Common use of AGREED FACTS Clause in Contracts

AGREED FACTS. 7. Since 1998, the Respondent has been registered in Ontario as a mutual fund salesperson (now known as a Dealing Representative). 8. Since 2012, the Respondent has been registered with Xxxxxxxxxx Financial Security Investment Inc. (“Desjardins”), a Member of the MFDA. 9. At all material times, the Respondent conducted business in the Scarborough, Ontario area. 10. At all material times, client IS was a client of Desjardins whose account was serviced by the Respondent. 11. On or about July 9, 2015, the Respondent submitted a letter of direction in respect of client IS’s account to Desjardins for processing that had been signed by client IS in order to process an internal transfer of funds (the “July 9 LOD”). 12. During its review of the July 9 LOD, Desjardins identified that the Respondent had failed to complete a section of the form that contained fee disclosure information. Desjardins asked the Respondent to properly complete a new letter of direction, including the fee disclosure information, and have client IS sign the new form. 13. In response to Desjardins’ request, the Respondent did not meet with client IS to complete the new form, but instead, photocopied the signature page of the July 9 LOD and completed the fee disclosure information section on this page prior to re-using the signature page by submitting it to Desjardins on or about August 24, 2015. 14. On or about February 24, 2015, the Respondent altered information on a letter of direction without having the client initial the alteration. Pre-Signed Account Forms 15. At all material times, Desjardins’ policies and procedures prohibited its Approved Persons, including the Respondent, from obtaining, possessing, and using pre-signed account forms. 16. In or around July 2015, the Respondent obtained and possessed 4 pre-signed account forms in respect of 1 client. 17. The pre-signed account forms consisted of letters of direction and know-your-client forms. 18. On or about August 24, 2015, in response to its supervisory inquiry in respect of the July 9 LOD, Desjardins identified that the Respondent had re-used client IS’s signature on the letter of direction the Respondent submitted on or about August 24, 2015. 19. As part of its investigation, Desjardins reviewed all client files serviced by the Respondent and identified the account forms that are the subject of this Settlement Agreement. 20. On November 11, 2015, Desjardins sent letters to all clients serviced by the Respondent in order to determine whether the Respondent had engaged in unauthorized trading or had clients signed pre-signed account forms. Desjardins identified no further concerns arising from client responses to these letters and no evidence of lack of authorization. 21. On January 25, 2016, Desjardins issued a warning letter to the Respondent in respect of the conduct that is the subject of this Settlement Agreement. 22. Desjardins also met with client IS, who confirmed that he authorized the transaction processed using the July 9 LOD and that the Respondent had disclosed all the required fee information at the time he signed the July 9 LOD.

AGREED FACTS. Registration History 7. Since 19981993, the Respondent has been registered in Ontario as a mutual fund salesperson (now known as a Dealing Representative). 8. Since 2012, the Respondent has been registered ) with Xxxxxxxxxx Sun Life Financial Security Investment Services (Canada) Inc. (“Desjardins”)Sun Life”)1, a Member of the MFDA. 98. At all material times, the Respondent conducted business in the ScarboroughNiagara Falls, Ontario area. 109. At all material times, the Respondent operated his business employing of one or more assistants. From February 2008 onwards, at least one of the assistants was registered in Ontario as a mutual fund salesperson. 10. The Respondent was responsible for ensuring that any work he delegated to the assistants, including completing account forms with client IS information, which the assistants then submitted to Sun Life for processing, was a client of Desjardins whose account was serviced by compliant with Sun Life and the RespondentMFDA’s policies, procedures, rules, and directions. 11. On or about July 9, Between August 2004 and March 2015, the Respondent submitted a letter of direction Respondent, or his assistants, for whom he was responsible, altered, and in respect of client IS’s account to Desjardins for processing that had been signed by client IS in order some instances, used to process an internal transfer of funds (transactions, 145 account forms by altering information on the “July 9 LOD”)account forms without obtaining client initials authorizing the changes. 12. During its review of the July 9 LODThe altered forms included Pre-Authorized Contribution forms, Desjardins identified that the Respondent had failed to complete a section of the form that contained fee disclosure information. Desjardins asked the Respondent to properly complete a new letter of direction, including the fee disclosure informationOrder forms, and have client IS sign the new formNew Account Application forms. 1 In 2002, Sun Life merged with Xxxxxxx Xxxxxxxx Inc. (“Clarica”). Clarica changed its name from Mutual Investco Inc. in 1999. 