Common use of AGREED FACTS Registration History Clause in Contracts

AGREED FACTS Registration History. ‌ 1. Since June 20, 2006, the Respondent has been registered in British Columbia as a dealing representative with Global Maxfin Investments Inc.1 (the “Member”), a Member of the MFDA. 2. At all material times, the Respondent carried on business in the Namaimo, British Columbia area. 1 Between June 20, 2006 and September 1, 2011, the Respondent was registered in British Columbia with Professional Investment Services (Canada) Inc. (“PIS”). On September 1, 2011, PIS amalgamated with the Member. 3. Between January 5, 2015 and March 1, 2018, the Respondent altered 12 account forms in respect of 9 clients by altering information on the account forms without having the clients initial the alterations. 4. The Respondent used liquid correction fluid to alter the account forms without the client initialing the documents to show the alteration was approved. 5. The altered account forms included Order Entry Forms and KYC Forms. 6. The alterations the Respondent made to the account forms included alterations to spousal/beneficiary information, fund codes, fund names and amounts. 7. At all material times, the Member’s policies and procedures prohibited its Approved Persons from using pre-signed account forms. 8. Between January 25, 2011 and May 18, 2018, the Respondent obtained, possessed and used to process transactions, 58 pre-signed account forms in relation to 17 clients. 9. The pre-signed account forms included, Know-Your-Client (“KYC”) Forms, Order Entry Forms, Transfer DSC Free or Mature Units to Front End Forms. 10. On May 23, 2018, the Member detected the pre-signed forms that are the subject of this Settlement Agreement during a compliance review of all of the Respondent’s files. 11. On June 11, 2018, the Member placed the Respondent on strict supervision for a period of 6 months, issued a warning letter, and imposed a fine of $2,500 on the Respondent. 12. On September 13, 2018, the Member sent letters to all of the clients serviced by the Respondent, asking whether the Respondent had asked them to sign incomplete or blank account forms to conduct business. The Member received no responses to its letters. 13. The Respondent has not been the subject of previous MFDA disciplinary proceedings. 14. There is no evidence of client loss in this matter or that the Respondent received any financial benefit from engaging in the misconduct beyond the commissions or fees to which he would have been ordinarily entitled had the transactions in the clients’ accounts been carried out in the proper manner. 15. There have been no client complaints in relation to the conduct described in this Settlement Agreement, and no evidence of unauthorized trading undertaken by the Respondent. 16. The Respondent has cooperated fully with Staff during the course of the investigation, and by agreeing to this settlement, has avoided the necessity of a full hearing on the merits.

AGREED FACTS Registration History. ‌7. The Respondent was registered in the securities industry commencing in 1999. 18. Since June 20, 2006, the The Respondent has been registered in British Columbia as a mutual fund salesperson (now known as a dealing representative representative) with Global Maxfin Investments Inc.1 Sun Life Financial Investment Services (the Canada) Inc. (“MemberSun Life”), a Member of the MFDA, in Nova Scotia since January 2014, and in British Columbia since May 2014. 29. At all material times, the Respondent carried on conducted business in the NamaimoHalifax, British Columbia Nova Scotia area. 1 Between June 20, 2006 and September 1, 2011, the Respondent was registered in British Columbia with Professional Investment Services (Canada) Inc. (“PIS”). On September 1, 2011, PIS amalgamated with the Member. 310. Between January 5, 2015 and March 1, 2018February 2015, the Respondent altered 12 Respondent, or his assistant for whom he was responsible, altered, and used to process transactions, 5 account forms in respect of 9 clients 1 client by altering information on the account forms without having the clients client initial the alterations. 4. The Respondent used liquid correction fluid to alter the account forms without the client initialing the documents to show the alteration was approved. 5. The altered account forms included Order Entry Forms and KYC Forms. 6changes. The alterations included changes to the Respondent client’s account number, net worth, investment objectives, contact information, and redemption instructions. The alterations were made to the forms consisting of 2 automatic withdrawal forms, 1 know-your-client form, 1 transfer authorization form, and 1 account forms included alterations to spousal/beneficiary information, fund codes, fund names and amountsapplication form. 711. At all material times, the MemberSun Life’s policies and procedures prohibited its Approved Persons Persons, including the Respondent, from using pre-signed account forms. 812. Between January 25, 2011 2014 and May 18, 2018April 2015, the Respondent Respondent, or his assistant for whom he was responsible, obtained, possessed possessed, and in 12 instances, used to process transactions, 58 14 pre-signed account forms in relation respect of 4 clients. The forms consisted of 3 limited trade authorization forms, 4 account application forms, 4 transfer authorization forms, 2 automatic withdrawal forms, and 1 application to 17 clientswithdraw funds form. 913. The With regard to 12 of the pre-signed account forms, the Respondent’s assistant only provided the signature pages to the clients without providing the other pages of the forms includedwith completed information. The clients signed but did not date the signature pages and returned them to the Respondent’s assistant, Know-Your-Client (“KYC”) Formswho then attached the signature pages she received from the clients to the other pages of the forms that she had completed, Order Entry Formsadded client signature dates on the forms, Transfer DSC Free or Mature Units and then submitted the complete forms to Front End FormsSun Life for processing. In all 12 instances, the Respondent’s assistant dated the forms subsequent to when the clients had signed the forms. 1014. On May 23, 2018, the Member Sun Life detected the pre-signed forms conduct that are is the subject of this Settlement Agreement settlement agreement during a compliance client file review it conducted of all client files maintained by the Respondent. 15. 