Common use of JOINT SETTLEMENT RECOMMENDATION Clause in Contracts

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 and January 2017, the Respondent obtained, possessed and, in some instances, used to process transactions, 36 pre-signed account forms in respect of 10 clients, contrary to MFDA Rule 2.1.1; and b) between September 2010 and January 2017, the Respondent, in his capacity as branch manager, reviewed and approved the use of 36 pre-signed account forms, contrary to MFDA Rules 2.5.5(f)1 and 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine in the amount of $12,500 upon acceptance of the Settlement Agreement (the “Fine”), pursuant to s. 24.1.1(b) of MFDA By-law No. 1; b) the Respondent shall be prohibited from acting as a branch manager for a period of 6 months, commencing the date of the order of the Hearing Panel accepting the Settlement Agreement pursuant s. 24.1.1(e) of MFDA By-law No. 1; c) the Respondent shall pay costs in the amount of $2,500 upon acceptance of the Settlement Agreement (“Costs”), pursuant to s. 24.2 of MFDA By-law No. 1; d) the Respondent’s payment of the Fine and Costs shall be made in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5; and f) the Respondent will attend in person, on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 February 2006 and January 2017May 2016, the Respondent engaged in securities related business beyond the terms of her registration as a mutual fund salesperson by providing investment advice to at least 11 clients in respect of non-mutual fund securities, contrary to the Member’s policies and procedures, and MFDA Rules 1.1.1, 1.1.2, 1.1.5(a) and 2.1.1; b) in February 2016, the Respondent altered, and used to process transactions, 2 account forms in respect of 3 clients by altering information on the account forms without having the client initial the alterations, contrary to MFDA Rule 2.1.1; and c) between November 2008 and February 2016, the Respondent obtained, possessed andpossessed, and in some instances, used to process transactions, 36 17 pre-signed account forms in respect of 10 12 clients, contrary to MFDA Rule 2.1.1; and b) between September 2010 and January 2017, the Respondent, in his capacity as branch manager, reviewed and approved the use of 36 pre-signed account forms, contrary to MFDA Rules 2.5.5(f)1 and 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall be suspended for a period of 1 month from conducting securities related business in any capacity while in the employ of or associated with a Member of the MFDA commencing from the date of the Hearing Panel’s final Order herein, pursuant to s. 24.1.1(c) of MFDA By-law No.1; b) the Respondent shall pay a fine in the amount of $12,500 15,000 in certified funds upon acceptance of the this Settlement Agreement (the “Fine”)Agreement, pursuant to s. section 24.1.1(b) of MFDA By-law No. 1; b) the Respondent shall be prohibited from acting as a branch manager for a period of 6 months, commencing the date of the order of the Hearing Panel accepting the Settlement Agreement pursuant s. 24.1.1(e) of MFDA By-law No. 1; c) the Respondent shall pay costs in the amount of $2,500 in certified funds upon acceptance of the this Settlement Agreement (“Costs”)Agreement, pursuant to s. section 24.2 of MFDA By-law No. 1; d) the Respondent’s payment of the Fine and Costs shall be made in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the Respondent shall in the future comply with MFDA Rules 2.1.1 1.1.1, 1.1.2, 1.1.5(a), and 2.5.52.1.1; and fe) the Respondent will attend in person, person on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 Between August 2013 and January 2017August 2018, the Respondent obtained, possessed andpossessed, and in some instances, used to process transactions, 36 9 pre-signed account forms in respect of 10 3 clients, contrary to MFDA Rule 2.1.1; and b) between September 2010 and January 2017, the Respondent, in his capacity as branch manager, reviewed and approved the use of 36 pre-signed account forms, contrary to MFDA Rules 2.5.5(f)1 and 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine in the amount of $12,500 7,000 in certified funds upon acceptance of the Settlement Agreement (the “Fine”)Agreement, pursuant to s. 24.1.1(b) of MFDA By-law No. 1No.1; b) the Respondent shall be prohibited from acting as a branch manager or in a supervisory role with a Member of the MFDA for a period of 6 months, commencing the date of the order of the Hearing Panel accepting the Settlement Agreement pursuant to s. 24.1.1(e) of MFDA By-law No. 1No.1; c) prior to acting as a branch manager or in a supervisory role in the future, the Respondent shall pay costs in successfully complete a branch manager’s course offered by the amount Canadian Securities Institute or the Investment Funds Institute of $2,500 upon acceptance of the Settlement Agreement (“Costs”)Canada, pursuant to s. 24.2 24.1.1(f) of MFDA By-law No. 1; d) the Respondent’s payment Respondent shall pay costs in the amount of the Fine and Costs shall be made $2,500 in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing PanelAgreement, pursuant to s. 24.2 of MFDA By-law No.1; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and f) the Respondent will attend in person, person (via videoconference) on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A” 7. Commencing in 1996, the Respondent was registered in the securities industry. 