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to the following violations of the By-laws, Rules or Policies of the MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts). a) between October 2010 and December 2015, the Respondent obtained, possessed, and in some instances, used to process transactions, 15 pre-signed account forms in respect of 11 clients, contrary to MFDA Rule 2.1.1; and b) in April 2013 and in May 2015, 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. 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 $7,500 pursuant to section 24.1.1(b) of By-law No. 1; b) the Respondent shall pay costs in the amount of $2,500, pursuant to section 24.2 of By-law No. 1; c) the payment by the Respondent of the Fine and Costs shall be made to and received by MFDA Staff in certified funds as follows: i. $2,500 (Costs) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $2,500 on or before the last business day of the first month following the date of Settlement Agreement; iii. $2,500 on or before the last business day of the second month following the date of Settlement Agreement; iv. $2,500 on or before the last business day of the third month following the date of Settlement Agreement; d) if the Respondent fails to make any of the payments described in subparagraph 5(c): i. any outstanding balance of the Fine and Costs owed by the Respondent shall become immediately due and payable to the MFDA; and ii. the Respondent shall be suspended from conducting securities related business while in the employ of or associated with a Member of the MFDA until such time as the total amount outstanding of the Fine and Costs owed by the Respondent is paid to the MFDA, pursuant to s. 24.3.13(c) of MFDA By-law No. 1; e) the Respondent shall in the future comply with MFDA Rules 2.1.1; and f) The Respondent will attend the Settlement Hearing in person. 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 MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts).: a) between October 2010 April 2012 and December September 2015, the Respondent obtained, possessed, and in some instances, used to process transactions, 15 pre-signed the signature of 10 clients on 13 account forms in respect of 11 clientsforms, contrary to MFDA Rule 2.1.1; and b) in between April 2013 2012 and in May September 2015, the Respondent altered 2 obtained, possessed and, in some instances, used to process transactions, 4 pre-signed account forms in respect of 1 client by altering information on the account forms without having the client initial the alterationsforms, contrary to MFDA 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 $7,500 12,500 pursuant to section s. 24.1.1(b) of MFDA By-law No. 1No.1 (the “Fine”); b) the Respondent shall pay costs in the amount of $2,500, 2,500 pursuant to section s. 24.2 of By-MFDA By- law No. 1No.1 (“Costs”); c) the payment by the Respondent of shall pay the Fine and Costs shall be made to and received by MFDA Staff in certified funds as follows: i. i) $2,500 (Costs) payable upon acceptance of entering into the Settlement Agreement by the Hearing PanelAgreement; ii. ) $2,500 2083.33 on or before the last business day of the first month following the date of Settlement Agreementthe settlement hearing; iii. ) $2,500 2083.33 on or before the last business day of the second month following the date of Settlement Agreementthe settlement hearing; iv. ) $2,500 2083.33 on or before the last business day of the third month following the date of Settlement Agreementthe settlement hearing; v) $2083.33 on the last business day of the fourth month following the date of the settlement hearing; vi) $2083.33 on the last business day of the fifth month following the date of the settlement hearing; and vii) $2083.33 on the last business day of the sixth month following the date of the settlement hearing; d) if the Respondent fails to make any of the payments described above in subparagraph 5(c): i. paragraph 5, any outstanding balance of the Fine and Costs owed by the Respondent shall become immediately due and payable to the MFDA; and ii. MFDA and the Respondent shall be immediately suspended from conducting securities related business while in the employ of or associated with a Member of the MFDA until such time as the total amount outstanding of the Fine and Costs owed by the Respondent is paid to the MFDA, pursuant to s. 24.3.13(c) of MFDA By-law No. 1No.1; e) the Respondent shall in the future comply with MFDA Rules Rule 2.1.1; and f) The the Respondent will attend in person, on the date set for the Settlement Hearing in personHearing. 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 MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts).: a) between October 2010 November 2016 and December 2015January 2017, the Respondent obtained, possessed, and in some instances1 instance, used to process transactionsa transaction, 15 5 pre-signed account forms in respect of 11 3 clients, contrary to MFDA Rule 2.1.1; and b) in April 2013 and in May 2015November 2016, the Respondent altered 2 account forms Respondent, acting in respect his capacity as branch manager, reviewed and approved the use of 1 client by altering information on the pre-signed account forms without having the client initial the alterationsform, contrary to MFDA Rule 2.1.12.1.1 and 2.5.5(f). 