Common use of AGREED FACTS Registration History Clause in Contracts

AGREED FACTS Registration History. ‌ 7. Since April 2008, the Respondent has been registered in Ontario as a dealing representative with Sun Life Investment Services (Canada) Inc. (the “Member”), a Member of the MFDA. 8. At all material times, the Respondent conducted business in the London, Ontario area. 9. Beginning in May 2017, the Member’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initials. 10. Between January 2015 and February 2019, the Respondent altered and, in some instances, used to process transactions, 24 account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterations. 11. The altered account forms included: 15 Know-Your Client (“KYC”) Forms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At all material times, the Member’s policies and procedures prohibited the use of pre- signed forms. 14. Between November 2014 and February 2017, the Respondent obtained, possessed and, in some instances, used to process transactions, 3 pre-signed account forms in respect of 4 clients. 15. The pre-signed account forms included: 1 Transfer Authorization, 1 PAC Form and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form. 16. In April 2019, the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account forms. 17. In May 2019, the Member conducted a full review of the client files maintained by the Respondent and discovered the remaining account forms that are the subject of this Settlement Agreement. 18. Between May 2019 and May 2020, the Member placed the Respondent under close supervision. 19. In June 2019, the Member sent a letter to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any commissions and fees that he would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 24. There is no evidence of client loss, complaints, or lack of authorization. 25. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 26. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources and expenses associated with conducting a full hearing of the allegations.

AGREED FACTS Registration History. ‌ 76. Since April 20081999, the Respondent has been registered in Ontario as a dealing representative mutual fund salesperson (now known as Dealing Representative) with Sun Life Financial Investment Services (Canada) Inc. 1 (the “MemberSun Life”), a Member member of the MFDA., or its predecessor, Xxxxxxx Xxxxxxxx Inc. 87. At all material times, the Respondent conducted business in the LondonOttawa, Ontario area. 1 In 2002, Sun Life and Xxxxxxx Xxxxxxxx Inc. merged. 9. Beginning in May 2017, the Member’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initials. 108. Between January 2015 April 2010 and February 2019April 2013, the Respondent altered andobtained, maintained, and in some instances, used to process transactionstrades, 24 account a total of 65 pre-signed order entry forms in respect of 22 clients by altering information on 15 clients. 9. The Respondent used 32 of the account pre-signed order entry forms without having to process trades. 10. In June 2013, MFDA Compliance Staff initially detected the client initial Respondent’s use of pre- signed order entry forms during a routine compliance examination of Sun Life and informed Sun Life of its findings. Sun Life immediately commenced an investigation, which revealed the alterationsfull extent of the Respondent’s misconduct as set out above. 11. The altered account forms included: 15 Know-Your Client (“KYC”) FormsAs part of its investigation, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment Sun Life sent letters to all of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorizationthe clients serviced by the Respondent to determine whether the Respondent had engaged in any unauthorized trading activity in these clients’ accounts. None of the clients reported any concerns to Sun Life. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At states that all material times, the Member’s policies and procedures prohibited the use of pre- signed forms. 14. Between November 2014 and February 2017, the Respondent obtained, possessed and, in some instances, used to process transactions, 3 pre-signed account forms in respect of 4 clients. 15. The pre-signed account forms included: 1 Transfer Authorization, 1 PAC Form and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form. 16. In April 2019, the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account forms. 17. In May 2019, the Member conducted a full review of the client files maintained by the Respondent and discovered the remaining account order entry forms that are the subject of this Settlement AgreementAgreement were completed in accordance with client instructions. The Respondent produced email communications from some of the affected clients confirming that the clients had authorized the transactions. 1813. Between May 2019 and May 2020In addition, the Member Respondent and Sun Life’s Financial Centre Manager met with the majority of clients for whom pre-signed order entry forms were identified to review the transactions in the client accounts. No issues were identified as a result of these meetings. 14. On October 22, 2013, Sun Life placed the Respondent under on close supervisionsupervision for a period of 90 days. 1915. In June 2019, The Respondent states that she acquired Limited Trade Authorizations (“LTAs”) for all of the Member sent a letter to all clients whose accounts were affected by the Respondent’s conduct and indicated her use of pre-signed order entry forms. The Respondent states that the Member she believed, incorrectly, that she was permitted to use pre-signed order entry forms where she had identified instances where forms were used in the client accounts which may not have been complete when they were signed by obtained an LTA from the client. The Member attached copies of client account statements for the 2 years prior Respondent did not contact Sun Life’s compliance staff to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the informationdetermine whether this belief was correct. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 2216. The Respondent has paid a total of $4,800 to states that she engaged in the Member conduct described in respect this Settlement Agreement for the convenience of the close supervision imposed by the Memberclients and to process trades in a timely manner. 2317. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any commissions the commission and fees that he she would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 2418. There is no evidence of client loss, complaints, or lack of authorizationThe Respondent cooperated with Xxx Life’s investigation into her conduct. 2519. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2620. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources resources, and expenses associated with conducting a full hearing of on the allegations. V. CONTRAVENTIONS

AGREED FACTS Registration History. ‌ 76. Since April 20081997, the Respondent has been registered as a mutual fund salesperson (now known as Dealing Representative) in Ontario as a dealing representative with Sun Life Financial Investment Services (Canada) Inc. Inc.1 (the “MemberSun Life”), a Member member of the MFDA. 87. At all material times, the Respondent conducted business in the LondonWaterloo, Ontario area. 9. Beginning 1 Before merging in May 20172002, the Member’s policies known as Sun Life Financial Services (Canada) Inc. and procedures prohibited Approved Persons from altering client account forms without obtaining client initials.Xxxxxxx Xxxxxxxx Inc. 108. Between January 2015 August 2006 and February 2019September 2013, the Respondent altered andobtained, possessed, and in some instances, used to process transactions, 24 a total of 49 blank pre-signed client account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterations27 clients. 119. The altered account forms included: 15 Of the 49 blank pre-signed forms, which included order entry forms, Pre-Authorized Contribution Agreement forms, and Know-Your Your-Client (“KYC”) Formsforms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization17 were used. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At all material times, the Member’s policies and procedures prohibited the use of pre- signed forms. 1410. Between November 2014 August 2006 and February 2017September 2013, the Respondent obtained, possessed andaltered, in some instances, and used to process transactions, 3 pre-signed account forms 6 order entry forms, in respect of 4 7 clients. 1511. The pre-signed account forms included: 1 Transfer Authorization, 1 PAC Form and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form. 16. In April 2019, Sun Life’s compliance staff detected the Member conducted conduct that is the subject of this Settlement Agreement as a result of an audit of a sample of the Respondent’s client files and identified 5 deficient account on October 31, 2013. 12. Sun Life conducted an interview with the Respondent on November 8, 2013. After the interview, on November 25, 2013, Sun Life conducted a further comprehensive audit of all the Respondent’s files, revealing further irregular forms. 1713. In May 2019As part of its investigation, the Member conducted a full review of the client files maintained Sun Life sent letters to all clients serviced by the Respondent and discovered to determine whether the remaining account forms Respondent had engaged in any unauthorized trading in their accounts. None of the clients reported any concerns to Sun Life. 14. As part of its investigation, Sun Life directed the Respondent’s Branch Manager to meet with all clients affected by the conduct that are is the subject of this Settlement AgreementAgreement whose forms were submitted for processing. 1815. Between May 2019 and May 2020Additionally, Sun Life telephoned 21 of the Member clients affected by the Respondent’s conduct. 16 of these clients reported satisfaction with the handling of their accounts, while the remaining 5 were either unreachable or unable to communicate in English. 16. The Respondent had obtained limited trade authorizations for all of the affected clients. 17. On June 16, 2014, Sun Life placed the Respondent under close supervisionsupervision for a 12 month period. No compliance concerns regarding the Respondent have arisen as a result. 19. In June 2019, the Member sent a letter to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 2318. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any the commissions and fees that he would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 2419. There The Respondent is no evidence of client loss, complaints, or lack of authorizationremorseful. 2520. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2621. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources and expenses associated with conducting a full hearing of the allegations. V. CONTRAVENTIONS