13. In response to Desjardins’ requestthe instances where one of the Respondent’s assistants altered the account forms, the Respondent did not meet with client IS knew or ought to complete have known that the new form, but instead, photocopied the signature page of the July 9 LOD and completed the fee disclosure information section on this page prior to re-using the signature page by submitting it to Desjardins on or about August 24, 2015account forms were altered. 14. On or about February 24, Between August 2004 and March 2015, the Respondent altered information on a letter of direction without having the client initial the alteration. Pre-Signed Account Forms 15. At all material times, Desjardins’ policies and procedures prohibited its Approved Persons, including the Respondent, from obtainingor his assistants, possessingfor whom he was responsible, obtained, possessed, and using in some instances, used to process transactions, 246 pre-signed account forms. 15. The Pre-Signed Account Forms included Pre-Authorized Contribution forms, Order forms, and New Account Application forms. 16. In or around July 2015, the Respondent instances where one of the Respondent’s assistants obtained and possessed 4 the pre-signed account forms, the Respondent knew or ought to have known that the account forms in respect of 1 clientwere pre-signed. 17. The preSun Life’s compliance staff detected the conduct that is the subject of this Settlement Agreement during a branch audit on December 3, 2014 and subsequent follow-signed account forms consisted of letters of direction and know-your-client formsup investigation. 18. On or about August 24, 2015, in response to its supervisory inquiry in respect of Sun Life identified the July 9 LOD, Desjardins identified that conduct involving the Respondent had re-used forms described above across 201 client IS’s signature on the letter of direction the Respondent submitted on or about August 24, 2015files. 19. As part of its investigation, Desjardins reviewed all client files serviced by the Respondent and identified the account forms that are the subject of this Settlement Agreement. 20. On November 11, 2015, Desjardins Sun Life sent letters to all clients serviced by the Respondent in order to determine whether the Respondent had engaged in any unauthorized trading or had clients signed pre-signed account formstrading. Desjardins identified no further concerns arising from client responses to these letters and There is no evidence of lack any client concerns in response to these letters. 20. On June 3, 2015, Sun Life placed the Respondent under close supervision for a period of authorizationsix months. 21. On January 25At Sun Life’s requirement, the Respondent also: a) successfully completed the Conduct and Practices Handbook course offered by the Canadian Securities Institute; b) transferred a substantial portion of his book of business to other Sun Life Advisors; c) transitioned to the role of Sales Associate Advisor (an Sales Associate Advisor works for, and under the supervision of, another Dealing Representative); and d) will resign from his position at Sun Life effective September 1, 2016, Desjardins issued a warning letter to the Respondent in respect of the conduct that is the subject of this Settlement Agreement. 22. Desjardins also met with client IS, who confirmed that he authorized the transaction processed using the July 9 LOD and that the Respondent had disclosed all the required fee information at the time he signed the July 9 LOD.

AGREED FACTS. 7. Since 1998From January 8, 2015 to April 29, 2019, the Respondent has been was registered in Ontario as a mutual fund salesperson Dealing Representative with Sun Life Financial Investment Services (now known as a Dealing Representative). 8. Since 2012, the Respondent has been registered with Xxxxxxxxxx Financial Security Investment Canada) Inc. (the “DesjardinsMember”), 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 ScarboroughOakville, Ontario area. 10. At all material times, client IS was a client of Desjardins whose account was serviced by the Respondent. 11. On or about July 9, 2015, the Respondent submitted a letter of direction in respect of client ISMember’s account to Desjardins for processing that had been signed by client IS in order to process an internal transfer of funds (the “July 9 LOD”). 12. During its review of the July 9 LOD, Desjardins identified that the Respondent had failed to complete a section of the form that contained fee disclosure information. Desjardins asked the Respondent to properly complete a new letter of direction, including the fee disclosure information, and have client IS sign the new form. 13. In response to Desjardins’ request, the Respondent did not meet with client IS to complete the new form, but instead, photocopied the signature page of the July 9 LOD and completed the fee disclosure information section on this page prior to re-using the signature page by submitting it to Desjardins on or about August 24, 2015. 14. On or about February 24, 2015, the Respondent altered information on a letter of direction without having the client initial the alteration. Pre-Signed Account Forms 15. At all material times, Desjardins’ policies and procedures prohibited its Approved Persons, including the Respondent, Persons from obtaining, possessing, and using obtaining pre-signed account blank forms. The Member’s Approved Persons were only permitted to use a form after it had been duly executed by a client and after the information on the form has been properly completed. 