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 $7,500 8,000 in certified funds pursuant to section 24.1.1(bs. 24.1.1.(b) of MFDA By-law No. 1; b) the Respondent shall pay costs in the amount of $2,500, 2,500 in certified funds pursuant to section s. 24.2 of MFDA By-law No. 1; c) The Respondent shall be prohibited from acting as a branch manager or in any supervisory capacity for a Member of the payment MFDA for a period of 6 months commencing upon the date the Settlement Agreement is accepted by the Hearing Panel, pursuant to s. 24.1. 1. of By Law No. 1; d) The Respondent shall be required to successfully complete the Branch Managers Course offered by the Canadian Securities Institute prior to holding the position of Branch Manager in the future; e) The payment of the Fine fine and Costs costs shall be made to and received by MFDA Staff in certified funds as follows: i. $2,500 (Costsfine) and $2,500 (costs) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $2,500 (fine) on or before the last business day of the first 3rd month following the date of the acceptance of the Settlement AgreementAgreement by the Hearing Panel; iii. $2,500 3,000 (fine) on or before the last business day of the second 6th month following the date of the acceptance of the Settlement AgreementAgreement by the Hearing Panel; iv. $2,500 on or before the last business day of the third month following the date of Settlement Agreement; d) if the Respondent fails to make any of the payments described in subparagraph 5(c): i. any outstanding balance of the Fine and Costs owed by the Respondent shall become immediately due and payable to the MFDA; and ii. the Respondent shall be suspended from conducting securities related business while in the employ of or associated with a Member of the MFDA until such time as the total amount outstanding of the Fine and Costs owed by the Respondent is paid to the MFDA, pursuant to s. 24.3.13(c) of MFDA By-law No. 1; ef) the Respondent shall in the future comply with MFDA Rules 2.1.1Rule 2.1.1 and 2.5.5(f); and fg) The the Respondent will attend in person, on the date set for the Settlement Hearing in personHearing. 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 MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts). a) between October 2010 June 2008 and December January 2015, the Respondent obtained, possessed, and in some two instances, used to process transactionstrades, 15 4 pre-signed account forms in respect of 11 clients, contrary to MFDA Rule 2.1.1; and b) in April 2013 and in May 2015, the Respondent altered 2 account forms in respect of 1 client by altering information on the account forms without having the client initial the alterationsclient, contrary to MFDA 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 $7,500 4,500 pursuant to section s. 24.1.1(b) of MFDA By-law No. 11 (the “Fine”); b) the Respondent shall pay costs in the amount of $2,500, 2,500 pursuant to section s. 24.2 of MFDA By-law No. 11 (“Costs”); c) the payment by the Respondent of the Fine and Costs shall be made to and received by MFDA Staff paid in certified funds as follows: i. seven installments: the first installment in the amount of $2,500 (Costs) upon shall be paid on the date of the settlement hearing, the remaining six installments in the amount of $750 each are payable on or before the final business day of the six months that follow the date of the acceptance of the Settlement Agreement settlement agreement by the Hearing Panel; ii. $2,500 on or before the last business day of the first month following the date of Settlement Agreement; iii. $2,500 on or before the last business day of the second month following the date of Settlement Agreement; iv. $2,500 on or before the last business day of the third month following the date of Settlement Agreement; d) if the Respondent fails to make any of the installment payments described in subparagraph 5(c): i. any outstanding balance of subparagraphs (a)-(c) above when the Fine and Costs owed by payments become due, then without further notice to the Respondent, the Respondent shall become immediately due and payable to the MFDA; and ii. the Respondent shall summarily be suspended from conducting securities related business in any capacity while in the employ of or associated with a any MFDA Member of until the MFDA until such time as the total full amount outstanding of the Fine and Costs owed by the Respondent is paid to the MFDA, pursuant to s. 24.3.13(c) of MFDA By-law No. 1have been paid; e) the Respondent shall in the future comply with MFDA Rules Rule 2.1.1; and f) The the Respondent will attend in person, on the date set for the Settlement Hearing in personHearing. 