Common use of AGREED FACTS Registration History Clause in Contracts

AGREED FACTS Registration History. 6. The Respondent has been registered in the securities industry since 1988. 7. The Respondent has been registered as a mutual fund salesperson (now known as a Dealing Representative) for Worldsource Financial Management Inc. (“Worldsource”), a Member of the MFDA, in British Columbia since January 21, 1993 and in Ontario since January 13, 2005. 8. At all material times, the Respondent carried on business from the main branch located in Vancouver, British Columbia or a sub-branch office of Worldsource located New Westminster, British Columbia. 9. At all material times, Worldsource’s policies and procedures prohibited its Approved Persons from using blank or partially complete pre-signed account forms, including photocopies of pre-signed account forms, to conduct business. 10. In July 2006, Worldsource issued a caution letter to the Respondent for obtaining and maintaining pre-signed account forms. 11. Between March 2010 and May 2014, the Respondent obtained, maintained and used to process redemptions 10 pre-signed account forms in respect of three clients, as described in greater detail below: Client Name Account Form Date of Account Form Description of Form When Signed by Client Client KD Redemption Form Mar/16/2010 The investment instructions were completed after the client had signed the form. Redemption Form May/14/2010 The investment instructions were completed after the client had signed the form. Redemption Form Jan/19/2011 Partially completed form. Faxed signature. Redemption Form Mar/19/2011 Partially completed form. Faxed signature. Redemption Form Oct/20/2011 Partially completed form. Faxed signature, and the redemption instruction were completed after in ink. Redemption Form Feb/13/2014 Faxed signature. The redemption instruction was completed in ink. Redemption Form Mar/19/2014 Faxed signature. The redemption instruction was completed in ink. Client BK Redemption Form Dec/07/2013 The investment instructions were completed after the client had signed the form. Redemption Form Jan/06/2014 Imaged signature. Blank signed form. Client RD Redemption Form May/09/2014 Imaged signature. Blank signed form. 12. Worldsource detected the Respondent’s use of pre-signed account forms during an audit of the Respondent’s sub-branch in August 2014. 13. Worldsource subsequently conducted an audit of 25 of the client files maintained by the Respondent. Worldsource did not detect any further use of pre-signed account forms during its audit. 14. On August 20, 2014, the Respondent provided Staff with a written statement in which he admitted that he obtained, maintained and used pre-signed account forms, as described above in paragraph 11. The Respondent states that he engaged in these activities in order to facilitate the redemption requests made by the clients. 15. On September 17, 2014, Worldsource issued a reprimand letter to the Respondent and imposed the following terms and conditions on him: (a) a fine in the amount of $7,500; (b) a charge of $1,000 in respect of the costs of the audit; (c) an additional review of the Respondent’s sub-branch review to ensure that he was adhering to Worldsource’s policies and procedures; and (d) “close supervision” for a period of three months, which required pre-approval of all of the Respondent’s trades by Worldsource’s compliance department. 16. There is no evidence that: (a) the Respondent processed any trades or changes to client information without the knowledge or authorization of his clients; (b) clients suffered any financial harm as a result of the maintenance or use of the pre- signed account forms by the Respondent; (c) 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; and (d) any clients have complained about the Respondent’s conduct. 17. Between 2010 to 2014 the Respondent mislead Worldsource about his use of pre-signed forms when he affirmed, in Worldsource’s Annual Registration Renewal Questionnaires, that he did not “have in my possession or control any pre-signed client forms for WFM [Worldsource] related business” and that he understood “that having pre-signed forms is a violation of corporate and regulatory policies”..

