Foreign Exchange Services

In global FX markets, CNB FX engages in price quoting, order taking, trade execution, and other related activities. CNB FX does not act as broker, agent, fiduciary, fnancial advisor or in any similar capacity on behalf of its clients, unless otherwise expressly agreed in writing.

• CNB FX may trade prior to, alongside, or following the execution of client transactions and receipt of client requests for quotes or indicative prices. The reasons for such trading may include the execution of other client transactions, hedging or sourcing liquidity for market making purposes, management of CNB FX’s risk, or as part of a previously commenced trading strategy.
• CNB FX and its clients may have divergent or conflicting interests in these activities. CNB FX takes reasonable steps to identify and manage conflicts of interests in accordance with applicable laws, rules, and regulations.
• CNB FX’s activities may affect a trigger, or the delay or prevention of a trigger, of stop loss orders, barriers, knock-outs, knock-ins, and other similar instruments which are dependent on market movements. CNB FX employs reasonably designed means to avoid undue market impact and to manage resulting conflicts of interest.
• CNB FX may utilize a number of internal and external sources of liquidity in order to provide bids and offers, and to execute transactions with clients.
• Any statement provided by CNB FX should not be construed as a recommendation or investment advice regarding the value or advisability of any trading activity, and is not based on or tailored to a client’s particular circumstances or characteristics. A client is expected to evaluate the appropriateness of any transaction based on the client’s own assessment of the transaction’s merits and all facts and circumstances in connection therewith, in consultation with its own independent advisers as appropriate.
• During periods of volatile markets, CNB FX endeavors to continue to serve its clients but may not be able to provide the product offering, level of execution, liquidity, or pricing as would be the case under more normal market conditions, and as such, CNB FX is not responsible or liable for the impact that such constraints may present.
• Large orders from clients may require management by CNB FX in order to maintain reasonable market integrity. There are certain transactions that may be required in the ordinary course of business, such as transactions related to merger and acquisition activity, which could have a sizable impact on the market. These transactions will be appropriately managed and executed by CNB FX.
• There is no single FX market and different venues may show a different spot price at a given moment. Trades may be executed directly between two FX traders in the market, by voice brokers or on electronic trading platforms. Each venue has its own liquidity and depth and there are times where there are differences in the prices available on different venues due to imperfect market information or different liquidity. CNB FX traders use their skill and discretion in deciding which venue to use for their trades in the public market. Similarly, the FX trader may refer to price and volume information from a number of venues in order to determine whether to fill a counterparty order.

When CNB FX accepts a client’s order at a price (such as a limit order), CNB FX is agreeing to attempt to complete the trade as principal for the price requested by the client. Where the trade is a limit order, CNB FX will use its professional judgment to determine whether a limit has been reached, including where a third-party pricing source is a determinant in establishing this reference price. CNB FX’s acceptance of a client’s order does not mean that CNB FX will be able to complete the transaction at the order price level requested or that a tradeable market exists to execute at that level. CNB FX’s ability or willingness to fill such an order may be impacted by a number of factors, including, without limitation, its client exposure, market exposure, and overall market strategy. CNB FX retains discretion regarding the manner in which it may satisfy such orders, which shall be exercised and appropriately timestamped in accordance with applicable local laws, rules, and regulations.

• CNB FX and clients must be clear about the time frame for the order to be active. An order is active until it expires (per a set expiration date) or is cancelled. If the client wishes to cancel an active order, the client must contact CNB FX sales advisor during normal business hours, who will confirm the cancellation of the order.
• CNB FX will attempt to execute the full size of a client order given prevailing market conditions and client instructions. CNB FX will assume that partial fills are acceptable to clients unless mutually agreed otherwise.
• There may be circumstances where CNB FX is unable to accept a client order or client transaction request. Further, CNB FX’s undertaking to work a client order does not create a contract between the client and CNB FX that commits CNB FX to execute any or all of the order or to execute the client transaction request on the terms provided. Market risk shall only transfer to CNB FX following CNB FX’s determination that an order has been filled or a request for quote has been accepted, at which point it will create an agreement between CNB FX and the client on the terms and conditions specified between the parties. Prior to this determination, either party may cancel the order or request for quote subject to any existing arrangements agreed between CNB FX and the client from time to time (provided that any full or partial fill which has already been achieved by CNB FX prior to such cancellation will be effective against the client).
• For algorithmic trading services, where required, CNB FX determines internal routing preferences based on factors including applicable best execution obligations and ongoing liquidity analysis.

