Ontario OSC Fines Caldwell $2 Million for Best Execution Lapses
- Toronto-based firm executed most of its trades through an affiliated investment dealer, Caldwell Securities.

Ontario Securities Commission (OSC) today said it had fined Toronto-based Caldwell Investment Management Ltd. (CIM) CAD 1.8 million ($1.35 million) for not getting the best Execution Execution Execution is the process during which a client submits an order to the brokerage, which consequently executes it resulting in an open position in a given asset. The execution of the order occurs only when it is filled. There is typically a time delay between the placement of the order and the execution which is called latency.In the retail FX space, reliable brokers always strive to deliver best execution to their clients in order to maintain a solid business relationship with them. This is a co Execution is the process during which a client submits an order to the brokerage, which consequently executes it resulting in an open position in a given asset. The execution of the order occurs only when it is filled. There is typically a time delay between the placement of the order and the execution which is called latency.In the retail FX space, reliable brokers always strive to deliver best execution to their clients in order to maintain a solid business relationship with them. This is a co Read this Term price for its customer transactions and failing to properly supervise the process.
The provincial regulator also ordered the asset manager to pay a further CAD 250,000 to cover the cost of the OSC’s investigation involving its equity and bond trades. CIM, in a Settlement Settlement Settlement in finance refers to the process when a buyer makes payment and receives the agreed-upon services or goods. The term is used on exchanges such as New York Stock Exchange (NYSE) when security changes hands. When the asset is transferred and placed in the new buyer's name, it is considered settled. This process could take a few hours or several days after a trade is made. It depends on the clearance process. In the United States, the settlement date for marketable stocks is usually 2 Settlement in finance refers to the process when a buyer makes payment and receives the agreed-upon services or goods. The term is used on exchanges such as New York Stock Exchange (NYSE) when security changes hands. When the asset is transferred and placed in the new buyer's name, it is considered settled. This process could take a few hours or several days after a trade is made. It depends on the clearance process. In the United States, the settlement date for marketable stocks is usually 2 Read this Term with the OSC, admitted the regulator’s findings.
According to a regulatory settlement, the disciplinary case stems from executing most of Caldwell clients' transactions through an affiliated company rather than making efforts to find the best alternative.
OSC staff further explained that the company used an in-house system for directing most of its client trades through its own related investment dealer Caldwell Securities Ltd. (CSL) when in many cases unaffiliated venues offered better commissions and spreads.
A clear conflict of interest
This pattern contrasts with the industry rules that require portfolio and investment fund managers to ensure that the transactions prices for customers’ trades are as favorable as possible amid the current market conditions.
The company not only overcharged its clients but also provided misleading statements to the regulators while looking into the conflicts of interest allegations. Further, CIM provided conflicting information to the firm’s independent review committee (IRC) that was established to oversee its activities. The problems occurred between January 2013 and November 2016.
The enforcement order also states CIM didn't live up to best execution requirements because it hadn’t a process in place to evaluate trades or collect information to determine if it was fulfilling its obligation.
“CIM’s failure to develop, document, and enforce clear policies and procedures for best execution led to self-interest dictating how client orders were handled. These are serious lapses in oversight that will not be tolerated,” said Jeff Kehoe, Director of the Enforcement Branch at the OSC.
Ontario Securities Commission (OSC) today said it had fined Toronto-based Caldwell Investment Management Ltd. (CIM) CAD 1.8 million ($1.35 million) for not getting the best Execution Execution Execution is the process during which a client submits an order to the brokerage, which consequently executes it resulting in an open position in a given asset. The execution of the order occurs only when it is filled. There is typically a time delay between the placement of the order and the execution which is called latency.In the retail FX space, reliable brokers always strive to deliver best execution to their clients in order to maintain a solid business relationship with them. This is a co Execution is the process during which a client submits an order to the brokerage, which consequently executes it resulting in an open position in a given asset. The execution of the order occurs only when it is filled. There is typically a time delay between the placement of the order and the execution which is called latency.In the retail FX space, reliable brokers always strive to deliver best execution to their clients in order to maintain a solid business relationship with them. This is a co Read this Term price for its customer transactions and failing to properly supervise the process.
The provincial regulator also ordered the asset manager to pay a further CAD 250,000 to cover the cost of the OSC’s investigation involving its equity and bond trades. CIM, in a Settlement Settlement Settlement in finance refers to the process when a buyer makes payment and receives the agreed-upon services or goods. The term is used on exchanges such as New York Stock Exchange (NYSE) when security changes hands. When the asset is transferred and placed in the new buyer's name, it is considered settled. This process could take a few hours or several days after a trade is made. It depends on the clearance process. In the United States, the settlement date for marketable stocks is usually 2 Settlement in finance refers to the process when a buyer makes payment and receives the agreed-upon services or goods. The term is used on exchanges such as New York Stock Exchange (NYSE) when security changes hands. When the asset is transferred and placed in the new buyer's name, it is considered settled. This process could take a few hours or several days after a trade is made. It depends on the clearance process. In the United States, the settlement date for marketable stocks is usually 2 Read this Term with the OSC, admitted the regulator’s findings.
According to a regulatory settlement, the disciplinary case stems from executing most of Caldwell clients' transactions through an affiliated company rather than making efforts to find the best alternative.
OSC staff further explained that the company used an in-house system for directing most of its client trades through its own related investment dealer Caldwell Securities Ltd. (CSL) when in many cases unaffiliated venues offered better commissions and spreads.
A clear conflict of interest
This pattern contrasts with the industry rules that require portfolio and investment fund managers to ensure that the transactions prices for customers’ trades are as favorable as possible amid the current market conditions.
The company not only overcharged its clients but also provided misleading statements to the regulators while looking into the conflicts of interest allegations. Further, CIM provided conflicting information to the firm’s independent review committee (IRC) that was established to oversee its activities. The problems occurred between January 2013 and November 2016.
The enforcement order also states CIM didn't live up to best execution requirements because it hadn’t a process in place to evaluate trades or collect information to determine if it was fulfilling its obligation.
“CIM’s failure to develop, document, and enforce clear policies and procedures for best execution led to self-interest dictating how client orders were handled. These are serious lapses in oversight that will not be tolerated,” said Jeff Kehoe, Director of the Enforcement Branch at the OSC.