AGREED FACTS Registration History. 6. The At all material times, the Respondent has been registered was the President and a shareholder of Rattenburry Financial Management Inc. (“RFM”), a Member of the MFDA located in the securities industry since 1988Edmonton, Alberta. 7. The Respondent was registered in Alberta as an Officer (Trading) of RFM from March 14, 2003, and as the Ultimate Designated Person, Chief Compliance Officer and a Director of RFM from September 28, 2009, until October 28, 2011. 8. RFM became a Member of the MFDA on February 8, 2002 and was registered in Alberta and British Columbia. RFM resigned its membership in the MFDA effective October 28, 2011. 9. Since November 1, 2011, following the resignation of RFM, the Respondent has been registered as a mutual fund salesperson (now known as a Dealing Representative) for Worldsource Financial Management Inc. (“Worldsource”)with FundEx Investments Inc., a Member of the MFDA, in British Columbia since January 21, 1993 and in Ontario since January 13, 2005. 810. At all material timesBetween November 22, the Respondent carried on business from the main branch located 2010 and December 1, 2010, MFDA Compliance Staff attended at RFM’s head office in Vancouver, British Columbia or Edmonton and a sub-branch office of Worldsource located New Westminster, British Columbia. 9. At all material times, Worldsource’s policies and procedures prohibited its Approved Persons from using blank or partially complete pre-signed account forms, including photocopies of pre-signed account forms, in Grande Prairie to conduct business. 10. In July 2006, Worldsource issued a caution letter to the Respondent for obtaining and maintaining pre-signed account formscompliance examination. 11. Between March 2010 and May 2014During the on-site examination of RFM, the Respondent obtained, maintained and used to process redemptions 10 MFDA Compliance Staff found a total of 63 pre-signed account trade instruction forms in respect the files for the accounts of three clients, as described in greater detail below: Client Name Account Form Date of Account Form Description of Form When Signed by Client Client KD Redemption Form Mar/16/2010 The investment instructions were completed after the client had signed the form. Redemption Form May/14/2010 The investment instructions were completed after the client had signed the form. Redemption Form Jan/19/2011 Partially completed form. Faxed signature. Redemption Form Mar/19/2011 Partially completed form. Faxed signature. Redemption Form Oct/20/2011 Partially completed form. Faxed signature, and the redemption instruction were completed after in ink. Redemption Form Feb/13/2014 Faxed signature. The redemption instruction was completed in ink. Redemption Form Mar/19/2014 Faxed signature. The redemption instruction was completed in ink. Client BK Redemption Form Dec/07/2013 The investment instructions were completed after the client had signed the form. Redemption Form Jan/06/2014 Imaged signature. Blank signed form. Client RD Redemption Form May/09/2014 Imaged signature. Blank signed form. 12. Worldsource detected the Respondent’s use of pre-signed account forms during an audit of the Respondent’s sub-branch in August 2014. 13. Worldsource subsequently conducted an audit of 25 of the client files maintained 10 clients serviced by the Respondent. Worldsource did not detect any further use of The pre-signed account forms during its audit. 14. On August 20, 2014, the Respondent provided Staff with a written statement in which he admitted were photocopies of original blank trade instruction forms that he obtained, maintained and used pre-had been signed account forms, as described above in paragraph 11. The Respondent states that he engaged in these activities in order to facilitate the redemption requests made by the clients. 12. The pre-signed forms consisted of Investment Order forms, which included a section to allow for the updating of a client’s Know-Your-Client (“KYC”) information, and Redemption Request forms. 13. MFDA Compliance Staff found evidence that the Respondent had used the photocopies of the pre-signed forms to execute trades in the clients’ accounts. 14. MFDA Compliance Staff also found email correspondence dated May 10, 2010 from the Respondent to clients NH and PH requesting that the clients sign blank trade instruction forms that the Respondent could use to process trades in their accounts at a later date. 15. On September 17October 12, 20142011, Worldsource issued a reprimand letter to the Respondent and imposed was interviewed by MFDA Staff Investigators. The Respondent admitted that he had used the following terms and conditions on him: (a) a fine photocopies of the blank pre-signed forms to execute trades in the amount of $7,500; (b) a charge of $1,000 in respect of the costs of the audit; (c) an additional review of the Respondent’s sub-branch review to ensure clients’ accounts. The Respondent stated that he was adhering to Worldsource’s policies and procedures; and (d) “close supervision” for a period of three months, which required pre-approval of all of the Respondent’s trades by Worldsource’s compliance departmentwere processed pursuant to the clients’ instructions following discussions with the clients. In some instances, the Respondent was able to produce copies of emails from the clients authorizing the trades in their accounts that the Respondent had subsequently carried out using the pre-signed forms. 16. There is no evidence that: (a) None of the Respondent clients have filed a complaint concerning the pre-signed forms or indicated to MFDA Staff that trades were processed any trades or changes to client information in their accounts without the their knowledge or authorization instructions. MFDA Staff did not find any evidence of his clients; (b) clients suffered any financial harm as a result of the maintenance unauthorized or use of the pre- signed account forms by the Respondent; (c) 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 discretionary trading in the clients’ accounts been carried out in the proper manner; and (d) any clients have complained about the Respondent’s conductaccounts. 17. Between 2010 to 2014 By engaging in the conduct described above, the Respondent mislead Worldsource about failed to observe high standards of ethics and conduct in the transaction of business, contrary to MFDA Rule 2.1.1(b). 18. The Respondent has not previously been subject to MFDA disciplinary proceedings. 19. The Respondent has cooperated with MFDA Staff’s investigation into his use of pre-signed forms when he affirmed, in Worldsource’s Annual Registration Renewal Questionnaires, that he did not “have in my possession or control any pre-signed client forms for WFM [Worldsource] related business” and that he understood “that having pre-signed forms is a violation of corporate and regulatory policies”..conduct.