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 MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts).: a) between October 2010 August 2014 and December April 2015, the Respondent obtained, possessed, and in some instances, used to process transactions, 15 7 pre-signed account forms in respect of 11 4 clients, contrary to MFDA Rule 2.1.1; and; b) in April 2013 between October 2012 and in May 2015February 2016, the Respondent altered 2 account and used to process transactions, 14 client forms in respect of 1 client 12 clients, by altering information on the account forms without having the client clients initial the alterations, contrary to MFDA Rule 2.1.1; and c) between September 2010 and March 2016, the Respondent: i. directed his assistant, for whom he was responsible, to falsely indicate that she had witnessed client signatures on two Limited Trade Authorization forms; and ii. submitted one client Limited Trading Authorization form to the Member for processing that did not meet the Member’s signature verification requirements. thereby failing to comply with the Member’s policies and procedures, contrary to MFDA Rules 2.5.1, 1.1.2, and 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) the Respondent shall be suspended from conducting securities related business in any capacity while in the employ or associated with any Member of the MFDA for a period of six months from the date of the settlement hearing, pursuant to section 24.1.1(e) of MFDA By-law No. 1; b) the Respondent shall pay a fine in the amount of $7,500 2,500 in certified funds upon acceptance of the Settlement Agreement, pursuant to section 24.1.1(b) of By-law No. 1; bc) the Respondent shall pay costs in the amount of $2,5002,500 in certified funds upon acceptance of the Settlement Agreement, pursuant to section 24.2 of By-law No. 1; c) the payment by the Respondent of the Fine and Costs shall be made to and received by MFDA Staff in certified funds as follows: i. $2,500 (Costs) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $2,500 on or before the last business day of the first month following the date of Settlement Agreement; iii. $2,500 on or before the last business day of the second month following the date of Settlement Agreement; iv. $2,500 on or before the last business day of the third month following the date of Settlement Agreement; d) if the Respondent fails to make any of the payments described in subparagraph 5(c): i. any outstanding balance of the Fine and Costs owed by the Respondent shall become immediately due and payable to the MFDA; and ii. the Respondent shall be suspended from conducting securities related business while in the employ of or associated with a Member of the MFDA until such time as the total amount outstanding of the Fine and Costs owed by the Respondent is paid to the MFDA, pursuant to s. 24.3.13(c) of MFDA By-law No. 1; e) the Respondent shall in the future comply with MFDA Rules 2.1.11.1.2, 2.1.1 and 2.5.1; and fe) The the Respondent will attend the Settlement Hearing in person. 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 MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts).: a) between October 2010 March 2014 and December February 2015, the Respondent obtainedaltered and, possessed, and in some 17 instances, used to process transactions, 15 pre-signed 20 account forms in respect of 11 clients2 clients by using photocopies of previously signed signature pages from other forms or altering previously used account forms, contrary to MFDA Rule 2.1.1; and b) in April 2013 between March 2014 and in May 2015October 2014, the Respondent altered 2 obtained and possessed 1 pre-signed account forms form in respect of 1 client by altering information on the account forms without having the client initial the alterationsclient, contrary to MFDA 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 $7,500 10,000 pursuant to section s. 24.1.1(b) of MFDA By-law No. 1, payable in two installments as follows: i) the first installment of $5,000 shall be paid on or before the first business day of the 6 months that follow the date of acceptance of the Settlement Agreement by the Hearing Panel; ii) the second installment of $5,000 shall be paid on or before the first business day of the 12 months that follow the date of acceptance of the Settlement Agreement by the Hearing Panel; b) the Respondent shall pay costs in the amount of $2,500, 2,500 pursuant to section s. 24.2 of MFDA By-law No. 1; c) the payment by the Respondent of the Fine and Costs shall be made to and received by MFDA Staff in certified funds as follows: i. $2,500 (Costs) , payable immediately upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $2,500 on or before the last business day of the first month following the date of Settlement Agreement; iii. $2,500 on or before the last business day of the second month following the date of Settlement Agreement; iv. $2,500 on or before the last business day of the third month following the date of Settlement Agreement; dc) if the Respondent fails to make any of the payments described in subparagraph 5(c): i. any outstanding balance of (a) when the Fine and Costs owed by payments become due, then without further notice to the Respondent, the Respondent shall become immediately due and payable to the MFDA; and ii. the Respondent shall summarily be suspended from conducting securities related business in any capacity while in the employ of of, or associated with a Member with, any MFDA Member, until the full amount of the MFDA until such time as the total amount outstanding of the Fine and Costs owed by the Respondent is paid to the MFDA, pursuant to s. 24.3.13(c) of MFDA By-law No. 1fine has been paid; ed) the Respondent shall in the future comply with MFDA Rules Rule 2.1.1; and fe) The the Respondent will attend in person, on the date set for the Settlement Hearing in personHearing. 