AGREED FACTS Registration History. ‌ 7. Since April 2008From February 2001 to March 2016, the Respondent has been registered in Ontario as a dealing representative mutual fund salesperson (now known as a Dealing Representative) with Sun Life Investment State Farm Investor Services (Canada) Inc. Co. (the “MemberState Farm”), a Member of the MFDA. 8. On March 30, 2016, the Respondent resigned from State Farm. 9. The Respondent is no longer registered in the securities industry in any capacity. 10. At all material times, the Respondent conducted business in the LondonToronto, Ontario area. 911. Between January 2006 and November 2014, the Respondent altered, and used to process transactions, 5 account forms in respect of 5 clients, by using liquid correction fluid or pen to alter information on the account forms to reflect client instructions without obtaining client initials authorizing the alternations. 12. The Respondent states that the alterations were made with the verbal approval of clients. 13. The altered account forms consisted of personal information change, RESP withdrawal, fund redemption and KYC forms. 14. Beginning in May 20172010, the MemberState Farm’s policies and procedures prohibited its Approved Persons from altering client using pre-signed account forms without obtaining client initialsforms. 1015. Between January 2015 March 2006 and February 2019November 2015, the Respondent altered andobtained, possessed, and in some at least 6 instances, used to process transactions, 24 account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterations. 11. The altered account forms included: 15 Know-Your Client (“KYC”) Forms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At all material times, the Member’s policies and procedures prohibited the use of pre- signed forms. 14. Between November 2014 and February 2017, the Respondent obtained, possessed and, in some instances, used to process transactions, 3 32 pre-signed account forms in respect of 4 16 clients. 1516. The Respondent states that he obtained the pre-signed forms for the convenience of the client, and that in some instances, when such forms were filled out based on verbal instructions from clients, the completed copy was mailed to clients. 17. The pre-signed account forms included: 1 Transfer Authorizationconsisted of personal information change, 1 PAC Form RESP withdrawal, fund purchase, fund switch, account transfer and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form. 16. In April 2019, the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account systematic withdrawal plan forms. 1718. In May 2019March 2016, State Farm’s compliance staff identified the Member conducted a full review of the client files maintained by the Respondent altered and discovered the remaining account pre-signed forms that are the subject of this Settlement Agreement. 18. Between May 2019 and May 2020, Agreement as a result of a routine audit of the Member placed Respondent’s files after the Respondent under close supervisionleft State Farm. 19. In June 2019As part of its investigation, State Farm conducted a review of all of the Member client files serviced by the Respondent and sent a letter letters to all clients whose accounts were affected by of the Respondent’s conduct and indicated that clients to determine whether the Member Respondent had identified instances where forms were used engaged in the client accounts which may not have been complete when they were signed by the clientany unauthorized trading. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the No clients review the KYC information and account statements and contact the Member if the clients identified reported any discrepancies in the informationconcerns. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any other than the commissions and or fees that he would ordinarily be entitled to receive had the transactions been carried out completed in the proper manner. 2421. There is no evidence of client loss, complaints, loss or lack of authorization. 2522. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2623. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources resources, and expenses associated with conducting a full hearing of on the allegations.

AGREED FACTS Registration History. ‌ 7. Since April November 2008, the Respondent has been licensed in the securities industry. 8. Since February 17, 2011, the Respondent has been registered in Ontario as a dealing representative with Sun Life Investment Services (Canada) Xxxxxxxxxx Financial Security Investments Inc. (the “Member”), a Member of the MFDA. 89. At all material times, the Respondent conducted business in the LondonKitchener, Ontario area. 910. Beginning in May 2017June 2016, the Member’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initialsof the Member required clients to initial any changes on documents or otherwise provide written authorization for the changes to the document. 1011. Between January 2015 October 2014 and February 2019July 2018, the Respondent altered and, in some instances, and used to process transactions, 24 20 account forms in respect of 22 17 clients by altering information on the account forms without having the client initial the alterations. 1112. The altered account forms included: 15 9 Know-Your Your-Client (“KYC”) Update Forms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings 4 New Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment 4 Letters of Beneficiary Xxxxxxxxx, 0 Transfer Form, 1 Order Ticket, Non Financial Change Form and 1 Transfer Authorization and 1 Limited Trade Authorizationfor Registered Investments. 1213. The alterations made by the Respondent consist of changes to: client investment knowledgerisk tolerances, client employer information, investment objectives, joint applicant information, client risk toleranceaddresses, signature dates, investment time horizon, client income, client net worth, account numbers, PAC instructions, relinquishing institution information and account beneficiary informationfund codes. 1314. At all material times, the Member’s policies and procedures prohibited the use of pre- its Approved Persons from retaining pre-signed or partially completed forms. 1415. Between November 2014 and February 2017In May 2014, the Respondent obtained, obtained and possessed and, in some instances, used to process transactions, 3 1 pre-signed account forms form in respect of 4 clients. 151 client. The pre-signed account forms included: 1 form was a Reimbursement of Transfer Authorization, 1 PAC Form and 1 Canada Revenue Agency (“CRA”) Direct Transfer FormFees form which was not used to process a transaction. 16. In April 2019, the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account forms. 17. In May 2019, the Member conducted a full review of the client files maintained by the Respondent and discovered identified the remaining pre-signed form that is the subject of this Settlement Agreement. 17. Upon further review of the Respondent’s client files, the Member identified the altered account forms that are the subject of this Settlement Agreement. 18. Between May 2019 and May 2020As part of its investigation, the Member placed took steps to address the Respondent under close supervision. 19. In June 2019, deficiencies in the Member sent a letter account forms it identified to all clients whose accounts were affected by determine the Respondent’s conduct accuracy of the information and indicated that the Member had identified instances where alterations made to the account forms were used in authorized, including by: obtaining client initials on the client accounts which may not have altered forms; confirming that new updated KYC Update Forms had been complete when they were signed by obtained for the client. The Member attached clients; or sending letters to the clients along with copies of client account statements for the 2 years prior to the letter altered forms and further listed the KYC information for each client. The Member requested that asking the clients review the KYC information and account statements and to contact the Member if the clients identified any discrepancies in changes made to the information. 20account forms were unauthorized. No clients responded contacted the Member to indicate that the alterations made to the Member’s letter with any concerns about the transactions or KYC information associated with their accountaltered account forms were unauthorized. 2119. On October 10August 22, 2019, the Member issued imposed a period of close supervision on the Respondent and issued a warning letter in to the Respondent with respect of to the pre-signed and altered account formsforms described above. 2220. On September 3, 2019, the Respondent signed an Undertaking to confirm, among other things, that he understands that obtaining pre-signed forms and altering forms without obtaining client initials is prohibited. 21. The Respondent has paid a total of $4,800 to the Member in respect of the remains under close supervision imposed by the Member. 2322. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any commissions and fees that he would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 2423. There is no evidence of client loss, complaints, loss or lack of authorization. 2524. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2625. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources and expenses associated with conducting a full hearing of the allegations.