1611. In or around July 2015Between December 10, 2015 and November 8, 2018, the Respondent obtained obtained, possessed, and possessed 4 used to process transactions, 9 pre-signed account forms in respect of 1 client6 clients. 1712. The pre-signed account forms consisted of letters a Know Your Client (“KYC”) form; a Tax Free Savings Account (“TFSA”) Application form; Pre-Authorized Account Contribution (“PAC”) forms; a transfer authorization form and a Locked-In Retirement Account or Life Income Fund transfer form. 13. Between September 9, 2015 and October 28, 2018, the Respondent altered and used to process transactions, 43 account forms in respect of direction 20 clients, by altering information on the account forms without having the client initial the alterations. 14. The altered account forms consisted of Registered Education Savings Plan Application forms; fund company investment application forms; direct transfer and know-your-client transfer authorization forms; KYC forms; a New Client Application Form; TFSA Application forms; a PAC form and a Limited Trading Authorization (“LTA”) form. In some instances, the Respondent used liquid correction fluid to alter information on the account forms. 1815. On or about August The Respondent altered information on the account forms such as account numbers; receiving institution information; investment instructions; fund codes and names; KYC information; beneficiary designations; purchase start and payment dates; purchase instructions and the client name on an LTA. 16. Between December 4, 2018 and January 24, 20152019, in response to its supervisory inquiry in respect the Member conducted a full review of the July 9 LOD, Desjardins identified that the Respondent had re-used client IS’s signature on the letter of direction the Respondent submitted on or about August 24, 2015. 19. As part of its investigation, Desjardins reviewed all client files serviced maintained by the Respondent and identified the account forms that are the subject of this Settlement Agreement. 17. On December 14, 2018, the Member imposed a program of close supervision on the Respondent. 18. On January 28, 2019, the Member imposed a program of enhanced supervision on the Respondent. 19. On February 27, 2019, the Respondent commenced a leave of absence and the completion of a close and enhanced supervision program on the Respondent was deferred. 20. On November 11March 6, 20152019, Desjardins sent letters the Member wrote to all clients whose accounts were serviced by the Respondent Respondent. The letter requested that clients review their KYC information and confirm their authorization for transactions in order to determine whether their accounts that occurred during the Respondent had engaged in unauthorized trading or had material time. None of the responses received by the clients signed pre-signed account forms. Desjardins identified no further concerns arising from client responses to these letters and no evidence of lack of authorizationraised any concerns. 21. On January 25April 29, 20162019, Desjardins issued a warning letter to the Respondent in respect of resigned from the conduct that is the subject of this Settlement AgreementMember. 22. Desjardins also met with client IS, who confirmed that he authorized the transaction processed using the July 9 LOD and There is no evidence that the Respondent received any financial benefit from the misconduct described above beyond the commissions or fees she would ordinarily be entitled to receive had disclosed all the required fee information at transactions been carried out in the time he signed proper manner. 23. There is no evidence of client complaints, client loss or lack of authorization for the July 9 LODunderlying transactions. 24. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 25. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources, and expenses associated with conducting a full hearing on the allegations. 26. The Respondent states that she has limited financial means, and as a result, she 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 7. Since 1998September 2009, the Respondent has been registered in Ontario as a mutual fund salesperson (now known as a Dealing Representative). 8. Since 2012, the Respondent has been registered ) with Xxxxxxxxxx Investia Financial Security Investment Services Inc. (“DesjardinsInvestia”), a Member of the MFDA. 98. At all material times, the Respondent conducted business in the ScarboroughToronto, Ontario area. 9. Beginning in November 2013, Investia’s policies and procedures required that where any material changes are made to a client’s trade documents, they must be initialed by the client. 10. Between December 2009 and February 2017, the Respondent falsified, and used to process transactions, 22 account forms in respect of 17 clients by altering information on the account forms without having the client initial the alterations. 11. The falsified account forms consisted of new account application, order instruction, transfer authorization, systematic instruction, and Know-Your-Client update forms. 