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 Respondent’s filesclients reported any concerns to Sun Life. 1116. On June 1110, 20182015, the Member Sun Life placed the Respondent on strict close supervision for a period of 6 12 months, issued and on September 30, 2015, Sun Life sent a warning letter, and imposed a fine of $2,500 on letter to the RespondentRespondent regarding the conduct described above. 12. On September 13, 2018, the Member sent letters to all of the clients serviced by the Respondent, asking whether the Respondent had asked them to sign incomplete or blank account forms to conduct business. The Member received no responses to its letters. 13. The Respondent has not been the subject of previous MFDA disciplinary proceedings. 1417. There is no evidence of client loss in this matter or that the Respondent received any financial benefit from engaging in the misconduct described in this Settlement Agreement, beyond the commissions or and fees to which that he would have been ordinarily be entitled to receive had the transactions in the clients’ accounts been carried out in the proper manner. 1518. There have is no evidence of client harm or lack of client authorization. 19. The Respondent has not previously been no client complaints in relation to the conduct described in subject of MFDA disciplinary proceedings. 20. The Respondent has expressed remorse for his conduct. 21. By entering into this Settlement Agreement, and no evidence of unauthorized trading undertaken by the Respondent. 16. The Respondent has cooperated fully saved the MFDA the time, resources and expenses associated with Staff during the course of the investigation, and by agreeing to this settlement, has avoided the necessity of conducting a full hearing on of the meritsallegations.

AGREED FACTS Registration History. ‌ 17. Since From November 7, 1995 to June 206, 20062005 and from May 24, 2006 to June 18, 2014, the Respondent has been was registered in British Columbia Ontario as a dealing representative mutual fund salesperson (now known as Dealing Representative) with Global Maxfin Investments Inc.1 Credential Asset Management Inc. 1 (the “MemberCredential”), a Member member of the MFDA. 28. At all material times, the Respondent carried on conducted business in the NamaimoXxxxxxx, British Columbia Ontario area. 1 9. The Respondent is not currently registered in the securities industry in any capacity. 10. Between June 20, 2006 September 2007 and September 1, 2011April 2014, the Respondent was registered obtained, possessed, and in British Columbia some instances, used to process transactions, 86 pre-signed account forms with Professional respect of 54 clients. 11. The 86 pre-signed forms, 82 of which were used to process transactions, included New Account Application Forms, Investment Instruction forms, and Know-Your-Client forms. 1 Formerly known as Ethical Funds Investment Services (Canada) Inc. (“PIS”). On September 1, 2011, PIS amalgamated with the Member.Inc. 312. Between January 5, 2015 September 2007 and March 1, 2018April 2014, the Respondent altered 12 altered, and in all but one instance, used to process transactions, 101 account forms in respect of 9 clients by altering information on the account forms without having the clients initial the alterations70 clients. 413. The 101 forms in question included New Account Application Forms, Investment Instruction forms, and Know-Your-Client forms. 14. On four forms, the Respondent used liquid correction fluid to alter the account forms without cut and pasted the client initialing signature from a previously filled out client form onto a new client form. On the documents to show remainder of the alteration was approved. 5. The altered account forms included Order Entry Forms and KYC Forms. 6. The alterations forms, the Respondent made material changes to the client account forms included alterations to spousal/beneficiary information, fund codes, fund names and amountsusing either pen or liquid correction fluid. 715. At all material timesOn February 12, 2012 and on March 22, 2013, the MemberRespondent mislead Credential in her responses to various questions contained in Credential’s policies and procedures prohibited its Approved Persons from using Annual Compliance Declaration. 16. In particular, the Respondent indicated in her responses that she: (a) understood that asking clients to sign pre-signed account forms.forms is prohibited; 8. Between January 25, 2011 and May 18, 2018, the Respondent obtained, possessed and (b) understood that clients must authorize all changes to signed documentation; (c) understood that white-out must not be used to process transactions, 58 alter documents; (d) had not used pre-signed account forms in relation the past year or requested clients to 17 clients.sign pre-signed account forms; and 9. The (e) did not have any pre-signed account forms included, Know-Your-Client (“KYC”) Forms, Order Entry Forms, Transfer DSC Free or Mature Units to Front End Forms.in her possession 1017. On May 23, 2018, the Member Credential detected the pre-signed forms conduct that are is the subject of this Settlement Agreement during after a compliance review Credential employee discovered a falsified document left by the Respondent on the photocopier in her branch office May 2014. Credential immediately commenced an investigation into the Respondent’s conduct, which identified the misconduct as set out above. 18. As part of its investigation, Credential reviewed of all the Respondent’s client files. 19. Credential placed the Respondent on a leave of absence of May 5, 2014. 20. On June 18, 2014, the Respondent resigned from Credential. 21. Between May and December 2014, Xxxxxxxxxx contacted all of the Respondent’s files. 11. On June 11, 2018, the Member placed the Respondent on strict supervision for a period of 6 months, issued a warning letter, and imposed a fine of $2,500 on the Respondent. 12. On September 13, 2018, the Member sent letters affected clients to all of the clients serviced by the Respondent, asking determine whether the Respondent had asked them engaged in unauthorized trading in the clients’ accounts. None of the clients reported any concerns to sign incomplete or blank account forms to conduct business. The Member received no responses to its lettersCredential. 