Notice of Settlement Hearing

The subject matter of the proposed Settlement Agreement concerns matters for which the Respondent may be disciplined as a Member of the MFDA, pursuant to ss. 20 and 24.1.2 of By-law No. 1 of the MFDA.

PARTICULARS

1. The proposed Settlement Agreement concerns allegations that: the Respondent
   1. during the period March 1, 2013 to September 30, 2014, it failed to adequately supervise, or failed to maintain adequate records of the supervision at its Head Office, sub-branch level, and branch level, of:
      1. daily trading activity;
      2. approval of new accounts;
      3. approval of amendments to know-your-client information; and
      4. leveraged accounts;

      contrary to MFDA Rules 2.2.1, 2.2.2, 2.2.3, 2.5.1, 2.9, and 5.1, and MFDA Policy No. 2;

   2. during the period March 1, 2012 to September 30, 2014, it failed to establish, implement and maintain adequate policies and procedures to conduct trend analysis reports to supervise its Approved Persons’ trading activity, contrary to MFDA Rules 2.2.1, 2.5.1, 2.9, and 2.10, and MFDA Policy No. 2;
   3. during the period March 1, 2012 to September 30, 2014, it failed to maintain adequate compliance resources, contrary to MFDA Rules 2.5.1 and MFDA Policy No. 2;
   4. during the period October 1, 2014 to July 31, 2016, it failed to adequately supervise, or failed to maintain adequate records of the supervision of:
      1. uniformity of certain client KYC information; and
      2. concentration of sector mutual funds in client accounts;

      contrary to MFDA Rules 2.2.1, 2.5.1, 2.9, and 5.1, and MFDA Policy No. 2;

   5. commencing on or about August 19, 2014, it failed to conduct a reasonable supervisory investigation in response to information it received that its Approved Person, Gilles Latour, was charged with offences pursuant to the Criminal Code of Canada for alleged conduct involving clients and other individuals, contrary to MFDA Rules 2.5.1 and MFDA Policy No. 3; and
   6. commencing May 2014, it failed to conduct a reasonable supervisory investigation regarding investment suitability concerns and portfolio concentration issues in the client accounts serviced by its Approved Person Lawrence Fike, contrary to MFDA Rule 2.5.1 and MFDA Policy No. 3.

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.