12. At all material times, client IS was a client of Desjardins whose account was serviced by the Respondent. 11. On or about July 9, 2015, the Respondent submitted a letter of direction in respect of client ISInvestia’s account to Desjardins for processing that had been signed by client IS in order to process an internal transfer of funds (the “July 9 LOD”). 12. During its review of the July 9 LOD, Desjardins identified that the Respondent had failed to complete a section of the form that contained fee disclosure information. Desjardins asked the Respondent to properly complete a new letter of direction, including the fee disclosure information, and have client IS sign the new form. 13. In response to Desjardins’ request, the Respondent did not meet with client IS to complete the new form, but instead, photocopied the signature page of the July 9 LOD and completed the fee disclosure information section on this page prior to re-using the signature page by submitting it to Desjardins on or about August 24, 2015. 14. On or about February 24, 2015, the Respondent altered information on a letter of direction without having the client initial the alteration. Pre-Signed Account Forms 15. At all material times, Desjardins’ policies and procedures prohibited its Approved Persons, including the Respondent, Persons from obtaining, possessing, and using pre-signed account forms. 1613. In or around July 2015Between March 2009 and December 2016, the Respondent obtained obtained, possessed, and possessed 4 used to process transactions, 7 pre-signed account forms in respect of 1 client6 clients. 1714. The pre-signed account forms consisted of letters of direction new account application, order instruction, and know-your-client systematic instruction forms. 1815. On or about August 24March 14, 20152017, in response to its supervisory inquiry in respect of the July 9 LOD, Desjardins identified that the Respondent had re-used client ISInvestia’s signature on the letter of direction the Respondent submitted on or about August 24, 2015. 19. As part of its investigation, Desjardins reviewed all client files serviced by the Respondent and compliance staff identified the account falsified and pre-signed forms that are the subject of this Settlement AgreementAgreement as a result of a routine branch audit. 2016. On November 11As part of its investigation, 2015, Desjardins Investia conducted a review of all of the client files serviced by the Respondent and sent letters to all of the clients who are current serviced by the Respondent in order to determine whether the Respondent had engaged in any unauthorized trading trading. No clients reported any concerns. 17. On May 24, 2017, Investia placed the Respondent under strict supervision. 18. On January 16, 2018, Investia issued a warning letter to the Respondent. 19. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above other than the commissions or fees he would ordinarily be entitled to had clients signed pre-signed account formsthe transactions been completed in the proper manner. 20. Desjardins identified no further concerns arising from client responses to these letters and There is no evidence of client loss or lack of authorization. 21. On January 25, 2016, Desjardins issued a warning letter to the The Respondent in respect of the conduct that is has not previously been the subject of this Settlement AgreementMFDA disciplinary proceedings. 22. Desjardins also met with client ISBy entering into this Settlement Agreement, who confirmed that he authorized the transaction processed using the July 9 LOD and that the Respondent had disclosed all has saved the required fee information at MFDA the time he signed time, resources, and expenses associated with conducting a full hearing on the July 9 LODallegations.

AGREED FACTS. 76. Since 1998, the The Respondent has been registered in Ontario as a mutual fund salesperson with Investors Group Financial Services Inc. (now known as “Investors Group”) since January 2002. The Respondent has been a Dealing Representative)mutual fund salesperson since January 1996. 7. On June 12, 2011, the Respondent met with clients KM and PM for the purposes of opening a joint non-registered account and a registered account for KM. 8. Since 2012On June 14, 2011, the Respondent has been registered with Xxxxxxxxxx Financial Security Investment Inc. Client Service Administrator (“DesjardinsCSA”), a Member of ) for Investors Group advised the MFDARespondent that the clients’ applications could not be processed for the following reasons: a. The checkbox labeled “retirement savings” had been checked in error in the “non- registered” section under Investment Information in the Account Opening Form for KM; and b. The investment time horizon did not match the low risk tolerance in the joint Investors Group MRS Account Opening Form for KM and PM. 9. At all material times, The CSA advised the Respondent conducted business in that the Scarborough, Ontario areaapplications would need to be corrected and the corrections would require the initials of clients KM and PM. 10. At all material times, client IS was a client of Desjardins whose account was serviced by The Respondent made the Respondentfollowing changes to the new application forms: a. Crossed out the checkbox labeled “retirement savings” in an Account Opening Form for KM and wrote initials which purported to be KM’s initials approving the change; and b. Crossed out the checkbox for “low” risk and checked off “medium” risk in the joint Investors Group MRS Account Opening Form for KM and PM and wrote initials which purported to be KM’s and PM’s initials approving the change. 