1322. The Respondent provided Staff with the following written statement dated October 23, 2014, with respect to her misconduct: When our manager approximately 3 decade years retired in 2006 (sic), there were several changes in our Credit Union, the most notable being the transition of 4 different managers (and the 4th one has already quit). I found myself in what I can honestly say was a very difficult working condition and although I had approached our union regarding difficulties, I did not been pursue anything, instead trying to work things out. I had worked at the subject of previous MFDA disciplinary proceedingsCredit Union for 27+ years in many capacities, and only worked to serve our clients. All the irregularities above were to serve my clients, even if they were done in error. I am sorry that all that has happened…. 1423. There is no evidence that the Respondent received any benefit from her misconduct beyond the commissions or fees that she would ordinarily be entitled to receive had the transactions been carried out in a proper manner. 24. There is no evidence of client loss in this matter harm or that the Respondent received any financial benefit from engaging in the misconduct beyond the commissions or fees to which he would have been ordinarily entitled had of the transactions in the clients’ accounts been carried out in the proper mannerwere unauthorized. 1525. There have The Respondent has not previously been no client complaints in relation to the conduct described in subject of any MFDA disciplinary proceedings. 26. The Respondent cooperated with Xxxxxxxxxx’s investigation into her conduct. 27. By entering into this Settlement Agreement, and no evidence of unauthorized trading undertaken by the Respondent. 16. The Respondent has cooperated fully with Staff during saved the course of MFDA the investigationtime, resources, and by agreeing to this settlement, has avoided the necessity of expenses associated with conducting a full hearing on the merits.

AGREED FACTS Registration History. ‌ 17. Since June 20, 2006Commencing in 2005, the Respondent has been was registered in the securities industry. 8. Between May 1, 2014 and December 18, 2019 in Ontario, Quebec, and British Columbia Columbia, the Respondent was registered as a dealing representative with Global Maxfin Investments Inc.1 IPC Investment Corporation. (the “Member”), a Member of the MFDA. 29. The Respondent was terminated by the Member on December 18, 2019, and he is not presently registered in the securities industry. 10. At all material times, the Respondent carried on conducted business in the NamaimoOttawa, British Columbia Ontario area. 1 11. Between June 20December 8, 2006 2015 and September 1August 31, 20112018, while the Respondent was registered in British Columbia with Professional Investment Services (Canada) Inc. (“PIS”). On September 1, 2011, PIS amalgamated with an Approved Person of the Member. 3. Between January 5, 2015 he altered, and March 1used to process transactions, 2018, the Respondent altered 12 11 account forms in respect of 9 clients by altering information on the account forms without having the clients client initial the alterations. 4. The Respondent used liquid correction fluid to alter the account forms without the client initialing the documents to show the alteration was approved. 512. The altered account forms included Order Entry Forms included: 6 trade tickets; 4 order entry forms; and KYC Forms1 trade authorization for registered investments form. 613. The alterations made by the Respondent made to the account forms included consist of alterations to spousal/beneficiary information, to: investment instructions; fund codes, fund names ; account numbers; and amountsclient signature dates. 714. At all material times, the Member’s policies and procedures prohibited its Approved Persons from using pre-the use of pre- signed account forms. 815. Between January 25June 15, 2011 2015 and May 18February 26, 20182019, while the Respondent was an Approved Person of the Member, he obtained, possessed and and, in some instances, used to process transactions, 58 49 pre-signed account forms in relation to 17 respect of 28 clients. 916. The pre-signed account forms included, : 25 Know-Your-Client (“KYC”) Formsforms, Order Entry Forms, Transfer DSC Free or Mature Units to Front End Forms6 new account application forms (“NAAF”); 11 order entry forms; 3 trade tickets; 2 transfer application forms; and 1 pre-authorized approval contribution form. 1017. On May 23Between December 17, 20182015 and January 7, 2016, while the Respondent was an Approved Person of the Member, the Respondent photocopied an order entry form that had been signed by 2 clients and altered the form to complete 4 additional transactions. 18. In July 2019, the Member detected conducted a branch review and identified the pre-signed forms, altered forms, and re-used account forms that are the subject of this Settlement Agreement during Agreement. 19. On July 10, 2019, as a compliance review of all result of the RespondentMember’s files. 11. On June 11, 2018findings during its branch review, the Member placed suspended the Respondent until his termination on strict supervision for a period of 6 monthsDecember 18, issued a warning letter, and imposed a fine of $2,500 on the Respondent2019. 1220. On September 13, 2018In October 2019, the Member sent audit letters to all of the clients whose accounts were serviced by the Respondent. This audit letter included a two‐year transaction summary and the clients KYC information for each of their accounts, asking whether and requested the Respondent client contact the Member if they did not authorize any of the transactions or if they had asked them to sign incomplete or blank account forms to conduct businessany concerns regarding their recorded KYC information. The Member received no did not receive any client responses to its lettersthat indicated there were unauthorized transactions within any client accounts or that incorrect KYC information had been recorded. 13. The Respondent has not been the subject of previous MFDA disciplinary proceedings. 1421. There is no evidence of client loss in this matter or that the Respondent received any financial benefit from engaging in the misconduct described above beyond the any commissions or and fees to which that he would have been ordinarily be entitled to receive had the transactions in the clients’ accounts been carried out in the proper manner. 1522. There have been is no evidence of client complaints in relation to the conduct described in loss or lack of authorization. 23. By entering into this Settlement Agreement, and no evidence of unauthorized trading undertaken by the Respondent. 16. The Respondent has cooperated fully saved the MFDA the time, resources and expenses associated with Staff during the course of the investigation, and by agreeing to this settlement, has avoided the necessity of conducting a full hearing on of the meritsallegations.