AGREED FACTS Registration History. ‌ 7. Since April 2008January 1999, the Respondent has been registered in Ontario as a mutual fund salesperson (now known as a dealing representative representative) with Sun Life Financial Investment Services (Canada) Inc. (the “Member”)Sun Life”)1, a Member of the MFDA. 8. At all material times, the Respondent conducted business in the LondonMarkham, Ontario area. 9. Beginning in May Between June 2012 and July 2017, the Member’s policies Respondent altered, and procedures prohibited Approved Persons from altering client account forms without obtaining client initials. 10. Between January 2015 and February 2019, the Respondent altered and, in some instances, used to process transactions, 24 21 account forms in respect of 22 13 clients by altering information on the account forms without having the client initial the alterations. 1110. The altered account forms included: 15 consisted of Know-Your Your-Client (“KYC”) Forms), 3 DSC Switch Authorization, Investment Application, Order Ticket, New Account Application, Transfer Authorization, Limited Trade Authorization, Home Buyer’s Plan Withdrawal Request, and Pre- Authorized Contribution Chequing (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorizationforms. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 1311. At all material times, client GR was a client of Sun Life whose accounts were serviced by the Member’s policies and procedures prohibited the use of pre- signed formsRespondent. 1412. Between November 2014 and On or about February 201726, 2013, the Respondent obtainedphotocopied the signed client signature page from a previously completed KYC account form signed by client GR, possessed andattached it to a new PAC account form, in some instances, and used the form to process transactions, 3 pre-signed account forms in respect of 4 clientsa transaction. 1513. The pre-signed account forms included: 1 Transfer AuthorizationOn July 21, 1 PAC Form and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form. 16. In April 20192017, Sun Life identified the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account forms. 17. In May 2019, the Member conducted a full review of the client files maintained by the Respondent and discovered the remaining account forms that are the subject of this the Settlement Agreement, as a result of a routine branch audit. As part of its investigation, Sun Life reviewed all of the client files serviced by the Respondent. 1814. Between May 2019 and May 2020Effective July 21, the Member 2017, Sun Life placed the Respondent under close supervisionsupervision for a period of at least six months. 191 On June 25, 2005, Clarica Investo Inc. changed its name to Sun Life. 15. In June 2019On September 12, the Member 2017, Sun Life sent a letter audit letters to all of the clients whose accounts were affected serviced by the Respondent in order to inform the clients of the Respondent’s conduct activities and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that confirm whether the clients review had authorized the KYC information and account statements and contact the Member if the clients identified any discrepancies transactions in the information. 20their accounts. No clients responded raised any concerns in response to the Member’s letter with any concerns about the transactions or KYC information associated with their accountletters. 2116. On October 10November 15, 20192017, Sun Life issued a warning letter to the Member issued Respondent and imposed on the Respondent a warning letter in respect continued period of the pre-signed and altered account formsclose supervision for one year. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 2317. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described conduct set out above beyond any the commissions and or fees that he she would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 2418. There is no evidence of client loss, complaints, loss or lack of authorizationauthorization for the underlying transactions. 2519. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2620. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources resources, and expenses associated with conducting a full hearing of on the allegations.

AGREED FACTS Registration History. ‌ 7. Since April 2008, the The Respondent has been registered in Ontario as a mutual fund salesperson (now known as a dealing representative representative) with Sun Life Financial Investment Services (Canada) Inc. (the “MemberSun Life”), a Member of the MFDA, in Nova Scotia since March 2008, and Alberta since June 2013. 8. The Respondent was also previously registered with Sun Life in Alberta from March 2005 to December 2009. 9. At all material times, the Respondent conducted business in the LondonSt. Xxxxxxx, Ontario Nova Scotia area. 9. Beginning in May 2017, the Member’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initials. 10. Between January 2015 March 2014 and February 20192015, the Respondent altered and, in some 17 instances, used to process transactions, 24 20 account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterations2 clients. 11. The altered account forms included: 15 Know-Your Client (“KYC”) consisted of 14 Transfer Authorization Forms, 3 Pre- Authorized Contribution (“PAC”) Know-Your-Client Forms, 2 Tax Free Savings Account (“TFSA”) Investment Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization Forms and 1 Limited Trade AuthorizationAuthorization Form. 12. The alterations made by With regard to 15 of the 20 account forms, the Respondent consist used photocopies of changes to: previously signed client investment knowledgesignature pages from other account forms to complete the form. The Respondent submitted to Sun Life at least 12 of these account forms for processing. 13. With regard to the remaining 5 account forms, client investment objectivesthe Respondent altered previously used account forms and re-submitted them to Sun Life to process additional transactions. In particular, client risk tolerance, investment time horizon, client income, client net worth, the Respondent altered account numbers, PAC client signature dates, know-your-client information and/or investment instructions, and account beneficiary information. 1314. At all material times, the MemberSun Life’s policies and procedures prohibited its Approved Persons, including the use of pre- signed forms. 14. Between November 2014 and February 2017Respondent, the Respondent obtained, possessed and, in some instances, used to process transactions, 3 from obtaining pre-signed account forms in respect of 4 clientsforms. 15. The pre-Between March 2014 and October 2014, the Respondent obtained and possessed 1 pre- signed account forms included: Order Ticket Form in respect of 1 Transfer Authorization, 1 PAC Form and 1 Canada Revenue Agency (“CRA”) Direct Transfer Formclient. 16. In April 2019Sun Life detected the conduct that is the subject of this Settlement Agreement during a compliance audit conducted on October 27, the Member conducted an 2014, and a further follow-up audit of on February 19 and March 10, 2015. This audit included a sample of the Respondent’s client files and identified 5 deficient account forms. 17. In May 2019, the Member conducted a full review of the all client files maintained by the Respondent. 17. As part of its investigation, Sun Life sent letters to all clients serviced by the Respondent to determine whether the Respondent had engaged in any unauthorized trading activity in the clients’ accounts. None of the clients reported any concerns to Sun Life. 18. On August 13, 2015, Xxx Life sent a warning letter to the Respondent regarding the conduct described above and discovered placed the remaining account forms Respondent on close supervision for a period of 12 months. No further concerns have arisen as a result. 19. The Respondent states that are the subject clients had authorized all of the transactions referenced in this Settlement Agreement. 18. Between May 2019 and May 2020, the Member placed the Respondent under close supervision. 19. In June 2019, the Member sent a letter to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above above, beyond any the commissions and or fees that he she would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 24. There is no evidence of client loss, complaints, or lack of authorization. 2521. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2622. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources and expenses associated with conducting a full hearing of the allegations.

AGREED FACTS Registration History. ‌ 7. Since April 20081999, the Respondent has been registered in Ontario as a dealing representative mutual fund salesperson with Sun Life Investment Services (Canada) Inc. (the “Member”)Sun Life”)1, a Member of the MFDA. Since about 2009, the Respondent has also been registered in Quebec. 8. At all material times, the Respondent conducted business in the LondonOttawa, Ontario area. 9. Beginning in May 2017At all material times, the Member’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initialsRespondent conducted business with the support of an unregistered assistant. The Respondent was responsible for the actions of his assistant. 10. Between January 2015 and February 2019, the Respondent altered and, in some instances, used to process transactions, 24 account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterations. 11. The altered account forms included: 15 Know-Your Client (“KYC”) Forms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At all material times, client IR and client SD were clients of Sun Life whose accounts were serviced by the MemberRespondent. 11. On or about June 11, 2014, the Respondent, or his assistant for whom he was responsible, photocopied the client signature page from a previously completed account form signed by client IR, attached it to a new account form, and used the form to process a transaction. 12. On or about March 9, 2015, the Respondent, or his assistant for whom he was responsible, cut client SD’s signature from a previously completed account form, pasted it onto a new account form, and used the form to process a transaction. 1 On June 25, 2005, Clarica Investo Inc. changed its name to Sun Life. 13. There is no evidence that clients IR and SD did not authorize the transactions described above. 14. Between August 22, 2013 and May 22, 2015, the Respondent, or his assistant for whom he was responsible, altered information on 3 account forms in respect of 4 clients without having the clients initial the alterations. 15. The altered account forms consisted of a pre-authorized contribution agreement form, a signature form for electronic applications, and an order ticket. 16. At all material times, Sun Life’s policies and procedures prohibited its Approved Persons, including the use of pre- Respondent, from obtaining and using pre-signed account forms. 1417. Between November 2014 September 2010 and February 2017July 2015, the Respondent Respondent, or his assistant for whom he was responsible, obtained, possessed and, in some instances, used to process transactions, 3 pre-27 pre- signed account forms in respect of 4 19 clients. 1518. The pre-signed account forms included: 1 Transfer Authorizationincluded transfer authorization forms, 1 PAC Form know-your-client forms, and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form. 16. In April 2019, the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account order forms. 17. In May 2019, the Member conducted a full review of the client files maintained by the Respondent and discovered the remaining account forms that are the subject of this Settlement Agreement. 18. Between May 2019 and May 2020, the Member placed the Respondent under close supervision. 19. In June 2019, the Member sent a letter to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any commissions and fees that he would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 24. There is no evidence of client loss, complaints, or lack of authorization. 25. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 26. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources and expenses associated with conducting a full hearing of the allegations.

