osc bulletin - westlawecarswell.com · samuel ramos, and rahim jiwa) ... csa (small firms, or...

The Ontario Securities Commission

OSC Bulletin

May 18, 2017

Volume 40, Issue 20

(2017), 40 OSCB

The Ontario Securities Commission administers the Securities Act of Ontario (R.S.O. 1990, c. S.5) and the

Commodity Futures Act of Ontario (R.S.O. 1990, c. C.20)

The Ontario Securities Commission Published under the authority of the Commission by: Cadillac Fairview Tower Thomson Reuters 22nd Floor, Box 55 One Corporate Plaza 20 Queen Street West 2075 Kennedy Road Toronto, Ontario Toronto, Ontario M5H 3S8 M1T 3V4 416-593-8314 or Toll Free 1-877-785-1555 416-609-3800 or 1-800-387-5164 Contact Centre – Inquiries, Complaints: Fax: 416-593-8122 TTY: 1-866-827-1295 Office of the Secretary: Fax: 416-593-2318

The OSC Bulletin is published weekly by Thomson Reuters Canada, under the authority of the Ontario Securities Commission. Thomson Reuters Canada offers every issue of the Bulletin, from 1994 onwards, fully searchable on SecuritiesSource™, Canada’s pre-eminent web-based securities resource. SecuritiesSource™ also features comprehensive securities legislation, expert analysis, precedents and a weekly Newsletter. For more information on SecuritiesSource™, as well as ordering information, please go to:

http://www.westlawecarswell.com/SecuritiesSource/News/default.htm

or call Thomson Reuters Canada Customer Support at 1-416-609-3800 (Toronto & International) or 1-800-387-5164 (Toll Free Canada & U.S.). Claims from bona fide subscribers for missing issues will be honoured by Thomson Reuters Canada up to one month from publication date. Space is available in the Ontario Securities Commission Bulletin for advertisements. The publisher will accept advertising aimed at the securities industry or financial community in Canada. Advertisements are limited to tombstone announcements and professional business card announcements by members of, and suppliers to, the financial services industry.

All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, or otherwise without the prior written permission of the publisher.

The publisher is not engaged in rendering legal, accounting or other professional advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. © Copyright 2017 Ontario Securities Commission ISSN 0226-9325 Except Chapter 7 ©CDS INC.

One Corporate Plaza 2075 Kennedy Road Toronto, Ontario M1T 3V4

Customer Support 1-416-609-3800 (Toronto & International)

1-800-387-5164 (Toll Free Canada & U.S.)Fax 1-416-298-5082 (Toronto)

Fax 1-877-750-9041 (Toll Free Canada Only) Email [email protected]

May 18, 2017 (2017), 40 OSCB

Table of Contents

Chapter 1 Notices / News Releases ...................... 4417 1.1 Notices .......................................................... 4417 1.1.1 CSA Staff Notice 31-350 Guidance on Small Firms Compliance and Regulatory Obligations ..................................................... 4417 1.2 Notices of Hearing ........................................ 4424 1.2.1 Eda Marie Agueci et al. – s. 144 ..................... 4424 1.3 Notices of Hearing with Related Statements of Allegations ........................... 4425 1.3.1 Jorge Neher – ss. 127, 127.1 ......................... 4425 1.4 News Releases .............................................. (nil) 1.5 Notices from the Office of the Secretary ............................................ 4428 1.5.1 Benedict Cheng et al. ..................................... 4428 1.5.2 MM Café Franchise Inc. et al. ......................... 4428 1.5.3 Money Gate Mortgage Investment Corporation et al. ............................................ 4429 1.5.4 Eda Marie Agueci et al. .................................. 4429 1.5.5 Jorge Neher .................................................... 4430 1.5.6 Ayaz Dhanani (also known as Azim Virani, Michael Lee, Alex Nebris, Paul Dhanani, Samuel Ramos, and Rahim Jiwa) .................. 4430 1.5.7 Larry Keith Davis ............................................ 4431 1.6 Notices from the Office of the Secretary with Related Statements of Allegations ............................ (nil) Chapter 2 Decisions, Orders and Rulings ............ 4433 2.1 Decisions ...................................................... 4433 2.1.1 Genus Capital Management Inc. .................... 4433 2.2 Orders............................................................ 4439 2.2.1 INFOR Acquisition Corp. ................................ 4439 2.2.2 Money Gate Mortgage Investment Corporation et al. – ss. 127(7), 127(8) ............ 4440 2.2.3 Lexam VG Gold Inc. ....................................... 4440 2.2.4 Dundee Acquisition Ltd. – s. 1(6) of the OBCA .................................... 4441 2.2.5 Dundee Acquisition Ltd. ................................. 4443 2.2.6 Ayaz Dhanani (also known as Azim Virani, Michael Lee, Alex Nebris, Paul Dhanani, Samuel Ramos, and Rahim Jiwa) – ss. 127(1), 127(10) ..................................... 4444 2.2.7 Halogen Software Inc. – s. 1(6) of the OBCA .................................... 4445 2.2.8 Halogen Software Inc. ................................... 4446 2.2.9 Lexam VG Gold Inc. – s. 1(6) of the OBCA .................................... 4447 2.2.10 Larry Keith Davis – ss. 127(1), 127(10) .......... 4449 2.3 Orders with Related Settlement Agreements .................................................... (nil) 2.4 Rulings ........................................................... (nil)

Chapter 3 Reasons: Decisions, Orders and Rulings .................................................. 4451 3.1 OSC Decisions ............................................. 4451 3.1.1 Benedict Cheng et al. – s. 127 ....................... 4451 3.1.2 MM Café Franchise Inc. et al. ........................ 4455 3.1.3 Ayaz Dhanani (also known as Azim Virani, Michael Lee, Alex Nebris, Paul Dhanani, Samuel Ramos, and Rahim Jiwa) – ss. 127(1), 127(10) ..................................... 4457 3.1.4 Larry Keith Davis – ss. 127(1), 127(10) ......... 4462 3.2 Director’s Decisions ...................................... (nil) 3.3 Court Decisions ............................................. (nil) Chapter 4 Cease Trading Orders .......................... 4463 4.1.1 Temporary, Permanent & Rescinding Issuer Cease Trading Orders ......................... 4463 4.2.1 Temporary, Permanent & Rescinding Management Cease Trading Orders ............. 4463 4.2.2 Outstanding Management & Insider Cease Trading Orders ................................... 4463 Chapter 5 Rules and Policies .................................. (nil) Chapter 6 Request for Comments .......................... (nil) Chapter 7 Insider Reporting .................................. 4465 Chapter 9 Legislation ............................................... (nil) Chapter 11 IPOs, New Issues and Secondary Financings ............................................. 4547 Chapter 12 Registrations ......................................... 4555 12.1.1 Registrants ..................................................... 4555 Chapter 13 SROs, Marketplaces,

Clearing Agencies and Trade Repositories ............................... 4557

13.1 SROs ............................................................. 4557 13.1.1 IIROC – Amendments to Dealer Member Rules and Form 1 Relating to the Futures Market Segregation and Portability Customer-Protection Regime – Request for Comment .................................................. 4557 13.2 Marketplaces ................................................ 4558 13.2.1 NEX SEF Limited – Application for Exemption from Recognition as an Exchange – Notice and Request for Comment ....................................................... 4558 13.3 Clearing Agencies ......................................... (nil) 13.4 Trade Repositories ........................................ (nil) Chapter 25 Other Information ................................... (nil) Index ............................................................................ 4593

May 18, 2017

(2017), 40 OSCB 4417

Chapter 1

Notices / News Releases 1.1 Notices 1.1.1 CSA Staff Notice 31-350 Guidance on Small Firms Compliance and Regulatory Obligations

CSA Staff Notice 31-350

Guidance on Small Firms Compliance and Regulatory Obligations

May 18, 2017 Introduction Canadian Securities Administrators staff (CSA staff or we) conducted compliance reviews of small firms registered with the CSA (small firms, or reviewed firms) in one or more of the following categories: investment fund manager (IFM), portfolio manager (PM) and exempt market dealer (EMD). The firms selected were primarily sole proprietorships or firms with one registered individual (i.e., one individual who was registered in a category that authorizes the individual to act as a dealer or an adviser on behalf of the registered firm, or in the case of an IFM, one individual registered as the chief compliance officer (CCO)). Substance and Purpose A registered firm must establish, maintain and apply policies and procedures that establish a system of controls and supervision that provides reasonable assurance the firm and individuals acting for it prudently manage the risks associated with its business. The CSA identifies opportunities to reduce the regulatory burden associated with compliance whenever possible, while balancing the regulatory outcomes it requires. As a result of the compliance reviews, CSA staff have concluded that additional guidance will assist small firms in meeting their compliance and regulatory obligations. Although we intend this notice to provide guidance to small firms, it may be useful to other registrants too. We strongly encourage firms to use this notice as a self-assessment tool to strengthen their compliance with securities legislation. Going forward, CSA staff will continue to monitor firms’ compliance in this area. Scope and Methodology From October 1, 2014 to June 30, 2016, we conducted compliance reviews of 65 small firms. We assessed the firms’ compliance against the requirements in applicable securities legislation, including National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103) and its Companion Policy (31-103CP). Summary of Results The following table sets out common deficiencies identified across all three registration categories and the percentage of small firms with the noted deficiencies we observed during our compliance reviews.

1. Significant business interruptions plan and succession planning – inadequate or missing (35%)

2. Monitoring systems (i.e., inadequate written policies and procedures (71%), incomplete books and records (25%), inadequate marketing materials (15%))

3. CCO annual report – inadequate or missing (29%)

4. Interim financial statements and accounting principles – incorrect accounting method and insufficient procedures (15%)

Notices / News Releases

May 18, 2017

(2017), 40 OSCB 4418

5. Inadequate excess working capital (9%)

6. Inadequate relationship disclosure information (63%)

7. Inadequate collection/documentation of know-your-client information (54%)

8. Non-delivery of or inadequate client statements (45%)

9. Inadequate or outstanding filings to regulators (34%)

Specific Issues and Guidance This notice provides details and guidance with respect to some of the deficiencies noted during our reviews. Specifically, we identified that small firms can be at risk of failing to meet requirements of applicable securities legislation if they do not have: (i) a comprehensive plan to address significant business interruptions and succession issues; (ii) monitoring systems that are reasonably likely to identify non-compliance at an early stage; and (iii) supervisory systems that allow the firm to correct non-compliant conduct in a timely manner. Additional findings noted during our reviews are presented below. 1. Significant Business Interruptions and Succession Planning Small firms often have only one registered individual to operate the business and service clients. This raises concerns regarding the impact on the firm’s clients in the event of the death, incapacitation or prolonged temporary absence of the sole registered individual. For example, if the sole advising representative at a PM is no longer capable of performing his or her registerable duties, client portfolios can no longer be managed by the firm unless the firm is able to register another advising representative. Alternatively, the client will have to engage another PM firm to manage his or her portfolio. In most cases of business interruption, there is a period where the client’s portfolio is not being managed, which could be a significant issue for clients who need to generate income to meet their cash flow needs (e.g., by selling securities). Client portfolios are also at higher risk especially in periods of volatile markets. As a result, business continuity planning is particularly important for small firms that manage client portfolios. It is advisable that a small firm’s plan specifically address issues of significant business interruptions, with an emphasis on the loss of key personnel and succession. Including steps to deal with succession planning when developing a written business continuity plan (BCP) allows firms to mitigate, respond to and recover from significant business interruptions that could impact their ability to provide services to clients. Pursuant to section 11.1 of NI 31-103, firms are required to establish, maintain and apply policies and procedures that establish a system of controls and supervision to ensure compliance with securities legislation and manage the risks associated with their business in accordance with prudent business practices. Section 11.1 of 31-103CP states that an acceptable compliance system includes internal controls to manage business risks, including risks that may relate to business interruption. In order to manage risks related to business interruption, small firms should consider: (i) developing a BCP that is appropriate for their size and business model, (ii) designating an individual to execute the BCP (BCP executor), and (iii) reviewing the BCP annually. When developing a BCP, firms should consider, as applicable to their business models, the following:

• procedures to mitigate, respond to, and recover from business interruptions and other types of disturbances that may disrupt the firm’s day-to-day operations;

• how the firm will communicate with clients, key personnel, third-party service providers, and regulators (e.g.,

provide an alternate means of communication); • procedures to protect, backup and recover the firm’s books and records (e.g., as a result of a cyber-security

incident or natural disaster); • details about the relocation of the firm’s office in the event of a temporary or permanent loss of the firm’s head

office or principal place of business; • the firm’s business succession or wind-down procedures (e.g., assignment of duties to key persons) in the

event of death, incapacitation or prolonged temporary absence of the sole registered individual; • who is responsible for notifying the regulators in the event of death, incapacitation or prolonged temporary

absence of the sole registered individual;


May 18, 2017

(2017), 40 OSCB 4419

• what information clients need to know about the BCP to ensure that it can be properly executed (e.g., by providing clients with the name and contact details of the BCP executor, and explaining to clients how they can access their assets in the event of loss of the firm’s key personnel, or by providing the client with the name and contact details of the relationship manager at the custodian where the clients’ assets are held);

• training of firm employees, including training about their specific duties if the BCP needs to be implemented; • how often the BCP needs to be updated and its effectiveness assessed; and • how the firm will assess the adequacy of the BCPs of outside service providers.

Small firms with only one individual that have no other support or administrative staff may need to designate a BCP executor external to the firm, such as a spouse, relative, legal counsel, or another registrant. When selecting an external BCP executor, firms should consider the capability of the designated individual to carry out this responsibility in the potentially stressful circumstances that would trigger the BCP (e.g., a spouse or relative may not be able to fulfill his or her non-registrable duties under the BCP). Small firms may also consider designating an additional alternate BCP executor, for example, in the event that the spouse of the sole registered individual has also passed away or is incapacitated where he/she was the designated BCP executor. There are circumstances where exemptive relief may be granted to assist in implementing a BCP. For example, while there is a restriction on acting for another registered firm set out in section 4.1 of NI 31-103, we are prepared to consider on a case-by-case basis applications for exemptive relief from the section 4.1 restriction on an expedited basis. In light of the potentially immediate adverse impact to clients, a significant business interruption such as death, incapacitation or prolonged temporary absence of the sole registered individual would likely be a valid business reason for a BCP executor to be registered with more than one registered firm. When working with an external BCP executor, it would be prudent, depending on a small firm’s business model, to ensure that:

• a written agreement is in place so that the BCP executor understands his or her responsibilities; • the BCP executor is familiar with the firm’s BCP; • the BCP executor is familiar with the firm’s business to properly wind down or temporarily manage the small

firm or facilitate the transfer of the firm’s client accounts; • a confidentiality agreement is in place if the BCP executor would have access to confidential client

information; and that the firm has properly pre-arranged client authorization to share this confidential information (e.g., in the relationship disclosure information documentation);

• if the BCP executor is another registrant, conflicts of interest between both firms have been considered (e.g.,

an external BCP executor could be managing clients of two firms in a scenario of temporary absence); and • the BCP executor understands securities legislation and is aware of costs (e.g., costs related to filing an

application for exemptive relief). 2. Monitoring systems Small firms may have resource constraints that make segregation of duties difficult or impossible. These challenges make ensuring good documentation practices and controls especially important for small firms in order to demonstrate good compliance. All firms must maintain records to accurately record business activities, financial affairs, and client transactions, and demonstrate the extent of a firm’s compliance with applicable requirements of securities legislation. In addition to maintaining books and records, firms must establish, maintain and apply policies and procedures that establish a system of controls and supervision sufficient to:

(i) provide reasonable assurance that the firm and each individual acting on its behalf comply with securities legislation; and

(ii) manage the risks associated with its business in accordance with prudent business practices.

Some reviewed firms that employ other non-registered staff (e.g., research analysts, relationship managers, administrative or support staff) did not establish, maintain and apply policies and procedures to establish such a system of controls and supervision.


May 18, 2017

(2017), 40 OSCB 4420

Small firms are encouraged to consider employing non-registered staff or using technology to perform additional verification procedures. For example, non-registered staff can proofread documents, double-check calculations, and verify that the registered advising or dealing representative has completed the know-your-client and other client forms. In some cases, firms may also find it helpful to use software or other tools to ensure the accuracy of their data (e.g., when calculating net asset values, return of capital, etc.). We remind small firms that as the size and scope of their business operations expand, they should be mindful of each individual’s duties and responsibilities and apply to register those individuals that are required to be registered under securities legislation (e.g., as an associate advising representative or dealing representative). Books and Records CSA staff found that the reviewed firms often did not maintain internal books and records to evidence the due diligence conducted to support their business activities. For example, they did not:

• record the investment decisions made; • prepare and maintain trade orders and trade blotters; • record the review and approval of marketing materials; • retain signed agreements with service providers; • retain signed subscription agreements between the firm’s clients and issuers; or • maintain records to evidence the reconciliation of client portfolio positions to custodian records.

The reviewed firms often did not maintain adequate books and records to evidence compliance with securities legislation and with the firm’s own policies and procedures. While firms may use the books and records of other parties (e.g., custodian) to reconcile their books and records, the registrant is ultimately responsible for maintaining their own separate set of books and records. Written Policies and Procedures CSA staff found that the reviewed firms often did not have adequate policies and procedures. For example, firms that are registered in multiple registration categories should develop policies and procedures governing all of the key functions relating to each registration category and a firm that is registered as an IFM should have specific policies and procedures related to core IFM business operations (i.e., fund accounting, transfer agent and trust accounting functions). If these functions are performed by third-party service providers, the firm should develop written oversight procedures and document how adequately the service providers are performing these outsourced functions. CSA staff found that the reviewed firms often did not have policies and procedures with respect to personal trading. Specifically, there was no documentation or evidence of a review/process in place to ensure that clients were treated fairly. All registrants must have policies and procedures to respond to conflicts of interest, such as those arising from personal trading. 3. CCO Annual Report The CCO must assess the overall compliance structure and internal controls at the firm at least annually. Questions about the adequacy of the firm’s compliance system, and whether the CCO is adequately performing his or her responsibilities may arise when the CCO has not drafted an annual compliance report, or submits a perfunctory report that concludes that the firm has complied with securities legislation without support for how this assessment was made. We would suggest that the CCO should describe in the report the steps that were taken to perform the assessment, the results of the assessment (including any significant instances of non-compliance such as those that create a risk of harm to a client or the capital markets), and what has been done or will be done to address the non-compliance. The CCO of a small firm can meet the annual report requirement by documenting this assessment in the firm’s board of directors’ minutes. 4. Interim Financial Statements and Accounting Principles All firms, including small firms, may have deficiencies with respect to their financial statements, use of accounting principles, or excess working capital calculations. We believe that the guidance set out in below will assist all firms in strengthening their policies and procedures in this area and their overall compliance with securities legislation.


May 18, 2017

(2017), 40 OSCB 4421

Firms should have detailed written financial policies and procedures clearly outlining who is expected to do what, when and how. For instance, firms that outsource to third parties or rely on staff to perform accounting functions should establish procedures that indicate who prepares and calculates the financial records, how they are calculated, who reviews and approves calculations and results, and when each of these activities occurs. Firms with only one individual should at a minimum develop procedures to state when and what financial records will be prepared. CSA staff found that some reviewed firms applied the cash basis accounting method instead of the accrual basis accounting method. For instance, firms were not accruing revenues as they were earned; instead, they were waiting for when cash was received to recognize revenues. Similarly, expenses were not being accrued as they were incurred; instead, they were expensed when paid. For example, if you are aware of an expense incurred for legal costs, but have not received the invoice, the expected amount of the legal expense should be accrued during the month it was incurred and not when the invoice is received. A firm’s financial statements must comply with required accounting principles (as defined in National Instrument 52-107 Acceptable Accounting Principles and Auditing Standards) in order to ensure that the firm’s resulting working capital calculation accurately reflects the firm’s actual capital position. Firms should review the guidance provided in:

• sections 12.10 to 12.11 of 31-103CP, and • section 2.7 of the Companion Policy to National Instrument 52-107 Acceptable Accounting Principles and

Auditing Standards.

5. Inadequate Excess Working Capital Firms must properly complete Form 31-103F1 Calculation of Excess Working Capital (the Form) to ensure that all working capital calculations are accurate at all times. Some reviewed firms had inadequate excess working capital during the period covered by our compliance reviews. These firms often did not perform their working capital calculations with sufficient frequency and, accordingly, were not aware of their working capital position at all times. While these firms often maintained a nominal amount of excess working capital, as expenses were incurred it caused a working capital deficiency. In this scenario, a firm might need to calculate its excess working capital position on a more frequent basis, such as daily or weekly. When some firms failed to maintain accounting records, this resulted in a failure to monitor the firm’s working capital position except during the annual audit. Since there were no accounting records available for review, CSA staff were not able to determine if the firm applied proper accounting treatment. CSA Staff also found that some firms did not follow the instructions set out in the Form. For example, a firm held investments but did not make the appropriate deduction for market risk under Line 9 of the Form. In other instances, firms did not deliver in a timely manner to the principal regulator the subordination agreements relating to related party debt that was excluded from the calculation of excess working capital. Guidance on how to properly complete the Form is provided in sections 12.1 and 12.2 of 31-103CP. Lastly, firms should include procedures for when and if a working capital deficiency should occur, indicating who is responsible for rectifying the deficiency and how the deficiency would be reported to the applicable regulator as soon as possible. Additional Guidance This notice provides guidance with respect to deficiencies which in our view may present particular challenges for small firms. We also refer firms to the following guidance with respect to other common deficiencies identified in our compliance reviews:

• CSA Staff Notice 31-336 Guidance for Portfolio Managers, Exempt Market Dealers and Other Registrants on the Know-Your-Client, Know-Your-Product and Suitability Obligations;

• CSA Staff Notice 31-334 CSA Review of Relationship Disclosure Practices; • section 14.14 of 31-103CP; • CSA Staff Notice 31-347 Guidance for Portfolio Managers for Service Arrangements with IIROC Dealer

Members; • National Instrument 33-109 Registration Information;


May 18, 2017

(2017), 40 OSCB 4422

• section 11.9 or 11.10 of NI 31-103; • section 13.4 of 31-103CP under the heading Individuals who have outside business activities; and • CSA Staff Notice 31-325 Marketing Practices of Portfolio Managers.