AGREED FACTS Registration History. ‌ 17. Since June 20, 2006March 1998, the Respondent has been registered in British Columbia the mutual fund industry. 8. From July 2003 to June 2017, the Respondent was registered in Ontario as a dealing representative mutual fund salesperson (now known as a Dealing Representative) with Global Maxfin Investments Inc.1 Investia Financial Services Inc. (the “MemberInvestia”), a Member of the MFDA. 29. The Respondent is no longer registered in the securities industry in any capacity. 10. At all material times, the Respondent carried on conducted business in the NamaimoScarborough, British Columbia Ontario area. 1 11. Beginning on or about February 9, 2012, Investia’s policies and procedures required client initials on any material changes made to client documents. 12. Between June 20, 2006 March 2010 and September 1, 2011May 2016, the Respondent was registered in British Columbia with Professional Investment Services (Canada) Inc. (“PIS”). On September 1altered, 2011and used to process transactions, PIS amalgamated with the Member. 3. Between January 5, 2015 and March 1, 2018, the Respondent altered 12 20 account forms in respect of 9 22 clients by altering information on the account forms without having the clients client initial the alterations. 4. The Respondent used liquid correction fluid to alter the account forms without the client initialing the documents to show the alteration was approved. 513. The altered account forms included Order Entry Forms consisted of new account application, order instruction, transfer authorization, and KYC FormsKnow-Your-Client (“KYC”) update forms. 614. The alterations the Respondent made to the account forms included alterations to spousal/beneficiary informationBeginning in December 2008, fund codes, fund names and amounts. 7. At all material times, the MemberInvestia’s policies and procedures prohibited its Approved Persons from using pre-signed account forms. 815. Between January 25, 2011 July 2004 and May 18, 2018July 2016, the Respondent obtained, possessed possessed, and in some instances, used to process transactions, 58 12 pre-signed account forms in relation to 17 respect of 8 clients. 916. The pre-signed forms consisted of new account forms includedapplication, Know-Your-Client (“KYC”) Formsnew client application, Order Entry Formsorder instruction, Transfer DSC Free or Mature Units to Front End Formsoutside activity disclosure, leveraged account review, transfer authorization, and KYC update forms. 1017. On May 23In or about January 2013, 2018, Investia conducted an audit of files maintained by the Member detected the Respondent and identified 3 pre-signed forms. Investia placed the Respondent under close supervision. 18. On October 23, 2013, Investia issued a cautionary letter to the Respondent advising him that the use of pre-signed forms was prohibited and that it was his responsibility to ensure that his conduct complies with Investia’s policies and procedures. The Respondent obtained 8 of the pre- signed forms and 5 of the altered forms that are the subject of this the Settlement Agreement during a compliance review of all of in the Respondent’s files. 11. On June 11, 2018, period after Investia issued the Member placed the Respondent on strict supervision for a period of 6 months, issued a warning letter, and imposed a fine of $2,500 on cautionary letter to the Respondent. 12. On September 13, 2018, the Member sent letters to all of the clients serviced by the Respondent, asking whether the Respondent had asked them to sign incomplete or blank account forms to conduct business. The Member received no responses to its letters. 13. The Respondent has not been the subject of previous MFDA disciplinary proceedings. 14. There is no evidence of client loss in this matter or that the Respondent received any financial benefit from engaging in the misconduct beyond the commissions or fees to which he would have been ordinarily entitled had the transactions in the clients’ accounts been carried out in the proper manner. 15. There have been no client complaints in relation to the conduct described in this Settlement Agreement, and no evidence of unauthorized trading undertaken by the Respondent. 16. The Respondent has cooperated fully with Staff during the course of the investigation, and by agreeing to this settlement, has avoided the necessity of a full hearing on the merits.