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 MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts).: a) between October 2010 February 2016 and December 2015July 2016, the Respondent obtained, possessed, and in some instances, used to process transactions, 15 14 pre-signed account forms in respect of 11 6 clients, contrary to MFDA Rule 2.1.1; and b) in April 2013 and in May 2015, 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. 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 $7,500 pursuant to section 24.1.1(bs. 24.1.1.(b) of MFDA By-law No. 1; b) the Respondent shall pay costs in the amount of $2,500, 2,500 pursuant to section s. 24.2 of MFDA By-law No. 1; c) the payment by the Respondent of the Fine and Costs shall be made to and received by MFDA Staff in certified funds as follows: i. $2,500 (CostsFine) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $2,500 on or before the last business day (Costs) upon acceptance of the first month following Settlement Agreement by the date of Settlement AgreementHearing Panel; iii. $2,500 on or before the last business day of the second 3rd month following the date of the acceptance of the Settlement Agreement; Agreement by the Hearing Panel; iv. $2,500 on or before the last business day of the third 6th month following the date of the acceptance of the Settlement AgreementAgreement by the Hearing Panel; d) if the Respondent fails to make any of the installment payments described above in subparagraph sub-paragraph 5(c): i. any outstanding balance of the Fine and Costs owed by the Respondent shall become immediately due and payable to the MFDA; and ii. the Respondent shall be suspended prohibited from conducting securities related business while in the employ of or associated with a Member of the MFDA until such time as the total amount outstanding of the Fine and Costs owed by the Respondent is paid to the MFDA, pursuant to s. 24.3.13(c) of MFDA By-law No. 1; e) the The Respondent shall in the future comply with MFDA Rules Rule 2.1.1; and f) The Respondent will attend the Settlement Hearing in person. 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 MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts).that: a) between October 2010 August 27, 2012 and December January 21, 2015, the Respondent he obtained, possessed, possessed and in some instances, instances used to process transactions, 15 5 pre-signed account forms in respect of 11 relation to 2 clients, contrary to MFDA Rule 2.1.1; and b) in April 2013 between August 27, 2012 and in May January 21, 2015, acting in his capacity of branch manager, he reviewed and approved the Respondent altered 2 use of 5 pre-signed account forms in respect of 1 client by altering information on the account forms without having the client initial the alterationsforms, contrary to MFDA Rule 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) i. the Respondent shall pay a fine in the amount of $7,500 6,500 pursuant to section 24.1.1(b) of By-law No. 1; b) ii. the Respondent shall pay costs in the amount of $2,500, 2,500 pursuant to section 24.2 of By-law No. 11 upon acceptance of this Settlement Agreement; c) iii. the payment by fine and costs shall be paid in 9 installments of $1,000 each, with the Respondent first installment to be paid on the date of the Fine settlement hearing, and Costs shall be made to and received by MFDA Staff in certified funds as follows: i. $2,500 (Costs) upon the remaining 8 installments payable on the last business days of the 8 months following the date of acceptance of the Settlement Agreement by the Hearing Panel; ii. $2,500 on or before the last business day of the first month following the date of Settlement Agreement; iii. $2,500 on or before the last business day of the second month following the date of Settlement Agreement; iv. $2,500 on or before the last business day of the third month following the date of Settlement Agreement; d) if the Respondent fails to make any of the installment payments described above in subparagraph 5(c): i. any outstanding balance of (iii) when the Fine and Costs owed by installments become due, then without further notice to the Respondent, the Respondent shall become immediately due and payable to the MFDA; and ii. the Respondent shall summarily be suspended from conducting securities related business while in the employ of of, or associated with with, any MFDA Member until the full amount of the Fine has been paid; v. the Respondent shall be prohibited from acting as a branch manager or in any supervisory capacity for a Member of the MFDA until such time as for a period of 1 month commencing upon the total amount outstanding of date the Fine and Costs owed Settlement Agreement is accepted by the Respondent is paid to the MFDAHearing Panel, pursuant to s. 24.3.13(c24.1.1 of By-law No.1; vi. the Respondent shall successfully complete the Branch Manager’s Course within 6 months of the date the Settlement Agreement is accepted by the Hearing Panel, pursuant to section 24.1.1(f) of MFDA By-law No. 1;; 1 Prior to September 2013, the Respondent’s conduct was contrary to MFDA Rule 2.5.5(d). e) vii. the Respondent shall in the future comply with MFDA Rules Rule 2.1.1; and f) The viii. the Respondent will attend in person at the Settlement Hearing in personHearing. 