AGREED FACTS Registration History. ‌ 7. Since April 20082002, the Respondent has been registered in Ontario as a dealing representative mutual fund salesperson (now known as a Dealing Representative) with Sun Life Investment Financial Services (Canada) Inc. (the “Member”)Sun Life”)1, a Member of the MFDA. 8. Between September 2009 and May 2015, Sun Life designated the Respondent as a branch manager. 9. At all material times, the Respondent conducted business in the LondonOttawa, Ontario area. 9. Beginning in May 2017, the Member’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initials. 10. Between January 2015 and February 2019, the Respondent altered and, in some instances, used to process transactions, 24 account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterations. 11. The altered account forms included: 15 Know-Your Client (“KYC”) Forms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At all material times, the MemberSun Life’s policies and procedures permitted clients to sign a Limited Trade Authorization (“LTA”), a document that authorizes Approved Persons to accept verbal instructions from a client in certain circumstances. 11. At all material times, Sun Life’s policies and procedures prohibited its Approved Persons, including the Respondent, from engaging in discretionary trading. 12. On February 6, 2014, client JR opened a mutual fund account at the Member (the “Mutual Fund Account”) and completed a KYC form, on which form client JR indicated that the time horizon for her investment in the Mutual Fund Account was less than five years, and that her risk tolerance was low to medium. Xxxxxx XX also signed a LTA at this time. 13. At the time Client JR opened the Mutual Fund Account, the Respondent explained to her the difference between deferred sales charges and front end load charges. Client JR informed the Respondent that she intended to use the monies invested in the Mutual Fund Account to pay taxes on a property within a period of pre- signed formsless than five years. 14. Between November 2014 and February 2017In March 2014, in accordance with client JR’s instructions, the Respondent obtainedprocessed a purchase in a money market fund in the Mutual Fund Account, possessed and, in some instances, used subject to process transactions, 3 pre-signed account forms in respect of 4 clientsa front end load charge. 15. The pre-signed account forms included: 1 Transfer AuthorizationOn April 24, 1 PAC Form and 1 Canada Revenue Agency 2014, the Respondent states that client JR verbally instructed the Respondent to process a switch in the Mutual Fund Account to transfer the monies to another fund with a risk rating of low to medium called the Signature Diversified Yield Fund (the “CRASwitch”) Direct Transfer Form). 16. In April 2019Prior to accepting the order for the Switch, the Member conducted an audit of a sample of Respondent states that client JR advised her that client JR did not need the Respondentinvested monies immediately. The Respondent failed to ask any further questions to determine client JR’s client files and identified 5 deficient account formstime horizon for the invested monies. 17. In May 2019Without obtaining instructions from client XX, the Member conducted Respondent used her discretion to select a full version of the Signature Diversified Yield Fund that was subject to a 7 year deferred sales charge (“DSC”), and processed the Switch. 18. At the time of the Switch, the Respondent failed to inform client XX that she would incur DSC fees if she redeemed monies from the investment within seven years. 19. On April 25, 2015, client JR redeemed her investment at a $10,822.89 gain, but incurred $6,052.29 in DSC fees. 20. In or around April 2015, client JR complained to Sun Life’s compliance department about the DSC fees arising from the Switch. 21. Sun Life completed a review of the client files maintained by complaint and refunded client JR the Respondent and discovered DSC fees incurred from the remaining account forms that are the subject of this Settlement Agreement. 18. Between May 2019 and May 2020, the Member placed the Respondent under close supervision. 19. In June 2019, the Member sent a letter to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account formsSwitch. 22. The Respondent has paid a total of also refunded to Sun Life the $4,800 to 3,631.37 commission that she received from the Member in respect of the close supervision imposed by the MemberSwitch. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any commissions and fees that he would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 24. There is no evidence of client loss, complaints, or lack of authorization. 25. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2624. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources resources, and expenses associated with conducting a full hearing of on the allegations.

