THE The Investment Dealers Association of Canada THE ... · Jerome Grady Stephen B. Bishop ... The Investment Dealers Association of Canada ("IDA") ... Christopher Robinson completed

IhT THE MATTER OF: The Investment Dealers Association of Canada

- and -

IN THE MATTER OF: Christopher Robinson

DECISION OF THE NOVA SCOTIA DISTRICT COUNCIL

HEARD: November 20,2001

DECISION: December 1 7,200 1

DISTRICT COUNCIL: Janice A. Stairs, Chair Jerome Grady Stephen B. Bishop

Alice L. Abbot, for the Investment Dealers Association of Canada

-Srinivasen P. Pillay, Q.C., for Christopher Robinson

DECISION AND REASONS

Introduction

The Investment Dealers Association of Canada ("IDA") alleges that Christopher Robinson (the "Respondent") violated the By-laws and Regulations of the IDA as follows:

Count I

On or about October 1995, Christopher Robinson failed to learn the essential facts relative to his customer, JL, contrary to Regulation 1300.1 (a).

Count 2

Between November 1995 and December 1997, Christopher Robinson failed to ensure that the recommendations made for the account of JL were appropriate for his client and in keeping with his investment objectives, contrary to Regulation l3OO.l (c).

Count 3

Between August 1995 and February 1998, Christopher Robinson failed to ensure that the recommendations made for the cash account of AB were appropriate for his client and in keeping with her investment objectives, contrary to Regulation 13 00.1 (c).

On or about November 1996, Christopher Robinson completed a New Account Application Form for his client AB, containing changes in his client's investment objectives and risk tolerance which did not reflect the client's true investment objectives and risk tolerance, contrary to Regulation 1300. l (a) and By-law 29.1.

Count 5

On or about November 1996, Christopher Robinson recommended that his client, AB, open a margin account, and failed to explain the risks in opening such an account, contrary to By-law 29.1.

Count 6

Between March 1994 and February 1998, Christopher Robinson failed to ensure that the recommendations made for the RRSP account of AB were appropriate for his client and in keeping with her investment objectives, contrary to Regulation 1 300.1 (c).

Count 7

On or about November 1995, Christopher Robinson completed a New Account Application Form for a joint account for his clients EKC and LC, indicating investment objectives and risk

II tolerance which did not reflect the clients' true investment objectives and risk tolerance, contrary to Regulation 1300.1 (a) and By-law 29.1.

Count 8

Between December 1995 and May 1997, Christopher Robinson failed to ensure that the recommendations made for the joint cash account of EKC and LC were appropriate for his clients and in keeping with their investment objectives, contrary to Regulation 1300.1 (c).

Count 9

Between May 1996 and August 1997, Christopher Robinson failed to ensure that the recommendations made for the RRSP account of EKC were appropriate for his client and in keeping with his investment objectives, contrary to Regulation 1300.1 (c).

Between December 1995 and August 1997, Christopher Robinson failed to ensure that the recommendations made for Locked-In RRSP account of RW were appropriate for his client and in keeping with his investment ob~ectives, contrary to Regulation 1300. I (c).

The hearing of this matter was held in Halifax, Nova Scotia, on November 20,2001 pursuant to a d* Notice of Hearing and Particulars dated October 30,2001.

,-

The issues to be determined by the District Council are:

1. Whether the Respondent was properly served with a Notice of Hearing and Particulars as provided for in By-law 20.1 1 ;

2. Whether the District Council accepts the facts alleged and the conclusions drawn by the IDA in the Notice of Hearing and Particulars in the absence of a Reply being filed by the Respondent or the Respondent being present in person or by counsel to respond to the allegations;

3. If the facts alleged and conclusions drawn are accepted do they prove the breaches by the Respondent; and

4. If it is proved that the Respondent breached the By-laws and Regulations, what is the appropriate penalty, if any, to be imposed.

Proper Service

At the hearing the District Council heard representations from Ms. Abbot and Mr. Pillay with respect to the issue of whether or not the Respondent was properly served with the Notice of Hearing and Particulars as provided for in By-law 20.1 1. Mr. Pillay argued that the Respondent

.- had not received actual notice of the hearing of this matter. Mr. Pillay contended that the rules of natural justice were to be broadly applied to administrative tribunal hearings and that it was incumbent upon the District Council not to proceed with the hearing unless there had been actual service of the Respondent.

