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: a) in October 2016, the Respondent processed 2 redemptions for 1 client where he determined the timing of the redemptions, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 and 2.1.1; b) between January 2011 and October 2016, the Respondent obtained, possessed, and used to process transactions, 7 pre-signed account forms in respect of 5 clients, contrary to MFDA Rule 2.1.1; and c) in March 2013, the Respondent altered and used to process transactions, 4 client account forms in relation to 1 client, by altering the client 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 $6,500 in certified funds pursuant to section 24.1.1(b) of By-law No. 1; b) The Respondent shall pay costs in the amount of $2,500 in certified funds 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. $1,000 (Fine) shall be paid on or before the last business day of the first month following the acceptance of the Settlement Agreement by the Hearing Panel; iii. $1,000 (Fine) shall be paid on or before the last business day of the second month following the acceptance of the Settlement Agreement by the Hearing Panel; iv. $1,000 (Fine) shall be paid on or before the last business day of the third month following the acceptance of the Settlement Agreement by the Hearing Panel; v. $1,000 (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; vi. $1,000 (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; vii. $1,500 (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; d) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.1; and e) 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 MFDA: a) in October 2016, the Respondent processed 2 redemptions for 1 client where he determined the timing of the redemptions, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 between September 2006 and 2.1.1; b) between January 2011 and October 2016August 2014, the Respondent obtained, possessed, and in some instances, used to process transactions, 7 51 pre-signed account forms in respect of 5 22 clients, contrary to MFDA Rule 2.1.1; b) between September 2006 and August 2014, the Respondent falsified, and in some instances, used to process transactions, 13 account forms in respect of 10 clients, contrary to MFDA Rule 2.1.1; and c) in March 2013between September 2006 and August 2014, the Respondent altered Respondent, acting in the capacity of alternate branch manager, reviewed and used to process transactions, 4 client approved 54 of the account forms described above in relation to 1 client, by altering the client account forms without having the client initial the alterationssubparagraphs (b) and (c), contrary to MFDA Rules 2.5.5(f) (prior to September 2013, MFDA Rule 2.5.5(d)) 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 in the amount of $6,500 in certified funds 10,000 pursuant to section s. 24.1.1(b) of MFDA By-law No. 1; b) The Respondent shall pay costs 1 (the “Fine”), payable in 4 installments in the amount of $2,500 in certified funds 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 each as follows: i. $2,500 (Costsi) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $1,000 (Fine) first installment shall be paid on or before the last business day of the first 3rd month following that follows the date of the acceptance of the Settlement Agreement by the Hearing Panel; iii. $1,000 (Fineii) the second installment shall be paid on or before the last business day of the second 6th month following that follows the date of the acceptance of the Settlement Agreement by the Hearing Panel; iv. $1,000 (Fineiii) the third installment shall be paid on or before the last business day of the third 9th month following that follows the date of the acceptance of the Settlement Agreement by the Hearing Panel; and (iv) the fourth installment shall be paid on or before the last business day of the 12th month that follows the date of the acceptance of the Settlement Agreement by the Hearing Panel; v. b) the Respondent shall pay costs in the amount of $1,000 (Fine) shall be paid 2,500 pursuant to s. 24.2 of MFDA By-law No. 1 is payable on or before the last business day of the fourth month following the acceptance date of the Settlement Agreement by the Hearing PanelHearing; vi. $1,000 c) if the Respondent fails to make any of the installment payments described above in above subparagraph (Fine) a), then without further notice to the Respondent, the Respondent shall be paid on summarily suspended from conducting securities related business in any capacity while in the employ of or before associated with any MFDA Member until the last business day full amount of the fifth month following the acceptance of the Settlement Agreement by the Hearing Panel; vii. $1,500 (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 PanelFine has been paid; d) the Respondent shall be prohibited from acting in the capacity of branch manager for a period of 5 months while in the employ of or associated with any Member of the MFDA, pursuant to s. 24.1.1(e) of MFDA By-law No.1; e) prior to being re-designated as a branch manager, the Respondent shall successfully complete the branch manager’s course offered by the Canadian Securities