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-lawsthat: i. between July 28, Rules or Policies of the MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts). a) between October 2010 2011 and December 2015August 5, the Respondent 2016, he obtained, possessed, and in some instances, used to process transactions, 15 87 pre-signed account forms in respect of 11 relation to 32 clients, contrary to MFDA Rule 2.1.1; and b) ii. on or about January 20, 2016, he processed 4 trades in April 2013 and in May 2015, the Respondent altered 2 account forms in respect of 1 client by altering information relation to 3 clients based on the account forms without having instructions of someone other than the client initial the alterationsclient, contrary to MFDA Rule Rules 2.3.1 and 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) i. the Respondent shall pay a fine in the amount of $7,500 17,500 pursuant to section 24.1.1(b) of By-law No. 1; b) ii. the Respondent shall pay costs in the amount of $2,500, 2,500 pursuant to section 24.2 of By-law No. 11 upon acceptance of this Settlement Agreement; c) iii. the payment by the Respondent of the Fine fine and Costs costs described above in subparagraphs 5(i) and (ii) shall be made to and received by MFDA Staff in certified funds as follows: i. a) $2,500 (Costscosts) shall be paid upon acceptance of the Settlement Agreement by the Hearing Panel; ii. b) $2,500 2,916.67 (fine) shall be paid on or before the last business day of the first month following the date acceptance of the Settlement AgreementAgreement by the Hearing Panel; iii. c) $2,500 2,916.67 (fine) shall be paid on or before the last business day of the second month following the date acceptance of the Settlement AgreementAgreement by the Hearing Panel; iv. d) $2,500 2,916.67 (fine) shall be paid on or before the last business day of the third month following the date acceptance of the Settlement AgreementAgreement by the Hearing Panel; de) $2,916.67 (fine) shall be paid on or before the last business day of the fourth month following the acceptance of the Settlement Agreement by the Hearing Panel; f) $2,916.67 (fine) shall be paid on or before the last business day of the fifth month following the acceptance of the Settlement Agreement by the Hearing Panel; g) $2,916.67 (fine) shall be paid on or before the last business day of the sixth month following the acceptance of the Settlement Agreement by the Hearing Panel; iv. if the Respondent fails to make any of the payments described above in subparagraph 5(c):5(iii) then: i. a) any outstanding balance of the Fine fine and Costs costs owed by the Respondent shall immediately become immediately due and payable to the MFDA; and ii. b) the Respondent shall continue to be suspended prohibited from conducting securities related business while in the employ of or associated with a Member of the MFDA until such time as the total amount outstanding of the Fine fine and Costs costs owed by the Respondent is paid to the MFDA, pursuant to s. section 24.3.13(c) of MFDA By-law No. 1; e) v. the Respondent shall in the future comply with MFDA Rules 2.3.1 and 2.1.1; and f) The vi. the Respondent will attend in person at the Settlement Hearing in personHearing. 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 (“MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts).”): a) between October 2010 January 2009 and December February 2015, the Respondent obtained, possessed, and in some instances, used to process transactionstrades, 15 76 pre-signed account forms in respect of 11 14 clients, contrary to MFDA Rule 2.1.1; and b) in April 2013 between January 2009 and in May February 2015, the Respondent altered 2 Respondent, acting in the capacity as alternate branch manager, reviewed and approved the use of 36 pre-signed account forms in respect of 1 client by altering information on the account forms without having the client initial the alterationsforms, contrary to MFDA Rule 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 $7,500 11,500 pursuant to section s. 24.1.1(b) of MFDA By-law No. 1No.1 (the “Fine”); b) the Fine shall be payable in 12 installments in the amount of $958.33 each, which are due on or before the final business day of the 12 months that follow the date of the acceptance of the settlement agreement by the Hearing Panel; c) the Respondent shall pay costs in the amount of $2,500, 2,500 pursuant to section s. 24.2 of MFDA By-law No. 1; c) the payment by the Respondent of the Fine and Costs shall be made to and received by MFDA Staff in certified funds as follows: i. $2,500 (Costs) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $2,500 on or before the last business day of the first month following the date of Settlement Agreement; iii. $2,500 on or before the last business day of the second month following the date of Settlement Agreement; iv. $2,500 on or before the last business day of the third month following the date of Settlement AgreementNo.1; d) if the Respondent fails to make any of the payments described in subparagraph 5(c): i. any outstanding balance of the Fine and Costs