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Re: Sentinel Financial Management Corp.

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. between July 2012 and July 2016, failed to adequately conduct proper Tier 1 trade supervision to:
      1. ensure that each order accepted and each recommendation made for client accounts, including client accounts holding exempt market products, were suitable for the clients and in keeping with those clients’ investment objectives and “Know Your Client” information; and
      2. perform supervisory inquiries, either adequately or at all, and failed to maintain adequate records of trade supervision conducted including inquiries made, responses received, and resolutions achieved following supervisory inquiries, including with respect to exempt market products;

      contrary to MFDA Rule 2.2.1(c), and MFDA Policy No. 2;

    2. commencing in April 2013, failed to adequately supervise the activity of an Approved Person, JW, who was under close supervision, including activity with respect to deficiencies in trade suitability and the collection of “Know Your Client” information, contrary to MFDA Rules 2.5.1, 2.2.1(a), 2.2.1(c), and 2.2.2;
    3. commencing in June 2015, failed to adequately supervise the activity of an Approved Person, TM, who was under close supervision, including activity with respect to deficiencies in trade suitability and the collection of “Know Your Client” information, contrary to MFDA Rules 2.5.1, 2.2.1(a), 2.2.1(c), and 2.2.2; and
    4. commencing in July 2012, failed to complete reviews of sub-branches and their Approved Persons, either adequately or at all, contrary to MFDA Policy No. 2 and MFDA Policy No. 5.
  1. 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.
  • Paige Ward
    Paige Ward
    Corporate Secretary

    Mutual Fund Dealers Association of Canada
    121 King St. West, Suite 1000
    Toronto, ON M5H 3T9
    Telephone: 416-943-5838
    Fax: 416-361-9781
    E-mail: corporatesecretary@mfda.ca

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