Institute in relation to the mutual fund industry; f) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.12.5.5; and eg) 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 MFDA: a) in October 2016, the Respondent processed 2 redemptions for 1 client where he determined the timing of the redemptions, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 between February 2016 and 2.1.1; b) between January 2011 and October July 2016, the Respondent obtained, possessed, and used to process transactions, 7 14 pre-signed account forms in respect of 5 6 clients, contrary to MFDA Rule 2.1.1; and c) in March 2013, the Respondent altered and used to process transactions, 4 client account forms in relation to 1 client, by altering the client 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 the Respondent shall pay a fine in the amount of $6,500 in certified funds 7,500 pursuant to section 24.1.1(bs. 24.1.1.(b) of MFDA By-law No. 1; b) The the Respondent shall pay costs in the amount of $2,500 in certified funds pursuant to section s. 24.2 of MFDA By-law No. 1; c) The the payment by the Respondent 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) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $1,000 2,500 (FineCosts) shall be paid on or before the last business day of the first month following the upon acceptance of the Settlement Agreement by the Hearing Panel; iii. $1,000 (Fine) shall be paid 2,500 on or before the last business day of the second 3rd month following the date of the acceptance of the Settlement Agreement by the Hearing Panel; ; iv. $1,000 (Fine) shall be paid 2,500 on or before the last business day of the third 6th month following the acceptance date of the Settlement Agreement by the Hearing Panel; v. $1,000 (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; vi. $1,000 (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; vii. $1,500 (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; d) if the Respondent fails to make any of the installment payments described above in 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 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 Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.1Rule 2.1.1; and ef) 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 MFDA: a) in October between December 2015 and February 2016, the Respondent processed 2 redemptions for 1 client where he determined signed the timing signatures of the redemptions, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 and 2.1.1; b) between January 2011 and October 2016, the Respondent obtained, possessed, and used to process transactions, 7 pre-signed 4 clients on 5 account forms in respect of 5 clients, contrary to MFDA Rule 2.1.1; and c) in March 2013, the Respondent altered and used to process transactions, 4 client account forms in relation to 1 client, by altering the client 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 $6,500 in certified funds 3500 pursuant to section 24.1.1(b) of By-law No. 11 (the “Fine”); b) The the Respondent shall pay costs in the amount of $2,500 in certified funds 2500 pursuant to section 24.2 of By-law No. 11 (the “Costs”); c) The the payment by the Respondent of the fine Fine and costs 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. $1,000 2,500 (Fine) shall be paid on or before the last business day of the first month following the upon acceptance of the Settlement Agreement by the Hearing Panel; iii. $1,000 (Fine) shall be paid 250 on or before the last business day of the first month following the date of Settlement Agreement; iv. $250 on or before the last business day of the second month following the acceptance date of the Settlement Agreement by the Hearing PanelAgreement; iv. v. $1,000 (Fine) shall be paid 250 on or before the last business day of the third month following the acceptance date of the Settlement Agreement by the Hearing PanelAgreement; v. vi. $1,000 (Fine) shall be paid 250 on or before the last business day of the fourth month following the acceptance date of the Settlement Agreement by the Hearing Panel; vi. $1,000 (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; vii. $1,500 (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 PanelAgreement; 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 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 Respondent shall be prohibited from conducting securities related business in any capacity while in the employ of or associated with a MFDA Member for a period of 6 months pursuant to s. 24.1.1(b) of MFDA By-law No. 1; f) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.12.1.1; and eg) 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 MFDA: a) in October 2016, the Respondent processed 2 redemptions for 1 client where he determined the timing of the redemptions, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 between September 2014 and 2.1.1; b) between January 2011 and October May 2016, the Respondent obtained, possessed, and used to process transactions, 7 36 pre-signed account forms in respect of 5 3 clients, contrary to MFDA Rule 2.1.1; and c) in March 2013, the Respondent altered and used to process transactions, 4 client account forms in relation to 1 client, by altering the client 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 the Respondent shall pay a fine in the amount of $6,500 in certified funds 11,500 pursuant to section 24.1.1(bs. 24.1.1.