AGREED FACTS Registration History. ‌ 17. Since June 20, 2006, the The Respondent has been registered in British Columbia as a mutual fund salesperson (now known as a dealing representative representative) with Global Maxfin Investments Inc.1 Quadrus Investment Services Ltd. (the “MemberQuadrus”), a Member of the MFDAMFDA1, in Newfoundland and Labrador since January 2000, and in Ontario since October 2016. 28. From October 2009 to November 2016, the Respondent was also registered in Nova Scotia as a mutual fund salesperson with Xxxxxxx. 9. At all material times, the Respondent carried on conducted business in the NamaimoSt. John’s, British Columbia Newfoundland and Labrador area. 1 Quadrus became a Member of the MFDA in March 2002. 1 Between June 20, 2006 and September 1, 2011, the Respondent was registered in British Columbia with Professional Investment Services (Canada) Inc. (“PIS”). On September 1, 2011, PIS amalgamated with the Member. 3. Between January 5, 2015 and March 1, 2018, the Respondent altered 12 account forms in respect of 9 clients by altering information on the account forms without having the clients initial the alterations. 4. The Respondent used liquid correction fluid to alter the account forms without the client initialing the documents to show the alteration was approved. 5. The altered account forms included Order Entry Forms and KYC Forms. 6. The alterations the Respondent made to the account forms included alterations to spousal/beneficiary information, fund codes, fund names and amounts. 710. At all material times, the Member’s Quadrus’ policies and procedures prohibited its Approved Persons from using pre-signed account forms. 811. Between January 25, February 2011 and May 18, 2018February 2017, the Respondent obtained, possessed possessed, and in some instances, used to process transactions, 58 29 pre-signed account forms in relation to 17 respect of 23 clients. 912. The pre-signed account forms included, Know-Your-Client (“KYC”) Forms, Order Entry Forms, Transfer DSC Free or Mature Units to Front End Formsconsisted of: • 8 transfer authorization forms; • 6 subsequent investment forms; • 5 redemption forms; • 4 Registered Education Savings Plan withdrawal forms; • 2 switch forms; • 1 loan application form; • 1 release of collateral form; • 1 Canada Revenue Agency direct transfer form; and • 1 investment application form. 1013. On May or about September 23, 20182013, the Member detected Respondent altered one transfer authorization form in respect of one client by using whiteout and pen to alter information on the form without having the client initial the alterations. 14. In May 2017, Xxxxxxx conducted a review of all of the Respondent’s client files after a client whose account was serviced by the Respondent attended at the Respondent’s branch with a pre-signed form and spoke with a Quadrus representative. During the review, Xxxxxxx identified the pre-signed and altered account forms that are the subject of this Settlement Agreement during a compliance review of all of the Respondent’s filesAgreement. 1115. On June 11May 30, 20182017, Xxxxxxx issued a disciplinary letter to the Member Respondent with respect to the conduct described above and placed the Respondent on strict under close supervision for a period of 6 months, issued a warning letter, and imposed a fine of $2,500 on the Respondentone year. 1216. On September 13In June and July 2017, 2018, the Member Xxxxxxx sent letters to all of the 199 clients serviced by the Respondent, asking Respondent to determine whether the Respondent had asked them to sign incomplete or blank account forms to conduct businessengaged in any unauthorized trading. The Member received no responses to its lettersNo clients reported concerns. 13. The Respondent has not been the subject of previous MFDA disciplinary proceedings. 1417. There is no evidence of client loss in this matter or that the Respondent received any financial benefit from engaging in the misconduct described above beyond the any commissions or and fees to which that he would have been ordinarily be entitled to receive had the transactions in the clients’ accounts been carried out in the proper manner. 1518. There have is no evidence of client loss or lack of authorization. 19. The Respondent has not previously been no client complaints in relation to the conduct described in subject of MFDA disciplinary proceedings. 20. By entering into this Settlement Agreement, and no evidence of unauthorized trading undertaken by the Respondent. 16. The Respondent has cooperated fully saved the MFDA the time, resources and expenses associated with Staff during the course of the investigation, and by agreeing to this settlement, has avoided the necessity of conducting a full hearing on of the meritsallegations.