Ms. Abbott reviewed the provisions of By-law Nos. 20 and 23 as they relate to the requirements for the senrice of a Notice of Hearing and Particulars. By-law 23.2 states:

"A notice of hearing and particulars provided for in By-law 20.1 1 shall be served by personal service or by registered mail to the attention of and addressed to the latest residence or business address shown in the records of the Association for the person, firm or corporation to whom such notice of hearing and particulars is directed."

Ms. Abbot reviewed her communications with the Respondent's counsel prior to issuance of the Notice of Hearing and Particulars which commenced on or about August20, 2001, and continued regularly through to September 25, 200 1, when Respondents' counsel advised Ms. Abbot that he had no instructions with regard to settlement discussions and he had no authority to accept service of the Notice of Hearing and Particulars on behalf of the Respondent. Ms. Abbot filed with the District Council an affidavit of Ricki Anderson, Senior Secretary with the IDA in Toronto, Ontario, which stated in part as follows:

"2. I was instructed to serve Christopher Robinson with the Notice of Hearing of disciplinary proceedings, initiated by the Investment Dealers Association. I checked with the Association's registration department for the last known home address of Christopher Robinson. The address on file is 820 Purcell's Cove Road, P.O. Box 3 121, Box 3, Halifax, NS B3K 5Y 1. Attached as Exhibit "A" is a copy of the email from Nellie Bolarinho of the Registration department to me, dated October 29, 2001. I was concerned that it might be outdated, so I checked the Canada 411 website for addresses for Christopher Robinson in Halifax. The Canada 41 1 website is an on-line telephone and address directory. There were two listings for a C. Robinson and one listing for a Chris Robinson listed in Halifax. I checked the telephone numbers against the telephone number in our registration records, 902.475.1759. A copy of the Canada 4 1 1 website printout is attached as Exhibit "B" to this affidavit. I found that the Chris Robinson at 816 Purcell's Cove Road, Halifax, Nova Scotia, B3J 2L4 listed on the Canada 411 website had that same telephone number. Accordingly, I felt it was likely that address was the most current.

3. On Wednesday, October 3 1, 2001 I sent a letter by registered mail, dated October 30, 2001 and addressed to Christopher Robinson, at 816 Purcell's Cove Road, Halifax, Nova Scotia, 835 2L4, with the Notice of Hearing of disciplinary proceedings initiated by the Association. Copies of the letter and the Notice of Hearing are attached as Exhibit "C" of this affidavit.

4. I checked the Canada Post website continuously for delivery confirmation of the original Notice of Hearing, and by November 6, 2001, it still had not been picked up. A copy of the website printout is attached as Exhibit "D" of this affidavit. On that date, the IDA'S disclosure to Christopher Robinson was ready to be provided to him. As our letter and Notice of Hearing previously sent had not yet been picked up, I checked the Registration file myself and found that Mr. Robinson's most recent UTN dated, April 30, 2001, indicated an address of 820 Purcell's Cove Road, P.O. Box 3 121, Box 3, Halifax, NS B3K 5Y 1. Attached hereto as Exhibit "E" is a copy of the UTN. Accordingly, I sent a copy of the Notice of Hearing along with the disclosure documents to 820 Purcell's Cove Road, P.O. Box 3 12 1, Box 3, Halifax, NS B3K 5Y 1, the address on file in our Registration department and on the UTN.

5. On November 6, 2001 I sent two letters dated November 2, 2001, addressed to Christopher Robinson, one banker's box of documents for disclosure and a copy of the Notice of Hearing, by FedEx, to 820 Purcell's Cove Road, P.O. Box 3121, Box 3, Halifax. NS B3K 5Y1. Attached as Exhibit "F", respectively to this affidavit, is a copy of the address label, courier request form and courier receipt. Attached as Exhibit "G" is a copy of the November 2, 2001 letter, which is a cover letter to the disclosure materials. Attached as Exhibit "H" is a copy of the other November 2, 2001 letter, with hearing details. After sending the information out I noticed on the letters dated November 2, 2001 that the address listed is 816 Purceli's Cove Road. These letters were not sent to 8 16 Purcell's

Cove Road but were included in a box of documents along with a copy of the original letter and Notice of Hearing, which was sent by FedEx to 820 Purcell's Cove Road, on November 6, 2001. In the process of making sure the box would be delivered within the time frame allotted, I did not change the address on the letter, which had been prepared several days earlier.