(b) of MFDA By-law No. 1; b) The the Respondent shall pay costs in the amount of $2,500 in certified funds pursuant to section s. 24.2 of MFDA By-law No. 1; c) The the payment by the Respondent 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) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $1,000 2,500 (FineCosts) shall be paid on or before the last business day of the first month following the upon acceptance of the Settlement Agreement by the Hearing Panel; iii. $1,000 (Fine) shall be paid 5,000 on or before the last business day of the second 3rd month following the date of the acceptance of the Settlement Agreement by the Hearing Panel; iv. $1,000 (Fine) shall be paid 4,000 on or before the last business day of the third 6th month following the acceptance date of the Settlement Agreement by the Hearing Panel; v. $1,000 (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; vi. $1,000 (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; vii. $1,500 (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; d) if the Respondent fails to make any of the installment payments described above in 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 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 Respondent shall successfully complete an ethics or other industry course acceptable to the MFDA within one year of the Hearing Panel’s Order; f) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.1Rule 2.1.1; and eg) 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 MFDA: a) in October 2016between April 2012 and September 2015, the Respondent processed 2 redemptions for 1 client where he determined signed the timing signature of the redemptions, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 and 2.1.1; b) between January 2011 and October 2016, the Respondent obtained, possessed, and used to process transactions, 7 pre-signed 10 clients on 13 account forms in respect of 5 clientsforms, contrary to MFDA Rule 2.1.1; and cb) in March 2013between April 2012 and September 2015, the Respondent altered and obtained, possessed and, in some instances, used to process transactions, 4 client pre-signed account forms in relation to 1 client, by altering the client 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 the Respondent shall pay a fine in the amount of $6,500 in certified funds 12,500 pursuant to section s. 24.1.1(b) of MFDA By-law No. 1No.1 (the “Fine”); b) The the Respondent shall pay costs in the amount of $2,500 in certified funds 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 Fine and costs shall be made to and received by MFDA Staff Costs in certified funds as follows: i. i) $2,500 (Costs) payable upon acceptance of entering into the Settlement Agreement by the Hearing PanelAgreement; ii. ) $1,000 (Fine) shall be paid 2083.33 on or before the last business day of the first month following the acceptance date of the Settlement Agreement by the Hearing Panelsettlement hearing; iii. ) $1,000 (Fine) shall be paid 2083.33 on or before the last business day of the second month following the acceptance date of the Settlement Agreement by the Hearing Panelsettlement hearing; iv. ) $1,000 (Fine) shall be paid 2083.33 on or before the last business day of the third month following the acceptance date of the Settlement Agreement by the Hearing Panelsettlement hearing; v. v) $1,000 (Fine) shall be paid 2083.33 on or before the last business day of the fourth month following the acceptance date of the Settlement Agreement by the Hearing Panelsettlement hearing; vi. ) $1,000 (Fine) shall be paid 2083.33 on or before the last business day of the fifth month following the acceptance date of the Settlement Agreement by the Hearing Panel;settlement hearing; and vii. ) $1,500 (Fine) shall be paid 2083.33 on or before the last business day of the sixth month following the acceptance date of the Settlement Agreement by the Hearing Panelsettlement hearing; d) if the Respondent fails to make any of the payments described above in paragraph 5, any outstanding balance of the Fine and Costs shall become immediately due and payable to the 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 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 2.3.1Rule 2.1.1; and ef) 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 MFDA: a) in October 2016, the Respondent processed 2 redemptions for 1 client where he determined the timing of the redemptions, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 : between June 2008 and 2.1.1; b) between January 2011 and October 20162015, the Respondent obtained, possessed, and in two instances, used to process transactionstrades, 7 4 pre-signed account forms in respect of 5 clients, contrary to MFDA Rule 2.1.1; and c) in March 2013, the Respondent altered and used to process transactions, 4 client account forms in relation to 1 client, by altering the client 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 the Respondent shall pay a fine in the amount of $6,500 in certified