AGREED FACTS Registration History. ‌ 17. Since June 20From November 15, 20062016 to March 12, 2019, the Respondent has been was registered in British Columbia Ontario as a dealing representative Dealing Representative with Global Maxfin Investments Inc.1 TD Investment Services Inc. (the “Member”), a Member of the MFDA. 28. At all material times, the Respondent carried on conducted business in the NamaimoLondon, British Columbia Ontario area. 1 Between June 209. On March 12, 2006 and September 1, 20112019, the Respondent was Member terminated the Respondent, and he is not currently registered in British Columbia with Professional Investment Services (Canada) Inc. (“PIS”). On September 1, 2011, PIS amalgamated with the Membersecurities industry in any capacity. 3. Between January 5, 2015 and March 1, 2018, the Respondent altered 12 account forms in respect of 9 clients by altering information on the account forms without having the clients initial the alterations. 4. The Respondent used liquid correction fluid to alter the account forms without the client initialing the documents to show the alteration was approved. 5. The altered account forms included Order Entry Forms and KYC Forms. 6. The alterations the Respondent made to the account forms included alterations to spousal/beneficiary information, fund codes, fund names and amounts. 710. At all material times, the Member’s policies and procedures prohibited its Approved Persons from using pre-signed account formssigning client signatures and initials. 811. Between January 25December 6, 2011 2018 and May 18December 10, 2018, the Respondent obtainedsigned the signatures of 2 clients on 3 account forms, possessed and used submitted them to process transactions, 58 pre-signed the Member for processing. 12. The account forms in relation to 17 clientsconsisted of Transaction and Account Maintenance forms. 913. The pre-In one instance, the Member identified a missing signature on one of the Transaction and Account Maintenance forms after the Respondent originally submitted it to the Member for processing. As part of a supervisory inquiry, the Member required the Respondent to obtain a customer signature to complete the form. In response, the Respondent reprinted a copy of the form, completed the information and signed the client’s signature on the account forms included, Know-Your-Client (“KYC”) Forms, Order Entry Forms, Transfer DSC Free or Mature Units to Front End Formsform. 1014. On May 23December 10, 2018, the Member detected conducted a Tier 2 branch review of the pre-signed Respondent’s files and identified one of the Transaction and Account Maintenance forms that is subject of this Settlement Agreement. As a result, the Member initiated a supervisory review of the Respondent’s trading activity. 15. On January 31, 2019 and February 1, 2019, the Member examined 25 client files that were maintained by the Respondent between January and December 2018 and identified the 2 remaining account forms that are the subject of this Settlement Agreement during Agreement. 16. On February 20, 2019, the Member interviewed the Respondent about the 3 account forms that are the subject of this Settlement Agreement. During this interview, the Respondent denied signing the signatures of the clients on the accounts forms, and falsely advised the Member that the clients had attended at the branch location and signed the account forms. 17. On February 26, 2019, the Member conducted a compliance review of all further interview of the Respondent’s files, at which time, the Respondent admitted to signing the clients’ signatures on the 3 account forms described above. 1118. The Member sent a letter to or left messages for the clients whose account forms are the subject matter of this Settlement Agreement requesting that the client contact the branch for an appointment to discuss their accounts and to complete new documentation. The clients did not respond to the Member’s letter. 19. On June 11March 12, 20182019, the Member placed the Respondent on strict supervision for a period of 6 months, issued a warning letter, and imposed a fine of $2,500 on terminated the Respondent’s registration. 12. On September 13, 2018, the Member sent letters to all of the clients serviced by the Respondent, asking whether the Respondent had asked them to sign incomplete or blank account forms to conduct business. The Member received no responses to its letters. 13. The Respondent has not been the subject of previous MFDA disciplinary proceedings. 1420. There is no evidence of client loss in this matter or that the Respondent received any financial benefit from engaging in the misconduct conduct set out above beyond the commissions or fees to which he would have been ordinarily be entitled to receive had the transactions in the clients’ accounts been carried out in the proper manner. 1521. There have is no evidence of client loss, complaints, or lack of authorization for the underlying transactions. 22. The Respondent has not previously been no client complaints in relation to the conduct described in subject of MFDA disciplinary proceedings. 23. By entering into this Settlement Agreement, and no evidence of unauthorized trading undertaken by the Respondent. 16. The Respondent has cooperated fully with Staff during saved the course of MFDA the investigationtime, resources, and by agreeing to this settlement, has avoided the necessity of expenses associated with conducting a full hearing on the meritsallegations. 24. The Respondent states that he has limited financial means, and as a result, he is unable to pay a monetary penalty that is greater than the total of the fine and costs amounts set out in this Settlement Agreement. MFDA Staff have received evidence which corroborates the Respondent’s statement.

AGREED FACTS Registration History. ‌ 17. Since June 20, 2006, the Respondent has been registered in British Columbia Ontario as a mutual fund salesperson (now known as a dealing representative representative)1 with Global Maxfin Investments Inc.1 WFG Securities Inc. (the “Member”), a Member of the MFDA. 28. At all material times, the Respondent carried on conducted business in the NamaimoVaughan, British Columbia Ontario area. 1 Between June 20, 2006 and September 1, 2011, the Respondent was registered in British Columbia with Professional Investment Services (Canada) Inc. (“PIS”). On September 1, 2011, PIS amalgamated with the Member. 3. Between January 5, 2015 and March 1, 2018, the Respondent altered 12 account forms in respect of 9 clients by altering information on the account forms without having the clients initial the alterations. 4. The Respondent used liquid correction fluid to alter the account forms without the client initialing the documents to show the alteration was approved. 5. The altered account forms included Order Entry Forms and KYC Forms. 6. The alterations the Respondent made to the account forms included alterations to spousal/beneficiary information, fund codes, fund names and amounts. 79. At all material times, the Member’s policies and procedures prohibited its Approved Persons from using pre-signed account formssigning a client’s name to a document. 810. Between January 252018 and September 2018, 2011 and May 18, 2018while the Respondent was an Approved Person of the Member, the Respondent signed the initials of clients on 8 trade tickets next to alterations he made to information on the trade tickets, and submitted them to the Member for processing. 