Conclusion All firms, including small firms, are encouraged to meet or exceed industry best practices in complying with regulatory requirements and to have policies, procedures and systems that are appropriate to their size and business model. The CSA will continue to review and evaluate firms’ compliance with securities legislation. Firms can keep up-to-date on regulatory developments by actively reviewing staff notices and publications, participating in information outreach sessions organized by various CSA members, and signing up for mailings from the various CSA members. Questions Please refer your questions to any of the following: Curtis Brezinski Compliance Auditor, Capital Markets, Securities Division Financial and Consumer Affairs Authority of Saskatchewan 306-787-5876 [email protected] Angela Duong Compliance Auditor Manitoba Securities Commission 204-945-8973 [email protected] Reid Hoglund Regulatory Analyst Alberta Securities Commission 403-297-2991 [email protected] To-Linh Huynh Senior Analyst Financial and Consumer Services Commission (New Brunswick) 506-643-7856 [email protected] Éric Jacob Directeur principal de l’inspection Autorité des marchés financiers 514-395-0337, extension 4741 [email protected] Jonathan Lee Senior Compliance Analyst British Columbia Securities Commission 604-899-6670 [email protected] Janice Leung Manager, Adviser/IFM Compliance British Columbia Securities Commission 604-899-6752 [email protected]


May 18, 2017

(2017), 40 OSCB 4423

Susan Pawelek Accountant Compliance and Registrant Regulation Ontario Securities Commission 416-593-3680 [email protected] Chris Pottie Manager, Compliance and SRO Oversight Policy and Market Regulation Branch Nova Scotia Securities Commission 902-424-5393 [email protected] Kat Szybiak Senior Legal Counsel Compliance and Registrant Regulation Ontario Securities Commission 416-593-3686 [email protected] Craig Whalen Manager of Licensing, Registration and Compliance Office of the Superintendent of Securities Newfoundland and Labrador 709-729-5661 [email protected]


May 18, 2017

(2017), 40 OSCB 4424

1.2 Notices of Hearing

1.2.1 Eda Marie Agueci et al. – s. 144

IN THE MATTER OF EDA MARIE AGUECI, DENNIS WING,

SANTO IACONO, JOSEPHINE RAPONI, KIMBERLEY STEPHANY, HENRY FIORILLO, GIUSEPPE (JOSEPH) FIORINI, JOHN SERPA,

IAN TELFER, JACOB GORNITZKI and POLLEN SERVICES LIMITED

NOTICE OF HEARING (Section 144 of the Securities Act, RSO 1990, c S.5)

WHEREAS on June 24, 2015, the Ontario Securities Commission made an Order (the “Order”) under sections 127 and 127.1 of the Securities Act, RSO 1990, c S.5 (the “Act”) relating to sanctions and costs against Eda Marie Agueci (“Agueci”), Dennis Wing, Kimberley Stephany, Henry Fiorillo (“Fiorillo”) and Pollen Services Limited (collectively, the “Respondents”);

AND WHEREAS on November 30, 2015, the Commission granted an application by Agueci to vary the Order pursuant to section 144 of the Act and the Commission amended the Order to allow Agueci to liquidate certain securities and to direct a payment to the Commission in compliance with the Order;

TAKE NOTICE that the Commission will hold a hearing pursuant to section 144 of the Act to consider whether, in the Commission’s opinion, it would not be prejudicial to the public interest to make an order:

1. varying the Order, as amended, to:

a. allow Fiorillo to trade and/or acquire mutual funds, exchange-traded funds, government bonds and/or guaranteed investment certificates for the account of his Individual Pension Plan, subject to the terms set out in paragraph 3(c)(iii) of the Order;

b. specifically include “hedge fund manager(s)” as permitted to manage Fiorillo’s securities holdings, subject to the terms set out in paragraph 3(d) of the Order; and

c. allow Fiorillo to invest in non-securities related businesses operated either by Fiorillo or Fiorillo’s family members, provided that advance notice of thirty days is given to the Commission prior to the investment; and

2. for such further and other relief as Fiorillo may request and the Commission may permit;

BY REASON OF the application record filed by Fiorillo on May 3, 2017 requesting a variation to the Order, as amended, including the Affidavit of Fiorillo sworn March 10, 2017 and the Consent executed on behalf of all parties except for Pollen Services Limited;

AND TAKE FURTHER NOTICE that Fiorillo requested that the application be heard in writing, pursuant to Rule 15.5 of the Ontario Securities Commission Rules of Procedure (2014), 37 OSCB 4168 (the “Rules”), and that Staff of the Commission and the Respondents, except for Pollen Services Limited, have consented to the variation sought to the Order;

AND TAKE FURTHER NOTICE that any party to the proceeding may be represented by a representative at the hearing;

AND TAKE FURTHER NOTICE that the Notice of Hearing is also available in French on request of a party, participation may be in either French or English and participants must notify the Secretary’s Office in writing as soon as possible, and in any event, at least thirty (30) days before a hearing if the participant is requesting a proceeding to be conducted wholly or partly in French; and

ET AVIS EST ÉGALEMENT DONNÉ PAR LA PRÉSENTE que l'avis d'audience est disponible en français sur demande d’une partie, que la participation à l'audience peut se faire en français ou en anglais et que les participants doivent aviser le Bureau du secrétaire par écrit le plut tôt possible et, dans tous les cas, au moins trente (30) jours avant l'audience si le participant demande qu'une instance soit tenue entièrement ou partiellement en français.

DATED at Toronto this 12th day of May, 2017.

“Grace Knakowski” Secretary to the Commission


May 18, 2017

(2017), 40 OSCB 4425

1.3 Notices of Hearing with Related Statements of Allegations 1.3.1 Jorge Neher – ss. 127, 127.1

IN THE MATTER OF JORGE NEHER

NOTICE OF HEARING

(Sections 127 and 127.1 of the Securities Act, RSO 1990, c S.5) TAKE NOTICE that the Ontario Securities Commission will hold a hearing pursuant to sections 127 and 127.1 of the Securities Act, RSO 1990, c S.5, at the offices of the Commission located at 20 Queen Street West, 17th Floor, Toronto, commencing on May 16, 2017 at 3:30 p.m. or as soon thereafter as the hearing can be held; AND TAKE FURTHER NOTICE that the purpose of the hearing is for the Commission to consider whether it is in the public interest to approve the Settlement Agreement dated May 12, 2017 between Staff of the Commission and Jorge Neher; BY REASON OF the allegations set out in the Statement of Allegations of Staff of the Commission dated May 12, 2017 and such additional allegations as counsel may advise and the Commission may permit; AND TAKE FURTHER NOTICE that any party to the proceeding may be represented by a representative at the hearing; AND TAKE FURTHER NOTICE that upon failure of any party to attend at the time and place aforesaid, the hearing may proceed in the absence of that party, and such party is not entitled to any further notice of the proceedings. DATED at Toronto, this 12th day of May, 2017. “Grace Knakowski” Secretary to the Commission


May 18, 2017

(2017), 40 OSCB 4426

IN THE MATTER OF THE SECURITIES ACT,

R.S.O. 1990, c. S.5, AS AMENDED

AND

IN THE MATTER OF JORGE NEHER

STATEMENT OF ALLEGATIONS OF

STAFF OF THE ONTARIO SECURITIES COMMISSION Staff of the Ontario Securities Commission (“Staff”) make the following allegations: A. Overview 1. This matter concerns the failure by Jorge Neher (“Neher”) to comply with important policies in place at his firm aimed at

maintaining the integrity of capital markets by ensuring confidential, material information is safeguarded and that trading is appropriately restricted in order to prevent impropriety or the appearance of impropriety.

B. The Respondent(s) 2. In the relevant period of 2014-2015, Neher was a partner in the Bogota, Colombia office of Norton Rose Fulbright

(“NRF”), a major international law firm. 3. Neher was the lead partner for a firm client, which was an Ontario reporting issuer. C. Background to Allegations NRF Policies 4. On October 29, 2014, Neher was sent an email that also went to all members of NRF attaching a copy of the newly-

adopted Norton Rose Fulbright Global Practices Standards policy by email. The policy applied worldwide to all members of the firm, including partners. The policy included policies on trading in publicly-listed securities (the “Trading Policy”). The Bogota office had not previously been subject to a similar policy regarding trading in publicly-listed securities.

5. The Trading Policy notes that a fundamental principle of securities legislation is that everyone investing in securities

should have equal access to information that may affect their decision to trade in securities. The Trading Policy also notes:

Firm members, whether lawyers, agents or staff member, will undoubtedly become aware of material undisclosed information in the conduct of the firm’s business, either concerning a client or concerning a public company with which a client is dealing. It is critical that firm members preserve and maintain the confidentiality of this material undisclosed information and do not disclose this information to any third parties, except in accordance with applicable securities laws…This policy is designed to assist in preventing any impropriety or the appearance of any impropriety regarding a firm member trading in securities of a public company.

6. Further, the Trading Policy sets out, among other obligations: (a) Firm members are required to report when they possess material, undisclosed information with respect to

publicly-listed entities so that those entities could be added to the Black Book, a list of issuers for which trading of securities is prohibited; and

(b) Pre-clearance is required prior to any purchase or sale of securities of a public company or related derivative.

7. Despite being sent the October 29, 2014 email, Neher failed in his obligations to read, understand and comply with the Trading Policy as set out below.


May 18, 2017

(2017), 40 OSCB 4427

Prohibited Trading by Neher 8. After the Trading Policy had been sent to him, Neher failed to seek pre-clearance of trades in shares of the client,

which were conducted through a trading account located in Toronto, as required by the Trading Policy. This included purchases of the client’s securities while those purchases were expressly prohibited due to the client having been placed on NRF’s Black Book list. Neher had no personal knowledge that the client had been placed on this list, although he would have known this had he followed the Trading Policy. Neher’s trades were part of an investment strategy in shares of the client that he had pursued since April 2014, before the Trading Policy was adopted and sent to him.

Importance of Trading Policies to the Public Interest 9. Policies like the Trading Policy are an important part of maintaining the integrity of capital markets by ensuring

confidential, material information is safeguarded and that trading is appropriately restricted in order to prevent impropriety or the appearance of impropriety.

10. As a lawyer, Neher was in a position of trust and is subject to a high professional standard to avoid any appearance of

conflicts of interest and any appearance of misuse of confidential information obtained in the course of the solicitor-client relationship. Neher should have taken reasonable steps to ensure that he was complying with NRF’s policies before trading in publicly-listed securities of a client.

D. Conduct Contrary to the Public Interest 11. Neher’s conduct was contrary to the public interest as he failed to adhere to the high standard of conduct expected of

him in the circumstances. 12. Staff reserve the right to make such other allegations as Staff may advise and the Commission may permit. DATED at Toronto, this 12th day of May, 2017.


May 18, 2017

(2017), 40 OSCB 4428

1.5 Notices from the Office of the Secretary 1.5.1 Benedict Cheng et al.

FOR IMMEDIATE RELEASE May 11, 2017

IN THE MATTER OF

THE SECURITIES ACT, RSO 1990, c S.5

AND

IN THE MATTER OF BENEDICT CHENG,

FRANK SOAVE, JOHN DAVID ROTHSTEIN and

ERIC TREMBLAY TORONTO – The Commission issued its Reasons and Decision on Settlement following the Settlement Hearing held in the above named matter. A copy of the Reasons and Decision on Settlement dated May 10, 2017 is available at www.osc.gov.on.ca. OFFICE OF THE SECRETARY GRACE KNAKOWSKI SECRETARY TO THE COMMISSION For media inquiries: [email protected] For investor inquiries: OSC Contact Centre 416-593-8314 1-877-785-1555 (Toll Free)

1.5.2 MM Café Franchise Inc. et al.


IN THE MATTER OF


AND

IN THE MATTER OF

MM CAFÉ FRANCHISE INC., TECHOCAN INTERNATIONAL CO. LTD.,

1727350 ONTARIO LIMITED, MARIANNE GODWIN,

DAVE GARNET CRAIG and HAIYAN (HELEN) GAO JORDAN

TORONTO – The Commission issued its Oral Reasons for Approval of a Settlement following a Settlement Hearing held in the above-named matter. A copy of the Oral Reasons for Approval of a Settlement dated April 24, 2017 is available at www.osc.gov.on.ca. OFFICE OF THE SECRETARY GRACE KNAKOWSKI SECRETARY TO THE COMMISSION For media inquiries: [email protected] For investor inquiries: OSC Contact Centre 416-593-8314 1-877-785-1555 (Toll Free)


May 18, 2017

(2017), 40 OSCB 4429

1.5.3 Money Gate Mortgage Investment Corporation et al.

FOR IMMEDIATE RELEASE

May 11, 2017


RSO 1990, c S.5

AND

IN THE MATTER OF MONEY GATE MORTGAGE

INVESTMENT CORPORATION, MONEY GATE CORP.,

MORTEZA KATEBIAN and PAYAM KATEBIAN

TORONTO – The Commission issued an Order in the above named matter which provides that:

1. pursuant to subsection 127(8) of the Act, Staff’s application to extend paragraph 1 of the Temporary Order to May 30, 2017, is granted;

2. the hearing of Staff’s application to

extend paragraph 2 of the Temporary Order shall continue on May 29, 2017 at 10:00a.m., and pursuant to subsection 127(7) of the Act, paragraph 2 of the Temporary Order is extended to the conclusion of that hearing; and

3. this proceeding is adjourned until May

29, 2017, at 10:00 a.m. A copy of the Order dated May 11, 2017 is available at www.osc.gov.on.ca. OFFICE OF THE SECRETARY GRACE KNAKOWSKI SECRETARY TO THE COMMISSION For media inquiries: [email protected] For investor inquiries: OSC Contact Centre 416-593-8314 1-877-785-1555 (Toll Free)

1.5.4 Eda Marie Agueci et al.


IN THE MATTER OF

EDA MARIE AGUECI, DENNIS WING, SANTO IACONO, JOSEPHINE RAPONI,

KIMBERLEY STEPHANY, HENRY FIORILLO, GIUSEPPE (JOSEPH) FIORINI, JOHN SERPA,

IAN TELFER, JACOB GORNITZKI and POLLEN SERVICES LIMITED

TORONTO – The Commission issued a Notice of Hearing for a hearing to consider an application made pursuant to section 144 of the Act to vary an Order issued June 24, 2015 in the above matter. A copy of the Notice of Hearing dated May 12, 2017 is available at www.osc.gov.on.ca. OFFICE OF THE SECRETARY GRACE KNAKOWSKI SECRETARY TO THE COMMISSION For media inquiries: [email protected] For investor inquiries: OSC Contact Centre 416-593-8314 1-877-785-1555 (Toll Free)


May 18, 2017

(2017), 40 OSCB 4430

1.5.5 Jorge Neher


IN THE MATTER OF

JORGE NEHER TORONTO – The Office of the Secretary issued a Notice of Hearing for a hearing to consider whether it is in the public interest to approve a settlement agreement entered into by Staff of the Commission and Jorge Neher. The hearing will be held on May 16, 2017 at 3:30 p.m. on the 17th floor of the Commission's offices located at 20 Queen Street West, Toronto. A copy of the Notice of Hearing dated May 12, 2017 and Statement of Allegations of Staff of the Ontario Securities Commission dated May 12, 2017 are available at www.osc.gov.on.ca. OFFICE OF THE SECRETARY GRACE KNAKOWSKI SECRETARY TO THE COMMISSION For media inquiries: [email protected] For investor inquiries: OSC Contact Centre 416-593-8314 1-877-785-1555 (Toll Free)

1.5.6 Ayaz Dhanani (also known as Azim Virani, Michael Lee, Alex Nebris, Paul Dhanani, Samuel Ramos, and Rahim Jiwa)

FOR IMMEDIATE RELEASE

May 15, 2017

IN THE MATTER OF AYAZ DHANANI (also known as AZIM VIRANI,

MICHAEL LEE, ALEX NEBRIS, PAUL DHANANI, SAMUEL RAMOS, and RAHIM JIWA)

TORONTO – The Commission issued its Decision and Reasons and an Order pursuant to Subsections 127(1) and 127(10) of the Securities Act in the above noted matter. A copy of the Decision and Reasons and the Order dated May 15, 2017 are available at www.osc.gov.on.ca. OFFICE OF THE SECRETARY GRACE KNAKOWSKI SECRETARY TO THE COMMISSION For media inquiries: [email protected] For investor inquiries: OSC Contact Centre 416-593-8314 1-877-785-1555 (Toll Free)


May 18, 2017

(2017), 40 OSCB 4431

1.5.7 Larry Keith Davis


IN THE MATTER OF

LARRY KEITH DAVIS TORONTO – The Commission issued its Reasons and an Order pursuant to Subsections 127(1) and 127(10) of the Securities Act in the above noted matter. A copy of the Reasons and the Order dated May 15, 2017 are available at www.osc.gov.on.ca. OFFICE OF THE SECRETARY GRACE KNAKOWSKI SECRETARY TO THE COMMISSION For media inquiries: [email protected] For investor inquiries: OSC Contact Centre 416-593-8314 1-877-785-1555 (Toll Free)


May 18, 2017

(2017), 40 OSCB 4432

This page intentionally left blank

May 18, 2017

(2017), 40 OSCB 4433

Chapter 2

Decisions, Orders and Rulings 2.1 Decisions 2.1.1 Genus Capital Management Inc. Headnote National Policy 11-203 Process for Exemptive Relief in Multiple Jurisdictions – Plan Sponsors, CAP Members, and named service provider exempted from the dealer registration and prospectus requirements in the Legislation in respect of trades in securities of mutual funds to tax-assisted and non-tax assisted savings plans (which act as ‘overflow’ savings plans connected to tax-assisted capital accumulation plans serviced by the same service provider), subject to certain terms and conditions – contributions to the non-tax assisted savings plans limited by reference to specified limits in the Income Tax Act (Canada). Applicable Legislative Provisions Statutes Cited Securities Act, R.S.O. 1990, c. S.5, as am., ss. 25(1)(a), 53, 74(1). Rules Cited National Instrument 81-101 Mutual Fund Prospectus Disclosure. National Instrument 81-102 Investment Funds. National Instrument 45-106 Prospectus and Registration Exemptions. Published Documents Cited Amendments to NI 45-106 Registration and Prospectus Exemption for Certain Capital Accumulation Plans, October 21, 2005 (2005), 25 OSCB 8681.

April 21, 2017

IN THE MATTER OF THE SECURITIES LEGISLATION OF

ONTARIO (the Jurisdiction)

AND

IN THE MATTER OF

THE PROCESS FOR EXEMPTIVE RELIEF APPLICATIONS IN MULTIPLE JURISDICTIONS

AND

IN THE MATTER OF

GENUS CAPITAL MANAGEMENT INC. (the Filer)

DECISION

Background The principal regulator in the Jurisdiction has received an application from the Filer for a decision, on behalf of the Filer (including its respective directors, officers, representatives and employees acting on its behalf), any Plan Sponsor (as defined herein) and any Fund (as defined herein), under the securities legislation of the Jurisdiction of the principal regulator (the Legislation) for a ruling that:

Decisions, Orders and Rulings

May 18, 2017

(2017), 40 OSCB 4434

(a) the dealer registration requirements contained in the Legislation shall not apply to the Filer (including its respective directors, officers, representatives and employees acting on its behalf) or any Plan Sponsor of a CAP (as defined herein) or a Non-Tax Assisted CAP (as defined herein) that uses the services of the Filer in respect of its CAP or Non-Tax Assisted CAP in respect of trades in the securities of the Funds to a CAP or a Non-Tax Assisted CAP sponsored by the Plan Sponsor for which the Filer provides services, subject to certain terms and conditions (the Dealer Registration Relief); and

(b) the prospectus requirements contained in the Legislation shall not apply in respect of the distribution of

securities of Funds to CAPs or Non-Tax Assisted CAPs sponsored by a Plan Sponsor for which the Filer provides services (the Prospectus Relief),

(the Dealer Registration Relief and the Prospectus Relief are collectively, the Exemption Sought). Under the Process for Exemptive Relief Applications in Multiple Jurisdictions (for a passport application):

(a) the Ontario Securities Commission is the principal regulator for this application, and (b) the Filer has provided notice that subsection 4.7(1) of Multilateral Instrument 11-102 Passport System (MI 11-

102) is intended to be relied upon in the jurisdictions of (i) Québec, Newfoundland and Labrador, the Yukon Territory and Nunavut in respect of the Exemption Sought with respect to CAPs and (ii) Alberta, British Columbia, Saskatchewan, Manitoba, Québec, New Brunswick, Nova Scotia, Prince Edward Island, Newfoundland and Labrador, Nunavut, the Yukon Territory and the Northwest Territories in respect of the Exemption Sought with respect to Non-Tax Assisted CAPs.