11. On or about July 9, 2015Several minutes later, the Respondent submitted a letter of direction in respect of client IS’s returned the account application forms to Desjardins for processing that had been signed by client IS in order to process an internal transfer of funds (the “July 9 LOD”)CSA. 12. During its review of the July 9 LOD, Desjardins identified that The CSA was concerned with how quickly the Respondent had failed was able to complete a section of obtain the form that contained fee disclosure informationclients’ initials approving the changes and reported the matter to the Regional Coordinator for Investors Group. Desjardins asked Shortly thereafter, Investors Group commenced an investigation into the Respondent to properly complete a new letter of direction, including the fee disclosure information, and have client IS sign the new formmatter. 13. In response The Respondent admitted to DesjardinsInvestors Group that he had made the changes to the account application forms and had falsified the initials of clients KM and PM. The Respondent advised that he had done so as a matter of convenience to the clients and that he had contacted KM and PM via telephone to tell them that he had initialed the documents on their behalf. The falsified initials gave effect to the clients’ request, intentions with respect to the Respondent did not meet with client IS to complete the new form, but instead, photocopied the signature page of the July 9 LOD and completed the fee disclosure information section on this page prior to re-using the signature page by submitting it to Desjardins on or about August 24, 2015accounts. 14. On or about February 24June 20, 20152011, the Respondent altered information on a letter of direction without having met with clients KM and PM to show the client initial clients the alteration. Pre-Signed Account Forms 15. At all material times, Desjardins’ policies modified account application forms and procedures prohibited its Approved Personsthe changes that he had made to them, including the Respondent, from obtaining, possessing, initials that he had made which purported to be the initials for KM and using pre-signed account formsPM. 16. In or around July 2015, the Respondent obtained and possessed 4 pre-signed account forms in respect of 1 client. 17. The pre-signed account forms consisted of letters of direction and know-your-client forms. 18. On or about August 24, 2015, in response to its supervisory inquiry in respect of the July 9 LOD, Desjardins identified that the Respondent had re-used client IS’s signature on the letter of direction the Respondent submitted on or about August 24, 2015. 19. As part of its investigation, Desjardins reviewed all client files serviced by the Respondent and identified the account forms that are the subject of this Settlement Agreement. 20. On November 11, 2015, Desjardins sent letters to all clients serviced by the Respondent in order to determine whether the Respondent had engaged in unauthorized trading or had clients signed pre-signed account forms. Desjardins identified no further concerns arising from client responses to these letters and no evidence of lack of authorization. 21. On January 25, 2016, Desjardins issued a warning letter to the Respondent in respect of the conduct that is the subject of this Settlement Agreement. 22. Desjardins also met with client IS, who confirmed that he authorized the transaction processed using the July 9 LOD and that the Respondent had disclosed all the required fee information at the time he signed the July 9 LOD.V. CONTRAVENTIONS

AGREED FACTS. 76. Since 1998, the The Respondent has been was registered in Ontario New Brunswick as a mutual fund salesperson with Investia Financial Services Inc. (now known “Investia”) from August 20, 2004 until his resignation on August 19, 2008. During the period of registration, the Respondent had 1 client and completed only 1 transaction. 7. The Respondent is a co-owner (along with three other individuals) of a fishing camp called The Ledges Fishing Corp. (“The Ledges”). The Ledges is a company incorporated pursuant to the laws of New Brunswick. The Respondent is listed on corporate documents of The Ledges as a Dealing Representative)its Vice-President. 8. Since 2012On March 31, 2006, the Respondent has been registered with Xxxxxxxxxx Financial Security Investment Inc. (“Desjardins”), became a Member Director of the MFDAThe Ledges. 9. At all material timesOn May 11, 2006, the Respondent conducted business in completed and submitted Investia’s “Annual Review of Professional Activities” form. The Respondent did not disclose on the Scarborough, Ontario areaform his status as a co-owner of The Ledges and his position as Vice-President and Director of The Ledges. 