11. The alterations made by the Respondent on the trade tickets included alterations to: trade instructions, client signature dates and special instructions. 12. At all material times, the Member’s policies and procedures prohibited Approved Persons from altering information on a signed document without the client initialing the document to show that the changes were approved. 13. In May 2018, while the Respondent was an Approved Person of the Member, he altered 1 account form in respect of 1 client by altering information on a trade ticket without having the client initial the alterations, and used this altered form to process a transaction. 1 In September 2009, the registration category mutual fund salesperson was changed to “dealing representative” when National Instrument 31-103 came into force. 14. The Respondent altered the trading instructions, special instructions and representative commission percentage on the trade ticket without having the client initial these alterations. 15. At all material times, the Member’s policies and procedures prohibited Approved Persons from holding an account form which was signed by a client and was blank or only partially completed. 16. Between January 2015 and October 2018, while the Respondent was an Approved Person of the Member, he obtained, possessed and used to process transactions, 58 30 pre-signed account forms in relation to 17 respect of 21 clients. 917. The pre-signed account forms includedconsisted of: 25 Trade Tickets, Know-Your-Client (“KYC”) Forms, Order Entry Forms, Transfer DSC Free or Mature Units to Front End 3 New Account Application Forms and 2 Non Financial Information Update Forms. 10. On May 23, 2018, the Member detected the pre-signed forms that are the subject of this Settlement Agreement during a compliance review of all of the Respondent’s files. 11. On June 11, 2018, the Member placed the Respondent on strict supervision for a period of 6 months, issued a warning letter, and imposed a fine of $2,500 on the Respondent. 12. On September 13, 2018, the Member sent letters to all of the clients serviced by the Respondent, asking whether the Respondent had asked them to sign incomplete or blank account forms to conduct business. The Member received no responses to its letters. 13. The Respondent has not been the subject of previous MFDA disciplinary proceedings. 14. There is no evidence of client loss in this matter or that the Respondent received any financial benefit from engaging in the misconduct beyond the commissions or fees to which he would have been ordinarily entitled had the transactions in the clients’ accounts been carried out in the proper manner. 15. There have been no client complaints in relation to the conduct described in this Settlement Agreement, and no evidence of unauthorized trading undertaken by the Respondent. 16. The Respondent has cooperated fully with Staff during the course of the investigation, and by agreeing to this settlement, has avoided the necessity of a full hearing on the merits.

AGREED FACTS Registration History. ‌ 17. Since June 20February 1989, 2006the Respondent has been registered in the mutual fund industry. 8. Since August 2010, the Respondent has been registered in Ontario as a mutual fund salesperson (now known as a dealing representative) with FundEX Investments Inc. (the “Member”), a Member of the MFDA. 9. Since August 2014, the Respondent has been registered in British Columbia as a dealing representative with Global Maxfin Investments Inc.1 (the “Member”), a Member of the MFDA. 210. At all material times, the Respondent carried on conducted business in the NamaimoStratford, British Columbia Ontario area. 1 Between June 20, 2006 and September 1, 201111. At all material times, the Respondent was registered in British Columbia with Professional Investment Services (Canada) Inc. (“PIS”). On September 1, 2011, PIS amalgamated with the MemberMember had policies and procedures that required client initials on all changes made to client documents. 312. Between January 5, 2015 April 2014 and March 1, 2018May 2016, the Respondent altered 12 and used to process transactions, 2 account forms in respect of 9 2 clients by altering information on the account forms without having the clients client initial the alterations. 4. The Respondent used liquid correction fluid to alter the account forms without the client initialing the documents to show the alteration was approved. 513. The altered account forms included consisted of Order Entry Forms and KYC Formsforms. 614. The alterations the Respondent made to alterations on the account forms included including alterations to spousal/beneficiary information, a fund codes, fund names code and amountsthe transaction type. 715. At all material times, the Member’s Member had policies and procedures that prohibited its Approved Persons from obtaining or using pre-signed account forms. 816. Between January 25, March 2011 and May 18, August 2018, the Respondent obtained, possessed possessed, and used to process transactions, 58 6 pre-signed account forms in relation to 17 respect of 5 clients. 917. The pre-signed account forms included, Know-Your-Client (“KYC”) Forms, consisted of Order Entry Forms, Transfer DSC Free or Mature Units to Front End Formsforms. 1018. In or about August 2017, the Member conducted an audit of files maintained by the Respondent and identified 5 pre-signed forms. 19. On May 23February 8, 2018, the Member detected issued a warning letter to the Respondent advising her that the use of pre-signed forms was prohibited, and on February 9, 2018, the Respondent signed a Letter of Undertaking from the Member acknowledging that she had read and understood the Member’s policies and procedures regarding pre-signed forms, and agreed that she would comply with the Member’s policies and procedures. The Respondent also acknowledged that she would comply with all applicable rules and regulations of the MFDA and provincial securities regulations in the jurisdictions in which she is registered. 20. The Respondent obtained 1 of the pre-signed forms that are is the subject of this the Settlement Agreement during a compliance review of all of in the Respondent’s files. 11. On June 11, 2018, period after the Member placed issued the warning letter to the Respondent on strict supervision for a period of 6 months, issued a warning letter, and imposed a fine of $2,500 on the Respondent. 12. On September 13, 2018, the Member sent letters to all of the clients serviced by the Respondent, asking whether after the Respondent had asked them to sign incomplete or blank account forms to conduct business. The Member received no responses to its letterssigned the Letter of Undertaking. 13. The Respondent has not been the subject of previous MFDA disciplinary proceedings. 14. There is no evidence of client loss in this matter or that the Respondent received any financial benefit from engaging in the misconduct beyond the commissions or fees to which he would have been ordinarily entitled had the transactions in the clients’ accounts been carried out in the proper manner. 15. There have been no client complaints in relation to the conduct described in this Settlement Agreement, and no evidence of unauthorized trading undertaken by the Respondent. 16. The Respondent has cooperated fully with Staff during the course of the investigation, and by agreeing to this settlement, has avoided the necessity of a full hearing on the merits.