AGREED FACTS Registration History. 6. The From December 2003 to March 2014, the Respondent has been was registered in the securities industry since 1988. 7. The Respondent has been registered British Columbia as a mutual fund salesperson (now known as a Dealing Representative) for Worldsource salesperson1 with Xxxxxxxxxx Financial Management Security Investments Inc. (“WorldsourceDesjardins”), a Member of the MFDA. 7. From December 2003 to November 6, 2012, the Respondent was also registered as a branch manager with Desjardins. He ceased to be registered as a branch manager as a result of the events described herein. 1 Now referred to as a dealing representative. 8. Prior to being registered with Desjardins, the Respondent was registered in British Columbia since January 21as a mutual fund salesperson with Hub Capital Inc. (“Hub”), 1993 and in Ontario since January 13also a Member of the MFDA, 2005from July 2002 to December 2003. 89. From July 1996 to July 2002, the Respondent was registered in British Columbia as a mutual fund salesperson with other mutual fund dealers. 10. The Respondent was terminated for cause on March 4, 2014 as a result of the events described herein. The Respondent is not currently registered in the securities industry in any capacity 11. At all material times, the Respondent carried on conducted business from the main a branch office located in Vancouver, British Columbia or a sub-branch office of Worldsource located New WestminsterSurrey, British Columbia. 9. At all material times, Worldsource’s policies and procedures prohibited its Approved Persons from using blank or partially complete pre-signed account forms, including photocopies of pre-signed account forms, to conduct business. 10. In July 2006, Worldsource issued a caution letter to the Respondent for obtaining and maintaining pre-signed account forms. 11. Between March 2010 and May 2014, the Respondent obtained, maintained and used to process redemptions 10 pre-signed account forms in respect of three clients, as described in greater detail below: Client Name Account Form Date of Account Form Description of Form When Signed by Client Client KD Redemption Form Mar/16/2010 The investment instructions were completed after the client had signed the form. Redemption Form May/14/2010 The investment instructions were completed after the client had signed the form. Redemption Form Jan/19/2011 Partially completed form. Faxed signature. Redemption Form Mar/19/2011 Partially completed form. Faxed signature. Redemption Form Oct/20/2011 Partially completed form. Faxed signature, and the redemption instruction were completed after in ink. Redemption Form Feb/13/2014 Faxed signature. The redemption instruction Respondent was completed in ink. Redemption Form Mar/19/2014 Faxed signature. The redemption instruction was completed in ink. Client BK Redemption Form Dec/07/2013 The investment instructions were completed after the client had signed branch manager of the form. Redemption Form Jan/06/2014 Imaged signature. Blank signed form. Client RD Redemption Form May/09/2014 Imaged signature. Blank signed formlocation. 12. Worldsource detected The Respondent first met AP in 1989, when AP moved into the same neighbourhood as the Respondent’s use of pre-signed account forms during an audit of the Respondent’s sub-branch in August 2014. 13. Worldsource subsequently conducted an audit of 25 At the time of the client files maintained by events giving rise to this proceeding, AP was registered in British Columbia as a mutual fund dealing representative with Networth Financial Corp. (“Networth”), also a Member of the RespondentMFDA. Worldsource did not detect any further use of pre-signed account forms during its auditOn March 28, 2012, AP’s registration with Networth was terminated. 14. On August 20In or around April 2012, 2014, XX joined the Respondent provided Staff with Respondent’s branch as a written statement non-associate life insurance agent working on a part-time basis. She worked from home and did not occupy an office in which he admitted that he obtained, maintained and used pre-signed account forms, as described above in paragraph 11. The Respondent states that he engaged in these activities in order to facilitate the redemption requests made by the clientsRespondent’s branch office. 15. On September 17July 16, 20142012, Worldsource issued a reprimand letter to XX informed the Respondent and imposed the following terms and conditions on him: (a) that she intended to join Desjardins as a fine in the amount of $7,500; (b) a charge of $1,000 in respect of the costs of the audit; (c) an additional review of the Respondent’s sub-branch review to ensure that he was adhering to Worldsource’s policies and procedures; and (d) “close supervision” for a period of three monthsmutual fund dealing representative effective September 1, which required pre-approval of all of the Respondent’s trades by Worldsource’s compliance department2012. 