Peter Currie

The applicant, a registered representative, sought a review of an IIROC decision finding he facilitated off-book share purchases for two clients without his firm's knowledge and approval.

The central issue was whether the purchasers were 'clients' at the time of the transactions.

The Commission applied a contextual approach, finding that the applicant gave investment advice, directed the transaction through his firm, and the purchasers reasonably believed they were clients.

The Commission concluded the IIROC panel correctly found a client relationship existed and dismissed the application for review.

The respondent, a partner at a global law firm, admitted to engaging in conduct contrary to the public interest by failing to pre-clear trades in securities of a client issuer, in violation of his firm's policy.

Although there was no allegation of insider trading or violation of Ontario securities law, the respondent was in a special relationship with the issuer.

The Ontario Securities Commission approved a settlement agreement between Staff and the respondent, finding the agreed-upon sanctions and costs to be reasonable and in the public interest.