RBC Private Counsel USA Inc

and types of clients
This section provides a description of requirements to open an account and the types of
clients to whom we typically provide investment advice.
Our clients are typically individuals, their   generally U.S. $250,000. The minimum       investable per Investment Manager or
families and personal holding companies,       investment with an individual Investment   Sub- Advisor, as applicable, to satisfy the
and trusts.                                    Manager is typically U.S.                  underlying asset, geographic and style
                                                                                          allocations.
                                               $100,000. However, the minimum
5.1 A+ Program and Access Program
                                               threshold to achieve a diversified
                                                                                          5.2 PIM Program
Generally, the minimum account size to         portfolio that matches the client’s
open an A+ account is equivalent to CDN        investment objectives and risk profile     Generally, the minimum account size to
$100,000, but could be lower subject to        may be higher. The actual investment       open a PIM account is equivalent to CDN
total investments with PC USA. For the         amount will be dependent on the            $100,000, but could be lower subject to
Access Program, the initial investment is      portfolio models and the minimum           total investments with PC USA.

Item 6 – Investment manager and
sub-advisor selection and evaluation
This section provides a description of our process for selecting, evaluating and providing
performance reporting of Investment Managers in the Access Program and Sub-Advisors in the
A+ Program. It also provides certain information about our PIM Program and a description of
some of the risks of which you should be aware and of our proxy voting practices.

6.1 A+ Program and Access Program              professionals, investment approach and      • 	 $25 million of product assets under
                                               historical performance.                         management
6.1.1 Selection of investment managers
                                                                                           • 	 Three years of portfolio management
and sub- advisors and analysis by the          The Committee consists of at least four
                                                                                               tenure
investment committee                           investment professionals from one or
                                               more of our affiliates. To be approved,     • 	 Reasonable management fees and
RBC Global Advisory Research Group
                                               each Investment Manager and Sub-                expenses
recommends fixed income and equity
                                               Advisor must pass a thorough review by      Investment Managers and Sub-Advisors
Investment Managers and Sub-Advisors
                                               the Committee that includes a detailed      meeting the above criteria are then
for both the Access Program and the A+
                                               discussion of facts and informed            subjected to a more rigorous evaluation
Program based on research, as
                                               opinions derived from a comprehensive       focused on four broad categories:
described below.
                                               due diligence and evaluation process.
From these recommendations, the                Our analysts employ well-defined            • 	 Firm and Product
Investment Committee (the                      research, evaluation, and reporting         • 	 Investment Approach
“Committee”) has selected a range of           activities when assessing each category.
Investment Managers for the Access                                                         • 	 Investment Professionals
                                               The process typically begins with the
Program and a range of Sub-Advisors            following minimum screening criteria:       • 	 Performance
for the A+ Program to which client assets
can be allocated. In selecting the             • Three years of operating and             Objectively understanding the quality
Investment Managers and Sub-Advisors,             performance histories                    and effectiveness of an Investment
consideration is given to, among other                                                     Manager and Sub-Advisor or particular
                                               • 	 $100 million of firm assets under
things, firm and product, investment                                                       portfolio strategy requires in-depth
                                                   management

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examination of performance, including a      6.1.3 Performance of investment                Sub-Advisors in the A+ Program and
detailed analysis of the sources of          managers and sub-advisors                      affiliates of RBC PC USA.
returns. Not all Investment Managers
and Sub-Advisors should be compared          Performance information on the                 Recommending affiliate Sub-Advisors may
to one another, nor are all products         Investment Managers and Sub-Advisors is        be perceived as a conflict of interest. We
directly comparable. Information             calculated by the respective Investment        manage this by ensuring that Investment
learned in performance reviews is used       Managers and Sub-Advisors. We calculate        Counsellors and Investment Advisors are
...