AGREED FACTS Registration History. ‌ 76. Since April 2008August 16, 1991, the Respondent has been registered in Ontario as a dealing representative mutual fund salesperson with Sun Life Financial Investment Services (Canada) Inc. (the “MemberSun Life”), a Member of the MFDA.MFDA.1 87. At all material times, the Respondent conducted business in the LondonKitchener, Ontario areaOntario. 9. Beginning in May 20171 From August 16, the Member’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initials. 10. Between January 2015 and February 20191991 to June 25, 2005, the Respondent altered andwas registered with Xxxxxxx Xxxxxxxx Inc. (“Clarica”), in some instancesa subsidiary of Sun Life. On June 25, used 2007, Clarica changed its name to process transactions, 24 account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterationsSun Life. 118. The altered account forms included: 15 Know-Your Client (“KYC”) FormsOn or about September 27, 3 Pre- Authorized Contribution (“PAC”) Forms2012, 2 Tax Free Savings Account (“TFSA”) Application Formsclient JS, 1 who is an employee of Sun Life, attended a presentation by the Respondent for Sun Life’s head office employees. Following the presentation, client XX gave the Respondent a cheque for $5,000 and asked him to deposit it into her Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorizationaccount. Client JS did not provide any trade instructions to the Respondent at that time. 129. Upon the Respondent’s return to his office, the Respondent processed two trades in the RESP account of client XX. First, the Respondent invested the $5,000 contribution received from client JS in the CI Signature High Income Fund. Second, the Respondent transferred $4,000 of existing grant monies held in the RESP account from the CI Money Market Fund to the CI Signature High Income Fund.2 10. The alterations made by Respondent did not discuss either of the Respondent consist of changes to: trades with client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary informationJS or obtain the client’s authorization prior to executing the trades. 1311. At all material times, the MemberSun Life’s policies and procedures (the “Policies and Procedures”) prohibited its Approved Persons from executing trades without prior authorization by the clients. The Respondent was aware that the Policies and Procedures prohibited the use execution of pre- signed formstrades without prior authorization by the clients. 12. On October 1, 2012, the Respondent received an email from client JS questioning why the Respondent had transferred $4,000 from the CI Money Market Fund into the CI Signature High Income Fund. The Respondent immediately replied that the new fund had a “lower expense cost”, “excellent returns”, and it was “appropriate to diversify further” given the existing investments held in the RESP account. 13. On October 15, 2012, the Respondent received an email from client JS in which she 2 This transaction was processed as a “switch”. As a result, client JS did not incur any sales charges with respect to this transaction. advised: Unfortunately since I did not approve the trade ahead of time, this is considered discretionary trading. As a result, I do have an obligation to report this incident to Compliance… I also understand subsequent to your email, my new $5,000 deposit was also placed in the same fund. We should have discussed this purchase prior to the fund selection however I also recognize I should have provided direction when I handed you the cheque. This was an oversight on my part. I am okay with the purchase you made for this deposit. As for the grant money that was in [CI Money Market Fund], given the current market situation, I would prefer to keep the grant money in [CI Money Market Fund]. Could you please arrange to have the switch reversed? 14. Between November 2014 and February 2017The Respondent immediately replied to client JS by email stating, the Respondent obtained“J, possessed and, I don’t need this b@llshit in some instances, used to process transactions, 3 pre-signed account forms in respect of 4 clientsmy life. I was doing you a favour. You can find yourself another advisor.” 15. The pre-signed account forms included: 1 Transfer Authorization, 1 PAC Form and 1 Canada Revenue Agency (“CRA”) Direct Transfer FormClient JS reported the events described above to Sun Life. 16. In April 2019On or about October 23, the Member conducted 2012, Sun Life issued an audit of a sample of apology to client JS with respect to the Respondent’s conduct, agreed to reverse both trades, and provided client files and identified 5 deficient account formsJS with $100 to compensate her for any lost opportunity cost as a result of the unauthorized transactions. 17. In May 2019On or about January 29, the Member conducted 2013, Sun Life sent letters, which included copies of account transaction histories for 2011 and 2012, to a full review sample of 50 of the client files maintained clients whose accounts were serviced by the Respondent and discovered to determine whether the remaining account forms that are Respondent had processed unauthorized transactions in their accounts. Sun Life did not receive any complaints from these clients with respect to the subject of this Settlement AgreementRespondent’s conduct. 18. Between May 2019 and May 2020, The Respondent had a system in place whereby he relayed client instructions to his assistant who actually completed the Member placed forms signed in blank by the clients. The Respondent under close supervisionacknowledges that he remains responsible for all trades processed in the accounts using the pre- signed forms notwithstanding the fact that his assistant was the individual that handled the paperwork. 19. In June 2019On March 2, 2010, the Member sent MFDA issued a cautionary letter to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where Respondent for maintaining pre-signed forms were used previously found in the his client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the informationfiles. 20. No clients responded On November 29, 2012, Sun Life conducted a client file review at the Respondent’s office. During the review, Sun Life identified three Sun Life pre-authorized chequing/automatic withdrawal (“PAC/AWD”) forms which had been signed by client PG prior to the Member’s letter with any concerns about information on the transactions or KYC information associated with their accountform being populated. The three PAC/AWD forms were dated March 29, 2010, April 27, 2011 and March 12, 2012, respectively. 21. On October 10or about March 29, 20192010, March 31, 2011 and March 12, 2012, the Member issued Respondent (or his assistant on his behalf) received instructions from client PG by email to process a one-time purchase of mutual funds in client PG’s account using client PG’s tax refund monies from the Respondent Canada Revenue Agency. The Respondent’s assistant on his behalf sent a warning letter in respect blank PAC/AWD form to client PG which client PG signed and then scanned and returned as an attachment to an email. The Respondent’s assistant on his behalf populated the rest of the pre-information on the pre- signed and altered account formsPAC/AWD form. 22. The There have been no client complaints against the Respondent has paid a total and there is no evidence of $4,800 to the Member in respect client harm arising out of the close supervision imposed by the MemberRespondent’s possession and use of pre-signed forms. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any commissions benefits as a result of his possession and fees that he would ordinarily be entitled to receive had the transactions been carried out in the proper manneruse of pre-signed forms. 24. There is no evidence In 2012, new procedures were put in place at the Respondent’s office to deter the use of client losspre-signed forms. Xxxxxxxx were provided to every Approved Person in the Respondent’s office. As well, complaints, or lack of authorizationpre-fillable forms were integrated into the Respondent’s practice. 25. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 26. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources and expenses associated with conducting a full hearing of the allegations.

AGREED FACTS Registration History. ‌ 7. Since April 2008June 2001, the Respondent has been registered in Ontario as a dealing representative mutual fund salesperson (now known as a Dealing Representative) with Sun Life Investment Services (Canada) Inc. (the “Member”)Sun Life”)1, a Member of the MFDA. 8. The Respondent has also been registered in Quebec since November 2005 and in New Brunswick since March 2011. 9. At all material times, the Respondent conducted business in the LondonOttawa, Ontario area. 910. Beginning in May 2017At all material times, the Member’s policies Respondent conducted business with the support of his current unregistered assistant, LD. The Respondent was responsible for the actions of LD. 11. May 2008 and procedures prohibited Approved Persons from altering client May 2015, the Respondent, or his assistant for whom he was responsible, altered and used to process transactions, 6 account forms in respect of 5 clients. 12. The Respondent, or his assistant, altered 6 of the account forms by altering information on the account form without obtaining client initialsinitials authorizing the alterations. 1013. The altered account forms included pre-authorized contribution agreement forms and Know-Your-Client forms. 14. Between January 2015 May 2008 and February 2019May 2015, the Respondent altered andRespondent, or his assistant for whom he was responsible, obtained, possessed, and in some instances, used to process transactions, 24 account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterations. 11. The altered account forms included: 15 Know-Your Client (“KYC”) Forms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At all material times, the Member’s policies and procedures prohibited the use of 40 pre- signed forms. 14. Between November 2014 and February 2017, the Respondent obtained, possessed and, in some instances, used to process transactions, 3 pre-signed account forms in respect of 4 24 clients. 15. The pre-signed account forms included: included transfer authorization forms, pre-authorized contribution agreement forms and new account application forms. 1 Transfer AuthorizationEffective June 25, 1 PAC Form and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form2007, Xxxxxxx Xxxxxxxx Inc. changed its name to Sun Life. 16. In On April 201928, 2015 and during a subsequent follow up investigation, Sun Life’s dealer operations staff detected the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account forms. 17. In May 2019, the Member conducted a full review of the client files maintained by the Respondent and discovered the remaining account forms conduct that are is the subject of this Settlement Agreement. 17. As part of its investigation, Sun Life reviewed all client files serviced by the Respondent and sent letters to all clients serviced by the Respondent in order to determine whether the Respondent had engaged in any unauthorized trading. No clients reported any concerns to Sun Life. 18. Between May 2019 and May 2020On July 15, the Member 2015, Sun Life placed the Respondent under close supervisionsupervision for a period of 12 months. On August 31, 2015, Sun Life issued a Warning Letter to the Respondent and recited the Respondent to complete a relevant industry course. 19. In June 2019, the Member sent a letter to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any the commissions and fees that he would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 2420. There is no evidence of client loss, complaints, harm or lack of authorization. 2521. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2622. The Respondent has expressed remorse for his conduct. 23. The Respondent has cooperated fully with Staff during the course of its investigation. 24. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources resources, and expenses associated with conducting a full hearing of on the allegations.