8. Between May 2004 and October 1, 2018, the Respondent was registered in Ontario as a mutual fund salesperson (now known as a dealing representative) with Global Maxfin Investments Inc. (the “Member”), a Member of the MFDA. 9. In May 2004 the Member designated the Respondent as a branch manager. 10. In October 2016, the Respondent ceased acting as a branch manager. 11. On October 1, 2018, the Respondent resigned, and he is not currently registered in the securities industry in any capacity. 12. At all material times, the Respondent conducted business in the Mississauga, Ontario area.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 December 6, 2018 and January 2017December 10, 2018, the Respondent obtainedsigned the signature of 2 clients on 3 account forms, possessed and, in some instances, used to process transactions, 36 pre-signed and submitted the account forms in respect of 10 clientsto the Member for processing, contrary to MFDA Rule 2.1.1; and b) between September 2010 February 20, 2019 and January 2017February 26, 2019, the RespondentRespondent misled the Member during its investigation into his conduct when he falsely stated that clients signed account forms, in his capacity as branch manager, reviewed and approved when the use of 36 pre-Respondent had signed the client’s signature on the account forms, contrary to MFDA Rules 2.5.5(f)1 and Rule 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine in the amount of $12,500 2,500 in certified funds upon acceptance of the Settlement Agreement (the “Fine”)Agreement, pursuant to s. 24.1.1(b) of MFDA By-law No. 1No.1; b) the Respondent shall be prohibited from acting as a branch manager for a period of 6 months, commencing the date of the order of the Hearing Panel accepting the Settlement Agreement pursuant s. 24.1.1(e) of MFDA By-law No. 1; c) the Respondent shall pay costs in the amount of $2,500 in certified funds upon acceptance of the Settlement Agreement (“Costs”)by the Hearing Panel, pursuant to s. 24.2 of MFDA By-law No.1; c) the Respondent shall be prohibited from conducting securities related business in any capacity while in the employ of or associated with a Member of the MFDA for a period of 6 months, commencing from the date the Settlement Agreement is accepted by the Hearing Panel, pursuant to s. 24.1.1(e) of MFDA By-Law No. 1; d) the Respondent’s payment of the Fine and Costs shall be made in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and fe) the Respondent will attend in person, person or by videoconference on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 Between December 2016 and January 2017, the Respondent obtainedmisappropriated $1,300 by directing the proceeds of redemptions from a joint account that he and his former spouse had opened for the benefit of their children to the Respondent’s personal bank account without the knowledge or authorization of his former spouse, possessed andthereby failing to deal fairly, honestly and in some instancesgood faith with the client, used and engaging in business conduct which is unbecoming and detrimental to process transactions, 36 pre-signed account forms in respect of 10 clientsthe public interest, contrary to MFDA Rule 2.1.1; and b) between September 2010 and January 2017In December 2016, the Respondent, in his capacity as branch manager, reviewed Respondent signed client YM’s signatures and approved initials on two trade forms without the use knowledge or authorization of 36 pre-signed account formsclient YM, contrary to the policies and procedures of the Member and MFDA Rules 2.5.5(f)1 2.1.1, 2.10 and 2.1.11.1.2. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the The Respondent shall pay a fine costs in the amount of $12,500 2,500 in certified funds upon acceptance of the Settlement Agreement (Agreement, pursuant to section 24.2 of By-law No. 1; b) The Respondent shall be prohibited from conducting securities related business in any capacity while in the “Fine”), employ of or associated with a MFDA Member for a period of 2 years pursuant to s. 24.1.1(b) of MFDA By-law No. 1; b) the Respondent shall be prohibited from acting as a branch manager for a period of 6 months, commencing the date of the order of the Hearing Panel accepting the Settlement Agreement pursuant s. 24.1.1(e) of MFDA By-law No. 1; c) the Respondent shall pay costs in the amount of $2,500 upon acceptance of the Settlement Agreement (“Costs”), pursuant to s. 24.2 of MFDA By-law No. 1; d) the Respondent’s payment of the Fine and Costs shall be made in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the The Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and fd) the The Respondent will attend the Settlement Hearing in person, on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 April 2018 and January 20172019, the Respondent obtained, possessed signed the signature or initials of 16 clients on 38 account forms and, in some instances, used submitted the forms to process transactionsthe Member for processing, 36 pre-contrary to MFDA Rule 2.1.1; b) between April 2018 and January 2019, the Respondent signed the signature of another Approved Person on 3 account forms in respect of 10 clients2 clients and submitted the forms to the Member for processing, contrary to MFDA Rule 2.1.1; c) on September 26, 2018, the Respondent altered 2 account forms in respect of 1 client by altering information on the account forms without having the client initial the alterations, contrary to MFDA Rule 2.1.1; and bd) between September 2010 April 2018 and January 2017July 2018, the Respondent, in his capacity as branch manager, reviewed Respondent obtained and approved the use of 36 possessed 3 pre-signed account formsforms in respect of 3 clients, contrary to MFDA Rules 2.5.5(f)1 and Rule 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine be prohibited from conducting securities related business in any capacity while in the amount employ of $12,500 upon acceptance or associated with any MFDA Member for a period of 2 years commencing from the date the Settlement Agreement (is accepted by the “Fine”)Hearing Panel, pursuant to s. 24.1.1(b24.1.1(e) of MFDA By-law No. 1; b) the Respondent shall be prohibited from acting as pay a branch manager for a period fine in the amount of 6 months, commencing the date $21,000 in certified funds upon acceptance of the order of the Hearing Panel accepting the Settlement Agreement Agreement, pursuant to s. 24.1.1(e24.1.1(b) of MFDA By-law No. 1; c) the Respondent shall pay costs in the amount of $2,500 5,000 in certified funds upon acceptance of the Settlement Agreement (“Costs”)Agreement, pursuant to s. 24.2 of MFDA By-law No. 1; d) the Respondent’s payment Respondent shall successfully complete the Ethics and Professional Conduct Course offered by the IFSE Institute, or an ethics course acceptable to Staff of the Fine and Costs shall be made in certified funds and received by the MFDA MFDA, prior to becoming re-registered as follows: i. Costs upon acceptance a dealing representative with a Member of the Settlement Agreement by the Hearing PanelMFDA, pursuant to s. 24.1.1(f) of MFDA By-law No. 1; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and f) the Respondent will attend in person, on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 April 26, 2014 and January 2017May 22, 2019, the Respondent obtained, possessed andpossessed, and in some instances, used to process transactions, 36 21 pre-signed account forms in respect of 10 7 clients, contrary to MFDA Rule 2.1.1; and b) between September 2010 on May 24, 2013 and January 2017March 6, 2015, the RespondentRespondent altered and used to process transactions, 2 account forms in his capacity as branch managerrespect of 2 clients, reviewed and approved by altering information on the use of 36 pre-signed account formsforms without having the client initial the alterations, contrary to MFDA Rules 2.5.5(f)1 and Rule 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine in the amount of $12,500 10,000 in certified funds upon acceptance of the Settlement Agreement (the “Fine”)Agreement, pursuant to s. section 24.1.1(b) of MFDA By-law No. 1No.1; b) the Respondent shall be prohibited from acting as a branch manager for a period of 6 months, commencing the date of the order of the Hearing Panel accepting the Settlement Agreement pursuant s. 24.1.1(e) of MFDA By-law No. 1; c) the Respondent shall pay costs in the amount of $2,500 in certified funds upon acceptance of the Settlement Agreement (“Costs”)Agreement, pursuant to s. section 24.2 of MFDA By-By- law No. 1No.1; d) the Respondent’s payment of the Fine and Costs shall be made in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). ec) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and fd) the Respondent will attend in person, person on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A” III. AGREED FACTS Registration History‌ 7. Since 1989, the Respondent has been registered in the securities industry. 8. Since 1997, the Respondent has been registered in Ontario as a dealing representative with Canfin Magellan Investments Inc. (the “Member”), a Member of the MFDA. 9. At all material times, the Respondent conducted business in the Etobicoke, Ontario area. 10. At all material times, the Member’s policies and procedures prohibited its Approved Persons from obtaining or using pre-signed account forms. 11. Between April 26, 2014 and May 22, 2019, the Respondent obtained, possessed, and in some instances, used to process transactions, 21 pre-signed account forms in respect of 7 clients. 12. The pre-signed account forms included:

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 December 10, 2015 and January 2017November 8, 2018, the Respondent obtained, possessed andpossessed, in some instances, and used to process transactions, 36 9 pre-signed account forms in respect of 10 6 clients, contrary to MFDA Rule 2.1.1; and b) between September 2010 9, 2015 and January 2017October 28, 2018, the RespondentRespondent altered and used to process transactions 43 account forms in respect of 20 clients, in his capacity as branch manager, reviewed and approved by altering information on the use of 36 pre-signed account formsforms without having the clients initial the alterations, contrary to MFDA Rules 2.5.5(f)1 and Rule 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine in the amount of $12,500 2,500 in certified funds upon acceptance of the Settlement Agreement (the “Fine”)Agreement, pursuant to s. section 24.1.1(b) of MFDA By-law No. 1No.1; b) the Respondent shall be prohibited from acting as a branch manager conducting securities related business in any capacity while in the employ of or associated with any Member of the MFDA for a period of 6 months, commencing 3 months from the date of the order of the Hearing Panel accepting the Settlement Agreement is accepted by the Hearing Panel, pursuant s. to section 24.1.1(e) of MFDA By-law No. 1No.1; c) the Respondent shall pay costs in successfully complete the amount IFSE Ethics and Professional Conduct (EPC) course offered by The Investment Funds Institute of $2,500 upon Canada within one year from the date of the acceptance of the Settlement Agreement (“Costs”)by the Hearing Panel, pursuant to s. 24.2 section 24.1.1(f) of MFDA By-law No. 1; d) the Respondent’s payment Respondent shall pay costs in the amount of the Fine and Costs shall be made $2,500 in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing PanelAgreement, pursuant to section 24.2 of MFDA By- law No.1; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and f) the Respondent will attend in personperson or by videoconference, on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between Between September 2010 2014 and January 2017February 2018, the Respondent copied and pasted the signatures of 4 clients from account forms previously signed by the clients onto 11 new account forms, contrary to MFDA Rule 2.1.1.; and b) In December 2015, the Respondent obtained, possessed andpossessed, and in some instances, used to process transactions, 36 9 pre-signed account forms in respect of 10 clientsone client, contrary to MFDA Rule 2.1.1; and b) between September 2010 and January 2017, the Respondent, in his capacity as branch manager, reviewed and approved the use of 36 pre-signed account forms, contrary to MFDA Rules 2.5.5(f)1 and 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the The Respondent shall pay a fine be prohibited from conducting securities related business in any capacity while in the amount of $12,500 upon acceptance employ or associated with any Member of the Settlement Agreement (MFDA for a period of five months commencing from the “Fine”)date the settlement agreement is accepted by the Hearing Panel, pursuant to s. 24.1.1(bsection 24.1.1(e) of MFDA By-law No. 1; b) the The Respondent shall be prohibited from acting as pay a branch manager for a period fine in the amount of 6 months, commencing the date $7,500 in certified funds upon acceptance of the order of the Hearing Panel accepting the Settlement Agreement Agreement, pursuant s. 24.1.1(eto section 24.1.1(b) of MFDA By-law No. 1; c) the The Respondent shall pay costs in the amount of $2,500 in certified funds upon acceptance of the Settlement Agreement (“Costs”)Agreement, pursuant to s. section 24.2 of MFDA By-law No. 1; d) the Respondent’s payment of the Fine and Costs shall be made in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the The Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.52.1.1; and fe) the The Respondent will attend in person, on the date set for the Settlement HearingHearing in person (via videoconference). 