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Summary:
IIROC is moving ahead with proposals to introduce a minor contravention program (“MCP”) which would be a middle ground between a cautionary letter and formal disciplinary action. Unlike the original proposal, the MCP would not be available for dealer members but only for Approved Persons (individuals). MCP Notices would be issued for contraventions of IIROC requirements that are isolated and result in limited harm to the public. The MCP would be based on stated criteria for eligibility, and sanctions would be fixed at $5,000 per contravention (an increase from the $2,500 originally proposed). Each case would have to be approved in a streamlined process by a one-member hearing panel. A public notice setting out all matters resolved by way of MCP Notice would be issued quarterly but without identifying the Approved Person. They are also proposing to adopt a staff policy on Early Resolution Offers to complete settlement agreements earlier in the enforcement process based on the stated