Interpretation Terms defined in National Instrument 14-101 Definitions and MI 11-102 have the same meaning if used in this decision, unless otherwise defined. For the purposes of this decision, the following terms have the following meanings:

(a) CAP has the meaning given to the term “capital accumulation plan” as defined in section 1.1 of the CAP

Guidelines (as defined herein), namely, a tax assisted investment or savings plan that permits the members of the CAP to make investment decisions among two or more options offered within the plan. CAPs include a defined contribution registered pension plan, a group registered retirement savings plan, a group registered education savings plan, a group tax-free savings plan or a deferred profit sharing plan, and in Québec and Manitoba, include a simplified pension plan.

(b) CAP Guidelines means the Guidelines for Capital Accumulation Plans published in May 2004 by the Joint

Forum of Financial Market Regulators, as updated in 2009 and 2010. (c) Fund means a mutual fund as defined in section 1 of the Legislation, whether offered by prospectus or

pursuant to prospectus exemptions in the Legislation, and which in both cases, comply with Part 2 of National Instrument 81-102 Investment Funds (NI 81-102) and are established and managed by the Filer, but does not include an exchange-traded fund.

(d) Member means a current or former employee, or a person who belongs, or did belong, to a trade union or

association, or (i) his or her spouse (ii) a trustee, custodian or administrator who is acting on his or her behalf, or for his or her benefit, or on

behalf of, or for the benefit of, his or her spouse or (iii) his or her holding entity, or a holding entity of his or her spouse that has assets in a CAP or a Non-Tax Assisted CAP and also includes any person who is eligible to participate in a CAP or Non-Tax Assisted CAP.

(e) Non-Tax Assisted CAP means an investment or savings plan that meets the definition of CAP in the CAP Guidelines and that is administered in accordance with the CAP Guidelines, but for the fact that it is an investment or savings plan that is non-tax assisted.


May 18, 2017

(2017), 40 OSCB 4435

(f) Plan means, depending on the context in which it is used, a CAP or a Non-Tax Assisted CAP or both of them. (g) Plan Sponsor means any employer, trustee, trade union or association or a combination of them that

establishes a CAP or a Non-Tax Assisted CAP and uses the services of the Filer in respect of such CAP or Non-Tax Assisted CAP, and includes the Filer to the extent that the Plan Sponsor has delegated some or all of its responsibilities to the Filer.

Representations This decision is based on the following facts represented by the Filer: 1. The Filer is a corporation organized under the laws of British Columbia with its head office in Vancouver, British

Columbia. The Filer is registered in British Columbia, Alberta, Manitoba, Ontario, Québec, Nova Scotia, New Brunswick, Newfoundland and Labrador, Prince Edward Island and the Yukon as a portfolio manager and an exempt market dealer, and in British Columbia, Ontario and Québec as an investment fund manager.

2. The Filer’s principal business is to provide investment management services through pooled funds and specialty equity

and fixed income investment portfolios, to individuals, families, foundations, endowments, not-for-profit organizations, institutions and multi-employer pension and benefit plans. The Filer serves as the manager and principal portfolio manager for each of its pooled funds, and for certain of its funds has retained arm’s length sub-advisors for all or a portion of the assets of the funds. The Filer expects to establish additional pooled funds, as well as prospectus qualified mutual funds, in the future.

3. The Filer intends to assist Plan Sponsors in initial Plan design and set up and may provide non-discretionary advice to

Plan Sponsors, including doing research and providing recommendations regarding investments Plan Sponsors might select as investment options within a Plan.

4. The investment options for the Members of Plans will include Funds and may also include other investment options,

such as segregated funds managed by insurance companies. Where the investment options include Funds, the Funds will comply with Part 2 of NI 81-102 in respect of its investment restrictions and practices. None of the Funds will be exchange-traded funds.

5. The services that the Filer provides to Plan Sponsors may also include recordkeeping of Member data, transactions

processing in respect of Member accounts, provision of Member statements as required under pension standards legislation and/or the applicable recordkeeping agreement, and processing changes to Member accounts such as termination, death, retirement or change in marital status.

6. The Filer will not engage in discretionary decision-making with respect to Plans or Member accounts, and will not select

investments for the Plans or Member accounts or provide investment advice to Members. The Filer does not provide custodial services in respect of the Plans or the Funds.

7. The Filer intends to only service Plans which, to the extent that they offer investment funds as investment options

within the Plans, will only offer the Filer’s proprietary funds as investment options within the Plan. As such, the Plans could offer other investment options (e.g. segregated funds), but the only investment funds offered therein would be those established and managed by the Filer.

8. Members will make initial investment decisions to invest in Funds chosen by the Plan Sponsor, although the Plan

Sponsor may establish a default option if the Member fails to make an investment choice, and subsequent changes to those investment decisions, with or without the assistance of an advisor selected by the Member (which will not be the Filer). Plan Sponsors may facilitate access to a registrant for advice to Members. The applicable investment instructions of Members will be transmitted to the Filer. The interest in the securities of Funds will be registered in the name of the applicable Plan Sponsor or the Filer for the account of the relevant Plan. The Filer will process the trades in the Funds as instructed and will establish and maintain the records reflecting the interest of each Member or Plan Sponsor, as the case may be, in each Fund and for each Plan.

9. The Filer will also allow Members to call the Filer for information about the Plan and will facilitate access to a variety of

self-help tools that allow Members to make investment decisions regarding their investments held through the Plans. 10. The Filer, the Plan Sponsors and the Funds will trade within the Plans or to Members of the Plans in accordance with

the conditions set out in proposed amendments to National Instrument 45-106 Prospectus Exemptions related to CAPs, which were published by the Canadian Securities Administrators (the CSA) on October 21, 2005 (the Proposed CAP Exemption) and adopted in the form of a blanket exemption in all jurisdictions, other than in Ontario, Québec, Newfoundland and Labrador, the Yukon Territory and Nunavut (the CAP Blanket Exemption). The Proposed CAP


May 18, 2017

(2017), 40 OSCB 4436

Exemption and the CAP Blanket Exemption contemplate both dealer registration and prospectus exemptions, where required.

11. Although no equivalent to the CAP Blanket Exemption has been adopted in the jurisdictions of Ontario, Québec,

Newfoundland and Labrador, the Yukon Territory and Nunavut, CSA Notice 81-405 Request for Comment on Proposed Exemptions for Certain Capital Accumulation Plans published (the CAP Staff Notice) states that, in Ontario, the conditions described in the Proposed CAP Exemption will form the basis of the circumstances in which staff of the Ontario Securities Commission expects that they could recommend that the Ontario Securities Commission grant discretionary relief to an applicant. The jurisdictions in which no equivalent to the CAP Blanket Exemption was adopted made it clear that they would be prepared to grant discretionary relief on terms similar to those contained in the Proposed CAP Exemption. The CAP Staff Notice stated that the purpose of the Proposed CAP Exemption was to remove existing barriers to trading mutual fund securities with members of CAPs where there is no valid regulatory reason for having such barriers.

12. As Plan Sponsors will typically approach consultants, such as the Filer, for assistance with respect to securities

regulatory issues (when the investment choices are Funds), the Filer is seeking an exemption on behalf of the Filer, Plan Sponsors and Funds, as applicable, from the dealer registration and prospectus requirements, including the obligation to deliver a prospectus, where required, provided the conditions as described in this decision are adhered to.

13. The Filer is not in default of securities legislation in any jurisdiction. 14. The Filer may be requested by a Plan Sponsor to provide services to a Non-Tax Assisted CAP established by the Plan

Sponsor for the benefit of individual Members. These Non-Tax Assisted CAPs would not constitute CAPs, as defined in the CAP Guidelines, the Proposed CAP Exemption or the CAP Blanket Exemption, since they are not “tax-assisted” under applicable legislation. Non-Tax Assisted CAPs are intended as non-registered employee savings plans to which excess contributions of Members that cannot be invested in a CAP because of legislative limits for such CAP investments will be invested on behalf of the Members.

15. Non-Tax Assisted CAPs are established in conjunction with CAPs because Canadian tax legislation imposes a limit on

the amounts that may be contributed to a CAP. The benefit formula under a Plan Sponsor’s benefit program sometimes results in contributions that exceed that tax limit. A Plan Sponsor may establish a Non-Tax Assisted CAP to allow for those excess contributions to be invested in the same manner as the tax assisted contributions. These excess contributions to Non-Tax Assisted CAPs are not expected to be significant and in any event will be limited by the calculation set out in the conditions to this decision and subject to the remaining conditions set out in this decision.

16. Non-Tax Assisted CAPs will operate in the same manner as CAPs in terms of the relationship between Members and

Plan Sponsors, and the duties, rights and responsibilities of Members and Plan Sponsors and the services that the Filer will provide. The only significant difference between the two types of Plans is the tax assisted nature of one and not the other.

17. Each Member of a Non-Tax Assisted CAP of a Plan Sponsor that the Filer provides services to will also be a member

of the Plan Sponsor’s CAP. 18. The Filer will administer the Non-Tax Assisted CAPs in accordance with the CAP Guidelines and, in the case of the

Non-Tax Assisted CAPs, in a similar fashion to the related CAPs for the applicable Members. The Filer will only administer Non-Tax Assisted CAPs which originate out of CAPs of a Plan Sponsor also serviced by the Filer.

Decision The principal regulator is satisfied that the decision meets the test set out in the Legislation for the principal regulator to make the decision. The decision of the principal regulator under the Legislation is that the Exemption Sought is granted provided that: 1. for the Dealer Registration Relief

(a) the Plan Sponsor selects the Funds that Members will be able to invest in under the Plans; (b) the Plan Sponsor establishes a policy, and provides Members with a copy of the policy and any amendments

to it, describing what happens if a Member does not make an investment decision;


May 18, 2017

(2017), 40 OSCB 4437

(c) in addition to any other information that the Plan Sponsor believes is reasonably necessary for a Member to make an investment decision within the Plan, and unless that information has previously been provided, the Plan Sponsor provides the Member with the following information about each Fund the Member may invest in: (i) the name of the Fund; (ii) the name of the manager of the Fund and its portfolio adviser; (iii) the fundamental investment objective of the Fund; (iv) the investment strategies of the Fund or the types of investments the Fund may hold; (v) a description of the risks associated with investing in the Fund; (vi) where a Member can obtain more information about each Fund’s portfolio holdings; and (vii) where a Member can obtain more information generally about each Fund, including any continuous

disclosure;

(d) the Plan Sponsor provides Members with a description and amount of any fees, expenses and penalties relating to the Plan, as the case may be, that are borne by Members, including: (i) any costs that must be paid when a Fund is bought or sold; (ii) costs associated with accessing or using any of the investment information, decision-making tools or

investment advice provided by the Plan Sponsor; (iii) the management fees paid by the Funds; (iv) the operating expenses paid by the Funds; (v) record keeping fees; (vi) any costs for transferring among investment options, including penalties, book and market value

adjustments and tax consequences; (vii) account fees; and (viii) fees for services provided by the Filer, provided that the Plan Sponsor may disclose the fees, penalties and expenses on an aggregate basis, if the Plan Sponsor discloses the nature of the fees, expenses and penalties, and the aggregated fees do not include fees that arise because of a choice that is specific to a particular Member;

(e) the Plan Sponsor has, within the past year, provided the Members with performance information about each Fund the Members may invest in, including: (i) the name of the Fund for which the performance is being reported; (ii) the performance of the Fund, including historical performance for one, three, five and ten years if

available; (iii) a performance calculation that is net of investment management fees and mutual fund expenses; (iv) the method used to calculate the Fund’s performance return calculation, and information about where

a Member could obtain a more detailed explanation of that method; (v) the name and description of a broad-based securities market index, selected in accordance with

National Instrument 81-106 Investment Fund Continuous Disclosure, for the Fund, and corresponding performance information for that index; and

(vi) a statement that past performance of the Fund is not necessarily an indication of future performance;


May 18, 2017

(2017), 40 OSCB 4438

(f) the Plan Sponsor has, within the past year, informed Members if there were any changes in the choice of Funds that Members could invest in and where there was a change, provided information about what Members needed to do to change their investment decision, or make a new investment;

(g) the Plan Sponsor provides Members with investment decision-making tools that the Plan Sponsor reasonably

believes are sufficient to assist them in making an investment decision within the Plan; (h) the Plan Sponsor must provide the information required by paragraphs (b), (c), (d) and (g) prior to the Member

making an investment decision under the Plan; (i) if the Plan Sponsor makes investment advice from a registrant available to Members, the Plan Sponsor must

provide Members with information about how they can contact the registrant; (j) the maximum amount that may be contributed in respect of a Member to a Non-Tax Assisted CAP in a given

year is limited to any positive difference between: (i) the maximum amount that the Member and the Plan Sponsor would have been able to contribute for

that year to the applicable CAP under the terms of the applicable CAP if contributions to the applicable CAP were not restricted to the maximum dollar limit provided in the Income Tax Act (Canada) (the ITA); and

(ii) the maximum dollar limit provided in the ITA for the applicable CAP, provided that this maximum amount that may be contributed in respect of a Member to the Non-Tax Assisted CAP in a given year shall not exceed an amount equal to the “money purchase limit”, as defined in the ITA, for the year. In this paragraph (j), the amount determined under (i) shall be no more than 18% of the Member’s “earned income” as defined in the ITA and the “maximum dollar limit” means the “RRSP dollar limit” as defined in the ITA (in the case where the applicable CAP is an RRSP), the “money purchase limit” as defined in the ITA (in the case where the applicable CAP is a DCPP), one-half of the “money purchase limit” (in the case where the applicable CAP is a DPSP) or any applicable maximum fixed dollar contribution prescribed under the ITA (in the case of any other type of CAP).

2. for the Prospectus Relief (a) the conditions set forth in paragraph 1 above are met; (b) the Funds comply with Part 2 of NI 81-102; and (c) where a Member chooses to invest in a publicly available Fund selected by the Plan Sponsor as an

investment option for a Non-Tax Assisted Plan, the current prospectus of the Fund and/or Fund Facts as permitted by the Legislation, will be made available, upon demand, to the Member;

3. before the first time a Fund relies on this Decision, the Fund files a notice in the form found in Appendix C of the

Proposed CAP Exemption in each jurisdiction in which the Fund expects to distribute its securities; 4. this Decision, as it relates to the jurisdiction of a Decision Maker with respect to the Dealer Registration Relief will

terminate upon the coming into force in securities rules of a registration exemption for trades in a security of a mutual fund to a CAP or 90 days after the Decision Maker publishes in its Bulletin a notice or a statement to the effect that it does not propose to make such a rule;

5. this Decision, as it relates to the jurisdiction of a Decision Maker with respect to the Prospectus Relief will terminate

upon the coming into force in securities rules of a prospectus exemption for the distribution of a security of a mutual fund to a CAP or 90 days after the Decision Maker publishes in its Bulletin a notice or a statement to the effect that it does not propose to make such a rule.

“Janet Leiper” Commissioner Ontario Securities Commission “Frances Kordyback” Commissioner Ontario Securities Commission


May 18, 2017

(2017), 40 OSCB 4439

2.2 Orders 2.2.1 INFOR Acquisition Corp. Headnote National Policy 11-206 Process for Cease to be a Reporting Issuer Applications – The issuer ceases to be a reporting issuer under securities legislation. Applicable Legislative Provisions Securities Act, R.S.O. 1990, c. S.5, as am., s. 1(10)(a)(ii).

May 11, 2017


ONTARIO (THE “JURISDICTION”)

AND

IN THE MATTER OF

THE PROCESS FOR CEASE TO BE A REPORTING ISSUER APPLICATIONS

AND

IN THE MATTER OF

INFOR ACQUISITION CORP. (THE “FILER”)

ORDER

Background The principal regulator in the Jurisdiction has received an application from the Filer for an order under the securities legislation of the Jurisdiction of the principal regulator (the “Legislation”) that the Filer has ceased to be reporting issuers in all jurisdictions of Canada in which the Filer is a reporting issuer (the “Order Sought”). Under the Process for Cease to be a Reporting Issuer Applications (for a passport application):

(a) the Ontario Securities Commission is the principal regulator for this application; and

(b) the Filer has provided notice that sub-

section 4C.5(1) of Multilateral Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon in all of the Provinces and Territories of Canada, as applicable.

Interpretation Terms defined in National Instrument 14-101 Definitions and MI 11-102 have the same meaning if used in this order, unless otherwise defined.

Representations This order is based on the following facts represented by the Filer: 1. The Filer is not an OTC reporting issuer under

Multilateral Instrument 51-105 Issuers Quoted in the U.S. Over-the-Counter Markets;

2. The outstanding securities of the Filer, including

debt securities, are beneficially owned, directly or indirectly, by fewer than 15 securityholders in each of the jurisdictions of Canada and fewer than 51 securityholders in total worldwide;

3. No securities of the Filer, including debt securities,

are traded in Canada or another country on a marketplace as defined in National Instrument 21-101 Marketplace Operation or any other facility for bringing together buyers and sellers of securities where trading data is publicly reported;

4. The Filer is applying for an order that the Filer has

ceased to be a reporting issuer in all of the jurisdictions of Canada in which it is a reporting issuer; and

5. The Filer is not in default of securities legislation in

any jurisdiction. Order The principal regulator is satisfied that the order meets the test set out in the Legislation for the principal regulator to make the order. The decision of the principal regulator under the Legislation is that the Order Sought is granted. “Michael Balter” Manager, Corporate Finance Branch Ontario Securities Commisssion


May 18, 2017

(2017), 40 OSCB 4440

2.2.2 Money Gate Mortgage Investment Corporation et al. – ss. 127(7), 127(8)

IN THE MATTER OF


AND

IN THE MATTER OF

MONEY GATE MORTGAGE INVESTMENT CORPORATION,

MONEY GATE CORP., MORTEZA KATEBIAN and

PAYAM KATEBIAN

ORDER (Subsections 127(7) and 127(8) of the

Securities Act, RSO 1990, c S.5)

May 11, 2017 Timothy Moseley, Chair of the Panel William J. Furlong, Commissioner Mark J. Sandler, Commissioner THIS APPLICATION, made by Staff of the Commission, for an extension of the temporary order issued on April 27, 2017 in this matter (the Temporary Order), pursuant to subsections 127(7) and 127(8) of the Securities Act, RSO 1990, c S.5 (the Act) was heard on May 11, 2017, at the offices of the Commission, located at 20 Queen Street West, 17th Floor, Toronto, Ontario. ON READING the written submissions filed by Staff of the Commission and on hearing the oral submissions of the representatives for Staff of the Commission and for Money Gate Mortgage Investment Corporation, Money Gate Corp., Morteza Katebian and Payam Katebian; IT IS ORDERED THAT: 1. pursuant to subsection 127(8) of the Act, Staff’s

application to extend paragraph 1 of the Temporary Order to May 30, 2017, is granted;

2. the hearing of Staff’s application to extend

paragraph 2 of the Temporary Order shall continue on May 29, 2017 at 10:00a.m., and pursuant to subsection 127(7) of the Act, paragraph 2 of the Temporary Order is extended to the conclusion of that hearing; and

3. this proceeding is adjourned until May 29, 2017, at

10:00 a.m. “Timothy Moseley” “William J. Furlong” “Mark J. Sandler”

2.2.3 Lexam VG Gold Inc. Headnote National Policy 11-206 Process for Cease to be a Reporting Issuer Applications – The issuer ceased to be a reporting issuer under securities legislation. Applicable Legislative Provisions Securities Act, R.S.O. 1990, c. S.5, as am., s. 1(10)(a)(ii).

May 12, 2017


THE PROVINCE OF ONTARIO (the Jurisdiction)

AND

IN THE MATTER OF


AND

IN THE MATTER OF

LEXAM VG GOLD INC. (the Filer)

ORDER

Background The principal regulator in the Jurisdiction has received an application from the Filer for an order under the securities legislation of the Jurisdiction of the principal regulator (the Legislation) that the Filer has ceased to be a reporting issuer in all jurisdictions of Canada in which it is a reporting issuer (the Order Sought). Under the Process for Cease to be a Reporting Issuer Applications (for a passport application):

(a) the Ontario Securities Commission is the principal regulator for this application, and


section 4C.5(1) of Multilateral Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon in Alberta, British Columbia, Manitoba, Nova Scotia, Saskatchewan, Quebec, New Brunswick, Prince Edward Island, Newfoundland and Labrador, Northwest Territories, Nunavut and Yukon Territories.