6. On November 14, 2001, I checked the 'Canada Post website for delivery confirmation of the original letter and Notice of Hearing. The delivery message continued to state that delivery of the item was attempted and a card would be left advising the recipient that Canada Post had attempted delivery. This message is attached as Exhibit "I" to this affidavit.

7. On November 14, 2001, I checked the FedEx website for delivery confirmation of the letter, box of disclosure documents and Notice of Hearing. The message, attached as Exhibit "J" to this affidavit, stated that the package was delivered on November 8,2001 at 1 1 :00 am and signed for by L. Hanrahan.

8. On November 14, 2001, I called FedEx and spoke to Jana in customer service regarding confirmation of the delivery and I was informed verbally that the package was delivered to 820 Purcell's Cove Road. I explained to her that the recipient, Christopher Robinson, had not yet received the information. She informed me that she would open a trace and try to obtain more information. Later that same day, I was contacted by Penny Chen, a representative with FedEx, and she also confirmed that the package was in fact delivered to 820 Purcell's Cove Road. I explained to her that the recipient, Christopher Robinson, claimed he did not receive it. I requested that she try to find more information, if possible, about the person who signed for the package, L. Hanrahan.

9. On November 15,2001, I was contacted by Penny Chen from FedEx, who explained to me that the place of delivery was residential and that L. Hanrahan was an elderly lady at the house who was babysitting a little girl."

Ms. Abbot also filed with the District Council an affidavit of Michael Arthur, an investigator in the employ of the IDA in Toronto, Ontario, which stated in part as follows:

"2. On Tuesday, November 6, 2001 I requested the current telephone number for Mr. Robinson from Ricki Anderson, a Senior Secretary at the Association. I subsequently telephoned Mr. Robinson at 902-475-1759. The call was received by an answering machine which stated you had reached the home of Chris and Marie. I left a message stating my name and position with the Association and requested that Mr. Robinson return my call at 416-943-6925.

3. On Tuesday November 13, 2001 I telephoned Mr. Robinson at 902-475-1 759. I was advised by the woman who answered the phone that he was not in at the moment. I advised the woman that I worked with the Association

and left my name and telephone number as well as a request that Mr. Robinson return my call as soon as possible.

4. On Tuesday November 13,2001 I called Mr. Robinson again and spoke to the woman who answered. She identified herself as Marie, Mr Robinson's wife. I advised her that 1 was attempting to contact Mr. Robinson to ensure that he had received notification that a Disciplinary Hearing was going to be conducted on November 20" and 21'' regarding complaints filed against him with the Association. I advised her that the Association had sent a Notice of Hearing and a box of documents to Mr. Robinson regarding this hearing. She could not confirm that he had received them. She confirmed that their address was 820 Purcell's Cove Road, P.O. Box 3 121, Box 3, B3K-5Y 1. She stated that she would relay the message to Mr. Robinson as soon as she saw him."

Ms. Abbott then refened the District Council to two recent decisions of the IDA (Anderson and Walsh) which dealt with the issue of proper service.

After considering the foregoing information and submissions, and after considering the requirements of By-law 23.2, the District Council was satisfied that the IDA had made all reasonable attempts to ensure that the Respondent was aware of the charges, the particulars and the fact that a hearing would occur. The affidavit of Ms. Anderson indicated that the IDA had served the Notice of Hearing and Particulars by registered mail to the attention of the Respondent at his last address shown on the records with the IDA. Further, based on the - affidavit of Michael Arthur, the District Council was satisfied that 820 Purcell's Cove Road was the correct resideniial address for the Respondent. While the District Council acknowledged that it would be preferable for the Respondent to have been served personally, the District Council was satisfied that good and sufficient service had been completed pursuant to By-law 23.2 and the District Council elected to proceed with the hearing pursuant to the authority of By- law 20.1 6.

Facts and Proof

At this point Mr. Pillay withdrew fiom the hearing indicating he had no instructions to represent the Respondent on the merits of the allegations. With the consent of Ms. Abbott, Mr. Pillay tabled a letter prepared by the Respondent responding to the particulars set out in the Notice of Hearing ("Robinson Letter").

