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 August 1, 2016 and December 31, 2016, arranged for 344 clients to execute new account application forms and Know-Your-Client forms to transfer the clients to a new Member, when he was not registered with the new Member, thereby engaging in registrable activity and securities related business outside the scope of his registration, contrary to MFDA Rules 1.1.1 and 2.1.1;
   2. between August 1, 2016 and December 31, 2016, had 344 clients execute 829 undated new account application forms, Know-Your-Client forms, and transfer authorizations, which were later signed by another Approved Person registered with the new Member to effect the transfers, contrary to MFDA Rule 2.1.1;
   3. between 2012 and 2016, obtained, maintained, and/or used at least:
      1. 1. 46 pre-signed account forms;
         2. 16 accounts forms which were altered after the client had signed the forms; and
         3. 1 account form on which the client’s signature had been copied and pasted from another form,

      contrary to the Member’s policies and procedures and MFDA Rules 2.1.1 and 2.5.1 and 1.1.2;

   4. from 2012 to 2016:
      1. falsely certified each year on the Member’s annual registration renewals that he did not have in his possession or control any pre-signed forms; and
      2. failed to disclose to his Member on the 2016 Annual Audit Questionnaire his arrangement to share office space with another Approved Person,

      contrary to MFDA Rules 2.1.1 and 2.5.1 and 1.1.2; and

   5. in or around November 2016, engaged in 129 instances of discretionary trading, contrary to his Member’s policies and procedures and MFDA Rules 2.3.1(b), 2.1.1, 2.5.1, and 1.1.2.

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.