AGREED FACTS Registration History. ‌ 17. Since June 20, 2006, the The Respondent has been was registered in British Columbia Ontario as a dealing representative mutual fund salesperson (now known as a Dealing Representative) from 2001 to 2009 and from 2010 to 2018. 8. Between April 9, 2010 and May 28, 2018, she was registered as a Dealing Representative with Global Maxfin Investments Inc.1 CIBC Securities Inc. (the “Member”), a Member of the MFDA. 29. On May 28, 2018, the Member terminated the Respondent’s registration and she is not currently registered in the securities industry in any capacity. 10. At all material times, the Respondent carried on conducted business in the NamaimoToronto, British Columbia Ontario area. 1 Between June 20, 2006 and September 1, 2011, the Respondent was registered in British Columbia with Professional Investment Services (Canada) Inc. (“PIS”). On September 1, 2011, PIS amalgamated with the Member. 3. Between January 5, 2015 and March 1, 2018, the Respondent altered 12 account forms in respect of 9 clients by altering information on the account forms without having the clients initial the alterations. 4. The Respondent used liquid correction fluid to alter the account forms without the client initialing the documents to show the alteration was approved. 5. The altered account forms included Order Entry Forms and KYC Forms. 6. The alterations the Respondent made to the account forms included alterations to spousal/beneficiary information, fund codes, fund names and amounts. 711. At all material times, the Member’s policies and procedures prohibited its Approved Persons from using pre-signed account formssigning client signatures and initials. 812. Between January 25, 2011 February 8 and May 18April 4, 2018, the Respondent obtainedsigned the signature or initials of 4 clients on 3 account forms, possessed and used submitted the forms to process transactionsthe Member for processing. 13. In one of the instances, 58 pre-the Respondent signed the initials of 2 clients on an account form, and submitted it to the Member in response to a Member supervisory inquiry. 14. The account forms in relation to 17 clientsconsisted of new account application forms and family education savings plan applications. 915. The pre-Respondent states that she signed the clients’ signatures and initials on the account forms included, Know-Your-Client (“KYC”) Forms, Order Entry Forms, Transfer DSC Free or Mature Units to Front End Formsfor the purpose of client convenience and greatly regrets her actions in this regard. 1016. On May 2314, 2018 and May 28, 2018, as part of its investigation into the Respondent’s conduct described above at paragraph 12, the Member detected interviewed the pre-Respondent. 17. During the interviews, the Respondent falsely represented to the Member that she had not signed the signature or initials of 3 of the clients on 2 account forms. 18. Between February 15, 2018 and March 1, 2018, after a Member compliance administrator identified possible signature irregularities on account forms the Respondent had submitted to the Member for processing, the Member reviewed all new accounts opened and transactions processed by the Respondent over a 6 month period. This review identified two of the account forms that are the subject of this Settlement Agreement during a compliance review of all of the Respondent’s filesAgreement. 1119. On June 11In April 2018, 2018during the course of its trade review, the Member placed identified the remaining account form after the Respondent on strict supervision submitted it for a period of 6 months, issued a warning letter, and imposed a fine of $2,500 on the Respondentprocessing. 1220. On September 13, 2018Subsequent to identifying the account forms, the Member sent letters to all met with three of the affected clients serviced by to confirm authorization of the Respondentaccount openings and to verify signatures, asking whether but was unable to meet with the Respondent had asked them to sign incomplete or blank account forms to conduct business. The Member received no responses to its lettersfourth client despite multiple requests. 13. The Respondent has not been the subject of previous MFDA disciplinary proceedings. 1421. There is no evidence of client loss in this matter or that the Respondent received any financial benefit from engaging in the misconduct conduct set out above beyond the commissions or fees she would ordinarily be entitled to which he would have been ordinarily entitled receive had the transactions in the clients’ accounts been carried out in the proper manner. 1522. There have is no evidence of client loss or lack of authorization for the underlying transactions. 23. The Respondent has not previously been no client complaints in relation to the conduct described in subject of MFDA disciplinary proceedings. 24. By entering into this Settlement Agreement, and no evidence of unauthorized trading undertaken by the Respondent. 16. The Respondent has cooperated fully with Staff during saved the course of MFDA the investigationtime, resources, and by agreeing to this settlement, has avoided the necessity of expenses associated with conducting a full hearing on the meritsallegations.