May 18, 2017

(2017), 40 OSCB 4441

Interpretation Terms defined in National Instrument 14-101 Definitions and MI 11-102 have the same meaning if used in this order, unless otherwise defined. Representations This order is based on the following facts represented by the Filer: 1. the Filer is not an OTC reporting issuer under


2. the outstanding securities of the Filer, including

debt securities, are now beneficially owned, direct-ly or indirectly, by fewer than 15 securityholders in each of the jurisdictions of Canada and fewer than 51 securityholders in total worldwide;

3. no securities of the Filer, including debt securities,

traded in Canada or another country on a marketplace as defined in National Instrument 21-101 Marketplace Operation or any other facility for bringing together buyers and sellers of securities where trading data is publicly reported;

4. the Filer is applying for a decision that it is not a

reporting issuer in each of the jurisdictions of Canada in which it is currently a reporting issuer; and

5. the Filer is not in default of securities legislation in

any jurisdiction. Order The principal regulator is satisfied that the order meets the test contained under the Legislation for the principal regulator to make the order. The decision of the principal regulator under the Legislation is that the Order Sought is granted. “Winnie Sanjoto” Manager, Corporate Finance

2.2.4 Dundee Acquisition Ltd. – s. 1(6) of the OBCA Headnote Applicant deemed to have ceased to be offering its securities to the public under the Business Corporations Act (Ontario). Applicable Legislative Provisions Business Corporations Act, R.S.O. 1990, c. B.16, as am.,

s. 1(6).

IN THE MATTER OF THE BUSINESS CORPORATIONS ACT (ONTARIO),

R.S.O. 1990, c. B.16, AS AMENDED (the OBCA)

AND

IN THE MATTER OF

DUNDEE ACQUISITION LTD. (the Applicant)

ORDER

(Subsection 1(6) of the OBCA) UPON the application of the Applicant to the Ontario Securities Commission (the Commission) for an order pursuant to subsection 1(6) of the OBCA to be deemed to have ceased to be offering its securities to the public; AND UPON the Applicant representing to the Commission that: 1. The Applicant is an “offering corporation” as

defined in the OBCA, and has an authorized capital consisting of an unlimited number of Class A Restricted Voting Shares and Class B Shares.

2. The Applicant is a reporting issuer in all of the

provinces and territories of Canada (collectively, the Jurisdictions).

3. The Applicant has its head office at 1 Adelaide

Street East, 21st Floor, Toronto, Ontario, M5C 2V9.

4. The Applicant is a special purpose acquisition

corporation (a SPAC) formed for the purpose of effecting an acquisition of one or more businesses or assets, by way of a merger, share exchange, asset acquisition, share purchase, reorganization, or any other similar business combination.

5. The Applicant was the first publicly-listed SPAC in

Canada. The Applicant’s initial public offering (IPO) of $100 million Class A Restricted Voting Units closed on April 21, 2015, which was followed by a closing of the underwriters’ over-allotment option on May 20, 2015 for an additional $12.3 million Class A Restricted Voting Units.


May 18, 2017

(2017), 40 OSCB 4442

Each Class A Restricted Voting Unit consisted of one Class A Restricted Voting Share and one-half of a warrant. The gross proceeds from the distribution of the Class A Restricted Voting Units were deposited into an escrow account for the purpose of effecting the Applicant’s “qualifying acquisition”.

6. Under Toronto Stock Exchange Rules (TSX

Rules) approved by the Commission, at least 90% of the proceeds from a SPAC’s IPO must be set aside in an escrow account and invested in liquid and low risk securities. If a “qualifying acquisition” as contemplated by the TSX Rules is not completed within a permitted timeline, investors get their money back with interest. The founders of the SPAC – a sponsoring entity and (if applicable) certain directors and officers or other persons – provide seed financing to the SPAC. The seed financing covers underwriting fees and legal and other fees in connection with the IPO and qualifying acquisition. The founders are typically a small group of managers and financiers with the credibility and expertise necessary to raise the requisite funds and execute an appropriate qualifying acquisition. SPACs are designed to allow the public to co-invest with sophisticated managers and financiers, an opportunity that has traditionally been restricted to institutional investors and private equity investors.

7. Under the SPAC structure, prior to the meeting of

shareholders held to approve the qualifying acquisition, holders of Class A Restricted Voting Shares can elect (subject to closing) to redeem all or a portion of their Class A Restricted Voting Shares in exchange for a cash payment equal to the redemption price for the Class A Restricted Voting Shares, irrespective of whether they vote for or against, or do not vote on, the resolution to approve the qualifying acquisition at the meeting. Holders of Class A Restricted Voting Shares have the right to keep their warrants whether or not they decide to redeem their Class A Restricted Voting Shares.

8. On August 25, 2016 the Applicant and CHC

Student Housing Corp. announced that they had entered into an arrangement agreement (the Arrangement) to effect a business combination by way of a court approved plan of arrangement, which was to constitute the Applicant’s qualifying acquisition.

9. On November 29, 2016, the Applicant filed a

management information circular (the Circular) for its special meeting of shareholders (the Meeting) to be held on December 20, 2016, which append-ed a non-offering prospectus (the Prospectus) disclosing details about the proposed Arrangement as required by the TSX Rules.

10. On December 15, 2016, the Applicant announced that it was making certain modifications to the terms of the Arrangement, including raising of additional common equity concurrently with the closing of the Arrangement, and postponing the Meeting to January 27, 2017. The Applicant filed amendment no. 1 to the Circular on January 9, 2017 disclosing these changes and received a receipt for amendment no. 1 to the Prospectus on January 12, 2017.

11. On January 20, 2017, the Applicant announced

that the founders of the Applicant agreed to reduce the value of their founders’ shares by 75%, and on the same day filed amendment no. 2 to the Circular disclosing these changes.

12. The Arrangement was approved by the

Applicant’s shareholders at the Meeting on January 27, 2017. While the Arrangement was approved by the Applicant’s shareholders, as a result of the Applicant’s inability to meet the targeted minimum cash amount of $87.3 million in connection with the Arrangement due to higher than expected redemption deposits of Class A Restricted Voting Shares, upon completion of the voting in respect of resolutions to be considered at the Meeting, the Applicant adjourned the Meeting until further notice.

13. On March 31, 2017, the Applicant announced that

the Arrangement relating to its proposed business combination with CHC Student Housing Corp. has been terminated.

14. Under the Applicant’s articles of incorporation, as

amended (the Articles), the Applicant had until April 21, 2017 to consummate a business combination, failing which all of the issued and outstanding Class A Restricted Voting Shares issued in its IPO would be automatically redeemed within 10 days following that date.

15. The Applicant was not in a position to complete a

business combination by April 21, 2017. 16. On April 21, 2017, in accordance with its Articles,

the Applicant automatically redeemed the Class A Restricted Voting Shares from the proceeds of the escrow account. The redemption amount per Class A Restricted Voting Share was, as provided under the Articles, approximately $10.04 per Class A Restricted Voting Share based on the value of the escrow account as of March 31, 2017. Payment of such amounts constituted the Applicant’s final payment in respect of the liquidation of the escrow account that held the proceeds of the Applicant’s IPO. The Applicant’s warrants were also terminated in accordance with their terms on April 21, 2017.


May 18, 2017

(2017), 40 OSCB 4443

17. Promptly following such redemption, all of the Applicant’s Class A Restricted Voting Shares and warrants were delisted from the TSX.

18. As of the date hereof, all of the outstanding

securities of the Applicant, including debt securities, are beneficially owned, directly or indirectly, by fewer than 15 securityholders in each of the jurisdictions of Canada and fewer than 51 securityholders in total worldwide.

19. No securities of the Applicant, including debt

securities, are traded in Canada or another country on a marketplace as defined in National Instrument 21-101 – Marketplace Operation or any other facility for bringing together buyers and sellers of securities where trading data is publicly reported.

20. On April 20, 2017, the Applicant made an

application to the Ontario Securities Commission, as principal regulator on behalf of the securities regulatory authorities in the Jurisdictions, for a decision that the Applicant is not a reporting issuer in the Jurisdictions in accordance with the simplified procedure set out in National Policy 11-206 Process for Cease to be a Reporting Issuer Applications (the Order). The Order was granted on May 12, 2017.

21. The Applicant is not a reporting issuer in any

jurisdiction of Canada. 22. The Applicant is not in default of securities

legislation in the Jurisdictions. 23. The Applicant has no intention to seek public

financing by way of an offering of securities. AND UPON the Commission being satisfied that to do so would not be prejudicial to the public interest; IT IS HEREBY ORDERED by the Commission pursuant to subsection 1(6) of the OBCA that the Applicant be deemed to have ceased to be offering its securities to the public for the purpose of the OBCA. DATED at Toronto on this 12th day of May, 2017. “William J. Furlong” Commissioner Ontario Securities Commission “Mark J. Sandler” Commissioner Ontario Securities Commission

2.2.5 Dundee Acquisition Ltd. Headnote National Policy 11-206 Process for Cease to Be a Reporting Issuer Applications – The issuer ceases to be a reporting issuer under securities legislation. Applicable Legislative Provisions Securities Act, R.S.O. 1990, c. S.5, as am., s. 1(10)(a)(ii).

May 12, 2017



AND

IN THE MATTER OF


AND

IN THE MATTER OF

DUNDEE ACQUISITION LTD. (the Filer)

ORDER

Background The principal regulator in the Jurisdiction has received an application from the Filer for an order under the securities legislation of the Jurisdiction of the principal regulator (the Legislation) that the Filer has ceased to be a reporting issuer in all jurisdictions in Canada in which it is a reporting issuer (the Order Sought). Under the Process for Cease to be a Reporting Issuer Applications (for a passport application):



section 4C.5(1) of Multilateral Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon in British Columbia, Alberta, Saskatchewan, Mani-toba, Quebec, New Brunswick, Nova Scotia, Prince Edward Island, Newfound-land and Labrador, Northwest Territories, Yukon and Nunavut.


May 18, 2017

(2017), 40 OSCB 4444







4. the Filer is applying for an order that the Filer has



any jurisdiction. Order The principal regulator is satisfied that the order meets the test set out in the Legislation for the principal regulator to make the order. The decision of the principal regulator under the Legislation is that the Order Sought is granted. “Michael Balter” Manager, Corporate Finance Ontario Securities Commission

2.2.6 Ayaz Dhanani (also known as Azim Virani, Michael Lee, Alex Nebris, Paul Dhanani, Samuel Ramos, and Rahim Jiwa) – ss. 127(1), 127(10)

IN THE MATTER OF AYAZ DHANANI (also known as AZIM VIRANI,

MICHAEL LEE, ALEX NEBRIS, PAUL DHANANI, SAMUEL RAMOS, and RAHIM JIWA)

ORDER (Subsection 127(1) and (10) of the Securities Act, RSO 1990, c S.5)

Philip Anisman, Chair of the Panel

May 12, 2017

WHEREAS the Ontario Securities Commission held a hearing in writing on the application of Staff of the Commission (“Staff”) for an order imposing sanctions pursuant to subsections 127(1) and 127(10) of the Securities Act, RSO 1990, c S.5 (the “Act”);

ON READING the Findings of the British Columbia Securities Commission (the “BCSC”) dated May 30, 2016 and the Decision of the BCSC dated December 16, 2016, in the matter of Ayaz Dhanani (also known as Azim Virani, Michael Lee, Alex Nebris, Paul Dhanani, Samuel Ramos, and Rahim Jiwa) (“Dhanani”) and on reading the materials filed by Staff, Dhanani not having appeared and not having filed any materials, although properly served;

IT IS ORDERED THAT:

1. pursuant to paragraph 127(1)2 of the Act, trading in any securities or derivatives by Dhanani cease permanently;

2. pursuant to paragraph 127(1)2.1 of the Act, the acquisition of any securities by Dhanani is prohibited permanently;

3. pursuant to paragraph 127(1)3 of the Act, the exemptions contained in Ontario securities law do not apply permanently to Dhanani;

4. pursuant to paragraphs 127(1)7, 8.1, and 8.3 of the Act, Dhanani resign any position that he holds as a director or officer of any issuer or registrant, including an investment fund manager;

5. pursuant to paragraphs 127(1)8, 8.2 and 8.4 of the Act, Dhanani is prohibited permanently from becoming or acting as a director or officer of any issuer or registrant, including an investment fund manager; and

6. pursuant to paragraph 127(1)8.5, Dhanani is prohibited permanently from becoming or acting as a registrant, including an investment fund manager, or a promoter.

“Philip Anisman”


May 18, 2017

(2017), 40 OSCB 4445

2.2.7 Halogen Software Inc. – s. 1(6) of the OBCA Headnote Applicant deemed to have ceased to be offering its securities to the public under the Business Corporations Act (Ontario). Applicable Legislative Provisions Business Corporations Act, R.S.O. 1990, c. B.16, as am.,

s. 1(6).

IN THE MATTER OF THE BUSINESS CORPORATIONS ACT,


AND

IN THE MATTER OF

HALOGEN SOFTWARE INC. (the Applicant)

ORDER

(Subsection 1(6) of the OBCA) UPON the application of the Applicant to the Ontario Securities Commission (the Commission) for an order pursuant to subsection 1(6) of the OBCA to be deemed to have ceased to be offering its securities to the public; AND UPON the Applicant having represented to the Commission that: 1. The Applicant is an “offering corporation” as

defined in the OBCA, and has an authorized capital consisting of an unlimited number of common shares (the Common Shares), an un-limited number of preferred shares (the Preferred Shares) and an unlimited number of exchange-able shares (the Exchangeable Shares) of which 100 Common Shares, 65,934,140 Preferred Shares and 51,383,764 Exchangeable Shares are issued and outstanding as of the date hereof.

2. The Applicant has its head office at 495 March

Road, Kanata, Ontario, K2K 3G1. 3. Effective May 1, 2017, in accordance with a plan

of arrangement under section 182 of the OBCA (the Arrangement), Halogen Software Inc., a predecessor by amalgamation of the Applicant (Old Halogen), became a wholly-owned sub-sidiary of 2574387 Ontario Inc. (the Purchaser), a newly-formed subsidiary of Vector Talent Hold-ings, L.P. and its affiliates. Immediately following the Arrangement, Old Halogen amalgamated with the Purchaser, and the amalgamated company has the name “Halogen Software Inc.”

4. The Arrangement was approved by shareholders of Old Halogen at a special meeting of shareholders of Old Halogen held on April 24, 2017.

5. The Arrangement was approved by the Ontario

Superior Court of Justice (Commercial List) on April 26, 2017.

6. The common shares of Old Halogen, which traded

under the symbol “HGN” on the Toronto Stock Exchange, were de-listed effective at the close of trading on May 3, 2017.

7. The Applicant has no outstanding securities,

including debt securities, other than the Common Shares, Preferred Shares and Exchangeable Shares.

8. As of the date of this decision, all of the

outstanding Common Shares are beneficially owned, directly or indirectly, by Vector Talent Holdings, L.P., all of the outstanding Preferred Shares are beneficially owned, directly or indirectly, by Vector Talent Holdings LLC and all of the outstanding Exchangeable Shares are beneficially owned, directly or indirectly, by Michael Slaunwhite and his personal holding company, 10206890 Canada Inc.

9. No securities of the Applicant, including debt

securities, are traded in Canada or another country on a marketplace as defined in National Instrument 21-101 Marketplace Operation or any other facility for bringing together buyers and sellers of securities where trading data is publicly reported.

10. The Applicant is a reporting issuer, or the

equivalent, in all of the provinces and territories of Canada (the Jurisdictions), and is not in default of any requirement of securities legislation in the Jurisdictions.

11. The Applicant has no intention to seek public

financing by way of an offering of securities. 12. On May 4, 3017, the Applicant made an

application to the Ontario Securities Commission, as principal regulator on behalf of the securities regulatory authorities in the Jurisdictions, for a decision that the Applicant is not a reporting issuer in the Jurisdictions (the Reporting Issuer Relief).

13. Upon the granting of the Reporting Issuer Relief,

the Applicant will not be a reporting issuer or equivalent in any Jurisdiction.

AND UPON the Commission being satisfied that to do so would not be prejudicial to the public interest;


May 18, 2017

(2017), 40 OSCB 4446

IT IS HEREBY ORDERED by the Commission, pursuant to subsection 1(6) of the OBCA, that the Applicant is deemed to have ceased to be offering its securities to the public for the purpose of the OBCA. DATED at Toronto on this 12th day of May, 2017. “William J. Furlong” Commissioner Ontario Securities Commission “Mark Sandler” Commissioner Ontario Securities Commission

2.2.8 Halogen Software Inc. Headnote National Policy 11-206 Process for Cease to be a Reporting Issuer Applications – The issuer ceases to be a reporting issuer under securities legislation. Applicable Legislative Provisions Securities Act, R.S.O. 1990, c. S.5, as am., s. 1(10)(a)(ii).

May 12, 2017



AND

IN THE MATTER OF


AND

IN THE MATTER OF

HALOGEN SOFTWARE INC. (the Filer)

ORDER

Background The principal regulator in the Jurisdiction has received an application from the Filer for an order under the securities legislation of the Jurisdiction of the principal regulator (the Legislation) that the Filer has ceased to be a reporting issuer in all jurisdictions in Canada in which it is a reporting issuer (the Order Sought). Under the Process for Cease to be a Reporting Issuer Applications (for a passport application):



section 4C.5(1) of Multilateral Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon in British Columbia, Alberta, Saskatchewan, Mani-toba, Quebec, New Brunswick, Nova Scotia, Prince Edward Island, Newfound-land and Labrador, Northwest Territories, Yukon and Nunavut.


May 18, 2017

(2017), 40 OSCB 4447







4. the Filer is applying for an order that the Filer has



any jurisdiction. Order The principal regulator is satisfied that the order meets the test set out in the Legislation for the principal regulator to make the order. The decision of the principal regulator under the Legislation is that the Order Sought is granted. “Michael Balter” Manager, Corporate Finance Ontario Securities Commission

2.2.9 Lexam VG Gold Inc. – s. 1(6) of the OBCA Headnote Applicant deemed to have ceased to be offering its securities to the public under the Business Corporations Act (Ontario). Applicable Legislative Provisions Business Corporations Act, R.S.O. 1990, c. B.16, as am.,

s. 1(6).

IN THE MATTER OF THE BUSINESS CORPORATIONS ACT (ONTARIO),


AND

IN THE MATTER OF

LEXAM VG GOLD INC. (the Applicant)

ORDER

(Subsection 1(6) of the OBCA) UPON the application of the Applicant to the Ontario Securities Commission (the Commission) for an order pursuant to subsection 1(6) of the OBCA to be deemed to have ceased to be offering its securities to the public; AND UPON the Applicant representing to the Commission that: 1. The Applicant is incorporated under the OBCA. 2. The Applicant is an "offering corporation" as

defined in the OBCA. 3. The Applicant has an authorized capital consisting

of an unlimited number of common shares (the Common Shares), of which 226,570,860 Common Shares are outstanding.

4. The head office of the Applicant is located at 150

King Street West, Suite 2800, Toronto, Ontario, M5H 1J9, Canada.

5. On February 13, 2017, the Applicant entered into

an arrangement agreement with McEwen Mining Inc. (McEwen), pursuant to which McEwen agreed to acquire all of the issued and outstanding Common Shares by way of a court-approved plan of arrangement in accordance with Section 182 of the OBCA (the Arrangement).

6. The Arrangement was approved by the

shareholders of the Applicant at a special meeting of shareholders of the Applicant held on April 12, 2017.


May 18, 2017

(2017), 40 OSCB 4448

7. The Arrangement was approved by the Ontario Superior Court of Justice (Commercial List) on April 19, 2017.

8. The Arrangement was completed on April 26,

2017; and as a result of the Arrangement: (i) other than Mr. Robert R. McEwen, each holder of Common Shares immediately before the effective time of the arrangement received 0.056 of a share of common stock in the capital of McEwen (each such whole share being a McEwen Share) for each Common Share held; (ii) as a result of the policies of the New York Stock Exchange, Mr. Robert R. McEwen, an insider of McEwen, received 0.056 of a McEwen Share per Common Share in respect of 53,494,589 Common Shares held by him and 0.056 of a subscription receipt of McEwen (each a Subscription Receipt) per Common Share in respect of the remaining Common Shares held by him, resulting in him acquiring 2,995,697 McEwen Shares and 405,740 Subscription Receipts, each such Subscription Receipt convertible into one McEwen Share upon McEwen obtaining the requisite approval of its shareholders in accordance with the policies of the New York Stock Exchange; and (iii) holders of options to acquire Common Shares received, in exchange for such options, options to acquire McEwen Shares.

9. As of the date of this decision, all of the

outstanding Common Shares are beneficially owned, directly or indirectly, by McEwen and no other securities of the Applicant are outstanding.

10. The Common Shares had been listed and posted

for trading on the Toronto Stock Exchange (the TSX) under the symbol "LEX". On May 1, 2017, the TSX delisted the Common Shares.


for trading on the OTC Market's OTCQX (the OTCQX) under the symbol "LEXVF". On May 2, 2017, the OTCQX delisted the Common Shares.


for trading on the Frankfurt Stock Exchange under the symbol "VN3A". On May 3, 2017, the Frankfurt Stock Exchange delisted the Common Shares.

13. As of the date of this decision, no securities of the

Applicant, including debt securities, are listed, traded or quoted in Canada or another country on a "marketplace" as defined in National Instrument 21-101 Marketplace Operation or any other facility for bringing together buyers and sellers of securities where trading data is publicly reported.