Ms. Abbott filed with the District Council additional documentary evidence to support the allegations set out in the Notice of Hearing and Particulars. The Notice of Hearing and Particulars, supplemented by the additional documentary information filed by Ms. Abbot, disclosed the following:

The Respondent is not currently employed by a Member of the Association. His history as an approved person is as follows:

January 1992 to May 1998 RBCDS (RR, ROR) August 1998 to April 2001 Menill Lynch (ROR)

JL opened a cash account with the Respondent in October 1995. JL had inherited approximately $54,000 in securities fiom the estate of his father. The inherited securities transferred into JL's account were blue-chip and preferred shares. At the time, JL was 50 years old. He wished to re-invest in growth securities until his projected retirement date in 7 years. The NAAF filled out by the Respondent contained a number of errors which indicate the Respondent did not speak to JL in order to fill out the NAAF. The NAAF indicates a business telephone number for JL, yet he was not working at the time. JL's wife's name is incorrect. JL's age is incorrect. The personal financial information, including income, are not correct. JL's NAAF indicates the foIlowing investment objectives and risk factors:

INVESTMENT OBJECTIVES I

JL's NAAF indicates "nil" past investment experience. Commencing in November 1 995, JL's account departed significantly from his stated objectives. During that month, almost all his investment grade securities were sold, and replaced by Repap Enterprises and Hyal Pharmaceuticals, both speculative securities. At the end of the month, the account was held 12% in investment grade securities; 22% in good quality securities, and 65% in speculative securities. In December 1995, JL's account was changed to a margin account. The stated objectives and risk factors remained the same. By the end of November 1997, the net value of the portfolio declined to $3,500, a decline of 94%. The portfolio consisted of $10,997 in Hyal Pharmaceutical, and $665 in Exploration Brex, both high-risk, speculative securities. In December 1997, the value of Hyal dropped to $2,257 and the account fell into a debit position, where it remained until it was sold out. JL lost his entire original investment, plus additional funds he deposited to cover margin calls, for a total loss of $67,847. The Respondent recommended all transactions but one.

Income 0%

RISK FACTORS

AB - Cash Account

Long term growth 50%

Inter term growth 25%

Investment Grade 50%

AB opened a cash account with the Respondent in September 1993, after the death of her husband. She was 52. She deposited $75,000 inherited from her husband. Her objective was to invest to finance her retirement at age 60. AB's NAAF indicates the following investment objectives and risk factors:

Short term growth 25%

Good Quality Speculative 30% 1 20%

High Risk 0%

1 INVESTMENT OBJECTIVES I -. . -

AB's NAAF indicates past investment experience in mutual funds only. She had limited to fair investment knowledge. This is a summary of the speculative

RISK FACTORS

purchases in her cash (later margin) account:

Short term growth Income


In August 1995, AB's account began to go offside of her stated objectives. In that month, the account held 58% investment grade, 22% good quality, and 21% speculative securities. In November 1996, AB's account was changed to a margin account, to facilitate a loan to her son. The Respondent did not explain the risks of a margin account to her. In November 1996, AB's account held 54% investment grade; 18% good quality, and 25% speculative securities. An updated N U F was completed for the margin account, indicating the following investment objectives and risk factors:

4 Long term growth

Good Quality 40%

Speculative 10%

DATE August 15,1995 November 10, 1995 November 10,1995 May 16, 1996 June 7,1996 November 15, 1996 July 23, 1997

Inter term growth

High Risk 0%

25% 0%

SECURITY R ~ P ~ P Hyal Repap Absolut Oilexco Architel Gold Reserve

INVESTMENT OBJECTIVES

The change in investment objectives and risk factors indicate AB desired a higher turnover in portfolio, with increased risk. These changes were not discussed between the Respondent and AB. AB's actual objectives and risk tolerance did not change as indicated in the updated NAAF, which was not signed by AB. The trend towards speculation continued until September 1997, when the account held 1 1% investment grade; 48% good quality, and 42% speculative. In the Fall of 1997, a third party was reviewing AB's financial situation, and advised her of the risky nature of her portfolio with the Respondent. This led to a complaint to RBC DS in 1998. The Respondent recommended all transactions in AB's cash account.

COST $7,3 84.7 1 $9,939.22 $4,061 .OO $1 0,017.76 $6,833.84 $7,580.54 $7,424.06

Income i OYO

RISK FACTORS

50%


25%


Good Quality 40%



Speculative 20%

High Risk 0%

He did not advise her of the speculative nature or the risks Inherent in the speculative securities he recommended.

