Notice of Settlement Hearing

The subject matter of the proposed Settlement Agreement concerns matters for which the Respondent may be disciplined as an Approved Person of the MFDA, pursuant to ss. 20 and 24.1.1 of By-law No. 1 of the MFDA.

PARTICULARS

1. The proposed Settlement Agreement concerns allegations that the Respondent:
   1. between October 2008 and May 2014, failed to use due diligence to learn and accurately record the essential Know-Your-Client factors relative to five (5) clients prior to making investment recommendations and accepting investment orders from the clients, contrary to MFDA Rule 2.2.1 and 2.1.1;
   2. between October 2008 and May 2014, failed to use due diligence to ensure that each order accepted and recommendations made to five (5) clients were suitable for the clients and in keeping with their investment objectives having regard to the concentration of precious metal sector funds in the client accounts and the clients’ Know-Your-Client information, including the client’s investment knowledge and objectives, risk tolerance, age, and time horizon, contrary to MFDA Rules 2.2.1 and 2.1.1; and
   3. between October 2008 and May 2014, failed to present a balanced explanation of the risks and benefits of investing in precious metals sector funds, thereby failing to ensure that his recommendations were suitable for clients and in keeping with their investment objectives, contrary to MFDA Rule 2.2.1 and 2.1.1.

2. MFDA settlement hearings are typically held in the absence of the public pursuant to section 20.5 of MFDA By-law No. 1 and Rule 15.2(2) of the MFDA Rules of Procedure.