16. There is no evidence that: (a) AP and her family maintained investment accounts at Networth. In anticipation of AP becoming a mutual fund dealing representative at Desjardins, the Respondent processed any trades or changes and AP agreed that AP should transfer her own accounts and those of her family to client information without the knowledge or authorization of his clients; (b) clients suffered any financial harm as a result of the maintenance or use of the pre- signed account forms by the Respondent; (c) Desjardins, where the Respondent received any financial benefit from engaging would be the Approved Person assigned to the accounts until AP joined Desjardins, at which time the accounts would be re-assigned to AP 17. In fact, AP never became registered with Desjardins. 18. Between July 16, 2012 and September 5, 2012, AP completed the Desjardins account opening documents for 16 individuals (AP and fifteen of her family members) in the misconduct beyond the commissions or fees relation to which he would have been ordinarily entitled had the transactions in the clients’ accounts been carried 20 accounts, as set out in the proper manner; and chart below. The individuals were all members of AP’s family. Client(s) Documents Executed Date Executed by Client Who Met with Client Representative of Record Date Executed by Respondent AR New Account Application Form July 25, 2012 AP Respondent July 26, 2012 Dual Occupation Disclosure Portfolio Questionnaire Change of Dealer or Representative MD New Account Application Form July 18, 2012 AP Respondent July 18, 2012 Change of Dealer or Representative Portfolio Questionnaire Dual Occupation Disclosure DG New Account Application Form July 29, 2012 AP Respondent July 29, 2012 Dual Occupation Disclosure Portfolio Questionnaire Change of Dealer or Representative AP2 New Account Application Form July 16, 2012 AP Respondent July 16, 2012 Portfolio Questionnaire Change of Dealer or Representative KP(1) New Account Application Form July 18, 2012 AP Respondent July 18, 2012 Change of Dealer or Representative Portfolio Questionnaire Dual Occupation Disclosure KP(2) New Account Application Form July 18, 2012 AP Respondent July 18, 2012 Change of Dealer or Representative Dual Occupation Disclosure Portfolio Questionnaire KP(1) & KP(2) (dJoint WROS) any clients have complained about New Account Application Form July 18, 2012 AP Respondent July 18, 2012 Dual Occupation Disclosure Portfolio Questionnaire Change of Dealer or Representative 2 AP transferred her own account to the Respondent’s conduct. Member prior to transferring her family members. Client(s) Documents Executed Date Executed by Client Who Met with Client Representative of Record Date Executed by Respondent PD New Account Application Form August 15, 2012 AP Respondent August 17. Between 2010 to 2014 the , 2012 Change of Dealer or Representative Portfolio Questionnaire August 16, 2012 Dual Occupation August 17, 2012 KL New Account Application Form September 5, 2012 AP Respondent mislead Worldsource about his use September 5, 2012 Dual Occupation Disclosure Portfolio Questionnaire Change of pre-signed forms when he affirmedDealer or Representative Change of Dealer or Representative CM New Account Application Form July 25, in Worldsource’s Annual Registration Renewal Questionnaires2012 AP Respondent July 26, that he did not “have in my possession 2012 Dual Occupation Disclosure Portfolio Questionnaire Change of Dealer or control any pre-signed client forms for WFM [Worldsource] related business” and that he understood “that having pre-signed forms is a violation Representative SN New Account Application Form July 20, 2012 AP Respondent July 20, 2012 Dual Occupation Disclosure Portfolio Questionnaire Change of corporate and regulatory policies”..Dealer or Representative MP New Account Application Form July 25, 2012 AP Respondent July 26, 2012 Change of Dealer or Representative Dual Occupation Disclosure Portfolio Questionnaire MP&SR (Joint WROS) New Account Application Form July 25, 2012 AP Respondent July 26, 2012 Dual Occupation Disclosure Portfolio Questionnaire SR New Account Application Form July 25, 2012 AP Respondent July 26, 2012 Change of Dealer or Representative Dual Occupation Disclosure Portfolio Questionnaire SP & VP (Joint WROS) New Account Application Form July 19, 2012 AP Respondent July 19, 2012 Dual Occupation Disclosure Portfolio Questionnaire Change of Dealer or Representative SP & SP New Account Application Form August 17, 2012 AP Respondent August 17, 2012 Portfolio Questionnaire Change of Dealer or Representative Dual Occupation Disclosure September 14, 2012 September 14, 2012