owed by the Respondent shall become immediately due and payable to the MFDA; and ii. the Respondent shall be suspended prohibited from conducting securities related business while in the employ capacity of branch manager or associated with any other supervisory capacity for a period of 12 months for a Member of the MFDA until such time as the total amount outstanding of the Fine and Costs owed by the Respondent is paid to the MFDA, pursuant to s. 24.3.13(c24.1.1(e) of MFDA By-law No. 1No.1; e) the Respondent shall successfully complete the branch manager course offered by the Canadian Securities Institute before seeking re-designation as a branch manager, pursuant to s. 24.1.1(f) of MFDA By-law No.1; f) the Respondent shall in the future comply with MFDA Rules 2.5.5(f) and 2.1.1; andand 1 Rule 2.5.5(f) has been re-numbered and re-worded 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), and prior to December 2010, the Respondent’s conduct was contrary to MFDA Rule 2.5.3(b). fg) The the Respondent will attend in person, on the date set for the Settlement Hearing in personHearing. 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 MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts).: a) between October 2010 on March 29, 2016 and December 2015March 30, 2016, the Respondent obtainedprocessed a total of two transactions without the client’s authorization, possessedcontrary to MFDA Rule 2.1.1; b) on April 4, 2016, the Respondent failed to use due diligence to learn the essential facts of a client, when he completed the client’s Know-Your-Client information on an account form without having met or discussed the information with the client, contrary to MFDA Rules 2.2.1 and 2.1.1; c) on April 4, 2016, the Respondent failed to comply with two Member directives to contact a client to review the client’s Know-Your Client information and the suitability of investments in some instances, used to process transactions, 15 pre-signed account forms in respect of 11 clientsthe client’s account, contrary to MFDA Rule 2.1.1; and bd) in on April 2013 and in May 20154, 2016, the Respondent altered 2 account forms in respect of 1 client by altering information on falsely represented to the account forms without having Member that the client initial reviewed and approved the alterationsrisk tolerance for the client’s account, contrary to MFDA 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 $7,500 5,000 pursuant to section s. 24.1.1(b) of MFDA By-law No. 1No.1; b) the Respondent shall pay costs in the amount of $2,500, pursuant to section 24.2 of By-law No. 1; c) the payment by the Respondent of the Fine and Costs shall be made to and received by MFDA Staff in certified funds as follows: i. $2,500 (Costs) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $2,500 on or before the last business day of the first month following the date of Settlement Agreement; iii. $2,500 on or before the last business day of the second month following the date of Settlement Agreement; iv. $2,500 on or before the last business day of the third month following the date of Settlement Agreement; d) if the Respondent fails to make any of the payments described in subparagraph 5(c): i. any outstanding balance of the Fine and Costs owed by the Respondent shall become immediately due and payable to the MFDA; and ii. the Respondent shall be suspended prohibited from conducting securities related business in any capacity while in the employ of or associated with a Member of the MFDA until such time as the total amount outstanding for a period of the Fine and Costs owed by the Respondent is paid to the MFDA18 months, pursuant to s. 24.3.13(c24.1.1(e), contrary to MFDA By-Law No. 1; c) the Respondent shall pay costs in the amount of $2,500 pursuant to s. 24.2 of MFDA By-law No. 1No.1; ed) the Respondent shall in the future comply with MFDA Rules 2.2.1 and 2.1.1; and fe) The the Respondent will attend in person, on the date set for the Settlement Hearing in personHearing. 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-lawsthat: i. between July 28, Rules or Policies of the MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts). a) between October 2010 2011 and December 2015August 5, the Respondent 2016, he obtained, possessed, and in some instances, used to process transactions, 15 31 pre-signed account forms in respect of 11 relation to 19 clients, contrary to MFDA Rule 2.1.1; and b) ii. between August 8, 2012 and January 20, 2016, he processed 5 trades in April 2013 and in May 2015, the Respondent altered 2 account forms in respect of 1 client by altering information relation to 4 clients based on the account forms without having instructions of someone other than the client initial the alterationsclient, contrary to MFDA Rule 2.3.1 and 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: a) i. the Respondent shall pay a fine in the amount of $7,500 10,000 pursuant to section 24.1.1(b) of By-law No. 1; b) ii. the Respondent shall pay costs in the amount of $2,500, 2,500 pursuant to section 24.2 of By-law No. 11 upon acceptance of this Settlement Agreement; c) iii. the payment by the Respondent of the Fine fine and Costs costs described above in subparagraphs 5(i) and (ii) shall be made to and received by MFDA Staff in