funds 4,500 pursuant to section s. 24.1.1(b) of MFDA By-law No. 11 (the “Fine”); b) The the Respondent shall pay costs in the amount of $2,500 in certified funds pursuant to section s. 24.2 of MFDA By-law No. 11 (“Costs”); c) The payment by the Respondent of the fine Fine and costs 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 acceptance of the Settlement Agreement by the Hearing Panel; ii. $1,000 (Fine) 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 last final business day of the first month following six months that follow the date of the acceptance of the Settlement Agreement by the Hearing Panel; iii. $1,000 (Fine) shall be paid on or before the last business day of the second month following the acceptance of the Settlement Agreement by the Hearing Panel; iv. $1,000 (Fine) shall be paid on or before the last business day of the third month following the acceptance of the Settlement Agreement by the Hearing Panel; v. $1,000 (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; vi. $1,000 (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; vii. $1,500 (Fine) shall be paid on or before the last business day of the sixth month following the acceptance of the Settlement Agreement settlement agreement by the Hearing Panel; d) if the Respondent fails to make any of the installment payments described in subparagraphs (a)-(c) 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; e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.1Rule 2.1.1; and ef) 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 MFDA: a) in October 2016between March 2014 and February 2015, the Respondent processed 2 redemptions for 1 client where he determined the timing of the redemptionsaltered and, thereby engaging in authorized discretionary trading17 instances, contrary to MFDA Rules 2.3.1 and 2.1.1; b) between January 2011 and October 2016, the Respondent obtained, possessed, and used to process transactions, 7 pre-signed 20 account forms in respect of 5 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 cb) in between March 20132014 and October 2014, the Respondent altered obtained and used to process transactions, 4 client possessed 1 pre-signed account forms form in relation to respect of 1 client, by altering the client 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 the Respondent shall pay a fine in the amount of $6,500 in certified funds 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 the Respondent shall pay costs in the amount of $2,500 in certified funds 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. $1,000 (Finec) shall be paid on or before if the last business day Respondent fails to make any of the first month following payments described in subparagraph (a) when the acceptance 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 Settlement Agreement by the Hearing Panel; iii. $1,000 (Fine) shall be paid on or before the last business day of the second month following the acceptance of the Settlement Agreement by the Hearing Panel; iv. $1,000 (Fine) shall be paid on or before the last business day of the third month following the acceptance of the Settlement Agreement by the Hearing Panel; v. $1,000 (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; vi. $1,000 (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; vii. $1,500 (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 Panelfine has been paid; d) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.1Rule 2.1.1; and e) 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 MFDA: a) in on or about October 3, 2016, the Respondent processed 2 redemptions for 1 cut and pasted a client where he determined signature from an account form previously signed by a client onto a new account form, and used the timing of the redemptions, thereby engaging in authorized discretionary tradingnew account form to process a transaction, contrary to MFDA Rules 2.3.1 and Rule 2.1.1; b) between January March 2011 and October June 2016, the Respondent obtained, possessed, and used to process transactions, 7 pre-signed altered 13 account forms in respect of 5 clients8 clients by altering information on the account forms without having the clients initial the alterations, contrary to MFDA Rule 2.1.1; and c) in March 2013on or about January 15, 2016, the Respondent altered obtained and used to process transactions, 4 client possessed 2 pre-signed account forms in relation to respect of 1 client, by altering the client 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 the Respondent shall pay a fine in the amount of $6,500 13,000 in certified funds upon acceptance pursuant to section 24.1.1(bs. 24.1.1.