AGREED FACTS Registration History. 6. The Respondent has been registered in Since June 25, 2004, the securities industry since 1988. 7. The Respondent has been registered as a mutual fund salesperson (now known as a Dealing Representative) for Worldsource Financial Management Inc. with Quadrus Investment Services Ltd. (“WorldsourceQuadrus”)) in the Provinces of Manitoba, Alberta, British Columbia, New Brunswick, Ontario and Saskatchewan. 7. From March 7, 2005 to June 6, 2013 when he voluntarily surrendered his registration as a Member of Branch Manager, the MFDARespondent was registered as a Branch Manager with Quadrus in Manitoba. Despite being registered as a Branch Manager, the Respondent had not acted in British Columbia that capacity since January 21, 1993 and in Ontario since January 13, 2005July 2008. 8. At all material times, the Respondent carried on conducted business from in the main branch located in VancouverWinnipeg, British Columbia or a sub-branch office of Worldsource located New Westminster, British ColumbiaManitoba area. 9. At all material timesOn March 21, Worldsource2013, Quadrus commenced a branch compliance review of the Respondent’s policies office, in accordance with its obligations pursuant to MFDA Policy No. 5. 10. During the course of the branch compliance review, Xxxxxxx reviewed 50 client files and procedures prohibited its Approved Persons from identified one blank pre-signed account form, and 20 photocopies of partially completed pre- signed account forms which the Respondent had altered after the clients had signed them in order to process transactions, in respect of eight client accounts. 11. Following the March 2013 compliance review, the Respondent advised Xxxxxxx that it was not his practice to obtain blank pre-signed account forms or to alter account forms after clients had signed them, and that he did this strictly for the convenience of the clients. 12. The Respondent acknowledged that his conduct did not comply with regulatory requirements. Effective March 25, 2013, the Respondent ceased using blank pre-signed account forms or photocopies of account forms. 13. On July 10, 2013, the Respondent’s Branch Manager reviewed an additional 50 of the Respondent’s client files and identified 29 photocopies of partially complete pre-signed account formsforms which the Respondent had altered after the clients had signed them in order to process transactions, including photocopies in respect of 9 client accounts. All of the additional forms detected in July 2013 had been used prior to the compliance review conducted in March 2013. 14. On October 23, 2013, the Respondent’s Branch Manager reviewed an additional 50 client files and identified 2 blank pre-signed account forms, and 22 photocopies of partially complete pre-signed account forms which the Respondent had altered after the clients had signed them in order to conduct businessprocess transactions, in respect of 13 client accounts. All of the additional forms detected in October 2013 had been used prior to the compliance review conducted in March 2013. 1015. In July 2006, Worldsource Xxxxxxx issued a caution disciplinary letter to the Respondent for obtaining and maintaining his use of blank pre-signed and altered account forms. Xxxxxxx also required the Respondent to complete additional training regarding the use of accounts forms. 1116. Between March 2010 May 2013 and May April 2014, Xxxxxxx sent letters to each of the Respondent obtained, maintained and used to process redemptions 10 pre-signed account forms in respect of three clients, as described in greater detail below: Client Name Account Form Date of Account Form Description of Form When Signed 30 clients affected by Client Client KD Redemption Form Mar/16/2010 The investment instructions were completed after the client had signed the form. Redemption Form May/14/2010 The investment instructions were completed after the client had signed the form. Redemption Form Jan/19/2011 Partially completed form. Faxed signature. Redemption Form Mar/19/2011 Partially completed form. Faxed signature. Redemption Form Oct/20/2011 Partially completed form. Faxed signature, and the redemption instruction were completed after in ink. Redemption Form Feb/13/2014 Faxed signature. The redemption instruction was completed in ink. Redemption Form Mar/19/2014 Faxed signature. The redemption instruction was completed in ink. Client BK Redemption Form Dec/07/2013 The investment instructions were completed after the client had signed the form. Redemption Form Jan/06/2014 Imaged signature. Blank signed form. Client RD Redemption Form May/09/2014 Imaged signature. Blank signed form. 12. Worldsource detected the Respondent’s use of pre-signed account forms during an audit conduct described above, in order to inform the clients of the Respondent’s sub-branch activities and confirm that the clients had authorized the transactions in August 2014their accounts. None of the clients reported any concerns to Quadrus with respect to transactions conducted in their accounts. 13. Worldsource subsequently conducted an audit of 25 of the client files maintained by the Respondent. Worldsource did not detect any further use of pre-signed account forms during its audit. 14. On August 20, 2014, the Respondent provided Staff with a written statement in which he admitted that he obtained, maintained and used pre-signed account forms, as described above in paragraph 11. The Respondent states that he engaged in these activities in order to facilitate the redemption requests made by the clients. 