• Unless otherwise agreed, CNB FX provides what is commonly referred to as “all-in” pricing for FX transactions. Accordingly, unless we agree otherwise, the price of any FX transaction that CNB FX executes for clients may include what we believe to be a reasonable bid-ask spread and/or a mark-up. Such “all-in” pricing also applies to orders that CNB FX agrees to execute using its discretion (e.g., “at best” orders or orders executed over a specific period of time). For a live transaction, this means that interbank rates, often observed and reported by various news outlets, are indications of the basis from which CNB FX will apply a profit spread. For limit orders, this means that a client’s requested transaction would be subject to execution when the interbank market reaches a level where CNB FX’s profit spread can be realized.
• CNB FX’s pricing is based on a number of factors, including, without limitation, the type of instrument and transaction involved, prevailing market conditions, the accessibility of quotations and other pricing information, the transparency of the market, CNB FX’s rate of return, hedging and market risk, credit risk, operational costs, applicable regulatory requirements, and other internal and external factors. Interbank FX rates are indicative for the market, meaning that such rates may have been transacted by certain players of the market but are not always available to all market participants, including CNB FX.
• Pricing may vary for different clients for the same or substantially similar transactions for a number of reasons, including, without limitation, the client’s trading volumes, the service provided to the client by the sales team and other support services, credit quality, and the client’s overall relationship with City National Bank. Execution metrics may be provided at the discretion of CNB FX or where otherwise required by Applicable Law.

• “Last Look” generally describes the FX trade acceptance process in which CNB FX checks message validity, operational validity and credit limits, and compares the rate at which clients are attempting to trade versus the latest price update available to CNB FX. Trade requests are then accepted or rejected based on a set of tolerances. All electronic FX trades are subject to a Last Look check. Implementing Last Look functionality can allow CNB FX as a market maker to maintain tighter bid-offer spreads for its clients. Consistent with the FX Global Code, CNB FX does not, during the Last Look window, (i) apply a Last Look hold period, (ii) engage in pre-hedging activity in relation to the relevant transaction request, or (iii) utilize trade information for trading purposes.
• Unless otherwise agreed, CNB FX will apply “symmetrical last look” to electronic FX trading. “Symmetrical last look” refers to circumstances where client trade requests are rejected if the requested rate is outside of the deal acceptance parameter threshold, regardless of whether the rate is positive or negative to CNB FX.

• Protecting client information is of fundamental importance to CNB FX. CNB FX has arrangements in place designed to protect and safeguard client  information in accordance with applicable local laws, rules, and regulations.
• CNB FX makes use of certain client information contained in orders, transaction requests, and executed transactions. Subject to the terms in place between CNB and a client, and where permitted by Applicable Law, CNB FX may use the economic terms of orders, transaction requests, and executed transactions to manage its risk and to test or source liquidity, as well as to evaluate and implement its risk mitigation strategies and transactions.
• CNB FX may share client information outside the CNB group in accordance with Applicable Law or as otherwise set out in our applicable terms and conditions. CNB FX may also disseminate aggregated and anonymized information regarding transactions and other client processes purposes, including financial reporting, data contribution, and production of market color.
• CNB FX may share client information within the CNB group for internal purposes, including for client relationship management, risk management, and business management purposes.

• CNB FX is committed to adhering to the highest expected standards of behavior, acting with integrity, and complying with applicable laws and published industry best practices. We are focused on ensuring that CNB FX continues to act in a trustworthy and responsible manner as our clients have come to expect.
• As a wholly-owned subsidiary of the Royal Bank of Canada (RBC), CNB’s FX employees, officers and directors receive regular training on Royal Bank of Canada’s Code of Conduct (the “Code”). The code sets out the ethical principles by which all RBC and CNB employees are required to abide by, including how we conduct our business. The full text of the Code of Conduct is available at: https://www.rbccm.com/assets/rbccm/docs/legal/fixed-income/ficc-client-notice.pdf 

If you have any questions regarding this notice, we encourage you to contact your Relationship Manager. CNB FX believes that the cornerstone of a long-term relationship is an open, two-way dialogue, and we look forward to continuing this with you.