(b) of MFDA By-law No. 1; b) The the Respondent shall pay costs in the amount of $2,500 in certified funds upon acceptance pursuant to section s. 24.2 of MFDA By-law No. 1; c) The the payment by the Respondent of the fine Fine and costs Costs shall be made to and received by MFDA Staff in certified funds as follows: i. i) $2,500 (Costs) and $2,500 (Fine) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. ) $1,000 5,000 (Fine) shall be paid on or before the last business day of the first 3rd month following the date of the acceptance of the Settlement Agreement by the Hearing Panel; ; and iii. ) $1,000 5,500 (Fine) shall be paid on or before the last business day of the second 6th month following the acceptance date of the Settlement Agreement by the Hearing Panel; iv. $1,000 (Fine) shall be paid on or before the last business day of the third month following the acceptance of the Settlement Agreement by the Hearing Panel; v. $1,000 (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; vi. $1,000 (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; vii. $1,500 (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; d) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.1Rule 2.1.1; and e) 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 MFDA: a) in October 2016between September 25, the Respondent processed 2 redemptions for 1 client where he determined the timing of the redemptions2015 and February 27, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 and 2.1.1; b) between January 2011 and October 20162017, the Respondent obtained, possessed, and in some instances, used to process transactions, 7 16 pre-signed account forms in respect of 5 four clients, contrary to MFDA Rule 2.1.1; and c) in March 2013, the Respondent altered and used to process transactions, 4 client account forms in relation to 1 client, by altering the client 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 the Respondent shall pay a fine in the amount of $6,500 in certified funds 2,500, pursuant to section Section 24.1.1(b) of By-law MFDA Bylaw No. 11 (“Fine”); b) The the Respondent shall pay costs in the amount of $2,500 in certified funds 2,500, pursuant to section 24.2 of By-law Bylaw No. 11 (“Cost”); c) The the payment by the Respondent of the fine Fine and costs Costs shall be made to and received by MFDA Staff in certified funds as follows: i. $2,500 1,000 (Costs) shall be paid upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $1,000 (Costs) shall be paid on or before March 30, 2018; iii. $1,000 (Costs and Fine) shall be paid on or before the last business day of the first month following the acceptance of the Settlement Agreement by the Hearing Panel; iii. $1,000 (Fine) shall be paid on or before the last business day of the second month following the acceptance of the Settlement Agreement by the Hearing PanelApril 30, 2018; iv. $1,000 (Fine) shall be paid on or before the last business day of the third month following the acceptance of the Settlement Agreement by the Hearing Panel; v. $1,000 (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; vi. $1,000 (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; vii. $1,500 (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 PanelJune 29, 2018; d) if the Respondent fails to make any of the payments described above in subparagraph 5(c) then: i. any outstanding balance of the Fine and Costs owed by the Respondent shall immediately become due and payable to the MFDA; and ii. the Respondent shall be prohibited from conducting securities related business 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 2.3.1Rule 2.1.1; and ef) 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-lawsthat: i) between July 28, Rules or Policies of the MFDA: a) in October 2011 and August 5, 2016, the Respondent processed 2 redemptions for 1 client where he determined the timing of the redemptions, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 and 2.1.1; b) between January 2011 and October 2016, the Respondent obtained, possessed, and in some instances used to process transactions, 7 80 pre-signed account forms in respect of 5 clients, contrary to MFDA Rule 2.1.1; and c) in March 2013, the Respondent altered and used to process transactions, 4 client account forms in relation to 1 client, by altering the client account forms without having the client initial the alterations25 clients, contrary to MFDA Rule 2.1.1. 5. Staff and the Respondent agree and consent to the following terms of settlement: ai) The the Respondent shall pay a fine in the amount of $6,500 in certified funds 10,000 pursuant to section 24.1.1(b) of By-law No. 1; bii) The the Respondent shall pay costs in the amount of $2,500 in certified funds pursuant to section 24.2 of By-law No. 11 upon acceptance of this Settlement Agreement; ciii) The the payment by the Respondent of the fine and 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) $1,000 1,666.67 (Finefine) shall be paid on or before the last business day of the first month following the acceptance of the Settlement Agreement by the Hearing Panel; iii. c) $1,000 1,666.67 (Finefine) shall be paid on or before the last business day of the second month following the acceptance of the Settlement Agreement by the Hearing Panel; iv. d) $1,000 1,666.67 (Finefine) shall be paid on or before the last business day of the third month following the acceptance of the Settlement Agreement by the Hearing Panel; v. ; e) $1,000 1,666.67 (Finefine) 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; vi. $1,000 (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; vii. $1,500 (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; d) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.1; and e) 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 