AB - RRSP Account

In February 1994, AB opened an RRSP account with the Respondent. She deposited $16,897 in cash, and $48,404 in Industrial Income Fund mutual fund. There is no NAAF available for this account. AB wanted no more than moderate risk for the investments in her RRSP. The following is a summary of the speculative securities purchased into AB's RRSP account:

1 DATE I SECURITY I COST 1

The month following the transfer of the RRSP to the Respondent, the account held 58% investment grade, 16% good quality and 27% speculative securities. It remained in this range until August 1995, when the investment grade securities were sold. The account then held 0% investment grade, 52% good quality, and 48% speculative. It remained in this range until AB complained to RBC DS in 1998. The Respondent recommended all transactions in AB's RRSP account. He did not advise her of the speculative nature or the risks inherent in the speculative securities he recommended.

August 15, I995 November 10,1995 November 10, 1995 May 16, 1996 June 7, 1996 November 15, 1996

EKC - Cash Account

EKCts mother, JC, had an account with the Respondent. In June 1993, JC made the account joint with her children, EKC and HJG, to facilitate the transfer of the assets upon her death, and to familiarize her children with her estate as they were executors of her will. At that time, EKC was 52 years old. An NAAF was completed when the account was made joint, indicating the following investment objectives and risk factors:

Repap Hyal Repap AbsoIut Pointer Architel

I INVESTMENT OBJECTIVES 1

$6,069.04 $9,736.72 $4,963.00 $7,713.44 $5,052.50 $5,140.70

I RISK FACTORS

Income ) Long term growth 50% ( 0%

JC directed all trading in the account. The account held approximately 50% "blue chip1' securities, and 50% income securities until her death in November 1995. JC


I



Good Quality 50%

Speculative 0%

High Risk 0%

died on November 5, 1995. On November 10, 1995, an account was opened in the name of EKC and his wife Leona, for the purpose of receiving the transfer of EKC's share of his mother's estate. The NAAF contains the following objectives and risk factors:

INVESTMENT OBJECTIVES

The stated objectives and risk factors do not accord with those of EKC and his wife. Their objective for the account was to provide a "nest-egg" for the future. EKC wanted very moderate growth with safety. The NAAF was not signed nor seen by EKC or his wife at the time it was filled out.

RISK FACTORS

With respect to the original joint account held by JC and her son and daughter, a new NAAF, dated November 23, 1995, was completed to reflect JCfs death. It also indicated a change in objectives. It contains the following investment objectives and risk factors:

Income 0%

1 IXVESTMENT OBJECTIVES 1





Good Quality 40%

Speculative 20%

High Risk 0%

The NAAF filled out by the Respondent indicates an incorrect employer. In addition, there was no discussion with EKC or HJG regarding any change in objectives. The NAAF was not signed nor seen by EKC or HJG at the time it was

Income 0%

RISK FACTORS 7

filled out.


Inter term growth 25 %

The estate was divided amongst EKC, his sister and his brother, in December 1995. EKC's share of the assets of his mother's account, worth approximately $105,000, was transferred into the account he held jointly with his wife.



A number of high risk securities were purchased into the account, as follows:

Good Quality 40%

Speculative 20%

High Risk 0%

DATE December 14, 1995

1

January 24, 1996 May 2, 1996 August 15,1996

SE.CURITY Repap

COST $7,453.13 - -

Arequipa Arequipa Hyal

$5,96250 $6,993.75 $4,720.00

The Respondent did not advise EKC or LC of the speculative nature or of the risks inherent in these purchases prior to making them.

September 27, 1996 I Architel May 20, 1997 Gold Reserve

Upon his retirement in March, 1996? EKC opened an RRSP account with the Respondent. No separate NAAF was obtained for this account. In April 1996, this account received his government retiring allowance of $53,895, and the proceeds of the liquidation of a life insurance policy in the amount of $1 3,719. It also held a previous cash deposit of $8,456. No further assets were contributed to the account.

$9,250.00 $7,012.50

The following high-risk securities were purchased into the RRSP account.

1 DATE I SECURITY I COST

For the time period of May 1996 to November 1997, the RRSP account held in excess of 20% speculative securities, ranging from 20.31% November 1997, to 39.90% in September 1997. From March 1997, the account also held less than 2% in investment grade securities.

The Respondent did not ensure that the recommendations made to EKC were in accordance with his investment objectives. He did not advise EKC of the nature or of the risks inherent in the purchases prior to making them.