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 Between February 2014 and January February 2017, the Respondent obtained, possessed and, in some instances, altered and used to process transactions, 36 pre-signed 28 account forms in respect of 10 clients15 clients by altering information on the account forms without having the client initial the alterations, contrary to MFDA Rule 2.1.1; and b) between September 2010 and January 2017, the Respondent, in his capacity as branch manager, reviewed and approved the use of 36 pre-signed account forms, contrary to MFDA Rules 2.5.5(f)1 and 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine in the amount of $12,500 12,000 in certified funds upon the acceptance of the Settlement Agreement (the “Fine”)Agreement, pursuant to s. section 24.1.1(b) of MFDA By-law No. 1; b) the Respondent shall be prohibited from acting as a branch manager for a period pay costs in the amount of 6 months, commencing the date $2,500 in certified funds upon acceptance of the order of the Hearing Panel accepting the Settlement Agreement Agreement, pursuant s. 24.1.1(e) to section 24.2 of MFDA By-By- law No. 1; c) the Respondent shall pay costs be prohibited from acting as a branch manager or in any supervisory capacity for a Member of the amount MFDA for a period of $2,500 3 months commencing upon acceptance of the date the Settlement Agreement (“Costs”)is accepted by the Hearing Panel, pursuant to s. 24.2 section 24.1.1(f) of MFDA By-law No. 1; d) the RespondentRespondent shall successfully complete the branch manager’s payment course offered by either the Canadian Securities Institute or the Investment Funds Institute of Canada prior to acting as a branch manager in the Fine and Costs shall be made in certified funds and received by the future, pursuant to section 24.1.1(f) of MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing PanelBy-law No. 1; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and f) the Respondent will attend in person, on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between ): Between September 2010 2018 and January 2017August 2019, the Respondent obtainedsigned the signature of eight clients on eight account forms, possessed and, in some instances, used and submitted the forms to process transactions, 36 pre-signed account forms in respect of 10 clientsthe Member for processing, contrary to MFDA Rule 2.1.1; and b) between September 2010 and January 2017, the Respondent, in his capacity as branch manager, reviewed and approved the use of 36 pre-signed account forms, contrary to MFDA Rules 2.5.5(f)1 and 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine be prohibited from conducting securities related business in any capacity while in the amount employ of $12,500 upon acceptance or associated with any MFDA Member for a period of 1 year commencing from the date of this Settlement Agreement (the “Fine”)Agreement, pursuant to s. 24.1.1(b24.1.1(e) of MFDA By-law No. 1; b) the Respondent shall be prohibited from acting as pay a branch manager for a period fine of 6 months$1,800 in certified funds upon acceptance of this Settlement Agreement, commencing the date of the order of the Hearing Panel accepting the Settlement Agreement pursuant s. 24.1.1(eto section 24.1.1(b) of MFDA By-law No. 1; c) the Respondent shall pay costs in the amount of $2,500 1,800 in certified funds upon acceptance of the this Settlement Agreement (“Costs”)Agreement, pursuant to s. section 24.2 of MFDA By-law No. 1; d) the Respondent’s payment of the Fine and Costs shall be made in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and fe) the Respondent will attend in person, on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”. III. AGREED FACTS Registration History‌ 7. Between September 11, 2018 and October 9, 2019, the Respondent was registered in Nova Scotia as a Dealing Representative with BMO Investments Inc. (the “Member”), a Member of the MFDA.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 February 2014 and January 2017March 2018, the Respondent obtained, possessed andpossessed, and in some instances, used to process transactions, 36 15 pre-signed account forms in respect of 10 9 clients, contrary to MFDA Rule 2.1.1; and b) between September 2010 March 2014 and January February 2017, the RespondentRespondent altered and used to process transactions, 11 account forms in his capacity as branch managerrespect of 6 clients, reviewed and approved by altering information on the use of 36 pre-signed account formsforms without having the client initial the alterations, contrary to MFDA Rules 2.5.5(f)1 and Rule 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine in the amount of $12,500 upon acceptance of the Settlement Agreement (the “Fine”)11,500 in certified funds, pursuant to s. 24.1.1(b) of MFDA By-law NoNo.1, in installments as follows: i. $6,000 upon acceptance of this Settlement Agreement by the Hearing Panel; and ii. 1$5,500 on or before the last business day of the second month following the acceptance of the