15. On September 17, 2014, Worldsource issued a reprimand letter to the Respondent and imposed the following terms and conditions on him: (a) a fine in the amount of $7,500; (b) a charge of $1,000 in respect of the costs of the audit; (c) an additional review of the Respondent’s sub-branch review to ensure that he was adhering to Worldsource’s policies and procedures; and (d) “close supervision” for a period of three months, which required pre-approval of all of the Respondent’s trades by Worldsource’s compliance department. 16. There is no evidence that: (a) that the Respondent processed any trades or changes continued to client information without the knowledge or authorization of his clients; (b) clients suffered any financial harm as a result of the maintenance obtain, maintain or use of the blank pre- signed account forms or photocopies of partially completed account forms, after March 2013. 18. No clients serviced by the Respondent;Respondent have complained about his conduct. (c) 19. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described 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; and (d) any clients have complained about the Respondent’s conduct. 1720. Between 2010 to 2014 The Respondent has expressed remorse for his actions. 21. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 22. By entering into this Settlement Agreement, the Respondent mislead Worldsource about his use has saved the MFDA the time, resources and expenses associated with conducting a full hearing of pre-signed forms when he affirmed, in Worldsource’s Annual Registration Renewal Questionnaires, that he did not “have in my possession or control any pre-signed client forms for WFM [Worldsource] related business” and that he understood “that having pre-signed forms is a violation of corporate and regulatory policies”..the allegations.

AGREED FACTS Registration History. 6. The Since 1987, the Respondent has been registered in the securities industry since 1988. 7. The Respondent has been registered Ontario as a mutual fund salesperson (now known as a Dealing Representative) for Worldsource with Xx Xxxxxx Financial Management Inc. Corp. (“WorldsourceXx Xxxxxx Financial”), a Member of the MFDA, in British Columbia since January 21, 1993 and in Ontario since January 13, 2005. 87. At all material times, the Respondent carried on business from the main operated out of a Xx Xxxxxx Financial sub-branch located in VancouverWoodbridge, British Columbia or a Ontario. PRE-SIGNED FORMS 8. On March 28-30, 2011, MFDA compliance staff conducted an on-site audit of the Xx Xxxxxx Financial sub-branch office of Worldsource located New Westminster, British Columbiafrom which the Respondent operated. 9. At all material timesDuring the audit of the sub-branch, Worldsource’s policies MFDA compliance staff found that from June 20, 2009 to May 3, 2010, the Respondent obtained and procedures prohibited its Approved Persons from using used four blank or partially completed pre- signed forms to complete transactions for two clients, as described below: GB Blank pre-signed trade form dated June 22, 2009 and a Know-Your- Client (“KYC”) form dated June 20, 2009. The client telephoned the Respondent seeking to make a trade. The Respondent faxed the client the trade form and KYC form with only the client’s name and account formsnumber completed. The Respondent directed the client to sign and fax the forms back. The client faxed the signed KYC form and trade form to the Respondent, including photocopies of prewhich the Respondent completed and used to execute the trade. MD Pre-signed account formstrade form dated May 3, 2010 and photocopy of the pre- signed trade from dated May 3, 2010. During a meeting with the client, the Respondent had the client sign a trade form with only percentage amounts of fund purchases listed. After the meeting, the Respondent completed the remainder of the form and used the form to conduct businessexecute the trade. After the Respondent finished meeting with the client, the Respondent realized there was another trade to be executed which could not fit on the trade form. The client agreed to allow the Respondent to photocopy the trade form he had signed. The Respondent used the photocopied trade form to execute the trade. 10. In July 2006Staff’s investigation did not reveal any evidence of misappropriation, Worldsource issued a caution letter to the Respondent for obtaining and maintaining pre-signed account formsunauthorized trading, client harm, or client complaints in this matter. 