Robert Davis

The respondent, a U.S.-based internet securities firm, traded U.S. securities on behalf of Canadian residents without being registered in any Canadian jurisdiction.

The respondent acknowledged the breach, which it claimed was due to a good faith but erroneous belief that its non-solicitation of Canadian residents exempted it from registration.

A joint hearing of multiple provincial securities commissions was held to consider a settlement agreement.

The commissions approved the settlement agreement, which included a payment of $550,000 CAD and an undertaking by the respondent's Canadian affiliate to seek registration, finding the sanctions to be in the public interest and proportionate to the misconduct.