Compliance Memo

Compliance Memorandum 2013-08; Change of fund risk rankings: Bridgehouse Asset Managers (formerly Brandes Investment Partners)

For more information, contact:

Compliance Team

Date Issued:

June 14, 2013

We have been advised by Bridgehouse Asset Managers that they have recently made changes to the risk ranking of the Brandes Canadian Equity Fund, moving from a “Medium” to a “Medium - High” risk ranking.

As a best practice, the portfolios of any clients holding any of these funds should be reviewed for continued suitability of their portfolios. At a minimum, the KYC and portfolio review must take place prior to any new trades in the affected plans.

Where the existing holdings now exceed the client’s stated “Plan Risk Tolerance”, recommendations should be made to rebalance the portfolio to bring it into agreement with the Risk Tolerance, Investment Objectives and Time Horizon previously noted for the client’s plan.

We must caution advisors against updating risk tolerance of client plans to simply match new risk ranking of the existing holdings in an effort to keep the affected plans onside of KYC.

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