Settlement Agreement by the Hearing Panel; b) the Respondent shall be prohibited from acting as a branch manager for a period of 6 months, commencing the date of the order of the Hearing Panel accepting the Settlement Agreement pursuant s. 24.1.1(e) of MFDA By-law No. 1; c) the Respondent shall pay costs in the amount of $2,500 in certified funds upon acceptance of the Settlement Agreement (“Costs”)by the Hearing Panel, pursuant to s. 24.2 of MFDA By-law No. 1No.1; d) the Respondent’s payment of the Fine and Costs shall be made in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). ec) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and fd) the Respondent will attend in person, person or by teleconference on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 November 2006 and January April 2017, the Respondent obtained, possessed and, in some instances, used to process transactions, 36 51 pre-signed account forms in respect of 10 18 clients, contrary to MFDA Rule 2.1.1; and b) between September 2010 October 2007 and January February 2017, the RespondentRespondent altered, and used to process transactions, 3 account forms in his capacity as branch manager, reviewed and approved respect of 3 clients by altering information on the use of 36 pre-signed account formsforms without having the clients initial the alterations, contrary to MFDA Rules 2.5.5(f)1 and Rule 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine be prohibited from engaging in securities related business in any capacity while in the amount employ of $12,500 upon acceptance or associated with any MFDA Member for a period of 9 months, commencing on the date the Settlement Agreement (is accepted by the “Fine”)Hearing Panel, pursuant to s. 24.1.1(b24.1.1(e) of MFDA By-law No. 1; b) the Respondent shall be prohibited from acting as pay a branch manager for a period fine in the amount of 6 months, commencing the date $5,000 in certified funds upon acceptance of the order of the Hearing Panel accepting the Settlement Agreement Agreement, pursuant to s. 24.1.1(e24.1.1(b) of MFDA By-law No. 1No.1; c) the Respondent shall pay costs in the amount of $2,500 in certified funds upon acceptance of the Settlement Agreement (“Costs”)Agreement, pursuant to s. 24.2 of MFDA By-law No. 1No.1; d) the Respondent’s payment of the Fine and Costs shall be made in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and fe) the Respondent will attend in person, on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September December 2010 and January 2017February 2016, the Respondent obtainedaltered, possessed and, in some instances, and used to process transactions, 36 pre-signed 32 account forms in respect of 10 clients16 clients by altering information on the account forms without having the clients initial the alterations, contrary to MFDA Rule 2.1.1; and b) between September 2010 and January 2017, the Respondent, in his capacity as branch manager, reviewed and approved the use of 36 pre-signed account forms, contrary to MFDA Rules 2.5.5(f)1 and 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine in the amount of $12,500 9,000 in certified funds upon acceptance of the Settlement Agreement (the “Fine”)Agreement, pursuant to s. 24.1.1(b) of MFDA By-law No. 1No.1; b) the Respondent shall be prohibited from acting as a branch manager for a period of 6 months, commencing the date of the order of the Hearing Panel accepting the Settlement Agreement pursuant s. 24.1.1(e) of MFDA By-law No. 1; c) the Respondent shall pay costs in the amount of $2,500 in certified funds upon acceptance of the Settlement Agreement (“Costs”)Agreement, pursuant to s. 24.2 of MFDA By-law No. 1No.1; d) the Respondent’s payment of the Fine and Costs shall be made in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). ec) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and fd) the Respondent will attend in person, on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”. 7. Since July 1995, the Respondent has been registered in the mutual fund industry. 8. Since October 2010, the Respondent has been registered in Ontario as a mutual fund salesperson (now known as a Dealing Representative) with Investia Financial Services Inc. (“Investia”), a Member of the MFDA. 9. At all material times, the Respondent conducted business in the Richmond Hill, Ontario area. 10. Beginning on or about February 9, 2012, Investia’s policies and procedures required client initials on any material changes made to client documents. 11. Between December 2010 and February 2016, the Respondent altered, and used to process transactions, 32 account forms in respect of 16 clients by altering information on the account forms without having the clients initial the alterations. 