10. At all material timesShortly thereafter, client IS The Ledges offered for sale 18 preferred shares priced at $150,000 CDN per share. The preferred shares were offered for sale pursuant to an exemption from prospectus and registration requirements of the New Brunswick Securities Act. Ownership of a preferred share entitled the shareholder to specified fishing rights at The Ledges. 11. Between February 2007 and August 2007, The Ledges sold 13 of the 18 preferred shares. Twelve of the preferred shares were purchased by members of the public. The thirteenth share was purchased by another co-owner of The Ledges, Xxxxx X. Xxxxx, the Respondent’s father. None of the investors was a client of Desjardins whose account Investia. A total of $1,950,000 was serviced by raised through the Respondent. 11sale of the preferred shares. On or about July 9, 2015As far as the MFDA is aware, the Respondent submitted a letter of direction in respect of client IS’s account remaining five preferred shares have yet to Desjardins for processing that had been signed by client IS in order to process an internal transfer of funds (the “July 9 LOD”)be sold. 12. During its review The Respondent, in his capacity as Vice-President and a Director of The Ledges, was involved in explaining the details and terms of the July 9 LODpreferred share offering to prospective investors. Thereafter, Desjardins identified that individuals who expressed interest in purchasing a preferred share were directed to counsel for The Ledges, which handled the Respondent had failed to complete a section preparation and execution of the form that contained fee disclosure information. Desjardins asked legal documentation associated with the Respondent to properly complete a new letter of direction, including the fee disclosure information, and have client IS sign the new formpurchase. 13. In response addition to Desjardins’ requestmeeting with prospective investors, the Respondent did not meet with client IS to complete the new formRespondent, in his capacity as Vice-President and a Director of The Ledges, signed, on behalf of The Ledges, all but instead, photocopied the signature page one of the July 9 LOD and Subscription Agreements or Buy-Sell agreements completed by the fee disclosure information section on this page prior to re-using the signature page by submitting it to Desjardins on or about August 24, 2015investors. 14. On or about February 24The preferred shares were offered for sale pursuant to exemptions from the prospectus and registration requirements of the New Brunswick Securities Act and, 2015as such, the Respondent altered information distribution of the preferred shares was required to be reported by The Ledges to the New Brunswick Securities Commission (“NBSC”). The Respondent, on a letter behalf of direction without having The Ledges, signed the client initial requisite Exempt Distribution Form (Form 45-106F1) filed with the alteration. Pre-Signed Account FormsNBSC in respect of the distribution of the preferred shares. 15. At all material timesUpon receipt of the Form 45-106F1 filed by The Ledges with the NBSC, Desjardins’ policies and procedures prohibited its Approved PersonsNBSC Staff contacted Investia by letter dated May 28, including 2007 to advise Investia of the involvement of the Respondent in the distribution of the preferred shares. Prior to receiving this notification from NBSC Staff, Investia was aware of the Respondent’s status as a co-owner of The Ledges, from obtaining, possessing, but was not aware of his position as Vice-President and using pre-signed account formsDirector and his involvement in the sale of the preferred shares. 16. In or around July 2015On October 9, 2007, the Respondent obtained completed and possessed 4 pre-signed account forms in respect of 1 client. 17. The pre-signed account forms consisted of letters of direction and know-your-client forms. 18submitted an Investia “Outside Business Activity Approval Form”. On or about August 24the form, 2015, in response the Respondent disclosed his position as Vice-President of The Ledges but did not disclose the fact that The Ledges had sold preferred shares to its supervisory inquiry in respect members of the July 9 LOD, Desjardins identified that public or the Respondent had re-used client IS’s signature on nature and extent of his involvement in the letter of direction the Respondent submitted on or about August 24, 2015. 19. As part of its investigation, Desjardins reviewed all client files serviced by the Respondent and identified the account forms that are the subject of this Settlement Agreement. 20. On November 11, 2015, Desjardins sent letters to all clients serviced by the Respondent in order to determine whether the Respondent had engaged in unauthorized trading or had clients signed pre-signed account forms. Desjardins identified no further concerns arising from client responses to these letters and no evidence of lack of authorization. 21. On January 25, 2016, Desjardins issued a warning letter to the Respondent in respect sale of the conduct that is the subject of this Settlement Agreementpreferred shares. 22. Desjardins also met with client IS, who confirmed that he authorized the transaction processed using the July 9 LOD and that the Respondent had disclosed all the required fee information at the time he signed the July 9 LOD.