AGREED FACTS Registration History. ‌ 7. Since April 2008From May 10, 2007 to October 19, 2016, the Respondent has been was registered in Ontario as a mutual fund salesperson (now known as a dealing representative representative) in Alberta with Sun Life Financial Investment Services (Canada) Inc. (the “MemberSun Life”), a Member of the MFDA. 8. The Respondent is not currently registered in the securities industry in any capacity. 9. At all material times, the Respondent conducted business in the LondonEdmonton, Ontario Alberta area. 910. Beginning in May 2017On or about September 8, 2011, the MemberRespondent falsified an order ticket and used it to process a redemption in the account of client JG, by altering the date on an order ticket that had previously been submitted to Sun Life on another transaction. The Respondent then re-submitted the altered form to Sun Life for processing, without having the client initial the alteration. 11. The transaction was processed in accordance with the client’s instructions. 12. At all material times, Sun Life’s policies and procedures prohibited its Approved Persons from altering client using pre-signed account forms without obtaining client initialsforms. 1013. Between January 2015 24, 2012 and February 2019March 10, 2015, the Respondent altered andobtained, possessed and in some two instances, used to process transactions, 24 account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterations. 11. The altered account forms included: 15 Know-Your Client (“KYC”) Forms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At all material times, the Member’s policies and procedures prohibited the use of pre- signed forms. 14. Between November 2014 and February 2017, the Respondent obtained, possessed and, in some instances, used to process transactions, 3 8 pre-signed account forms in respect of 4 clients. 15. The These pre-signed client account forms included: 1 consisted of: i. Two Transfer Authorization, 1 PAC Form Authorization Forms for Registered Investments; ii. Two Client Information Forms (KYC Form); iii. Two New Account Application Forms; iv. One Limited Trade Authorization Form; and 1 Canada Revenue Agency (“CRA”) Direct Transfer Formv. One Order Ticket. 1614. In April 2019June 2015, the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account forms. 17. In May 2019, the Member conducted a full review Sun Life reviewed all of the client files maintained by the Respondent and discovered the remaining Respondent. Sun Life did not identify any pre-signed client account forms that are the subject of this Settlement Agreementor altered forms beyond those described in paragraphs 9 to 12 above. 15. On August 18. Between May 2019 and May 2020, the Member placed the Respondent under close supervision. 19. In June 20192015, the Member Xxx Life sent a letter letters to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where for who pre-signed or altered account forms were used identified to determine whether the Respondent engaged in any unauthorized trading activity in the client accounts which may not have been complete when they were signed by of the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20clients. No clients responded to the Member’s letter with Member to raise any concerns about the transactions or KYC information associated with their accountaccounts. 2116. On October September 21, 2015, Sun Life placed the Respondent under close supervision for a period of 12 months. Sun Life has conducted random audits of the client accounts maintained by the Respondent, as well as quarterly audits of her branch office. 17. On November 10, 20192015, the Member Sun Life issued the Respondent a warning letter in respect of to the Respondent, and required her to complete an industry course and sign an acknowledgement letter that she would cease using pre-signed and altered account forms. 2218. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence that On or about August 16, 2016, while the Respondent received any financial benefit from engaging in was under close supervision, and after having signed the misconduct described above beyond any commissions and fees that he would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 24. There is no evidence of client loss, complaints, or lack of authorization. 25. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 26. By entering into this Settlement Agreementacknowledgement letter, the Respondent has saved the MFDA the timeobtained and possessed one additional pre-signed account form from a client, resources and expenses associated with conducting a full hearing of the allegationswhich she submitted to Sun Life for processing.

AGREED FACTS Registration History. ‌ 7. Since April 2008May 23, 2007, the Respondent has been registered in Ontario Manitoba as a mutual fund salesperson (now known as a dealing representative representative) with Sun Life Financial Investment Services (Canada) Inc. (the “MemberSun Life”), a Member of the MFDA. 8. At all material times, the Respondent conducted business in the LondonWinnipeg, Ontario areaManitoba. 9. Beginning in May 2017, the Member’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initials. 10. Between January 2015 and February 2019, the Respondent altered and, in some instances, used to process transactions, 24 account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterations. 11. The altered account forms included: 15 Know-Your Client (“KYC”) Forms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At all material times, the MemberSun Life’s policies and procedures prohibited the use of pre- its Approved Persons from using pre-signed account forms. 1410. Between November 2014 June 2012 and February 2017March 2014, the Respondent obtained, possessed and, in some instances, maintained and used to process transactions, 3 13 partially complete pre-signed account forms or photocopies of partially complete pre-signed account forms, in respect of eight client accounts. 11. The 13 pre-signed forms were comprised of: i. Four Transfer Authorization Forms; ii. One Limited Trade Authorization Form; iii. Three Sun Life Order Tickets; iv. Four CCRA Direct Transfer Forms; and v. One New Account Application Form. 12. Between March 2013 and April 2014, the Respondent also obtained and maintained six blank pre-signed account forms in respect of 4 clientsfive client accounts. 1513. The six blank pre-signed account forms included: 1 Transfer Authorization, 1 PAC Form and 1 Canada Revenue Agency (“CRA”) were comprised of: i. Four CCRA Direct Transfer Forms; ii. One Sun Life Transfer Authorization Form; and iii. One Signature Form for Electronic Application. 16. In April 2019, the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account forms. 1714. In May 20192014, the Member conducted a full review Sun Life reviewed all of the client files maintained by the Respondent and discovered the remaining Respondent. Sun Life did not detect any use of pre-signed account forms beyond that are the subject of this Settlement Agreementdescribed in paragraphs 10 to 13, above. 1815. Between May 2019 and May 2020On September 5, the Member placed the Respondent under close supervision. 19. In June 20192014, the Member sent a letter audit letters were mailed to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where for whom pre-signed account forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached located, enclosing copies of client active mutual fund account statements for the 2 years prior to the letter statements, and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified requesting responses regarding any discrepancies in the information. 20unauthorized activity. No clients responded to the Member’s letter with any raise concerns about the transactions or KYC information associated with their accountaccounts. 2116. On October 10September 18, 20192014, the Member Sun Life issued the Respondent a warning letter in respect to the Respondent and placed him under close supervision for a period of 12 months commencing September 1, 2014. During the period of close supervision, all mutual fund transactions undertaken by the Respondent were subject to review. Sun Life conducted random audits of the pre-signed and altered account formsclient accounts maintained by the Respondent, as well as quarterly audits of his branch office. No compliance concerns arose as a result. 2217. The Respondent has paid a total of $4,800 to no prior disciplinary history with the Member in respect of the close supervision imposed by the MemberMFDA. 2318. There is no evidence of misappropriation, unauthorized trading, or client harm in this matter. 19. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any the commissions and or fees that he to which the Respondent would have been ordinarily be entitled to receive had the transactions in the clients’ accounts been carried out in the proper manner. 24. There is no evidence of client loss, complaints, or lack of authorization. 2520. The Respondent has not previously been cooperated fully with Staff during the subject course of MFDA disciplinary proceedings. 26. By entering into the investigation, and by agreeing to this Settlement Agreementsettlement, has avoided the Respondent has saved the MFDA the time, resources and expenses associated with conducting necessity of a full hearing of on the allegationsmerits. 21. The Respondent has expressed remorse for his misconduct.

AGREED FACTS Registration History. ‌ 78. Since April 2008From February 2008 to October 2015, the Respondent has been was registered in Ontario as a dealing representative mutual fund salesperson (now known as a Dealing Representative) with Sun Life Financial Investment Services (Canada) Inc. (the “MemberSun Life”), a Member of the MFDA. 89. Between 1993 and 2008, the Respondent worked as an assistant to another Approved Person, LD; between February 2008 and October 2015, she worked in the capacity of LD’s registered assistant. 10. At all material times, the Respondent conducted business in the LondonNiagara Falls, Ontario area. 911. Beginning The Respondent is currently employed in May 2017a non-registerable capacity with Quadrus Investment Services Ltd., a Member of the Member’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initialsMFDA. 1012. Between January 2015 February 2008 and February 2019March 2015, the Respondent altered and, in some instances, or used to process transactions, 24 162 account forms in respect of 22 clients by altering information on the account forms without having the obtaining client initial initials authorizing the alterations. 1113. The altered account forms included: 15 Knowincluded Pre-Your Client (“KYC”) Forms, 3 Pre- Authorized Contribution (“PAC”) Formsforms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructionsforms, and account beneficiary information. 13. At all material times, the Member’s policies and procedures prohibited the use of pre- signed New Account Application forms. 14. Between November 2014 and February 2017The Respondent was responsible for submitting the account forms to Sun Life for processing. In the instances where LD altered the account forms, the Respondent obtainedknew or ought to have known that the account forms were altered. 15. Between February 2008 and March 2015, possessed and, in some instances, the Respondent obtained or used to process transactions, 3 178 pre-signed account forms in respect of 4 clientsforms. 1516. The pre-signed account forms included: 1 Transfer Authorizationincluded Pre-Authorized Contribution forms, 1 PAC Form Order forms, and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form. 16. In April 2019, the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account New Account Application forms. 17. The Respondent was responsible for submitting the account forms to Sun Life for processing. In May 2019the instances where LD obtained the account forms, the Member conducted a full review of Respondent knew or ought to have known that the client files maintained by the Respondent and discovered the remaining account forms were pre-signed. 18. Sun Life’s compliance staff detected the conduct that are is the subject of this Settlement Agreement. 18. Between May 2019 Agreement during a branch audit on December 3, 2014 and May 2020, the Member placed the Respondent under close supervisionsubsequent follow-up investigation. 19. In June 2019, Sun Life identified the Member sent a letter to all clients whose accounts were affected by conduct involving the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the described above across approximately 200 client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the informationfiles. 20. No As part of its investigation, Sun Life sent letters to all clients responded serviced by the Respondent in order to determine whether the Member’s letter with Respondent had engaged in any unauthorized trading. There is no evidence of any client concerns about the transactions or KYC information associated with their accountin response to these letters. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any the commissions and fees that he she would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 2422. There is no evidence of client loss, complaints, harm or lack of client authorization. 2523. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2624. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources resources, and expenses associated with conducting a full hearing of on the allegations.