14. The Applicant was a reporting issuer, or the

equivalent, in each of the provinces and territories of Canada (collectively, the Jurisdictions) and applied to the Commission, as principal regulator, for a decision that it is not a reporting issuer in the

Jurisdictions in accordance with the simplified procedure set out in National Policy 11-206 Process for Cease to be a Reporting Issuer Applications (the Reporting Issuer Relief). The Reporting Issuer Relief was granted on May 12, 2017 and, as a result, the Applicant is not a reporting issuer or equivalent in any jurisdiction of Canada.

15. The Applicant is not in default of any requirement

of the securities legislation in any of the Jurisdictions.

16. The Applicant has no intention to seek public

financing by way of an offering of securities. AND UPON the Commission being satisfied to do so would not be prejudicial to the public interest; IT IS HEREBY ORDERED by the Commission pursuant to subsection 1(6) of the OBCA that the Applicant be deemed to have ceased to be offering its securities to the public for the purposes of the OBCA. DATED at Toronto on this 12th day of May, 2017. “William Furlong” Commissioner Ontario Securities Commission “Mark Sandler” Commissioner Ontario Securities Commission


May 18, 2017

(2017), 40 OSCB 4449

2.2.10 Larry Keith Davis – ss. 127(1), 127(10)

IN THE MATTER OF LARRY KEITH DAVIS

ORDER

(Subsections 127(1) and (10) of the Securities Act, RSO 1990, c S.5)

Philip Anisman, Chair of the Panel

May 15, 2017 WHEREAS on May 15, 2017, the Ontario Securities Commission held a hearing at the Commission’s offices at 20 Queen Street West, 17th Floor, Toronto, Ontario, to consider an application by Staff of the Commission (“Staff”) for an order imposing sanctions pursuant to subsections 127(1) and 127(10) of the Securities Act, RSO 1990, c S.5 (the “Act”); ON READING the Affidavit of Lee Crann, sworn May 8, 2017 (the “Affidavit”) and other materials filed by Staff concerning an appeal of the decisions of the British Columbia Securities Commission (“BCSC”) on which this application is based and a stay of execution of the BCSC Order pending this appeal granted by the British Columbia Court of Appeal and on hearing the submissions of Staff, no one appearing for Larry Keith Davis (the “Respondent”), although properly served as appears from the Affidavit, IT IS ORDERED that the hearing is adjourned to a date to be requested by Staff and determined by the Registrar. DATED at Toronto this 15th day of May, 2017 “Philip Anisman”


May 18, 2017

(2017), 40 OSCB 4450


May 18, 2017

(2017), 40 OSCB 4451

Chapter 3

Reasons: Decisions, Orders and Rulings 3.1 OSC Decisions 3.1.1 Benedict Cheng et al. – s. 127


RSO 1990, c S.5

AND

IN THE MATTER OF BENEDICT CHENG, FRANK SOAVE,

JOHN DAVID ROTHSTEIN and ERIC TREMBLAY

REASONS AND DECISION ON SETTLEMENT (Section 127 of the Securities Act, RSO 1990, c S.5)

Citation: Cheng, Benedict et al, 2017 ONSEC 14 Date: 2017-05-10

Hearing: April 18, 2017

Decision: May 10, 2017

Panel: Janet Leiper AnneMarie Ryan

– –

Commissioner and Chair of the Panel Commissioner

Appearances: Cullen Price – For Staff of the Commission

Mark Polley Sarah Walker

– For John David Rothstein

TABLE OF CONTENTS

I. INTRODUCTION II. THE ALLEGATIONS AGAINST THE SETTLING RESPONDENT III. BREACHES OF THE ACT IV. THE SETTLEMENT PROPOSED V. ANALYSIS

REASONS AND DECISION I. INTRODUCTION [1] By Statement of Allegations dated April 12, 2017, Staff of the Ontario Securities Commission commenced proceedings

against the Respondents, alleging tipping and insider trading. On April 18, 2017, the Commission held a hearing to consider whether it was in the public interest to approve a Settlement Agreement signed between Staff of the Commission and John David Rothstein (the "Settling Respondent").

[2] At the conclusion of the hearing, the Commission approved the Settlement Agreement and provided brief oral reasons,

with written reasons to follow. These are our written reasons approving the settlement.

Reasons: Decisions, Orders and Rulings

May 18, 2017

(2017), 40 OSCB 4452

II. THE ALLEGATIONS AGAINST THE SETTLING RESPONDENT [3] The Settlement Agreement includes a summary of facts with which the Settling Respondent agrees, but which facts

remain unproven against the remaining respondents. The allegations against the non-settling respondents remain the subject of ongoing proceedings, requiring proof at a merits hearing.

[4] The Settling Respondent was a Senior Vice President and National Sales Manager at an investment fund manager,

Aston Hill Asset Management Inc. (“AHAM”) in Toronto. In that capacity, he reported to Benedict Cheng, the President of Aston Hill Financial Inc. (“AHF”), and Co-Chief Investment Officer of AHF and AHAM.

[5] A representative of AHAM learned of a proposed material transaction concerning Amaya Gaming Group Inc. (“Amaya”)

and an investment opportunity for AHAM if it were to participate in financing the transaction. Mr. Cheng had signed a non-disclosure agreement concerning the information and was aware of material terms relating to the acquisition in advance of any public announcement.

[6] On June 11, 2014, Mr. Cheng sent an email to the Settling Respondent inviting him to one of the AHAM boardrooms.

Mr. Cheng provided the confidential information about the acquisition to the Settling Respondent and told him that he should inform others who had lost money on other investments promoted by AHF and AHAM. The Settling Respondent took this to mean that this would allow those others to make up for their losses. He agreed to follow Mr. Cheng's instructions.

[7] Approximately 2.5 hours after speaking with Mr. Cheng, the Settling Respondent entered an order to purchase 700

shares in an account in trust for his children for a total investment of $8,322. Following the announcement of the acquisition, the price for the shares had increased by approximately 60% relative to his purchase. The Settling Respondent sold his shares on June 13, 2014 for a total profit of $5,507, or a return of 66%. He had not traded in these shares before.

[8] Shortly after the discussion with Mr. Cheng, the Settling Respondent contacted Frank Soave, a First Vice President

and Investment Advisor at CIBC Wood Gundy via text. He provided further confidential information to Mr. Soave the following day. Mr. Soave purchased shares based on this information in the amount of $60,755.

[9] Trading was halted in the acquisition less than two hours after Mr. Soave’s purchase. The acquisition by Amaya was

announced later that day at or about 9:00 p.m. EDT. The next morning, the price per share had increased by approximately 57% relative to Mr. Soave's purchase price the day before.

[10] On June 13, 2014, Mr. Soave sold his shares in the company for a profit of $38,166. Following the sale, he texted the

Settling Respondent, "Thank you." III. BREACHES OF THE ACT [11] By engaging in the conduct described above, the Settling Respondent admitted that he breached Ontario securities law

by contravening subsections 76(1) and 76(2) of the Securities Act, RSO 1990, c S.5 (the “Act”). These are serious breaches as the improper use of insider information leads to unfair advantage to those who do so and to lack of confidence and cynicism in the fairness of public markets.

IV. THE SETTLEMENT PROPOSED [12] The parties submitted that a range of sanctions are appropriate in all of the circumstances, which include an

undertaking received from the Settling Respondent to cooperate in the future with Staff of the Commission. Such cooperation may include, where necessary, cooperating with Staff of the Commission in any further investigation of these matters and if required, testifying as a witness relating to the matters described in the Settlement Agreement.

[13] On March 13, 2014, the Commission published Staff Notice 15-702 Revised Credit for Cooperation Program, which

recognizes the role that cooperation by a respondent may play in reducing the sanctions recommended by Staff in connection with enforcement proceedings. The underlying policy is to encourage participants in the market to self-police, self-report and self-correct potential breaches of Ontario securities laws or misconduct that is otherwise contrary to the public interest.

[14] In this case, Staff and the Settling Respondent have agreed that the sanctions proposed are appropriate and have

taken into account cooperation as a significant mitigating factor.


May 18, 2017

(2017), 40 OSCB 4453

[15] Other mitigating factors described in the Settlement Agreement include: a. Timing of the Cooperation: The Settling Respondent agreed to cooperate immediately after his interview with

Staff on June 15, 2016. b. Dependants/Career Consequences: The Settling Respondent is the sole financial support of three school-

aged children. As a result of the investigation, he lost his job and is struggling to find other work. c. No Prior Record: The Settling Respondent has no prior record of breaching Ontario securities law. d. Tip Came from a Superior: Although not excusing the conduct, the Settling Respondent felt some pressure to

please his superior and to carry out the instruction to pass the information to a firm client. e. Small Profit: The Settling Respondent made approximately $5,500 in the shares that he purchased and sold in

June of 2014. f. Not Registered: The Settling Respondent worked in sales and was not a registrant.

V. ANALYSIS [16] Insider trading and tipping is generally accompanied by market participation bans, disgorgement of profits,

administrative penalties and orders to resign positions as director or officer. This array of sanctions is reflected in the Settlement Agreement in this case, however with significant credit for cooperation, particularly in the length of time for market participation bans.

[17] We have concluded that although there has been credit allowed for cooperation, it is consistent with the Staff Notice

15-702 and that the sanctions proposed are within the range for this type of conduct, particularly given the amounts involved and the consequences that the proceedings alone have imposed on the Settling Respondent. We find that the sanctions are appropriate and reasonable. Accordingly, on April 18, 2017, the Commission issued an Order approving the Settlement Agreement, along with the following provisions: a. trading in any securities or derivatives by the Settling Respondent shall cease for a period of two years,

pursuant to paragraph 2 of subsection 127(1) of the Act; b. the acquisition of any securities by the Settling Respondent shall cease for a period of two years, pursuant to

paragraph 2.1 of subsection 127(1) of the Act; c. the Settling Respondent was reprimanded, pursuant to paragraph 6 of subsection 127(1) of the Act; d. the Settling Respondent shall resign any positions that he holds as a director or officer of an issuer, pursuant

to paragraph 7 of subsection 127(1) of the Act; e. the Settling Respondent shall be prohibited from becoming or acting as a director or officer of any issuer for a

period of two years, pursuant to paragraph 8 of subsection 127(1) of the Act; f. the Settling Respondent shall resign any positions that he holds as a director or officer of a registrant,

pursuant to paragraph 8.1 of subsection 127(1) of the Act; g. the Settling Respondent shall be prohibited from becoming or acting as a director or officer of a registrant for a

period of two years, pursuant to paragraph 8.2 of subsection 127(1) of the Act; h. the Settling Respondent shall resign any positions that he holds as a director or officer of an investment fund

manager, pursuant to paragraph 8.3 of subsection 127(1) of the Act; i. the Settling Respondent shall be prohibited from becoming or acting as a director or officer of an investment

fund manager for a period of two years, pursuant to paragraph 8.4 of subsection 127(1) of the Act; j. the Settling Respondent shall be prohibited from becoming or acting as a registrant, as an investment fund

manager or as a promoter for a period of two years commencing on the date of the Order, pursuant to paragraph 8.5 of subsection 127(1) of the Act;


May 18, 2017

(2017), 40 OSCB 4454

k. the Settling Respondent pay an administrative penalty in the amount of $5,500, pursuant to paragraph 9 of subsection 127(1) of the Act, which shall be designated for allocation or for use by the Commission in accordance with subsections 3.4(2)(b)(i) or (ii) of the Act;

l. the Settling Respondent disgorge to the Commission the amount of $5,500, pursuant to paragraph 10 of

subsection 127(1) of the Act, which shall be designated for allocation or for use by the Commission in accordance with subsections 3.4(2)(b)(i) or (ii) of the Act; and

m. After the payments of the administrative penalty and the disgorgement amount set out above are made in full,

the Settling Respondent is permitted to trade in or acquire securities in his personal registered retirement savings plan accounts and/or his tax-free savings accounts and/or for any registered education savings plan accounts for which he is a beneficiary or a sponsor.

Dated at Toronto this 10th day of May, 2017. “Janet Leiper” “AnneMarie Ryan”


May 18, 2017

(2017), 40 OSCB 4455

3.1.2 MM Café Franchise Inc. et al.


RSO 1990, c S.5

AND

IN THE MATTER OF MM CAFÉ FRANCHISE INC.,

TECHOCAN INTERNATIONAL CO. LTD., 1727350 ONTARIO LIMITED,

MARIANNE GODWIN, DAVE GARNET CRAIG and

HAIYAN (HELEN) GAO JORDAN

ORAL REASONS FOR APPROVAL OF A SETTLEMENT Citation: MM Café Franchise Inc. et al, 2017 ONSEC 13 Date: 2017-04-24

Hearing: April 24, 2017

Decision: April 24, 2017

Panel: Timothy Moseley AnneMarie Ryan

– –

Commissioner and Chair of the Panel Commissioner

Appearances: Keir Wilmut Gavin Smyth

– For Staff of the Commission

Shawn Graham – For Marianne Godwin

Dave Garnet Craig – On his own behalf and on behalf of MM Café Franchise Inc.

ORAL REASONS AND DECISION

The following reasons have been prepared for publication in the Ontario Securities Commission Bulletin, based on the reasons delivered orally in the hearing as edited and approved by the panel, to provide a public record. [1] The respondents, Ms. Godwin and Mr. Craig, were respectively Chief Executive Officer and Chief Development Officer

of the respondent MM Café Franchise Inc. (“MM Café”) Both were also directors of that company. [2] MM Café has admitted that it contravened subsection 53(1) of the Securities Act1 (the “Act”) by conducting an illegal

distribution of its own securities. Ms. Godwin and Mr. Craig have admitted that as directors and officers, they contravened section 129.2 of the Act by authorizing, permitting, or acquiescing in MM Café's illegal distribution.

[3] While the parties have reached an agreement as to the sanctions that ought to be imposed, our obligation is to

consider whether to approve the agreement, which is the product of negotiation between Staff and the respondents. We must still be satisfied that the agreed-upon sanctions are appropriate in the circumstances and that it would be in the public interest to approve the settlement and issue the order contemplated by the agreement.

[4] For the reasons that follow, we will approve the settlement and issue the requested order. [5] The underlying conduct is serious. Investors put their money at risk without the benefit of protections that should have

been in place. As directors and officers of MM Café, Ms. Godwin and Mr. Craig had an obligation to obtain proper advice and ensure that MM Café was aware of, and followed, applicable regulations.

[6] The sanctions agreed to by the parties are not severe. Each of Ms. Godwin and Mr. Craig is prohibited from being a

director or officer for five years, or possibly as little as two years if they comply with the specified conditions. No administrative penalty is provided for and the agreed amount of costs is nominal.

1 RSO 1990, c S.5.


May 18, 2017

(2017), 40 OSCB 4456

[7] The Commission respects the negotiation process and accords significant deference to the resolution reached by the parties. In addition, this Panel had the opportunity to meet with counsel for Staff and for the respondents in a confidential conference. We reviewed the settlement agreement and we heard submissions from counsel.

[8] There are a number of mitigating factors in this case. The respondents co-operated with Staff's investigation, none of

them has previously been found to have breached the Act, none of them was previously registered with the Commission, and there is no evidence that they knowingly breached the Act.

[9] In addition, Ms. Godwin and Mr. Craig played a limited role. The agreed-upon contraventions relate only to Ms.

Godwin's and Mr. Craig's role as directors and officers. This is not about what they did. It's about what they allowed to happen, but should have prevented. They relied on a third party advisor to manage investor relations and they retained an agent to solicit investors. As they now know, those steps were not enough.

[10] Those who accept the role of director or officer of a company that is going to raise funds in the capital markets take on

an important responsibility. Ms. Godwin and Mr. Craig did not fulfill their obligations and it is appropriate that they be prohibited from taking on similar roles for some time.

[11] With respect to the agreed amount for costs, we note that both Ms. Godwin and Mr. Craig have limited financial

resources. Had this matter proceeded to a contested hearing, the respondents might very well have been subject to greater sanctions and costs than those called for by this agreement. We acknowledge that this settlement resolves the proceeding with certainty, and in an efficient way, saving the costs that would be incurred in a contested hearing against the respondents.

[12] Staff and the respondents submit that this settlement is in the public interest, and we agree. For all of these reasons,

we approve the settlement agreement as requested and we will issue an order substantially in the form of Schedule A to that agreement.

Dated at Toronto this 24th day of April, 2017. “Timothy Moseley” “AnneMarie Ryan”


May 18, 2017

(2017), 40 OSCB 4457

3.1.3 Ayaz Dhanani (also known as Azim Virani, Michael Lee, Alex Nebris, Paul Dhanani, Samuel Ramos, and Rahim Jiwa) – ss. 127(1), 127(10)

IN THE MATTER OF

AYAZ DHANANI (also known as AZIM VIRANI, MICHAEL LEE, ALEX NEBRIS,

PAUL DHANANI, SAMUEL RAMOS, and RAHIM JIWA)

DECISION AND REASONS (Subsections 127(1) and (10) of the Securities Act, RSO 1990, c S.5)

Citation: Dhanani, 2017 ONSEC 15 Date: 2017-05-12

Hearing: In Writing


Panel: Philip Anisman – Commissioner

Submissions by: Malinda N. Alvaro Evan Rankin (Student-at-law)


No submission was made by or on behalf of Ayaz Dhanani

TABLE OF CONTENTS

I. BACKGROUND II. DECISION III. REASONS IV. CONCLUSION SCHEDULE A: ORDER

DECISION AND REASONS I. BACKGROUND [1] In 2013 and 2014, Ayaz Dhanani (“Dhanani”), an unregistered resident of British Columbia, induced three individuals

whom he had befriended to invest in unidentified natural resource companies which he said were about to go public and the shares of which would increase significantly in a short time. In one instance, he used an alias, “Azim Virani”. He received from the three individuals a total of $188,800.00, but he did not invest their funds in a company. Although he subsequently informed two of these investors that their investment was doing well, their funds were used by him and his father for personal purposes. None of the investors received any funds back from him.1

[2] On May 30, 2016, after a hearing at which despite having received notice, Dhanani did not appear, the British

Columbia Securities Commission (the “BCSC”) found that his conduct was fraudulent and contravened section 57(b) of the British Columbia Securities Act (the “BC Act”).2 On December 16, 2016, following a sanctions hearing at which despite having again received notice, Dhanani did not appear, the BCSC made an order prohibiting Dhanani from participating in the securities market in British Columbia, requiring him to disgorge the $188,800.00 and imposing an administrative penalty of $225,000.00 (the “BCSC Order”).3

[3] On March 1, 2017, on the basis of a Statement of Allegations of Staff of the Commission (“Staff”) dated February 28,

2017 and the BCSC Order, the Ontario Securities Commission (the “Commission”) issued a Notice of Hearing pursuant to subsections 127(1) and (10) of the Securities Act (the “Act”)4 for a hearing to consider an order effectively prohibiting

1 Re Dhanani, 2016 BCSECCOM 179. An account with the funds of the third investor was frozen before the funds could be used. 2 Ibid; Securities Act, RSBC 1996, c 418. 3 Re Dhanani, 2016 BCSECCOM 413. 4 Securities Act, RSO 1990, c S.5, ss 127(1), (10).


May 18, 2017

(2017), 40 OSCB 4458

Dhanani from engaging in securities-related activities in Ontario.5 At the hearing on March 13, 2017, at which despite having been properly served,6 Dhanani did not appear, I granted Staff’s application to continue this proceeding as a written hearing and set a timetable for service and filing of Staff’s materials and Dhanani’s responding materials.7 Although my Order and Staff’s materials were served on Dhanani and filed, Dhanani did not file responding materials.8

II. DECISION [4] On the basis of the BCSC Order and the findings in its decisions of May 30 and December 16, 2016, it is in the public

interest to grant an order in the form in Schedule A, as requested by Staff, to prohibit Dhanani from participating in the securities market in Ontario.

III. REASONS [5] In view of the fact that securities markets and trading transcend provincial and national borders, the Commission has

long recognized that protection of Ontario investors may require it to address improper conduct that occurs outside of Ontario. In 1971, for example, it published a policy notifying registrants that a violation of the securities laws of any jurisdiction would be considered “in principle to be prejudicial to the public interest” and might affect their fitness for continued registration in Ontario.9 The Commission subsequently declared that insider trading outside Ontario, and by implication other conduct that would contravene the Act if it occurred in Ontario, could provide a basis for an order prohibiting trading in Ontario,10 and it has also exercised this protective authority with respect to individuals who have been convicted of securities-related criminal offences outside of Ontario.11

[6] In 2008, subsection 127(10) was added to the Act to provide express statutory authority for such orders “to facilitate

interprovincial enforcement of securities laws”.12 Subsection 127(10) now authorizes the Commission to make an order under subsection 127(1) in respect of a person who is subject to an order of a securities, derivatives or financial regulatory authority in any jurisdiction that imposes sanctions, conditions, restrictions or other requirements on the person.13

[7] Although the Commission’s authority and practice under this provision derive from regulatory considerations,14 they

have been analogized to principles of comity relating to the enforcement of judgments in civil proceedings.15 This is not surprising in view of the fact that securities legislation in Canada is largely uniform or harmonized, as are the sanctioning principles applied by securities regulatory authorities.16

5 Re Dhanani (2017), 40 OSCB 2073 (Notice of Hearing); 40 OSCB 2075 (Statement of Allegations). 6 Affidavit of Service of Lee Crann, sworn March 9, 2017 (Exhibit 1). 7 Re Dhanani (2017), 40 OSCB 2594 (Order). See Statutory Powers Procedure Act, RSO 1990, c S.22, s 5.1 (“SPPA”); Ontario Securities

Commission Rules of Procedure (2014), 37 OSCB 4168, r 11.5 (“Rules of Procedure”). The Notice of Hearing contained notice of Staff’s application for a written hearing and stated that if Dhanani did not attend, the hearing could proceed in his absence; see SPPA, s 7; Rules of Procedure, r 7.1.

