Notice of Settlement Hearing

PARTICULARS

1. The Settlement Agreement concerns allegations that:
   1. Between about November 5, 2004 and January 31, 2013, the Respondent recommended to at least 264 clients that the clients concentrate all or a substantial portion of their investment holdings in precious metals sector funds, without using adequate due diligence to assess the suitability of her investment recommendations on a client-by-client basis having regard to the essential Know-Your-Client (“KYC”) factors relevant to each individual client, including the client’s risk tolerance, investment objectives and investment knowledge, contrary to MFDA Rules 2.2.1 and 2.1.1;
   2. Between about November 5, 2004 and January 31, 2013, the Respondent recorded on account forms in respect of least 264 clients that the clients had, among other things, “100% high” risk tolerance, “100% aggressive growth” investment objectives, and “good” or better investment knowledge, in order to ensure that her investment recommendations to concentrate all or a substantial portion of the clients’ investment holdings in precious metals sector funds would be suitable for each client, contrary to MFDA Rules 2.2.1 and 2.1.1.
   3. Between about November 5, 2004 and January 31, 2013, the Respondent failed to fully and adequately explain, or omitted to explain the risks and benefits of investing in precious metals sector funds, thereby failing to ensure that her recommendations were suitable for the clients and in keeping with their investment objectives, contrary to MFDA Rules 2.2.1 and 2.1.1.
   4. Between December 7, 2014 and November 2, 2015, the Respondent obtained, possessed and in some cases, used to process transactions, 16 pre-signed client account forms in respect of 9 clients, contrary to MFDA Rule 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. If the Hearing Panel accepts the settlement agreement, then the proceeding will become open to the public and a copy of the decision of the Hearing Panel and the settlement agreement will be made available at www.mfda.ca.