12. The altered account forms consisted of new account application, order instruction, systematic instruction, trade ticket, and Know-Your-Client (“KYC”) update forms. 13. On May 18, 2017, Investia identified the altered account forms that are the subject of this Settlement Agreement as a result of a routine branch audit. 14. On June 27, 2017, Investia sent letters to all clients whose accounts the Respondent serviced in order to determine whether the Respondent engaged in unauthorized trading. No concerns were identified. 15. Between September 13, 2017 and March 7, 2018, Investia placed the Respondent under strict supervision. Investia also imposed on the Respondent, a $500 administrative charge and a $3 fee for each letter sent to clients. Investia sent a total of 55 letters. 16. On March 7, 2018, Investia issued a warning letter to the Respondent. 17. The Respondent engaged in the misconduct described above prior to when Investia distributed MFDA Bulletin #0661-E regarding “Signature Falsification” to its Approved Persons. 18. There is no evidence that the Respondent received any financial benefit from engaging in the misconduct described above beyond any commissions and fees that he would ordinarily be entitled to receive had the transactions been carried out in the proper manner. 19. There is no evidence of client loss or lack of authorization for the underlying transactions. 20. The Respondent has not previously been the subject of MFDA disciplinary proceedings. 21. By entering into this Settlement Agreement, the Respondent has saved the MFDA the time, resources, and expenses associated with conducting a full hearing of the allegations.

JOINT SETTLEMENT RECOMMENDATION. 3. Staff and the Respondent jointly recommend that the Hearing Panel accept the Settlement Agreement. 4. The Respondent admits to the following violations of the By-laws, Rules or Policies of the Mutual Fund Dealers Association of Canada (“MFDA”): a) between September 2010 August 23, 2017 and January 2017November 4, 2019, the Respondent obtained, possessed and, in some instances, and used to process transactions, 36 83 pre-signed account forms inrespect of 57 clients, contrary to MFDA Rule 2.1.1; b) between October 13, 2017 and June 9, 2019, the Respondent altered and used to process transactions, 11 account forms in respect of 10 12 clients, by altering information on the account forms without having the client initial the alterations, contrary to MFDA Rule 2.1.1; and bc) between September 2010 on or about October 1, 2018 and January 2017December 19, 2018, the Respondent, in his capacity as branch manager, reviewed Respondent re-used the signatures of 2 clients on 3 account forms by photocopying a signature from a previously signed form to complete a new transaction and approved submitting the use of 36 pre-signed account formsforms to the Member for processing, contrary to MFDA Rules 2.5.5(f)1 and Rule 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall pay a fine in the amount of $12,500 30,000 in certified funds upon acceptance of the Settlement Agreement (the “Fine”)Agreement, pursuant to s. 24.1.1(b) of MFDA By-law No. 1No.1; b) the Respondent shall be prohibited from acting as a branch manager for a period of 6 months, commencing the date of the order of the Hearing Panel accepting the Settlement Agreement pursuant s. 24.1.1(e) of MFDA By-law No. 1; c) the Respondent shall pay costs in the amount of $2,500 in certified funds upon acceptance of the Settlement Agreement (“Costs”)Agreement, pursuant to s. 24.2 of MFDA By-law No.1; c) the Respondent shall successfully complete the Ethics and Professional Conduct Course offered by the IFSE Institute, or an industry course acceptable to Staff of the MFDA, within 12 months of the acceptance of the Settlement Agreement, pursuant to section 24.1.1(f) of By-law No. 1; d) the Respondent’s payment of the Fine and Costs shall be made in certified funds and received by the MFDA as follows: i. Costs upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $4,000 (Fine) on or before the last business day of the third month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iii. $4,000 (Fine) on or before the last business day of the sixth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; iv. $4,500 (Fine) on or before the last business day of the ninth month from the date of the order of the Hearing Panel accepting the Settlement Agreement; 1 Rule 2.5.5(f) has been renumbered during the period of the Respondent’s conduct described in this Settlement Agreement. Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.5.5Rule 2.1.1; and fe) the Respondent will attend in person, person or by videoconference on the date set for the Settlement Hearing. 6. Staff and the Respondent agree to the settlement on the basis of the facts set out in Part III herein and consent to the making of an Order in the form attached as Schedule “A”.