11. Between March 2010 and May 2014, the Respondent obtained, maintained and used to process redemptions 10 pre-signed account forms in respect of three clients, as described in greater detail below: Client Name Account Form Date of Account Form Description of Form When Signed by Client Client KD Redemption Form Mar/16/2010 The investment instructions were completed after the client had signed the form. Redemption Form May/14/2010 The investment instructions were completed after the client had signed the form. Redemption Form Jan/19/2011 Partially completed form. Faxed signature. Redemption Form Mar/19/2011 Partially completed form. Faxed signature. Redemption Form Oct/20/2011 Partially completed form. Faxed signature, and the redemption instruction were completed after in ink. Redemption Form Feb/13/2014 Faxed signature. The redemption instruction was completed in ink. Redemption Form Mar/19/2014 Faxed signature. The redemption instruction was completed in ink. Client BK Redemption Form Dec/07/2013 The investment instructions were completed after the client had signed the form. Redemption Form Jan/06/2014 Imaged signature. Blank signed form. Client RD Redemption Form May/09/2014 Imaged signature. Blank signed form. 12. Worldsource detected the RespondentStaff’s use of pre-signed account forms during an audit of the Respondent’s sub-branch in August 2014. 13. Worldsource subsequently conducted an audit of 25 of the client files maintained by the Respondent. Worldsource investigation did not detect reveal any further use of pre-signed account forms during its audit. 14. On August 20, 2014, the Respondent provided Staff with a written statement in which he admitted evidence that he obtained, maintained and used pre-signed account forms, as described above in paragraph 11. The Respondent states that he engaged in these activities in order to facilitate the redemption requests made by the clients. 15. On September 17, 2014, Worldsource issued a reprimand letter to the Respondent and imposed the following terms and conditions on him: (a) a fine in the amount of $7,500; (b) a charge of $1,000 in respect of the costs of the audit; (c) an additional review of the Respondent’s sub-branch review to ensure that he was adhering to Worldsource’s policies and procedures; and (d) “close supervision” for a period of three months, which required pre-approval of all of the Respondent’s trades by Worldsource’s compliance department. 16. There is no evidence that: (a) the Respondent processed any trades or changes to client information without the knowledge or authorization of his clients; (b) clients suffered any financial harm as a result of the maintenance or use of the pre- signed account forms by the Respondent; (c) 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; and (d) any clients have complained about the Respondent’s conduct. 1712. Between 2010 The Respondent has no prior disciplinary history with the MFDA. He has cooperated with Staff during the course of the investigation, and by agreeing to 2014 this settlement, has avoided the Respondent mislead Worldsource about his use necessity of pre-signed forms when he affirmed, in Worldsource’s Annual Registration Renewal Questionnaires, that he did not “have in my possession or control any pre-signed client forms for WFM [Worldsource] related business” and that he understood “that having pre-signed forms is the MFDA conducting a violation of corporate and regulatory policies”..full hearing on the merits.

AGREED FACTS Registration History. 6. The Since 1985, the Respondent has been registered in the securities industry since 1988. 7. The Respondent has been registered Ontario as a mutual fund salesperson (now known as a Dealing Representative) for Worldsource with Xx Xxxxxx Financial Management Inc. Corp. (“WorldsourceXx Xxxxxx Financial”), a Member of the MFDA. 7. In 1997, in British Columbia since January 21the Respondent also became registered as a branch manager with Xx Xxxxxx Financial. The Respondent did not, 1993 and in Ontario since January 13however, 2005supervise any Approved Persons. 8. At all material times, the Respondent carried on business from the main operated out of a Xx Xxxxxx Financial sub-branch located in VancouverMississauga, British Columbia or a Ontario. PRE-SIGNED FORMS 9. On March 14, 2011, MFDA compliance staff conducted an on-site audit of the Xx Xxxxxx Financial sub-branch office of Worldsource located New Westminster, British Columbia. 9. At all material times, Worldsource’s policies and procedures prohibited its Approved Persons from using blank or partially complete pre-signed account forms, including photocopies of pre-signed account forms, to conduct businesswhich the Respondent operated. 