AGREED FACTS Registration History. ‌ 7. The Respondent was registered in the mutual fund industry commencing in September 1989. 8. Since April 2008August 2012, the Respondent has been registered in Ontario as a dealing representative mutual fund salesperson (now known as a Dealing Representative) with Sun Life Investment Investia Financial Services (Canada) Inc. (the “MemberInvestia”), a Member of the MFDA. 89. At all material times, the Respondent conducted business in the LondonToronto, Ontario area. 910. Beginning in May 2017November 2013, the MemberInvestia’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initialsrequired that where any material changes are made to a client’s trade documents, they must be initialed by the client. 1011. Between January 2015 2013 and February 20192017, the Respondent altered andaltered, in some instances, and used to process transactions, 24 19 account forms in respect of 22 17 clients by altering information on the account forms without having the client initial the alterations. 1112. The altered account forms included: 15 Know-Your Client (“KYC”) Formsconsisted of new account application, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructionstrade tickets, and account beneficiary informationfund order forms. 13. At all material times, the MemberInvestia’s policies and procedures prohibited the use of pre- its Approved Persons from using pre-signed account forms. 14. Between November 2014 and February 2017On or about January 8, 2016, the Respondent obtained, possessed andpossessed, in some instances, and used to process transactions, 3 2 pre-signed account forms in respect of 4 clientsa client. 15. The pre-signed account forms included: 1 Transfer Authorizationconsisted of a new account application, 1 PAC Form and 1 Canada Revenue Agency (“CRA”) Direct Transfer Formtransfer authorization form. 16. In On April 20194, 2017, Investia’s compliance staff identified the Member conducted an audit of a sample of the Respondent’s client files altered and identified 5 deficient account forms. 17. In May 2019, the Member conducted a full review of the client files maintained by the Respondent and discovered the remaining account pre-signed forms that are the subject of this Settlement AgreementAgreement as a result of a routine branch audit. 17. As part of its investigation, Investia conducted a review of all of the client files serviced by the Respondent and sent letters to all of the Respondent’s clients to determine whether the Respondent had engaged in any unauthorized trading. No clients reported any concerns. 18. Between On May 2019 and May 20208, the Member 2017, Investia placed the Respondent under close supervision. 19. In June 2019On October 30, the Member sent 2017, Investia issued a warning letter to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any other than the commissions and or fees that he would ordinarily be entitled to receive had the transactions been carried out completed in the proper manner. 2421. There is no evidence of client loss, complaints, loss or lack of authorization. 2522. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2623. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources resources, and expenses associated with conducting a full hearing of on the allegations.

AGREED FACTS Registration History. ‌ 7. Since April 20081988, the Respondent has been registered in the securities industry. 8. Since 2013, the Respondent has been registered in Ontario as a dealing representative Dealing Representative with Sun Life Investment Services (Canada) Worldsource Financial Management Inc. (the “MemberWorldsource”), a Member of the MFDA. 89. At all material times, the Respondent conducted business in the London, Ontario area. 9. Beginning in May 2017, the Member’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initials. 10. Between January 2015 February 2014 and February 2019May 2015, the Respondent altered and, in some instances, falsified and used to process transactions, 24 3 account forms in respect of 22 3 clients by altering information on the account forms without having the client clients initial the alterations. 11. The altered account forms included: 15 Know-Your Client (“KYC”) Formsconsisted of a switch form, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization a purchase form and 1 Limited Trade Authorizationa client suitability form. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At all material times, the MemberWorldsource’s policies and procedures prohibited its Approved Persons, including the use of pre- Respondent, from having clients sign pre-signed account forms. 1413. Between November February 2014 and February 2017May 2015, the Respondent obtained, possessed andpossessed, and in some instances, used to process transactions, 3 24 pre-signed account forms in respect of 4 10 clients. 14. The account forms included switch forms, trade tickets and purchase forms. 15. The pre-signed account forms included: 1 Transfer AuthorizationOn or about July 2015, 1 PAC Form and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form. 16. In April 2019, Worldsource’s compliance staff identified the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account forms. 17. In May 2019, the Member conducted a full review of the client files maintained by the Respondent and discovered the remaining account forms conduct that are is the subject of this Settlement AgreementAgreement during the course of a review of the Respondent’s files. 16. As part of its review, Worldsource reviewed a selection of client files serviced by the Respondent and sent letters to all clients serviced by the Respondent in order to determine whether the Respondent had engaged in any unauthorized trading. Worldsource received no complaints in response to its letters. 17. On July 27, 2016, Worldsource issued a cautionary letter to the Respondent and fined him $750. 18. Between May 2019 and May 2020, the Member placed the Respondent under close supervision. 19. In June 2019, the Member sent a letter to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct conduct described above beyond any commissions and fees that he would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 2419. There is no evidence of any client loss, complaints, loss or lack of client authorization. 2520. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2621. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources resources, and expenses associated with conducting a full hearing of the allegations.

AGREED FACTS Registration History. ‌ 7. Since The Respondent was registered in the mutual fund industry commencing in May 1998. 8. From April 20082008 to December 2016, the Respondent has been registered in Ontario as a dealing representative mutual fund salesperson (now known as a Dealing Representative) with Sun Life Investment Services (Canada) Worldsource Financial Management Inc. (the “MemberWorldsource”), a Member of the MFDA. 89. On December 31, 2016, the Respondent resigned from Worldsource. 10. The Respondent is no longer registered in the securities industry in any capacity. 11. At all material times, the Respondent conducted business in the LondonToronto, Ontario area. 912. Beginning in May 2017Between October 2014 and June 2015, the MemberRespondent falsified, and in at least 1 instance, used to process a transaction, 4 account forms in respect of 4 clients, by using liquid correction fluid or pen to alter information on the account forms to reflect client instructions without obtaining client initials authorizing the alternations. 13. The falsified account forms consisted of new account application and trading forms. 14. At all material times, Worldsource’s policies and procedures prohibited its Approved Persons from altering client using pre-signed account forms without obtaining client initialsforms. 1015. Between January May 2015 and February 20192016, the Respondent altered andobtained, possessed, and in some at least 16 instances, used to process transactions, 24 account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterations. 11. The altered account forms included: 15 Know-Your Client (“KYC”) Forms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At all material times, the Member’s policies and procedures prohibited the use of pre- signed forms. 14. Between November 2014 and February 2017, the Respondent obtained, possessed and, in some instances, used to process transactions, 3 45 pre-signed account forms in respect of 4 8 clients. 1516. The pre-signed account forms included: 1 Transfer Authorizationconsisted of new account application, 1 PAC Form fund purchase, fund switch, account transfer and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form. 16. In April 2019, the Member conducted an audit change of a sample of the Respondent’s client files and identified 5 deficient account advisor/dealer forms. 17. In May 20192016, MFDA Sales Compliance Staff alerted Worldsource after it identified pre- signed account forms in client files serviced by the Member Respondent after a field review of the Respondent’s branch location. 18. As part of its investigation, Worldsource conducted a full review of all of the client files maintained serviced by the Respondent and discovered sent letters to all of the remaining account forms that are Respondent’s clients to determine whether the subject of this Settlement AgreementRespondent had engaged in any unauthorized trading. No clients reported any concerns. 1819. Between On May 2019 and May 202030, the Member 2016, Worldsource placed the Respondent under close supervision. 1920. In June 2019On August 18, the Member sent 2016, Worldsource issued a disciplinary letter to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any other than the commissions and or fees that he would ordinarily be entitled to receive had the transactions been carried out completed in the proper manner. 2422. There is no evidence of client loss, complaints, loss or lack of authorization. 2523. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2624. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources resources, and expenses associated with conducting a full hearing of on the allegations.