MFDA: a) in October 2016, the Respondent processed 2 redemptions for 1 client where he determined the timing of the redemptions, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 between February 2014 and 2.1.1; b) between January 2011 and October 2016November 2015, the Respondent obtained, possessedpossessed and, and in some instances, used to process transactions, 7 17 pre-signed account forms in respect of 5 9 clients, contrary to MFDA Rule 2.1.1; and c) in March 2013, the Respondent altered and used to process transactions, 4 client account forms in relation to 1 client, by altering the client 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 the Respondent shall pay a fine in the amount of $6,500 in certified funds 5,000 pursuant to section s. 24.1.1(b) of MFDA By-law No. 11 (the “Fine”); b) The the Respondent shall pay costs in the amount of $2,500 in certified funds pursuant to section s. 24.2 of MFDA By-law No. 11 (“Costs”); c) The payment by the Respondent of shall pay the fine Fine and costs shall be made to and received by MFDA Staff Costs in certified funds as follows: i. $2,500 (Costs) payable upon acceptance of entering into the Settlement Agreement by the Hearing PanelAgreement; ii. $1,000 (Fine) shall be paid 1000 on or before the last business day of the first month following the acceptance of the Settlement Agreement by the Hearing PanelNovember 2017; iii. $1,000 (Fine) shall be paid 1000 on or before the last business day of the second month following the acceptance of the Settlement Agreement by the Hearing PanelDecember 2017; iv. $1,000 (Fine) shall be paid 1000 on or before the last business day of the third month following the acceptance of the Settlement Agreement by the Hearing PanelJanuary 2018; v. $1,000 (Fine) shall be paid 1000 on or before the last business day of the fourth month following the acceptance of the Settlement Agreement by the Hearing Panel;February 2018; and vi. $1,000 (Fine) shall be paid 1000 on or before the last business day of the fifth month following the acceptance of the Settlement Agreement by the Hearing Panel; vii. $1,500 (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 PanelMarch 2018; d) if the Respondent fails to make any of the payments described above in paragraph 5, any outstanding balance of the Fine and Costs shall become immediately due and payable to the 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.1; e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.1Rule 2.1.1; and ef) 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 MFDA: a) in October 2016, the Respondent processed 2 redemptions for 1 client where he determined the timing of the redemptions, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 between 2010 and 2.1.1; b) between January 2011 and October September 2016, the Respondent obtained, possessed, and in 9 instances, used to process transactions, 7 37 pre-signed account forms in respect of 5 27 clients, contrary to MFDA Rule 2.1.1; and cb) in March 2013between May 2010 and December 2015, the Respondent altered falsified, and in 8 instances, used to process transactions, 4 client 12 account forms in relation to 1 client, respect of 10 clients by altering information on the client account forms without having the client clients 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 the Respondent shall be prohibited for two months from conducting securities related business in any capacity while in the employ of or associated with any MFDA Member, pursuant to s. 24.1.1.(e) of MFDA By-law No. 1; b) the Respondent shall pay a fine in the amount of $6,500 in certified funds 2,500, pursuant to section s. 24.1.1(b) of By-law No. 1; b) The Respondent shall pay costs in the amount of $2,500 in certified funds pursuant to section 24.2 of MFDA By-law No. 1; c) The the Respondent shall pay costs in the amount of $2,500, pursuant to s. 24.2 of MFDA By-law No. 1; d) 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) 1,000 shall be paid upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $1,000 (Fine) 400 shall be paid on or before the last business day of the first month following the acceptance of the Settlement Agreement by the Hearing Panel; iii. $1,000 (Fine) 400 shall be paid on or before the last business day of the second month following the acceptance of the Settlement Agreement by the Hearing Panel; iv. $1,000 (Fine) 400 shall be paid on or before the last business day of the third month following the acceptance of the Settlement Agreement by the Hearing Panel; v. $1,000 (Fine) 400 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; vi. $1,000 (Fine) 400 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; vii. $1,500 (Fine) 400 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; dviii. $400 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; ix. $400 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; x. $400 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; and xi. $400 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; e) if the Respondent fails to make any of the payments described above in subparagraph 5(d) then: i. any outstanding balance of the fine and costs owed by the Respondent