8 Affidavit of Service of Lee Crann, sworn March 27, 2017 (Exhibit 2). Staff also filed a hearing brief that was marked as Exhibit 3. 9 National Policy No.17; see Notice: Canadian Provincial Securities Administration, [1971] OSCB 22(March); Notice: National Policy No.17 –

Violations of Securities Laws of Other Jurisdictions – Conduct Affecting Fitness for Registration, [1978] OSCB 129 (June). 10 See Re Kaiser Resources Limited (1981), 1 OSCB 13C at 16C:

“It is … our view that activity by a person of the type prohibited by section 75, wherever such activity takes place, may properly form the basis for a determination by the Commission … that it is in the public interest … to deny that person the benefit of the exemptions contained in … the Act. This is by no means to attempt to give an extraterritorial effect to the Act. Rather, it is an assertion by the Commission of its jurisdiction and responsibility to determine the sorts of activity which should disentitle persons from trading, or restrict their ability to trade, in securities in this Province. In so doing, the Commission is doing no more than to carry out its statutory obligation to supervise the capital markets of this Province.”

11 See e.g. Re Banks (2003), 26 OSCB 3377; Re Biller (2005), 28 OSCB 10131. The BCSC has exercised similar authority; see e.g. Re Holoboff, [1993] 29 BCSC Weekly Summary 7; Re Woods, [1997] 8 BCSC Weekly Summary 22; Re Seto, 2006 BCSECCOM 569.

12 Hansard, October 27, 2008, http://hansardindex.ontla.on.ca/hansardeissue/l080.htm, Budget Measures and Interim Appropriation Act, 2008 (No. 2), at 1409-1410; see SO 2008, c 19, Sched R, s 1.

13 Act, s 127(10)4. 14 See notes 9 and 10, above; see also Act, ss 2.1(3), (5). 15 See e.g. Re JV Raleigh Superior Holdings Inc. (2013), 36 OSCB 4639 at paras 22-26; Re New Futures Trading International Corp. (2013),

36 OSCB 5713 at paras 23-27; see also Re Black (2015), 38 OSCB 2043 at paras 83-85. 16 See e.g. Re M.C.J.C. Holdings Inc. (2002), 25 OSCB 1133 at 1135-36; Re Belteco Holdings Inc. (1998), 21 OSCB 7743 at 7746-47; Re

Eron Mortgage Corporation, [2000] 7 BCSC Weekly Summary 22 at 24; Re Anderson, 2004 BCSECCOM 699 at paras 30-32; Re Dhanani, note 3, above at para 10.


May 18, 2017

(2017), 40 OSCB 4459

[8] The BCSC Order, therefore, provides a sufficient basis for the Commission to make a parallel order under subsection 127(1), even though the conduct in question has no connection with Ontario.17 As subsection 127(10) does not limit “the generality of” subsection 127(1), the Commission retains its discretion to make an order that in its opinion is in the public interest and to determine the specifics of such an order; in exercising this discretion, however, the Commission will rely on the findings in the BCSC’s decisions on liability and sanctions.18

[9] In a proceeding like this one, under paragraph 127(10)4, an order under subsection 127(1) will generally be found to be

in the public interest, unless the respondent demonstrates otherwise.19 The order and findings of the other regulatory authority have the effect of imposing a burden on the respondent to adduce evidence that they should not be accepted or that the sanction imposed by the other authority is not in the public interest in Ontario.20 As other securities regulatory authorities in Canada follow adjudicative procedures and sanctioning practices much like the Commission’s, it will be the rare case in which a respondent will be able to satisfy this evidentiary burden.21 As a result, the Commission’s order will generally mirror the order of the other authority, subject to differences in legislation.22

[10] In this case, the BCSC’s findings and BCSC Order warrant an order in Ontario. Dhanani engaged in fraud in

connection with the purported sale of securities. As the BCSC said, his fraud was “most egregious and cynical”.23 Such fraud would have contravened the Act, had it occurred in Ontario;24 it represents a serious risk to our capital markets.25 An order to protect investors in Ontario, in the form in Schedule A, is in the public interest.

[11] Such an order is necessary because of the limits on provincial jurisdiction. In an ideal world, the BCSC Order would

apply throughout Canada when it is made, as has been recognized in four provinces that have amended their securities acts to make protective orders like those requested in this application automatically applicable in their province.26 To facilitate enforcement of such provisions and to enable other securities regulatory authorities in Canada to seek a “reciprocal” order under their own legislation, should they determine to so do, it is desirable for Staff to notify all other provincial and territorial securities regulatory authorities of all orders under section 127 when they are made by this Commission.27

[12] It would also be desirable for an order under subsection 127(10) to be made as soon as practicable after an order of

another securities regulatory authority. In an effort to make applications like this one more efficient, Staff generally request on the initial return date that the proceeding be conducted as a written hearing, as they did in this case. While this procedure is reasonable, a more expeditious process may be available. Staff might consider, in cases like this one, serving their factum and other materials when they serve the notice of hearing and informing the respondent of their

17 See e.g. note 9, above; Re DeLaet (2014), 37 OSCB 1615 at paras 51, 68; Re Transcap Corporation (2014), 37 OSCB 2119 at para 32; Re

Zeiben (2016), 39 OSCB 1299 at para 24; Re Sebastian (2016), 39 OSCB 1305 at para 19. 18 See e.g. Re Black (2014), 37 OSCB 5847 at paras 9, 26; cf. McLean v. British Columbia (Securities Commission), [2013] 3 SCR 895 at

para 54 (Commission must make own determination, but provision obviates “need for inefficient parallel and duplicative proceedings”). 19 This will not always be the case; an order based on a settlement agreement may not alone provide a factual basis that warrants a

“reciprocal” order in the public interest; see e.g. Re Moore, 2014 ABASC 88. The settlement agreement, including any admissions, when combined with the order, however, will usually be sufficient; see Re Moore, 2014 ABASC 139.

Cf. Lines v. British Columbia (Securities Commission), 2012 BCCA 316 (imposition of more onerous sanctions than those consented to in no contest settlement unreasonable). The Lines decision does not affect an order that is not more onerous than the order agreed to without admissions. Nor does it limit the Commission’s general exercise of discretion under s. 127(1) with respect to such an order; see ss 127(10)4 and 5. Staff may seek a more onerous sanction and may also adduce additional evidence; see e.g. Re Pierce, 2016 BCSECCOM 188 (more onerous sanction permissible); see also Re Pierce, 2016 BCSECCOM 264 (more onerous sanction imposed); and see e.g. Re Euston Capital Corp. (2009), 32 OSCB 6313 at paras 15-22 (Staff adduced additional evidence).

20 For this reason, a determination that a “reciprocal” order is in the public interest has been described as having a “low threshold”; see e.g. Re JV Raleigh Superior Holdings Inc., note 15, above at para 26; Re New Futures Trading International Corp., note 15, above at para 27; Re Optam Holdings Inc. (2017), 40 OSCB 2167 at para 16.

21 To meet the burden of showing that an order or findings should not be accepted as fact, Commission decisions require proof that the original decision was procured by fraud, involved a denial of natural justice or was made without jurisdiction; see e.g. Re New Futures Trading International Corp., note 15, above at para 27; Re Black, note 18, above at paras 29-33.

22 See e.g. Re Optam Holdings Inc., note 20, above at para 17; McLean v. British Columbia (Securities Commission), note 18, above at para 15 (“twin orders”); Re Zeiben, note 17, above at para 33; Re DeLaet, note 17, above at para 79. This is not the case in a proceeding under paragraph 127(10)1 or 2, based on a criminal conviction, or in a proceeding under paragraph 127(10)3 based on a finding by a court, and may not be the case in a proceeding under paragraph 127(10)4 based on an order of a non-Canadian regulator.

23 Re Dhanani, note 3, above at paras 12, 18, 24. 24 See Act, s 126.1; see also note 9, above. 25 The BCSC found that Dhanani “represents the upper end of risk to our capital markets”; Re Dhanani, note 3, above at para 18. 26 See Securities Act, RSA 2000, c S-4, ss 198(3)-(10); Securities Act, SNB 2004, c S-5.5, s 184.1; Securities Act, RSNS 1989, c 418, s

134B; Securities Act, Stats Que 1982, c 48; Cons Stats c V-1.1, ss 308.2.1.2-308.2.1.6. See also Re Narayan (2016), 39 OSCB 10503 at para 6.

27 The potential for such pan-Canadian orders and the orders, themselves, enhance the specific and general deterrence of orders made by the Commission.


May 18, 2017

(2017), 40 OSCB 4460

intention to request that the order they are seeking be made on the initial return date. If the respondent does not appear, this would expedite the process.28 This process is available under both the Commission’s current Rules of Procedure and its proposed Rules.29

IV. CONCLUSION [13] I shall make the order requested by Staff. The order parallels the BCSC Order, but it is not identical because of

differences between the Act and the BC Act.30 Suffice it to say that this order will effectuate the prohibitions in the BCSC Order to the extent and in the manner authorized by the Act and will bar Dhanani permanently from participation in Ontario’s capital market.

[14] The provision of the order relating to investment fund managers requires further explanation.31 The definitions of

“investment fund” and “investment fund manager” were added to the Act in 2002, but without imposing regulatory obligations on them.32 In 2005, when investment fund managers were not required to be registered, subsection 127(1) of the Act was amended to authorize the Commission to prohibit a person from becoming or acting as a director or officer of an investment fund manager and to prohibit a person from becoming or acting as a registrant, investment fund manager or promoter.33 In 2009, the Act was amended to require investment fund managers to be registered, but the authority in subsection 127(1) to make orders relating to investment fund managers was not altered.34 As result, paragraph 127(1)8.5, for example, continues to authorize an order that prohibits a person from acting as a registrant and an investment fund manager, even though the former term, “registrant”, now includes the latter.35 Because this paragraph continues to refer to both categories, the order expressly includes an investment fund manager in order to avoid any ambiguity.

[15] I shall order that (a) trading in any securities or derivatives by Dhanani cease permanently, (b) the acquisition of any

securities by Dhanani be prohibited permanently, (c) the exemptions contained in Ontario securities law not apply to Dhanani permanently, (d) Dhanani resign any positions he holds as a director or officer of any issuer or registrant, including an investment fund manager, (e) Dhanani be prohibited permanently from becoming or acting as a director or officer of any issuer or registrant, including an investment fund manager, and (f) Dhanani be prohibited permanently from becoming or acting as a registrant, including an investment fund manager, or promoter.

Dated at Toronto this 12th day of May, 2017. “Philip Anisman”

28 In this case by approximately two months. If the respondent objects to a written hearing or requires additional time, the matter can be

addressed on the initial return date and the panel can set a schedule. If the respondent does not appear, as in this case, and as is frequently the case, the matter can be determined expeditiously.

29 See Notice and Request for Comments Regarding the Rules of Procedure and Forms and Practice Guideline of the Ontario Securities Commission (2017), 40 OSCB 3743, r 11, 21(3).

30 Staff is not seeking disgorgement and monetary sanctions like those imposed by the BCSC; see text above at note 3. Apart from other considerations, these sanctions are not necessary in this case to protect investors or the market in Ontario.

31 Staff proposed that Dhanani be prohibited from becoming or acting as an investment fund manager pursuant to paragraph 127(1)8.5 to reflect the prohibition in the BCSC Order against his “acting in a management or consultative capacity in connection with activities in the securities market” under s. 161(1)(d)(iv) of the BC Act, as the Act does not authorize the Commission to make an order in these terms; see Written Submissions of Staff, March 20, 2017 at paras 43, 44.

32 See SO 2002, c 22, s 177; Amendments to the Securities Act and Commodity Futures Act, (2003), 26 OSCB 2765. 33 Act, ss 127(1)8.3-8.5; SO 2005, c 31, Sched 20, s 8. 34 SO 2009, c 18, Sched 26, s 4, amending Act, s 25. 35 This is also the case with respect to directors and officers of an investment fund manager; see Act, ss 127(1)8.1-8.4.


May 18, 2017

(2017), 40 OSCB 4461

SCHEDULE A

IN THE MATTER OF AYAZ DHANANI

(also known as AZIM VIRANI, MICHAEL LEE, ALEX NEBRIS, PAUL DHANANI, SAMUEL RAMOS, and RAHIM JIWA)

ORDER

(Subsection 127(1) and (10) of the Securities Act, RSO 1990, c S.5) Philip Anisman, Chair of the Panel

May 12, 2017 WHEREAS the Ontario Securities Commission held a hearing in writing on the application of Staff of the Commission (“Staff”) for an order imposing sanctions pursuant to subsections 127(1) and 127(10) of the Securities Act, RSO 1990, c S.5 (the “Act”); ON READING the Findings of the British Columbia Securities Commission (the “BCSC”) dated May 30, 2016 and the Decision of the BCSC dated December 16, 2016, in the matter of Ayaz Dhanani (also known as Azim Virani, Michael Lee, Alex Nebris, Paul Dhanani, Samuel Ramos, and Rahim Jiwa) (“Dhanani”) and on reading the materials filed by Staff, Dhanani not having appeared and not having filed any materials, although properly served; IT IS ORDERED THAT: 1. pursuant to paragraph 127(1)2 of the Act, trading in any securities or derivatives by Dhanani cease permanently; 2. pursuant to paragraph 127(1)2.1 of the Act, the acquisition of any securities by Dhanani is prohibited permanently; 3. pursuant to paragraph 127(1)3 of the Act, the exemptions contained in Ontario securities law do not apply permanently

to Dhanani; 4. pursuant to paragraphs 127(1)7, 8.1, and 8.3 of the Act, Dhanani resign any position that he holds as a director or

officer of any issuer or registrant, including an investment fund manager; 5. pursuant to paragraphs 127(1)8, 8.2 and 8.4 of the Act, Dhanani is prohibited permanently from becoming or acting as

a director or officer of any issuer or registrant, including an investment fund manager; and 6. pursuant to paragraph 127(1)8.5, Dhanani is prohibited permanently from becoming or acting as a registrant, including

an investment fund manager, or a promoter. _________________________ Philip Anisman


May 18, 2017

(2017), 40 OSCB 4462

3.1.4 Larry Keith Davis – ss. 127(1), 127(10)

IN THE MATTER OF LARRY KEITH DAVIS

REASONS (Subsections 127(1) and (10) of the Securities Act, RSO 1990, c S.5)

Citation: Davis, 2017 ONSEC 16 Date: 2017-05-15

Hearing: May 15, 2017


Panel: Philip Anisman – Commissioner and Chair of the Panel

Appearances: Malinda Alvaro Alvin Qian (Student-at-law)


No one appearing for Larry Keith Davis

REASONS

[1] On March 1, 2017, the Commission issued a Notice of Hearing on the basis of a Statement of Allegations filed by Staff of the Commission (“Staff”) requesting an order against Larry Keith Davis (the “Respondent”) pursuant to subsections 127(1) and 127(10) of the Securities Act, RSO 1990, c S.5 (the “Act”) and on the basis of an order of the British Columbia Securities Commission (the “BCSC”) dated November 7, 2016 (the “BCSC Order”); see Notice of Hearing (2017), 40 OSCB 2068.

[2] At the initial hearing on March 13, 2017, Staff filed the Affidavit of Service of Lee Crann, sworn March 9, 2017 (Exhibit 1), which stated that the Respondent had been properly served and that Staff had communicated with his counsel in the BCSC proceedings (“Respondent’s Counsel”). Neither the Respondent nor his counsel appeared at this hearing. Staff requested an adjournment pending resolution of the Respondent’s application for leave to appeal the BCSC decisions (Re Davis, 2016 BCSECCOM 214 (Findings); 2016 BCSECCOM 375 (Decision)) on which this proceeding is based to the British Columbia Court of Appeal (“BCCA”), and I adjourned the hearing to today; see Order (2017), 40 OSCB 2594.

[3] At the hearing today, Staff filed an Affidavit of Service of Lee Crann, sworn May 8, 2017 (Exhibit 2) stating that she had served the Respondent with a copy of my Order of March 13, 2017 and provided a copy to Respondent’s Counsel. This Affidavit contains an email from Respondent’s Counsel stating that leave to appeal the BCSC decisions and a stay of execution of the sanctions imposed by the BCSC pending determination of the appeal were granted by the Honourable Madam Justice Fenlon on March 22, 2017. Neither the Respondent nor his counsel appeared at the hearing.

[4] Staff also filed a copy of an order signed by Respondent’s Counsel and counsel for the BCSC (the “Appeal Order”), with an email from Respondent’s Counsel indicating that the order has been submitted to, but not yet signed by Fenlon, JA and agreeing to provide a copy of the signed order when it is received (Exhibit 3). On the basis of the Appeal Order, Staff requested that the hearing be adjourned pending the outcome of the Respondent’s appeal.

[5] The Commission has a discretion whether to grant such an adjournment despite the stay of execution, as the Respondent remains subject to the BCSC Order; see Act, s 127(10)4; see also e.g. Re Savage, 2009 ABASC 94 and Re Pierce, 2016 BCSECCOM 44, denying stays where proceedings challenging the original order were outstanding. In this case, as a result of the stay of execution granted by Fenlon, JA, the BCSC Order is not operative. An order pursuant to subsection 127(10) would therefore impose restrictions on the Respondent to which he is not currently subject in British Columbia, the province in which the original order was made.

[6] In these circumstances, an adjournment sine die is appropriate, with the understanding that if the appeal is denied, Staff will bring this matter back before the Commission as soon as practicable after the appeal decision is rendered, or at an earlier date if Staff considers it advisable. For these reasons, I am making an order granting the adjournment requested by Staff.

Dated at Toronto this 15th day of May, 2017.

“Philip Anisman”

May 18, 2017

(2017), 40 OSCB 4463

Chapter 4

Cease Trading Orders 4.1.1 Temporary, Permanent & Rescinding Issuer Cease Trading Orders

Company Name Date ofTemporary Order

Date ofHearing

Date of Permanent Order

Date ofLapse/Revoke

THERE IS NOTHING TO REPORT THIS WEEK. Failure to File Cease Trade Orders

Company Name Date of Order Date of Revocation

THERE IS NOTHING TO REPORT THIS WEEK. 4.2.1 Temporary, Permanent & Rescinding Management Cease Trading Orders

Company Name Date of Order

THERE IS NOTHING TO REPORT THIS WEEK. 4.2.2 Outstanding Management & Insider Cease Trading Orders

Company Name Date of Order or Temporary Order

Date ofHearing

Date ofPermanent Order

Date of Lapse/Expire

Date ofIssuer

Temporary Order

Performance Sports Group Ltd.

19 October 2016 31 October 2016 31 October 2016

Company Name Date of Order

CHC Student Housing Corp. 05 May 2017

Ellipsiz Communications Ltd. 05 May 2017

Stompy Bot Corporation 04 May 2017

Cease Trading Orders

May 18, 2017

(2017), 40 OSCB 4464


May 18, 2017

(2017), 40 OSCB 4465

Chapter 7

Insider Reporting

The following is a weekly summary of insider transactions by insiders of Ontario reporting issuers in SEDI ® (the System for Electronic Disclosure by Insiders).1 The weekly summary contains insider transactions reported during the 7-day period ending Sunday at 11:59 p.m. (i.e. the Sunday prior to the Bulletin Issue date).2

Guide to Codes

Relationship of Insider to Issuer (Rel=n) 1 Issuer 2 Subsidiary of Issuer 3 10% Security Holder of Issuer 4 Director of Issuer 5 Senior Officer of Issuer 6 Director or Senior Officer of 10% Security Holder 7 Director or Senior Officer of Insider or Subsidiary of Issuer (other than in 4,5,6) 8 Deemed Insider – 6 Months before becoming Insider

Nature of Transaction (T/O)

00 Opening Balance-Initial SEDI Report 10 Acquisition or disposition in the public market 11 Acquisition or disposition carried out privately 15 Acquisition or disposition under a prospectus 16 Acquisition or disposition under a prospectus exemption 22 Acquisition or disposition pursuant to a take-over bid, merger or acquisition 30 Acquisition or disposition under a purchase/ ownership plan 35 Stock dividend 36 Conversion or exchange 37 Stock split or consolidation 38 Redemption, retraction, cancellation, repurchase 40 Short sale 45 Compensation for property 46 Compensation for services 47 Acquisition or disposition by gift 48 Acquisition by inheritance or disposition by bequest 50 Grant of options 51 Exercise of options 52 Expiration of options 53 Grant of warrants 54 Exercise of warrants 55 Expiration of warrants 56 Grant of rights 57 Exercise of rights 59 Exercise for cash 70 Acquisition or disposition (writing) of third party derivative 71 Exercise of third party derivative 72 Other settlement of third party 73 Expiration of third party derivative 90 Change in nature of ownership 97 Other 99 Correction of Information

Note: The asterisk in the “Date/Month End Holding” column indicates the insider disagreed with the system calculated balance when the

transaction was reported.