certified funds as follows: i. a) $2,500 (Costscosts) shall be paid upon acceptance of the Settlement Agreement by the Hearing Panel; ii. b) $2,500 833.33 (fine) shall be paid on or before the last business day of the first month following the date acceptance of the Settlement AgreementAgreement by the Hearing Panel; iii. c) $2,500 833.33 (fine) shall be paid on or before the last business day of the second month following the date acceptance of the Settlement AgreementAgreement by the Hearing Panel; iv. d) $2,500 833.33 (fine) shall be paid on or before the last business day of the third month following the date acceptance of the Settlement AgreementAgreement by the Hearing Panel; de) $833.33 (fine) shall be paid on or before the last business day of the fourth month following the acceptance of the Settlement Agreement by the Hearing Panel; f) $833.33 (fine) shall be paid on or before the last business day of the fifth month following the acceptance of the Settlement Agreement by the Hearing Panel; g) $833.33 (fine) shall be paid on or before the last business day of the sixth month following the acceptance of the Settlement Agreement by the Hearing Panel; h) $833.33 (fine) shall be paid on or before the last business day of the seventh month following the acceptance of the Settlement Agreement by the Hearing Panel; i) $833.33 (fine) shall be paid on or before the last business day of the eighth month following the acceptance of the Settlement Agreement by the Hearing Panel; j) $833.33 (fine) shall be paid on or before the last business day of the ninth month following the acceptance of the Settlement Agreement by the Hearing Panel; k) $833.33 (fine) shall be paid on or before the last business day of the tenth month following the acceptance of the Settlement Agreement by the Hearing Panel; l) $833.33 (fine) shall be paid on or before the last business day of the eleventh month following the acceptance of the Settlement Agreement by the Hearing Panel; m) $833.33 (fine) shall be paid on or before the last business day of the twelfth month following the acceptance of the Settlement Agreement by the Hearing Panel; iv. if the Respondent fails to make any of the payments described above in subparagraph 5(c):5(iii) then: i. a) any outstanding balance of the Fine fine and Costs costs owed by the Respondent shall immediately become immediately due and payable to the MFDA; and ii. b) the Respondent shall continue to be suspended prohibited from conducting securities related business while in the employ of or associated with a Member of the MFDA until such time as the total amount outstanding of the Fine fine and Costs costs owed by the Respondent is paid to the MFDA, pursuant to s. section 24.3.13(c) of MFDA By-law No. 1; ev. the fine and costs shall be paid in 13 installments: the first installment in the amount of $2,500 shall be paid on the date of the settlement hearing, the remaining 12 installments in the amount of $833.33 each are payable on or before the final business day of the six months that follow the date of the acceptance of the settlement agreement by the Hearing Panel; vi. if the Respondent fails to make any of the installment payments described in subparagraphs (i)-(iii) above when the payments become due, then without further notice to the Respondent, the Respondent shall summarily be suspended from conducting securities related business in any capacity while in the employ of or associated with any MFDA Member until the full amount of the fine and costs have been paid; vii. Prior to becoming re-registered as a mutual fund salesperson with a Member of the MFDA, he shall complete an industry course acceptable to Staff of the MFDA, pursuant to s. 24.1.1(f) of MFDA By-law No. 1; viii. the Respondent shall in the future comply with MFDA Rules 2.3.1 and 2.1.1; and f) The ix. the Respondent will attend in person at the Settlement Hearing in personHearing. 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 MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 (under Agreed Facts).: a) between October 2010 2012 and December January 2015, the Respondent obtained, possessed, obtained and in some instances, used to process transactions, 15 22 pre-signed account forms in respect of 11 5 clients, contrary to MFDA Rule 2.1.1; and b) in April 2013 between October 2012 and in May January 2015, the Respondent altered 2 Respondent, acting in the capacity as branch manager, reviewed and approved the use of 22 pre-signed account forms in respect of 1 client by altering information on the account forms without having the client initial the alterationsforms, contrary to MFDA Rule 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 $7,500 8,000 pursuant to section s. 24.1.1(b) of MFDA By-law No. 1No.1 (the “Fine”); b) the Fine shall be paid in 9 installments of $888.88 each, payable on the last business days of the 9 months following the date of acceptance of the Settlement Agreement by the Hearing Panel; c) if the Respondent fails to make any of the installment payments described above in subparagraph (b) when the installments become due, then without further notice to the Respondent, the Respondent shall summarily be suspended from conducting securities related business while in the employ of, or