10. In July 2006During the audit of the sub-branch, Worldsource issued a caution letter MFDA compliance staff found that from October 18, 2010 to February 21, 2011, the Respondent for obtaining obtained and maintaining used six blank or partially completed pre-signed account formsforms to complete transactions for five clients, as described below: KA Switch form dated October 18, 2010. The Respondent met with the client and received instructions to process a switch in the client’s account. After meeting with the client, the Respondent realized he did not have the switch form necessary to process the client’s request. The Respondent telephoned the client, who allowed him to photocopy a switch form she had signed two days earlier. The Respondent used the photocopied switch form to execute the trade. MC Switch form dated October 19, 2010. After meeting with the client, the Respondent realized the fund code was entered improperly on a switch form. The client agreed to allow the Respondent to photocopy the switch form he had signed three days earlier and correct the fund code. The Respondent used the photocopied switch form to execute the trade. NB &MB Redemption form dated February 21, 2011. The client telephoned the Respondent and requested a redemption in his account. The client faxed the blank pre-signed redemption form, which the Respondent completed and used to process the redemption. LR & SR Redemption form dated December 21, 2010. The clients’ daughter (with power of attorney over the clients’ account) telephoned the Respondent and requested a redemption in the clients’ account. The clients’ daughter faxed a blank pre-signed redemption form (with the clients’ signatures), which the Respondent completed and used to process the redemption. TK Redemption form dated December 23, 2010. Know-Your-Client (“KYC”) form dated December 23, 2010. The client telephoned the Respondent and requested a redemption in her account. The client faxed the blank pre-signed redemption form and the partially completed KYC form to the Respondent, both of which the Respondent completed and used to process the redemption. 11. Between March 2010 and May 2014Staff’s investigation did not reveal any evidence of misappropriation, the Respondent obtainedunauthorized trading, maintained and used to process redemptions 10 pre-signed account forms client harm, or client complaints in respect of three clients, as described in greater detail below: Client Name Account Form Date of Account Form Description of Form When Signed by Client Client KD Redemption Form Mar/16/2010 The investment instructions were completed after the client had signed the form. Redemption Form May/14/2010 The investment instructions were completed after the client had signed the form. Redemption Form Jan/19/2011 Partially completed form. Faxed signature. Redemption Form Mar/19/2011 Partially completed form. Faxed signature. Redemption Form Oct/20/2011 Partially completed form. Faxed signature, and the redemption instruction were completed after in ink. Redemption Form Feb/13/2014 Faxed signature. The redemption instruction was completed in ink. Redemption Form Mar/19/2014 Faxed signature. The redemption instruction was completed in ink. Client BK Redemption Form Dec/07/2013 The investment instructions were completed after the client had signed the form. Redemption Form Jan/06/2014 Imaged signature. Blank signed form. Client RD Redemption Form May/09/2014 Imaged signature. Blank signed formthis matter. 12. Worldsource detected the RespondentStaff’s use of pre-signed account forms during an audit of the Respondent’s sub-branch in August 2014. 13. Worldsource subsequently conducted an audit of 25 of the client files maintained by the Respondent. Worldsource investigation did not detect reveal any further use of pre-signed account forms during its audit. 14. On August 20, 2014, the Respondent provided Staff with a written statement in which he admitted evidence that he obtained, maintained and used pre-signed account forms, as described above in paragraph 11. The Respondent states that he engaged in these activities in order to facilitate the redemption requests made by the clients. 15. On September 17, 2014, Worldsource issued a reprimand letter to the Respondent and imposed the following terms and conditions on him: (a) a fine in the amount of $7,500; (b) a charge of $1,000 in respect of the costs of the audit; (c) an additional review of the Respondent’s sub-branch review to ensure that he was adhering to Worldsource’s policies and procedures; and (d) “close supervision” for a period of three months, which required pre-approval of all of the Respondent’s trades by Worldsource’s compliance department. 16. There is no evidence that: (a) the Respondent processed any trades or changes to client information without the knowledge or authorization of his clients; (b) clients suffered any financial harm as a result of the maintenance or use of the pre- signed account forms by the Respondent; (c) 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; and (d) any clients have complained about the Respondent’s conduct. 1713. Between 2010 The Respondent has no prior disciplinary history with the MFDA. He has cooperated with Staff during the course of the investigation, and by agreeing to 2014 this settlement, and avoided the Respondent mislead Worldsource about his use necessity of pre-signed forms when he affirmed, in Worldsource’s Annual Registration Renewal Questionnaires, that he did not “have in my possession or control any pre-signed client forms for WFM [Worldsource] related business” and that he understood “that having pre-signed forms is the MFDA conducting a violation of corporate and regulatory policies”..full hearing on the merits.