis by the FCC Trading Desk and may be entered as a combination of orders in the default marketplace or on an ATS suitable for the execution of the order.  Special Terms Orders will expire at the close of the Default Marketplace.

Stop Loss Orders
Stop Loss Orders are orders that become marketable when a standard trading unit is traded at, or superior to, the stop loss price on the marketplace in which the order has been booked. These orders are handled by the desk OMS and EMS of FCC trading and will be routed through a smart order router if triggered.

On stop orders which are triggered to a market order are not permitted by FCC.  Client trading tools via Dataphile mandate a secondary limit is placed on each on-stop order.  If prompted by a client the FCC Trade Desk will insist the secondary limit is within 10% of the trigger price.  Monitoring of on stop orders is done by FCC Compliance who may deal directly with FCC IB clients or through the FCC Trading Desk in the event of an order in outside these guidelines.

Foreign Organized Regulated Marketplaces
In the pursuit of Best Execution, FCC Trading may make a determination that all or part of a client order must be transacted on a foreign organized regulated marketplace. FCC Trading would consider the available liquidity domestically and in the foreign market, any pricing or FX considerations in the foreign market as well as any clearing or settlement issues before deciding to transact in the foreign organized regulated market.

  1. Extenuating Circumstances

    In the event of technical or other issues that limit All Group (FCC)’s access to specific marketplaces, or limit access to routing automation, orders received will be directed to an available marketplace as circumstances warrant and as determined at the sole discretion of All Group.

  2. Disclosure of Marketplace

    An order executed on more than one marketplace will be reported to the client with multiple trade confirmations. Clients that receive such confirmations may contact their Investment Advisor for further details of the order execution.

  3. Extenuating Circumstances

    In the event of technical or other issues that limit All Group (FCC)’s access to specific marketplaces, or limit access to routing automation, orders received will be directed to either the default or alternative marketplace as circumstances warrant and as determined at the sole discretion of All Group.

  4. Amendments

    Changes to this policy may be made from time-to-time at the sole discretion of All Group. Changes will be posted to All Group’s website www.allgroup.ca