associated with, any MFDA Member until the full amount of the Fine has been paid; d) the Respondent shall pay costs in the amount of $2,500, 2,500 pursuant to section s. 24.2 of MFDA By-law No. 11 (“Costs”); ce) the payment by the Respondent of the Fine and Costs shall be made to and received by MFDA Staff in certified funds as follows: i. $2,500 (Costs) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $2,500 on or before the last business day of the first month following the date of Settlement Agreement; iii. $2,500 on or before the last business day of the second month following the date of Settlement Agreement; iv. $2,500 on or before the last business day of the third month following the date of Settlement Agreement; d) if the Respondent fails to make any of the payments described in subparagraph 5(c): i. any outstanding balance of the Fine and Costs owed by the Respondent shall become immediately due and payable to the MFDA; and ii. the Respondent shall be suspended prohibited from conducting securities related business acting in a supervisory capacity for a period of 3 months while in the employ of or associated with a Member of the any MFDA until such time as the total amount outstanding of the Fine and Costs owed by the Respondent is paid to the MFDAMember, pursuant to s. 24.3.13(c24.1.1(e) of MFDA By-law No. 1; 1 Rule 2.5.5(f) has been re-numbered 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). f) the Respondent shall successfully complete the branch manager course offered by the Canadian Securities Institute within 1 year of the settlement hearing date, pursuant to s. 24.1.1(f) of MFDA By-law No. 1; eg) the Respondent shall in the future comply with MFDA Rules 2.5.5(f) and 2.1.1; and fh) The the Respondent will attend in person, on the date set for the Settlement Hearing in personHearing. 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 MFDA: 1 The initial Settlement Agreement has been replaced by this Settlement Agreement to correct a clerical error identified in paragraph 8 on page 3 : (under Agreed Facts). a) between October 2010 September 2007 and December 2015April 2014, the Respondent obtained, possessed, and in some instances, used to process transactions, 15 86 pre-signed account forms in with respect of 11 54 clients, contrary to MFDA Rule 2.1.1; (b) between September 2007 and April 2014, the Respondent, altered, and in all but one instance, used to process transactions, 101 client account forms with respect of 70 clients, contrary MFDA Rule 2.1.1; and b(c) in April 2013 on February 12, 2012 and in May 2015March 22, 2013, the Respondent altered 2 account forms mislead the Member in respect of 1 client by altering information on her responses to various questions contained in the account forms without having the client initial the alterationsMember’s Annual Compliance Declaration, contrary to MFDA 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 $7,500 pursuant to section s. 24.1.1(b) of MFDA By-law No. 1No.1 (the “Fine”); (b) the Respondent shall pay costs in the amount of $2,500, 2,500 pursuant to section s. 24.2 of MFDA By-law No. 1No.1 (“Costs”); (c) the payment by the Respondent of the Fine and Costs together (the “Funds”) shall be made to and received by MFDA Staff payable in certified funds as follows: i. 6 installments, the first of which in the amount of $2,500 (Costs) upon shall be paid on the date of the settlement hearing, while the remaining five installments of $1,500 shall be payable on or before the first business day of the 5 months that follow the date of the acceptance of the Settlement Agreement settlement agreement by the Hearing Panel; ii. $2,500 on (d) the Respondent shall be prohibited from conducting securities related business in any capacity while in the employ or before the last business day associated with any Member of the first month following MFDA for a period of one year from the date of Settlement Agreementthe settlement hearing, pursuant to section 24.1.1.(e) of MFDA By-law No.1; iii. $2,500 on or before the last business day of the second month following the date of Settlement Agreement; iv. $2,500 on or before the last business day of the third month following the date of Settlement Agreement; d(e) if the Respondent fails to make any of the installment payments described in subparagraph 5(c):subparagraphs accordance with the installment schedule as set out in (a) –(c), above, then without further notice to the Respondent: i. any outstanding balance the full amount of the Fine and Costs owed by the Respondent shall Funds will become immediately due and payable to the MFDAowing immediately; and ii. the Respondent shall be suspended permanently prohibited from conducting securities related business in any capacity while in the employ of or associated with a any Member of the MFDA until such time as the total amount outstanding of the Fine and Costs owed by the Respondent is paid to the MFDA, pursuant to s. 24.3.13(csection 24.1.1.(e) of MFDA By-law No. 1No.1, pursuant to section 24.1.1.(e) of MFDA By-law No.1; e(f) the Respondent shall in the future comply with MFDA Rules Rule 2.1.1; and f(g) The the Respondent will attend the Settlement Hearing in personby teleconference. 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”.