AGREED FACTS Registration History. ‌ 7. Since April 2008The Respondent was registered in the mutual fund industry commencing in August 1998. 8. From July 2001 to May 2017, the Respondent has been was registered in Ontario as a dealing representative mutual fund salesperson (now known as a Dealing Representative) with Sun Life Investment Investia Financial Services (Canada) Inc. (the “MemberInvestia”), a Member of the MFDA. 89. On May 17, 2017, Investia terminated the Respondent’s registration as a result of the conduct described in this Settlement Agreement. 10. The Respondent is no longer registered in the securities industry in any capacity. 11. At all material times, the Respondent conducted business in the LondonToronto, Ontario area. 912. Beginning in May 2017At all material times, the MemberInvestia’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initialsrequired that where any material changes are made to a client’s trade documents, they must be initialed by the client. 1013. Between January July 2015 and February 2019November 2016, the Respondent altered andfalsified, in some instances, and used to process transactions, 24 6 account forms in respect of 22 8 clients by altering information on the account forms without having the client initial the alterations. 1114. The altered falsified account forms included: 15 Know-Your Client (“KYC”) Forms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment consisted of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization new account application and 1 Limited Trade Authorizationfund order forms. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 1315. At all material times, the MemberInvestia’s policies and procedures prohibited the use of pre- its Approved Persons from using pre-signed account forms. 1416. Between November 2014 February 2009 and February 2017, the Respondent obtained, possessed andpossessed, and in some instances, used to process transactions, 3 80 pre-signed account forms in respect of 4 57 clients. 1517. The pre-signed account forms included: 1 Transfer Authorizationconsisted of new account application, 1 PAC Form know-your-client update, fund order, Registered Education Savings Plan payment and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form. 16. In April 2019, the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account systematic instruction forms. 1718. In May 2019On March 9, 2017, Investia’s compliance staff identified the Member conducted a full review of the client files maintained by the Respondent falsified and discovered the remaining account pre-signed forms that are the subject of this Settlement AgreementAgreement as a result of a routine branch audit. 1819. Between May 2019 As part of its investigation, Investia conducted a review of all of the client files serviced by the Respondent and May 2020sent letters to all of the Respondent’s clients to determine whether the Respondent had engaged in any unauthorized trading. No clients reported any concerns. 20. On April 6, the Member 2017, Investia placed the Respondent under close supervision. 19. In June 2019, the Member sent a letter to all clients whose accounts were affected by the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any other than the commissions and or fees that he would ordinarily be entitled to receive had the transactions been carried out completed in the proper manner. 2422. There is no evidence of client loss, complaints, loss or lack of authorization. 2523. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 2624. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources resources, and expenses associated with conducting a full hearing of on the allegations.

AGREED FACTS Registration History. ‌ 7. Since April 20081996, the Respondent has been registered in Ontario British Colombia as a mutual fund salesperson (now known as a dealing representative representative) with Sun Life Financial Investment Services (Canada) Inc. (the “MemberSun Life”), a Member of the MFDA. 8. The Respondent is also registered as a dealing representative in Alberta and Ontario. 9. At all material times, the Respondent conducted carried on business in the LondonKelowna, Ontario British Columbia area. 9. Beginning in May 2017, the Member’s policies and procedures prohibited Approved Persons from altering client account forms without obtaining client initials. 10. Between January 2015 and February 2019, the Respondent altered and, in some instances, used to process transactions, 24 account forms in respect of 22 clients by altering information on the account forms without having the client initial the alterations. 11. The altered account forms included: 15 Know-Your Client (“KYC”) Forms, 3 Pre- Authorized Contribution (“PAC”) Forms, 2 Tax Free Savings Account (“TFSA”) Application Forms, 1 Registered Education Savings Plan (“RESP”) Appointment of Beneficiary Form, 1 Order Ticket, 1 Transfer Authorization and 1 Limited Trade Authorization. 12. The alterations made by the Respondent consist of changes to: client investment knowledge, client investment objectives, client risk tolerance, investment time horizon, client income, client net worth, account numbers, PAC instructions, and account beneficiary information. 13. At all material times, the MemberSun Life’s policies and procedures prohibited its Approved Persons, including the use of pre- Respondent, from holding, obtaining, or using pre-signed account forms. 1411. Between November 2014 December 2010 and February 2017January 2016, the Respondent obtained, possessed andpossessed, in some instances, or used to process transactions, 3 18 pre-signed account forms in respect of 4 12 clients. 1512. The pre-signed account forms included: 1 Transfer Authorizationconsisted of Electronic fund transfer, 1 PAC Form Pre-authorized chequing, and 1 Canada Revenue Agency (“CRA”) Direct Transfer Form. 16. In April 2019, the Member conducted an audit of a sample of the Respondent’s client files and identified 5 deficient account Order ticket forms. 1713. Either the Respondent or his assistant submitted pre-signed forms to Sun Life to process transactions in client accounts. 14. In May 2019January 2016, the Member conducted a full review Sun Life identified 2 of the client files maintained by the Respondent and discovered the remaining account pre-signed forms that are the subject of this Settlement AgreementAgreement during an onsite branch review. Sun Life subsequently commenced a review of all the client files serviced by the Respondent and identified the remaining pre-signed account forms. 1815. Between May 2019 and May 2020On February 29, the Member 2016, Sun Life placed the Respondent under close supervisionsupervision for an indefinite period. 1916. In June 20192009, the Member sent Sun Life issued a warning letter to all clients whose accounts were affected the Respondent after it identified 15 pre- signed account forms in client files serviced by the Respondent’s conduct and indicated that the Member had identified instances where forms were used in the client accounts which may not have been complete when they were signed by the client. The Member attached copies of client account statements for the 2 years prior to the letter and further listed the KYC information for each client. The Member requested that the clients review the KYC information and account statements and contact the Member if the clients identified any discrepancies in the information. 20. No clients responded to the Member’s letter with any concerns about the transactions or KYC information associated with their account. 21. On October 10, 2019, the Member issued the Respondent a warning letter in respect of the pre-signed and altered account forms. 22. The Respondent has paid a total of $4,800 signed an Acknowledgment to the Member in respect of the close supervision imposed by the Member. 23. There is no evidence dated September 1, 2009, stating that the Respondent received any financial benefit from engaging in the misconduct described above beyond any commissions and fees understood that he would ordinarily be entitled to receive had the transactions should not have clients execute forms that have not been carried out completed in the proper mannerfull. 2417. There is no evidence of client loss, complaints, or lack of authorization. 25. The Respondent has not previously been All the forms that are the subject of MFDA disciplinary proceedings. 26. By entering into this Settlement AgreementAgreement were obtained, possessed, or used, after the Respondent has saved the MFDA the time, resources and expenses associated with conducting a full hearing of the allegationswas warned by Sun Life in June 2009.