Legal & Regulatory Disclosures
First Avenue Investment Counsel Inc.
1. About These Disclosures
This page sets out the legal and regulatory disclosures that apply to the information on this website. It is provided for information only. It does not replace the Managed Account Relationship Disclosure Document, offering documents, or account agreements we provide to clients, which govern in all cases.
Effective: September 1, 2026. We may amend these disclosures from time to time.
2. Registration and Jurisdictions
First Avenue Investment Counsel Inc. is registered as an Investment Fund Manager (“IFM”), Portfolio Manager (“PM”), and Exempt Market Dealer (“EMD”) in the provinces of Ontario and Quebec, and as a PM and EMD in the provinces of British Columbia and Alberta. Our principal regulator is the Ontario Securities Commission.
We provide services only to residents of jurisdictions in which we are registered or are exempt from registration. Nothing on this website is directed at any person in a jurisdiction where it would be unlawful to publish or access it.
Registration does not mean that any securities regulator has approved, endorsed, or passed upon the merits of our services, our funds, or the content of this website.
Some members of our team are registered with securities regulators. Others support the firm in operations, finance, planning and administration and do not provide investment advice. Titles and designations used by our people are reviewed and approved by our Chief Compliance Officer. You can confirm the registration status and registration categories of any firm or individual through the National Registration Database at https://www.aretheyregistered.ca.
3. No Offer and No Advice
Nothing on this website is an offer to sell, a solicitation of an offer to buy, or a recommendation in respect of any security, product or service, whether or not it is described here.
Nothing on this website is investment, tax, legal or accounting advice, or a recommendation to buy, sell or hold any security. Information here is general in nature and does not take account of any person’s investment objectives, financial circumstances, risk tolerance or needs. You should obtain professional advice on your own situation before acting.
We provide investment advice only to clients, under a written agreement, after collecting know-your-client information and making a suitability determination. Submitting a form on this website does not create a client relationship.
4. Investment Risk
All investments involve risk, including the possible loss of principal. Past performance is not indicative of future results. No return is guaranteed and no objective described on this website is assured. Private and alternative investments carry additional risks.
Risks specific to each of our proprietary exempt market products are described in our Managed Account Relationship Disclosure Document and the relevant Schedule A, which are provided to clients in advance of investment and should be read carefully. Risks specific to any other investment are described in that investment’s offering documents.
5. Proprietary Products and Conflicts of Interest
Some of the investments we make for clients are proprietary products — the First Avenue funds, and the related and connected issuers through which we invest in real estate and other private investments. EMBLEM Developments Inc. is an affiliate of First Avenue Investment Counsel Inc. In addition, one or more principals of First Avenue hold interests in, or positions with, EMBLEM Developments Inc. Real estate investments described on this website are securities of a related issuer.
Because we manage or are related to these issuers, and because we and related parties receive fees in connection with them, investing client portfolios in them is a conflict of interest. We address it by disclosing our relationship to each issuer a client is invested in, together with any services provided by and compensation paid to related parties; by obtaining the client’s consent to the investment; and by investing only where our know-your-client and know-your-product process supports it and it is in the client’s interest. This is set out in our Managed Account Relationship Disclosure Document and the relevant product Schedule A delivered with it.
6. Eligibility — Exempt Market Investments
The funds and strategies described on this website are distributed under prospectus exemptions in National Instrument 45-106 Prospectus Exemptions. They are available only to investors who qualify and are not available to the public. Descriptions on this website are general summaries and are not offering documents. Eligibility is confirmed before any investment is made.
7. Illustrative Allocations and Portfolio Objectives
Asset allocations shown on this website are illustrative only. They are not a recommended allocation for any person. Actual allocations are determined by each client’s Investment Policy Statement and will differ.
Statements about what a diversified portfolio seeks to achieve — including lower volatility, or greater growth and income potential, relative to a portfolio of public equities and fixed income alone — describe objectives, not predictions. Diversification does not eliminate the risk of loss, and there is no assurance that these objectives will be achieved.
8. Institutional and Pension Comparisons
We describe our approach as “pension-style” to convey the investment frameworks we apply. Institutional pension plans differ materially from private clients in scale, time horizon, liability structure, liquidity needs, access and cost structure.
Data concerning pension plan asset allocation is included for context only, is drawn from the sources cited where it appears, and is not a recommendation for, or indicative of, any client portfolio or any outcome a client should expect.
9. Family Office Services, Consolidated Reporting, and Safekeeping
Consolidated financial summaries and related family office reporting are prepared for information only. They may include assets that we neither manage nor hold. Values for those assets are provided by clients or third parties and are not independently verified by us.
These summaries are not account statements. They do not replace the account statements, position cost reports or investment performance reports that we are required to deliver to clients as a registrant.
Where we refer to document safekeeping, we mean the retention and organization of records and documents. First Avenue is not a custodian of client cash or securities; client assets are held at a qualified custodian.
Tax, estate, succession and family governance services are provided in coordination with your own accountants, lawyers and other advisors. We do not provide legal advice or accounting services, and we do not act as your tax preparer, trustee or executor unless separately engaged in writing to do so.
10. Insights, Commentary, and Forward-Looking Statements
Content in our Insights library, and any market commentary we publish, is general information only and is current as at the date shown on it. It is not investment, tax, legal or accounting advice, does not take account of any individual’s circumstances, and should not be relied on as a recommendation.
Forward-looking information on this website — information that expresses predictions, expectations, beliefs, plans, projections, objectives, assumptions, or future events or performance — is made as of the publication date shown, unless otherwise stated. Forward-looking information involves a number of risks and uncertainties which could cause actual results or events to differ materially from those currently anticipated. We do not undertake any obligation to update or revise any forward-looking information, whether as a result of new information, future events or otherwise.
Content on this website includes information produced by our investment professionals. Any statements or conclusions are derived from data produced by Bloomberg, FactSet, and/or publicly available sources unless otherwise stated. Past performance is no guarantee of future results.
11. Third-Party Content and Media
Media appearances and third-party content referenced or linked from this website are the content of the publisher, not of First Avenue. Their inclusion is not an endorsement by us of the publisher or of any product, service or view expressed, and does not indicate any endorsement of First Avenue by the publisher.
Third-party commentary about First Avenue is not a client testimonial and does not reflect the experience of any client. We are not responsible for the content of third-party websites.
12. Identification and Trade Names
This website is published by First Avenue Investment Counsel Inc. We carry on business as “First Avenue Investment Counsel Inc.”, “First Avenue Investment Counsel” and “First Avenue”.
The content of this website may not be reproduced or redistributed without our written consent.
13. Complaints
If you have a concern or complaint about our services, please contact our Chief Compliance Officer at compliance@firstavenuecounsel.com. We will acknowledge a written complaint in writing within five business days and respond following our review.
Clients may also bring a complaint to the Ombudsman for Banking Services and Investments (OBSI), at no cost to the client, and Quebec residents may bring a complaint to the Autorité des marchés financiers. Time limits apply. Details of our complaint handling process, including how and when you may contact OBSI, are set out in our complaint handling summary, which is provided at client onboarding and is available on request.