$7,360.85 $7,68 1.80 $10,916.80 $2,275.00 $2,362.50 $5.925.80

I

May 2,1996 May 2,1996 July 2 7, 1996 September 27, 1996 September 27, 1996 August 20,1997

RW became a client of the Respondent's in November 1995, at the age of 33. At that time, he opened two accounts, a Locked-In RRSP (LIRRSP) and an RRIF. The RRIF was an RRSP RW had recently converted to provide income while he returned to school and started a business. Only one NAAF was obtained for RW's accounts. It contains the following investment objectives and risk factors:

Architel Arequipa Hyal Architel Hyal Gold Reserve

I INVESTMENT OBJECTIVES

RISK FACTORS 1

Income 1 Long term growth I Inter term growth 50% i 25% 1 25%


L


Good Quality 50%

Speculative 0%

High Risk 0%

The N M indicates "nil" investment experience. RW transferred $44,3 15 in cash and approximately $17,000 in securities into the RRIF. He transferred $26,681 to the LIRRSP. RW does not complain of the handling of the RRIF by the Respondent. The following speculative purchases were made into the LIRRSP:

Settlement Date

Dec. 8, 1995

, * - I Feb. 28, 1997 ( Hyal I

1$1,110 1 33% 1 33% i

Security Cost

Pharmaceutical Repap

Hyal

At the end of December 1995, the account held 68% speculative and 32% good quality securities. At the end of April 1996, the account held 40% speculative and 60% good quality. At the end of February 1997, the account held 33% speculative and 67% good quality. At the end of August 1997, the account held

Concentration in account

$8,700

I Pharmaceutical Aue. 12. 1997 I Gold Reserve

64% speculative and 36% good quality securities. This balance was maintained until the Respondent left RBC DS in May 1998. By that point, the account had

Concentration of speculative securities in

$8,700

lost more than 50% of the transferred-in value. Even if the two accounts, the RRIF and the LIRRSP, were considered together, the balance of the portfolio as a

34%

S7.040 .

whole is not in keeping with the stated investment objectives. The Respondent

34%

68%

did not ensure that the recommendations made for RW's account were in keeping with his investment objectives. He did not advise RW of the nature or of the risks inherent in the speculative purchases prior to making them.

account 68%

44%

The District Council reviewed the Robinson Letter, however, in the absence of the Respondent filing a Reply or attending the Hearing in person or by counsel to respond to the allegations, the District Council found the Robinson Letter of very limited evidentiary value. The District Council, in its discretion accepts, as it is permitted to do so pursuant to By-law 20.16, the facts alleged and the conclusions drawn by the IDA in the Notice of Hearing and Particulars as having been proven by the IDA.

64%

Penalty

The District Council heard representations from Ms. Abbott with respect to an appropriate penalty. The District Council took particular note of the fact that the violations as proved involved investors who were unsophisticated on investment matters and as a result relied almost entirely on the recommendations and advice of the Respondent. In light of these factors, the District Council agreed with the penalties proposed by Ms. Abbott. It is the decision of the District Council that the following penalties be imposed: *

Costs

With regard to the breaches of Regulation 1300.l(c) as set out in counts 2, 3, 6, 8, 9 and 10 of the Notice of Hearing and Particulars, the Respondent pay a fine of $5,000 per count for a total fine of $30,000;

With respect to the breach of Regulation 1300.1 (a) as set out in count 1 of the Notice of Hearing and Particulars, the Respondent pay a fine of $2,500;

With respect to the breaches of Regulation 1300.l(a) and By-law 29.1 as set out in counts 4 and 7 of the Notice of Hearing and Particulars, the Respondent pay a fine of $5,000 per count for a total fine of $10,000;

With respect to the breach of By-law 29.1 as set out in count 5 of the Notice of Hearing and Particulars, the Respondent pay a fine of $5,000;

The Respondent disgorge the gains he made in respect of the trades contrary to Regulation 1300.1 (c) which total $6,375.62;

If the Respondent is reinstated to membership at any time in the future, he be placed under strict supervision for a period of 12 months followed by close supervision for a further period of

The Respondent membership.

12 months with reports to be filed with the IDA; and

must take and pass the CPH Examination prior to being reinstated to

The District Council heard representations from Ms. Abbott with respect to the payment of costs. Based on the affidavit of Sheila Khakhar, an administrative assistant with the IDA, and the representations of Ms. Abbot, it is the decision of the District Council that the Respondent pay costs in an amount fixed at $25,000.

Dated at Halifax, Province of Nova Scotia, this day of December, 200 1. n

1 STEPHEN B. BISHOP /

Documents

THE The Investment Dealers Association of Canada THE ... · Jerome Grady Stephen B. Bishop ... The Investment Dealers Association of Canada ("IDA") ... Christopher Robinson completed