1 SEDI® is a registered trademark owned by CDS INC.

2 ©CDS INC.

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4466

Issuer Name Security Insider Name Rel'n Transaction Date T/O Unit Price

Date/Month End Holdings

Acquired/ Disposed

22 Capital Corp. Options Goldman, Jason Ira 4 08/05/2017 50 250,000 250,000

22 Capital Corp. Options Hua, Li 5 08/05/2017 50 10,000 10,000

22 Capital Corp. Options Lustig, Marc 3, 4 04/01/2017 00 500,000

22 Capital Corp. Options Mintz, Steven Michael 3, 4, 5 07/04/2017 00

22 Capital Corp. Options Mintz, Steven Michael 3, 4, 5 08/05/2017 50 0.1 250,000 250,000

5N Plus Inc. Common Shares Bertrand, Luc 4 05/05/2017 10 2.1553 1,067,600 42,600



5N Plus Inc. Deferred Share Units/Unités d'action reportées

Bertrand, Luc 4 05/05/2017 56 1.89 127,593 66,138

5N Plus Inc. Common Shares BOURASSA, JEAN-MARIE 4 08/05/2017 10 2.2719 927,100 20,000

5N Plus Inc. Common Shares BOURASSA, JEAN-MARIE 4 09/05/2017 10 2.4265 972,100 45,000


BOURASSA, JEAN-MARIE 4 05/05/2017 56 1.89 238,437 52,566


Le Prohon, Nathalie 4 05/05/2017 56 1.89 156,505 34,392


S. Hwang, Jennie 4 05/05/2017 56 1.89 169,769 47,407


T. Fahey, James 4 05/05/2017 56 1.89 169,769 47,407

Abattis Bioceuticals Corp. Common Shares Dancosse, Guy 4 08/05/2017 10 0.23 337,191 -72,000

Abattis Bioceuticals Corp. Common Shares Dancosse, Guy 4 08/05/2017 10 0.22 269,191 -68,000

ABcann Global Corporation Common Shares Chadwick, Dennis 7 28/04/2017 00

ABcann Global Corporation Common Shares Chadwick, Dennis 7 28/04/2017 16 0.8 3,973,478 3,973,478

ABcann Global Corporation Common Shares Chadwick, Dennis 7 28/04/2017 00

ABcann Global Corporation Common Shares Chadwick, Dennis 7 28/04/2017 16 0.8 244,844 244,844

ABcann Global Corporation Options Chadwick, Dennis 7 28/04/2017 00 2,250,000

ABcann Global Corporation Warrants Chadwick, Dennis 7 28/04/2017 00 728,634

ABcann Global Corporation Common Shares Clement, Kenneth 4, 5 28/04/2017 00

ABcann Global Corporation Common Shares Clement, Kenneth 4, 5 28/04/2017 16 0.8 1,282,873 1,282,873

ABcann Global Corporation Common Shares Clement, Kenneth 4, 5 28/04/2017 00

ABcann Global Corporation Common Shares Clement, Kenneth 4, 5 28/04/2017 16 0.8 31,923,536 31,923,536

ABcann Global Corporation Options Clement, Kenneth 4, 5 28/04/2017 00

ABcann Global Corporation Options Clement, Kenneth 4, 5 03/05/2017 50 0.8 145,000 145,000

ABcann Global Corporation Restricted Share Units Clement, Kenneth 4, 5 28/04/2017 00

ABcann Global Corporation Restricted Share Units Clement, Kenneth 4, 5 03/05/2017 56 1,200,000 1,200,000

ABcann Global Corporation Warrants Clement, Kenneth 4, 5 28/04/2017 00 1,282,873

ABcann Global Corporation Warrants Clement, Kenneth 4, 5 28/04/2017 00 397,728

ABcann Global Corporation Common Shares Easson, John Langley 4 28/04/2017 00

ABcann Global Corporation Common Shares Easson, John Langley 4 28/04/2017 16 0.8 125,000 125,000

ABcann Global Corporation Options Easson, John Langley 4 28/04/2017 00

ABcann Global Corporation Options Easson, John Langley 4 03/05/2017 50 0.8 50,000 50,000

ABcann Global Corporation Common Shares Guan, Ying (Jenny) 5 28/04/2017 00

ABcann Global Corporation Common Shares Guan, Ying (Jenny) 5 28/04/2017 16 0.8 2,149,860 2,149,860

ABcann Global Corporation Options Guan, Ying (Jenny) 5 28/04/2017 00 1,000,000

ABcann Global Corporation Restricted Share Units Guan, Ying (Jenny) 5 28/04/2017 00

ABcann Global Corporation Restricted Share Units Guan, Ying (Jenny) 5 03/05/2017 56 156,250 156,250

ABcann Global Corporation Warrants Guan, Ying (Jenny) 5 28/04/2017 00 7,768,000

ABcann Global Corporation Common Shares Humberstone, Timothy 7 28/04/2017 00

ABcann Global Corporation Common Shares Humberstone, Timothy 7 28/04/2017 16 0.8 96,000 96,000

ABcann Global Corporation Options Humberstone, Timothy 7 28/04/2017 00 150,000

ABcann Global Corporation Restricted Share Units Humberstone, Timothy 7 28/04/2017 00

ABcann Global Corporation Restricted Share Units Humberstone, Timothy 7 03/05/2017 56 44,000 44,000

ABcann Global Corporation Common Shares KRAMP, DARYL 4 28/04/2017 00

ABcann Global Corporation Common Shares KRAMP, DARYL 4 28/04/2017 16 0.8 62,500 62,500

ABcann Global Corporation Options KRAMP, DARYL 4 28/04/2017 00

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4467



Acquired/ Disposed

ABcann Global Corporation Options KRAMP, DARYL 4 03/05/2017 50 0.8 50,000 50,000

ABcann Global Corporation Common Shares Lucas, Paul 4 28/04/2017 00

ABcann Global Corporation Common Shares Lucas, Paul 4 28/04/2017 16 0.8 60,975 60,975

ABcann Global Corporation Common Shares Lucas, Paul 4 28/04/2017 16 0.8 92,225 31,250

ABcann Global Corporation Options Lucas, Paul 4 28/04/2017 00 200,000

ABcann Global Corporation Options Lucas, Paul 4 03/05/2017 50 0.8 250,000 50,000

ABcann Global Corporation Common Shares Molloy, John Patrick 7 28/04/2017 00

ABcann Global Corporation Common Shares Molloy, John Patrick 7 28/04/2017 16 0.8 250,000 250,000

ABcann Global Corporation Options Molloy, John Patrick 7 28/04/2017 00 150,000

ABcann Global Corporation Restricted Share Units Molloy, John Patrick 7 28/04/2017 00

ABcann Global Corporation Restricted Share Units Molloy, John Patrick 7 03/05/2017 56 100,000 100,000

ABE Resources Inc. Common Shares Bonneville, Paul 4 14/11/2016 00

ABE Resources Inc. Common Shares Bonneville, Paul 4 05/05/2017 51 0.1 25,000 25,000

ABE Resources Inc. Options Bonneville, Paul 4 26/04/2017 37 25,000 -25,000

ABE Resources Inc. Options Bonneville, Paul 4 05/05/2017 51 0.1 0 -25,000

ABE Resources Inc. Options Bonneville, Paul 4 05/05/2017 51 0.1 25,000

ABE Resources Inc. Options Bonneville, Paul 4 05/05/2017 51 0.1 25,000

ABE Resources Inc. Common Shares Bryce, Robert 4 26/04/2017 37 264,040 -264,040

ABE Resources Inc. Common Shares Bryce, Robert 4 12/05/2017 16 0.05 364,040 100,000



ABE Resources Inc. Options Bryce, Robert 4 26/04/2017 37 92,500 -92,500

ABE Resources Inc. Warrants Bryce, Robert 4 26/04/2017 37 50,000 -50,000

ABE Resources Inc. Warrants Bryce, Robert 4 12/05/2017 16 0.15 150,000 100,000

ABE Resources Inc. Common Shares Lacoursiere, Nancy 5 10/11/2016 00

ABE Resources Inc. Common Shares Lacoursiere, Nancy 5 03/05/2017 51 0.1 30,000 30,000

ABE Resources Inc. Options Lacoursiere, Nancy 5 26/04/2017 37 30,000 -30,000

ABE Resources Inc. Options Lacoursiere, Nancy 5 03/05/2017 51 0.1 0 -30,000

ABE Resources Inc. Common Shares Rougerie, Yves 4, 5 26/04/2017 37 198,650 -198,650

ABE Resources Inc. Common Shares Rougerie, Yves 4, 5 03/05/2017 10 0.125 30,000

ABE Resources Inc. Common Shares Rougerie, Yves 4, 5 03/05/2017 10 0.25 213,650 15,000




ABE Resources Inc. Options Rougerie, Yves 4, 5 26/04/2017 37 92,500 -92,500

ABE Resources Inc. Options Rougerie, Yves 4, 5 03/05/2017 51 0.2 42,500 -50,000

ABE Resources Inc. Options Rougerie, Yves 4, 5 03/05/2017 51 0.1 5,000 -37,500

ABE Resources Inc. Options Rougerie, Yves 4, 5 08/05/2017 37 -92,500

ABE Resources Inc. Warrants Rougerie, Yves 4, 5 26/04/2017 37 50,000 -50,000

ABE Resources Inc. Warrants Rougerie, Yves 4, 5 12/05/2017 16 0.15 450,000 400,000

Aberdeen Asia-Pacific Income Investment Company Limited

Common Shares Aberdeen Asia-Pacific Income Investment Company Limited

1 03/04/2017 38 4.57 7,000 7,000



1 06/04/2017 38 4.64 10,300 3,300



1 06/04/2017 38 4.63 14,000 3,700



1 10/04/2017 38 4.57 15,000 1,000



1 10/04/2017 38 4.58 21,000 6,000



1 13/04/2017 38 4.63 24,500 3,500



1 13/04/2017 38 4.64 28,000 3,500

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4468



Acquired/ Disposed



1 20/04/2017 38 4.64 35,000 7,000



1 21/04/2017 38 7,000 -28,000



1 21/04/2017 38 4.66 14,000 7,000



1 25/04/2017 38 4.64 21,000 7,000



1 26/04/2017 38 0 -21,000

Abitibi Royalties Inc. Common Shares Ball, Ian 4, 5 12/05/2017 10 9.25 75,392 300

Abitibi Royalties Inc. Common Shares Ball, Ian 4, 5 12/05/2017 10 9.28 78,492 3,100











Abitibi Royalties Inc. Common Shares Doyle, Louis 4 12/05/2017 10 9.1 2,300 300

Abitibi Royalties Inc. Common Shares Groia, Joseph 6 10/05/2017 10 9.22 110,202 500

Abitibi Royalties Inc. Common Shares Poisson, Daniel 5 10/05/2017 10 9.47 4,200 500

ACTIVEnergy Income Fund Trust Units Lauzon, Robert 6, 7 30/04/2007 00

ACTIVEnergy Income Fund Trust Units Lauzon, Robert 6, 7 10/05/2017 10 4.4079 7,100 7,100

AcuityAds Holdings Inc. Common Shares Dent, Roger 4 10/05/2017 30 207,545 2,750

Advantage Oil & Gas Ltd. Common Shares Blackwood, Donald Craig 5 10/05/2017 10 8.857 435,494 -10,000

Advantage Oil & Gas Ltd. Common Shares Mah, Andy 5 11/05/2017 10 9 1,050,196 -12,000

Aecon Group Inc. Deferred Share Units Butt, Michael 4 07/03/2017 56 15.88 27,983 6,297

Aecon Group Inc. Deferred Share Units Carrabba, Joseph Anthony 4 07/03/2017 56 15.88 30,948 6,297

Aecon Group Inc. Deferred Share Units Franceschini, Anthony P. 4 07/03/2017 56 15.88 29,257 6,297

Aecon Group Inc. Deferred Share Units Hole, James Douglas 4 07/03/2017 56 15.88 32,262 6,297

Aecon Group Inc. Deferred Share Units Sloan, Monica 4 07/03/2017 56 15.88 29,257 6,297

Aecon Group Inc. Deferred Share Units Tobin, Brian Vincent 4 07/03/2017 56 15.88 30,988 6,297

Aecon Group Inc. Deferred Share Units Wolburgh Jenah, Susan 4 07/03/2017 56 15.88 7,571 6,297

African Queen Mines Ltd. Common Shares Martohardjono, Ardito 4 10/05/2017 10 0.055 105,200 34,000

African Queen Mines Ltd. Common Shares Martohardjono, Ardito 4 11/05/2017 10 0.055 107,200 2,000

Agellan Commercial Real Estate Investment Trust

Units Agellan Capital Partners Inc.

5 08/05/2017 16 11.43 67,666 44,513


Units Camenzuli, Francis Xavier 4, 7, 5 25/01/2013 00


Units Camenzuli, Francis Xavier 4, 7, 5 08/05/2017 16 11.43 44,513 44,513


Units Camenzuli, Francis Xavier 4, 7, 5 11/05/2017 10 11.344 407,099 13,260


Units Millett, Daniel 5 11/05/2017 10 11.31 6,606 445


Units Millett, Daniel 5 11/05/2017 10 11.32 6,686 80

Agnico Eagle Mines Limited Common Shares Al-Joundi, Ammar 5 05/05/2015 00

Agnico Eagle Mines Limited Common Shares Al-Joundi, Ammar 5 05/05/2015 00 5,550

Agnico Eagle Mines Limited Common Shares Al-Joundi, Ammar 5 14/07/2015 30 36.41 16,262 712

Agnico Eagle Mines Limited Common Shares Blackburn, Alain 5 05/05/2017 51 28.03 10,798 2,500

Agnico Eagle Mines Limited Common Shares Blackburn, Alain 5 05/05/2017 10 63.81 8,298 -2,500

Agnico Eagle Mines Limited Options Blackburn, Alain 5 05/05/2017 51 28.03 194,000 -2,500

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4469



Acquired/ Disposed

AGT Food and Ingredients Inc. (formerly, Alliance Grain Traders Inc.)

Common Shares Al-Katib, Murad 3, 4, 5 09/05/2017 10 25.16 569,788 700


Common Shares Al-Katib, Murad 3, 4, 5 09/05/2017 10 25.23 571,288 1,500


Common Shares Bourassa, Gaetan Michael 5 09/05/2017 10 25 49,431 800


Common Shares Rosen, Howard N. 4 09/05/2017 10 25.34 60,000 5,000


Common Shares Rosen, Howard N. 4 09/05/2017 10 24.99 65,000 5,000

Air Canada Options (Long-Term Incentive Plan)

Meloul-Wechsler, Arielle 5 05/05/2017 50 73,267 5,000

Air Canada Share Units (Long-Term Incentive Plan)

Meloul-Wechsler, Arielle 5 05/05/2017 56 12.83 30,529 2,000

Akita Drilling Ltd. Non-Voting Shares Coleman, Raymond 5 04/05/2017 30 8.68 18,454 268

Akita Drilling Ltd. Non-Voting Shares Hensel, Fred 5 04/05/2017 30 8.68 29,670 196

Akita Drilling Ltd. Non-Voting Shares Reynolds, Darcy 5 04/05/2017 30 8.68 3,054 87

Alabama Graphite Corp. Common Shares Baxter, Donald 4, 5 05/05/2017 16 0.15 2,956,000 2,666,666

Alabama Graphite Corp. Warrants Baxter, Donald 4, 5 05/05/2017 16 0.2 5,416,666 2,666,666

Alabama Graphite Corp. Warrants Baxter, Donald 4, 5 05/05/2017 11 4,083,333 -1,333,333

Alabama Graphite Corp. Options stock options Depatie, Jean 4 10/05/2017 50 0.15 1,365,000 250,000

Alabama Graphite Corp. Common Shares Dinwoodie, Tyler Wayne Paul

5 03/05/2017 10 0.15 500,000 -1,000,000

Alabama Graphite Corp. Common Shares Dinwoodie, Tyler Wayne Paul

5 10/05/2017 16 0.15 1,500,000 1,000,000

Alabama Graphite Corp. Warrants Dinwoodie, Tyler Wayne Paul

5 10/05/2017 16 0.2 1,100,000 1,000,000

Alabama Graphite Corp. Warrants Dinwoodie, Tyler Wayne Paul

5 10/05/2017 11 600,000 -500,000

Alabama Graphite Corp. Options stock options Goffaux, Daniel Pierre 4 10/05/2017 50 0.15 1,100,000 250,000

Alabama Graphite Corp. Options stock options Hatch, Gareth 4 10/05/2017 50 0.15 950,000 250,000

Alabama Graphite Corp. Common Shares Pamplin, Ann-Marie Michelle

8 08/05/2017 10 0.145 21,500 10,000


8 09/05/2017 10 0.145 26,500 5,000


8 10/05/2017 10 0.145 120,500 2,000


8 11/05/2017 10 0.15 123,500 3,000


8 11/05/2017 10 0.145 126,500 3,000

Alchemist Mining Incorporated

Common Shares Anderson, Keith 4, 5 09/05/2017 10 0.07 3,081,200 -100,000

Algonquin Power & Utilities Corp.

Common Shares Bronicheski, David John 5 31/12/2016 30 2,038


Common Shares Bronicheski, David John 5 31/12/2016 30 6,283


Common Shares Bronicheski, David John 5 31/12/2016 30 479,607 2,038


Common Shares Robertson, Ian Edward 5 31/12/2016 30 3,146


Common Shares Robertson, Ian Edward 5 31/12/2016 30 1,261,398 3,257


Common Shares Snow, Michael Gerald 5 31/12/2016 30 128,336 1,304

Alianza Minerals Ltd. (formerly Tarsis Resources Ltd.)

Common Shares Brown, Mark Thomas 4 09/05/2017 10 0.15 2,060,000 10,000



Insider Reporting

May 18, 2017

(2017), 40 OSCB 4470



Acquired/ Disposed



Alimentation Couche-Tard Inc.

Unité d'action différée Bourque, Nathalie 4 08/05/2017 46 63.48 17,217 366


Unité d'action différée D'Amours, Jacques 4 08/05/2017 46 63.48 4,841 355


Unité d'action différée Élie, Jean André 4 08/05/2017 46 63.48 32,224 226


Unité d'action différée Fortin, Richard 4, 6, 7, 5 08/05/2017 46 63.48 18,456 355


Unité d'action différée Kau, Mélanie 4 08/05/2017 46 63.48 64,101 452


Unité d'action différée Leroux, Monique F. 4 08/05/2017 46 63.48 3,110 367


Unité d'action différée Plourde, Réal 4, 6, 7, 5 08/05/2017 46 63.48 4,770 354


Unité d'action différée Rabinowicz, Daniel 5 08/05/2017 46 63.48 4,296 183


Unité d'action différée Turmel, Jean 4 08/05/2017 46 63.48 98,487 485

Alix Resources Corp. Common Shares Jacob, Gerhard 4 26/04/2017 00

Alix Resources Corp. Common Shares Jacob, Gerhard 4 10/05/2017 50 0.05 300,000 300,000

Allied Properties Real Estate Investment Trust

Units Cunningham, Gordon R. 4 19/12/2006 11 20.99 16,750 1,500


Units Issued under Long-Term Incentive Plan

Cunningham, Gordon R. 4 19/12/2006 11 20.99 1,500


Units Griffiths, James Clark 4 19/12/2006 11 20.99 1,500 1,500



Griffiths, James Clark 4 19/12/2006 11 20.99 1,500


Units Sullivan, Daniel Francis 4 19/12/2006 11 20.99 16,750 1,500



Sullivan, Daniel Francis 4 19/12/2006 11 20.99 1,500

Almaden Minerals Ltd. Options Brown, Mark Thomas 4 04/05/2017 52 1.91 425,000 -25,000

Almaden Minerals Ltd. Options Brown, Mark Thomas 4 04/05/2017 50 1.99 25,000

Almaden Minerals Ltd. Options Brown, Mark Thomas 4 04/05/2017 50 1.99 450,000 25,000

Almaden Minerals Ltd. Options Poliquin, James Duane 4, 5 04/05/2017 50 1.99 1,555,000 100,000

Almadex Minerals Limited Stock Options Brown, Mark Thomas 4 05/05/2017 50 1.1 309,000 30,000

Almadex Minerals Limited Stock Options McDonald, Douglas John 4 05/05/2017 50 1.1 300,000 50,000

Almadex Minerals Limited Stock Options Poliquin, James Duane 4, 5 05/05/2017 50 1.1 951,000 93,000

Almadex Minerals Limited Stock Options Poliquin, Morgan James 4, 5 05/05/2017 50 1.1 1,560,000 100,000

Almadex Minerals Limited Stock Options WORRALL, WILLIAM JOSEPH

4 04/05/2017 50 1.1 300,000 80,000

Alset Minerals Corp. (formerly Alset Energy Corp.)