shall immediately become due and payable to the MFDA; and ii. the Respondent shall continue to be 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; f) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.1Rule 2.1.1; and eg) 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 MFDA: a) in between October 2016, the Respondent processed 2 redemptions for 1 client where he determined the timing of the redemptions, thereby engaging in authorized discretionary trading, contrary to MFDA Rules 2.3.1 2010 and 2.1.1; b) between January 2011 and October 2016December 2015, the Respondent obtained, possessed, and in some instances, used to process transactions, 7 15 pre-signed account forms in respect of 5 11 clients, contrary to MFDA Rule 2.1.1; and cb) in March 2013April 2013 and in May 2015, the Respondent altered and used to process transactions, 4 client 2 account forms in relation to respect of 1 client, client by altering information on the client 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 the Respondent shall pay a fine in the amount of $6,500 in certified funds 7,500 pursuant to section 24.1.1(b) of By-law No. 1; b) The the Respondent shall pay costs in the amount of $2,500 in certified funds 2,500, pursuant to section 24.2 of By-law No. 1; c) The the payment by the Respondent of the fine Fine and costs 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. $1,000 (Fine) shall be paid 2,500 on or before the last business day of the first month following the acceptance date of the Settlement Agreement by the Hearing PanelAgreement; iii. $1,000 (Fine) shall be paid 2,500 on or before the last business day of the second month following the acceptance date of the Settlement Agreement by the Hearing PanelAgreement; iv. $1,000 (Fine) shall be paid 2,500 on or before the last business day of the third month following the acceptance date of the Settlement Agreement by the Hearing Panel; v. $1,000 (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; vi. $1,000 (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; vii. $1,500 (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 PanelAgreement; 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; and e) the Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.1; and e) the Respondent will attend in person, on the date set for the Settlement Hearing2. 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: a) in October 2016between November 2012 and April 2014, the Respondent processed 2 redemptions for 1 client where he determined altered and used to process transactions, 3 account forms in respect of 3 clients, by altering information on the timing of account forms without having the redemptions, thereby engaging in authorized discretionary tradingclients initial the alterations, contrary to MFDA Rules 2.3.1 and Rule 2.1.1; b) between August 2012 and January 2011 and October 2016, the Respondent obtained, possessed, altered information on 17 account forms that had been previously signed by 10 clients and used in previous transactions in order to process transactions, 7 pre-signed account forms new transactions in respect of 5 the clients’ accounts, contrary to MFDA Rule 2.1.1; and c) in March 2013between February 2013 and February 2016, the Respondent altered obtained, possessed, and in some instances, used to process transactions, 4 client 51 pre-signed account forms in relation to 1 client, by altering the client account forms without having the client initial the alterationsrespect of 24 clients, contrary to MFDA Rule 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 in the amount of $6,500 in certified funds 20,000 pursuant to section 24.1.1(bs. 24.1.1.(b) of MFDA By-law No. 1; b) The the Respondent shall pay costs in the amount of $2,500 in certified funds pursuant to section s. 24.2 of MFDA By-law No. 1; c) The the payment by the Respondent of the fine Fine and costs Costs shall be made to and received by MFDA Staff in certified funds as follows: i. $5,000 (Fine) upon acceptance of the Settlement Agreement by the Hearing Panel; ii. $2,500 (Costs) upon acceptance of the Settlement Agreement by the Hearing Panel; iiiii. $1,000 (Fine) shall be paid 7,500 on or before the last business day of the first 3rd month following the date of the acceptance of the Settlement Agreement by the Hearing Panel; iii; iv. $1,000 (Fine) shall be paid 7,500 on or before the last business day of the second 6th month following the acceptance date of the Settlement Agreement by the Hearing Panel; iv. $1,000 (Fine) shall be paid on or before the last business day of the third month following the acceptance of the Settlement Agreement by the Hearing Panel; v. $1,000 (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; vi. $1,000 (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; vii. $1,500 (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; d) if the Respondent fails to make any of the installment payments described above in 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 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 Respondent shall in the future comply with MFDA Rules 2.1.1 and 2.3.1Rule 2.1.1; and ef) 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”.