Common Shares Robertson, Brian Ernest 4 11/05/2017 10 0.13 196,645


Common Shares Robertson, Brian Ernest 4 11/05/2017 16 0.13 220,000 195,000


Options Robertson, Brian Ernest 4 10/05/2017 50 0.15 300,000 100,000


Warrants Robertson, Brian Ernest 4 11/05/2017 16 0.2 195,000 195,000

Alta Vista Ventures Ltd. Common Shares Springett, Jason 3, 4 12/05/2017 11 7,516,000 800,000

AltaGas Ltd. Common Shares Stout, Kent Eugene 5 08/05/2017 10 31.6 22,786 -1,000

Amerigo Resources Ltd Common Shares Toor, Nauman (Nick) 3 09/05/2017 10 0.6 17,658,300 335,000

Amerigo Resources Ltd Common Shares Toor, Nauman (Nick) 3 10/05/2017 10 0.59 17,752,300 94,000

Amerigo Resources Ltd Common Shares Toor, Nauman (Nick) 3 05/05/2017 10 0.614 71,500

Amerigo Resources Ltd Common Shares Toor, Nauman (Nick) 3 05/05/2017 10 0.614 71,500

Antler Gold Inc. Common Shares Hansen, Carl 4 05/05/2017 00 75,000

Aphria Inc. (formerly, Black Sparrow Capital Corp.)

Common Shares Caciavillani, Cole 3, 4, 5 09/05/2017 10 5.91 6,766,667 100,000

Aphria Inc. (formerly, Black Sparrow Capital Corp.)

Common Shares Kozlov, Robert Avery 4 09/05/2017 10 5.88 8,500 1,500

Aralez Pharmaceuticals Inc. Options Adams, Adrian 4, 5 11/05/2017 50 357,567 252,316

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4471



Acquired/ Disposed

Aralez Pharmaceuticals Inc. Restricted Share Units Adams, Adrian 4, 5 11/05/2017 56 1,759,942 218,380

Aralez Pharmaceuticals Inc. Options Armstrong, Jennifer Lou 5 11/05/2017 50 78,834 52,104

Aralez Pharmaceuticals Inc. Restricted Share Units Armstrong, Jennifer Lou 5 11/05/2017 56 131,400 45,096

Aralez Pharmaceuticals Inc. Options Aryeh, Jason 8, 4 11/05/2017 50 30,000 15,000

Aralez Pharmaceuticals Inc. Restricted Share Units Aryeh, Jason 8, 4 11/05/2017 56 15,000 7,500

Aralez Pharmaceuticals Inc. Options Charles, Scott J. 5 11/05/2017 50 136,217 96,121

Aralez Pharmaceuticals Inc. Restricted Share Units Charles, Scott J. 5 11/05/2017 56 201,772 83,192

Aralez Pharmaceuticals Inc. Options Fowler, Neal Franklin 4 11/05/2017 50 30,000 15,000

Aralez Pharmaceuticals Inc. Restricted Share Units Fowler, Neal Franklin 4 11/05/2017 56 15,000 7,500

Aralez Pharmaceuticals Inc. Options Glickman, Mark A. 5 11/05/2017 50 131,180 92,621

Aralez Pharmaceuticals Inc. Restricted Share Units Glickman, Mark A. 5 11/05/2017 56 197,533 80,163

Aralez Pharmaceuticals Inc. Common Shares Harris, Robert Paul 4 03/05/2017 57 1.41 594,094 7,500

Aralez Pharmaceuticals Inc. Options Harris, Robert Paul 4 11/05/2017 50 220,831 15,000

Aralez Pharmaceuticals Inc. Restricted Share Units Harris, Robert Paul 4 03/05/2017 57 1.41 0 -7,500

Aralez Pharmaceuticals Inc. Restricted Share Units Harris, Robert Paul 4 11/05/2017 56 7,500 7,500

Aralez Pharmaceuticals Inc. Common Shares Kirsch, Arthur S. 4 03/05/2017 57 1.41 95,109 7,500

Aralez Pharmaceuticals Inc. Options Kirsch, Arthur S. 4 11/05/2017 50 48,321 15,000

Aralez Pharmaceuticals Inc. Restricted Share Units Kirsch, Arthur S. 4 03/05/2017 57 1.41 0 -7,500

Aralez Pharmaceuticals Inc. Restricted Share Units Kirsch, Arthur S. 4 11/05/2017 56 7,500 7,500

Aralez Pharmaceuticals Inc. Options Koven, Andrew 5 11/05/2017 50 178,750 126,158

Aralez Pharmaceuticals Inc. Restricted Share Units Koven, Andrew 5 11/05/2017 56 1,258,118 109,190

Aralez Pharmaceuticals Inc. Options Lee, Kenneth B Jr 4 11/05/2017 50 36,107 15,000

Aralez Pharmaceuticals Inc. Restricted Share Units Lee, Kenneth B Jr 4 11/05/2017 56 15,000 7,500

Aralez Pharmaceuticals Inc. Options Rudnick, Seth 4 11/05/2017 50 30,000 15,000

Aralez Pharmaceuticals Inc. Restricted Share Units Rudnick, Seth 4 11/05/2017 56 15,000 7,500

Aralez Pharmaceuticals Inc. Options Thrasher, Francis Martin 4 11/05/2017 50 43,095 15,000

Aralez Pharmaceuticals Inc. Restricted Share Units Thrasher, Francis Martin 4 11/05/2017 56 15,000 7,500

Aralez Pharmaceuticals Inc. Options Trachtenberg, Eric 5 11/05/2017 50 104,054 74,851

Aralez Pharmaceuticals Inc. Restricted Share Units Trachtenberg, Eric 5 11/05/2017 56 162,785 64,784

Aralez Pharmaceuticals Inc. Options Tursi, James Patrick 5 11/05/2017 50 136,217 96,121

Aralez Pharmaceuticals Inc. Restricted Share Units Tursi, James Patrick 5 11/05/2017 56 201,772 83,192

ARC Resources Ltd. Common Shares Berrett, Ryan Victor 5 17/04/2017 97 1,415 3

ARC Resources Ltd. Common Shares Calder, Sean Ross Allen 5 17/04/2017 97 877 2

ARC Resources Ltd. Common Shares Calder, Sean Ross Allen 5 17/04/2017 97 9,567 25



Armada Mercantile Ltd. Common Shares Skinder, Philip Joseph 4 03/05/2017 10 0.15 93,000 -4,000



Ascendant Resources Inc. Common Shares Brennan, Mark Peter 4, 5 10/05/2017 10 0.73 2,185,666 2,500

Ascendant Resources Inc. Common Shares Brennan, Mark Peter 4, 5 10/05/2017 10 0.7288 2,208,166 22,500

Athabasca Oil Corporation Deferred Share Units ECKHARDT, Ronald John 4 09/05/2017 56 347,194 15,000

Atlantic Gold Corporation (previously Spur Ventures Inc.)

Common Shares Armstrong, William Paul 4 12/09/2013 00


Common Shares Armstrong, William Paul 4 10/05/2017 51 0.37 100,000 100,000


Options Armstrong, William Paul 4 10/05/2017 51 0.37 510,000 -100,000


Common Shares Black, W. David 4 03/05/2017 51 0.4 375,000 100,000


Options Black, W. David 4 03/05/2017 51 0.4 460,000 -100,000

Aton Resources Inc. Options Clements, Anthony Paul 4 12/05/2016 00

Aton Resources Inc. Options Clements, Anthony Paul 4 06/07/2016 50 500,000 500,000

Aton Resources Inc. Options Clements, Anthony Paul 4 27/03/2017 50 1,250,000 750,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4472



Acquired/ Disposed

Atrium Mortgage Investment Corporation

Common Shares SILVER, MARK 4 29/08/2012 00


Common Shares SILVER, MARK 4 11/05/2017 30 11.83 6,149 6,149


Deferred Share Units SILVER, MARK 4 11/05/2017 30 3,227 -6,149

Aura Silver Resources Inc. Common Shares McNeice, John Darin 5 04/05/2017 10 0.09 3,882,000 2,000





AuRico Metals Inc. Options Ewing, Grant David 5 08/03/2017 00

AuRico Metals Inc. Options Ewing, Grant David 5 03/05/2017 50 1.06 200,000 200,000

Auryn Resources Inc. Common Shares Starr, James Russell Nelles 5 08/05/2017 10 2.96 1,043,200 2,500

AutoCanada Inc. Common Shares Dickinson, Arlene 4 05/05/2017 00

AutoCanada Inc. Deferred share units Dickinson, Arlene 4 05/05/2017 00

AutoCanada Inc. Common Shares Warsaba, Mark Douglas 5 01/04/2017 00 750

Avalon Advanced Materials Inc.

Common Shares Bubar, Donald Stephen 4, 5 11/05/2017 10 0.145 5,711,100 50,000

Avnel Gold Mining Limited Warrants Elliott International Capital Advisors Inc.

3 07/05/2017 55 13,416,891 -5,892,858

Avnel Gold Mining Limited Common Shares McDonald, Ian 5 03/05/2017 10 0.26 392,500 9,500



Avnel Gold Mining Limited Warrants Singer, Paul Elliott 3 07/05/2017 55 2,200,000 -3,035,714

Azarga Metals Corp. Common Shares Hopley, Michael John 4, 5 10/05/2017 46 0.235 77,921 21,276

Azarga Metals Corp. Common Shares Molyneux, Alexander 3, 4 10/05/2017 46 0.235 4,485,461 21,276

Azarga Metals Corp. Common Shares Pakhomov, Vladimir 4 10/05/2017 46 0.235 58,721 21,276

Azarga Metals Corp. Common Shares Steele, Blake Albert 4 10/05/2017 46 0.235 1,091,544 21,276

Azarga Uranium Corp. Common Shares Bayer, Alex 4 05/05/2017 46 0.35 328,582 31,344

Azarga Uranium Corp. Common Shares Church, Curtis 6 05/05/2017 46 0.35 7,444,345 25,074

Azarga Uranium Corp. Common Shares Havlin, Joseph 4 05/05/2017 46 0.35 1,225,162 31,344

Azarga Uranium Corp. Common Shares O'Kane, Matthew James Gerard

6 05/05/2017 46 0.35 517,451 31,344

Azarga Uranium Corp. Common Shares Steele, Blake Albert 5 05/05/2017 46 0.35 2,506,910 78,365

Azarga Uranium Corp. Common Shares Struijk, Apolonius 4 05/05/2017 46 0.35 250,126 25,074

Aztec Minerals Corp. Common Shares Schilling, James 4 02/05/2017 15 0.35 666,666 100,000

Aztec Minerals Corp. Common Shares Schilling, James 4 08/05/2017 10 766,666 100,000

Aztec Minerals Corp. Warrants Schilling, James 4 02/05/2017 15 175,000 50,000

B2Gold Corp. Common Shares Craig, Dale Alton 5 08/05/2017 51 3.06 60,904 30,700

B2Gold Corp. Common Shares Craig, Dale Alton 5 08/05/2017 10 3.11 30,204 -30,700

B2Gold Corp. Options Stock Options Craig, Dale Alton 5 08/05/2017 51 3.06 889,300 -30,700

B2Gold Corp. Options Stock Options Craig, Dale Alton 5 08/05/2017 51 3.06 858,600 -30,700

B2Gold Corp. Common Shares Gayton, Robert 4 18/01/2017 10 3.67 299,000 -34,000

B2Gold Corp. Common Shares Gayton, Robert 4 18/01/2017 47 3.67 279,000 -20,000

Bank of Nova Scotia, The Common Shares Bank of Nova Scotia, The 1 03/04/2017 38 68.632 1,154,130 577,065



Bank of Nova Scotia, The Common Shares Bank of Nova Scotia, The 1 05/04/2017 38 1,154,130 -1,154,130

Bank of Nova Scotia, The Common Shares Bank of Nova Scotia, The 1 06/04/2017 38 577,065 -577,065

Bank of Nova Scotia, The Common Shares Bank of Nova Scotia, The 1 06/04/2017 38 69.725 577,065

Bank of Nova Scotia, The Common Shares Bank of Nova Scotia, The 1 06/04/2017 38 69.725 893,410 316,345

Bank of Nova Scotia, The Common Shares Bank of Nova Scotia, The 1 06/04/2017 38 316,345 -577,065

Bank of Nova Scotia, The Common Shares Bank of Nova Scotia, The 1 07/04/2017 38 0 -316,345

Banro Corporation Common Shares Baiyin Nonferrous Group Co. Ltd.

3 25/02/2016 00


3 19/04/2017 36 0.17 60,889,060 60,889,060


3 19/04/2017 36 0.17 270,156,557 220,156,557

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4473



Acquired/ Disposed

Banro Corporation Rights Exchangeable Preferred Shares

Baiyin Nonferrous Group Co. Ltd.

3 25/02/2016 00 300,000



3 19/04/2017 36 0 -300,000



3 19/04/2017 36 0 -20,000

Banro Corporation Secured Notes due 2021 Baiyin Nonferrous Group Co. Ltd.

3 25/02/2016 00


3 19/04/2017 36 $51,250,000 $51,250,000


3 19/04/2017 36 $56,522,000 $5,272,000

Banro Corporation Senior Secured Notes Baiyin Nonferrous Group Co. Ltd.

3 01/03/2017 36 $0 -$40,000,000

Banro Corporation Common Shares KONDRAT, ARNOLD T. 5 09/05/2017 10 0.11 756,498 -73,034

Banro Corporation Common Shares KONDRAT, ARNOLD T. 5 09/05/2017 10 0.11 134,550 -426,966

Banro Corporation Secured Notes due 2021 Lu, Jiongjie 4 19/04/2017 36 0.75 $1,000,000

Banro Corporation Secured Notes due 2021 Lu, Jiongjie 4 19/04/2017 36 $1,000,000 $1,000,000

Banro Corporation Senior Secured Notes Lu, Jiongjie 4 19/04/2017 11 0.75 $1,000,000

Banro Corporation Senior Secured Notes Lu, Jiongjie 4 19/04/2017 11 750000 $1,000,000 $1,000,000

Banyan Gold Corp. Common Shares Class "A"

Alexco Resource Corp. 3 08/03/2017 10 0.095 50,000 50,000


Alexco Resource Corp. 3 08/05/2017 00










Alexco Resource Corp. 3 08/03/2017 10 0.08 4,375,000 4,375,000



Banyan Gold Corp. Options Alexco Resource Corp. 3 08/03/2017 53 0.115 4,375,000 4,375,000

Banyan Gold Corp. Options Alexco Resource Corp. 3 08/05/2017 00

Barkerville Gold Mines Ltd. Common Shares Lodder, Chris Andrea 4 29/07/2015 00

Barkerville Gold Mines Ltd. Common Shares Lodder, Chris Andrea 4 29/07/2015 00 47,000

Battle Mountain Gold Inc. Common Shares IDZISZEK, Chester (Chet) 4, 5 10/05/2017 51 0.25 1,978,397 400,000

Battle Mountain Gold Inc. Options IDZISZEK, Chester (Chet) 4, 5 10/05/2017 51 0.25 200,000 -400,000

BCE Inc. Common Shares Bibic, Mirko 7 08/05/2017 51 47.9 20,000 20,000

BCE Inc. Common Shares Bibic, Mirko 7 08/05/2017 10 62.3 0 -20,000

BCE Inc. Options Bibic, Mirko 7 08/05/2017 51 47.9 252,188 -20,000

BE Resources Inc. Options Crandall, Daniel Gary 4 12/05/2017 50 0.1 50,000 50,000

BE Resources Inc. Options Hua, Li 4 12/05/2017 00

BE Resources Inc. Options Hua, Li 4 12/05/2017 50 0.1 50,000 50,000

Beaufield Resources Inc. Common Shares ZHUANG, MIAOZHONG 4 11/04/2017 00

Beaufield Resources Inc. Options ZHUANG, MIAOZHONG 4 11/04/2017 00

Beaufield Resources Inc. Options ZHUANG, MIAOZHONG 4 11/04/2017 50 400,000 400,000

Beleave Inc. (formerly Stream Ventures Inc.)

Common Shares Ferreira, Roger Emmanuel 4 08/05/2017 46 2.37 610,540 4,500


Common Shares wnek, andrew thomas 4 29/12/2015 00


Common Shares wnek, andrew thomas 4 13/10/2016 11 1.13 22,321 22,321

BioNeutra Global Corporation

Options Hancock, David 4 15/10/2015 00


Options Hancock, David 4 09/05/2017 46 60,000 60,000


Options Smith, Bill 4, 5 09/05/2017 50 330,000 120,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4474



Acquired/ Disposed


Options Zhang, Huifen 4 09/05/2017 50 0.55 150,000 60,000


Options Zhu, Jianhua 4, 5 08/05/2017 50 0.55 475,000 120,000

Birchcliff Energy Ltd. Common Shares Geremia, Bruno P. 5 12/05/2017 10 6.79 67,000 2,000

Black Diamond Group Limited

Rights DSU Herdman, Robert 4 22/03/2017 56 4.5273 13,347 759


Rights DSU Olsson, David 4 22/03/2017 56 4.5273 16,002 1,408


Rights DSU Olsson, David 4 23/04/2017 56 3.7542 18,549 2,547

Black Iron Inc. Common Shares Spektor, Michael 5 05/05/2017 10 1,562,500 252,500





BlackIce Enterprise Risk Management Inc.

Common Shares PARUK, DALE 4, 5 03/05/2017 10 0.03 4,574,333 35,000

BlackIce Enterprise Risk Management Inc.

Common Shares PARUK, DALE 4, 5 05/05/2017 10 0.03 4,575,333 1,000

Bombardier Inc. Deferred Stock Units/Unités d'actions différées

Marcouiller, Pierre 4 11/05/2017 00

Bombardier Inc. Performance Share Units/Unites d'actions liees au rendement

TROGER, Laurent René Octave

5 05/05/2017 57 840,787 -54,760

Bombardier Inc. Subordinate Voting Shares Classe B/ Class B Shares ( Subordinate Voting)

TROGER, Laurent René Octave

5 05/05/2017 57 2.08 185,296 54,760

Bombardier Inc. Deferred Stock Units/Unités d'actions différées

Tyler, Antony N. 4 11/05/2017 00

Bonavista Energy Corporation

Common Shares Kobelka, Dean Mark 5 08/05/2017 57 3.25 186,936 3,315


Restricted Share Awards (RSA)

Kobelka, Dean Mark 5 08/05/2017 57 3.25 200,551 -5,000


Common Shares Shimek, Scott 5 08/05/2017 57 3.25 61,309 1,105



Shimek, Scott 5 08/05/2017 57 3.25 99,295 -1,667


Common Shares Wilhelm, Scott 5 08/05/2017 57 3.25 76,795 1,105



Wilhelm, Scott 5 08/05/2017 57 3.25 95,196 -1,667

Boreal Metals Corp. Common Shares Varas, Jorge Patricio 4 29/03/2017 00

Boreal Metals Corp. Common Shares Varas, Jorge Patricio 4 05/04/2017 16 0.05 2,000,000 2,000,000

Boreal Metals Corp. Warrants Varas, Jorge Patricio 4 29/03/2017 00

Boreal Metals Corp. Warrants Varas, Jorge Patricio 4 05/04/2017 16 0.1 1,000,000 1,000,000

Breathtec BioMedical, Inc. Common Shares Malhi, Kulwant 4, 5 19/01/2017 10 0.29 4,764,700 -242,000

Breathtec BioMedical, Inc. Common Shares Malhi, Kulwant 4, 5 22/04/2017 10 0.2 4,724,700 -40,000

BrightPath Early Learning Inc. (formerly Edleun Group, Inc.)

Common Shares BrightPath Early Learning Inc.

1 03/05/2017 38 0 -32,500

Brookfield Asset Management Inc.

Preferred Shares Class A Series 44


1 05/05/2017 38 26.35 4,031 4,031


Preferred Shares Class A Series 44


1 05/05/2017 38 0 -4,031


Common Shares Class A Limited Voting

Kerr, David Wylie 4, 6 28/04/2017 47 2,638,659 -400,000

Brookfield Business Partners L.P.

Limited Partnership Units Girsky, Stephen Jon 4 12/05/2017 10 27.262 4,000 2,000

Brookfield Business Partners L.P.

Limited Partnership Units Lacey, John Stewart 4 09/05/2017 10 26.933 7,000 900

Brookfield Infrastructure Partners L.P.

Limited Partnership Units Manios, Bahir 7 11/05/2017 10 53.92 25,000 2,700

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4475



Acquired/ Disposed

Brookfield Property Partners L.P.

Limited Partnership Units Shalett, Lisa 4 08/05/2017 10 21.68 100


Limited Partnership Units Shalett, Lisa 4 08/05/2017 10 21.68 2,100 100













BTB Real Estate Investment Trust

Parts avec restrictions Cyr, Benoit 5 09/05/2017 56 4.4784 26,326 10,494


Parts avec restrictions Gilbert, Dominic 5 09/05/2017 56 4.4784 11,948 4,782


Parts avec restrictions Léonard, Michel 4, 5 09/05/2017 56 4.4784 65,812 29,620

Cache Exploration Inc. Common Shares Bal, Jatinder Singh 4 03/05/2017 10 0.235 2,397,000 75,000

Cache Exploration Inc. Common Shares Bal, Jatinder Singh 4 04/05/2017 10 0.235 2,399,500 2,500

Cache Exploration Inc. Common Shares Bal, Jatinder Singh 4 05/05/2017 10 0.235 2,081,500 -318,000

Cadillac Ventures Inc. Common Shares Brewster, Norman 5 04/05/2017 10 0.05 4,650,120 35,000

Cadillac Ventures Inc. Common Shares Brewster, Norman 5 08/05/2017 97 0.05 6,650,120 2,000,000

Cadillac Ventures Inc. Common Shares Novak, Neil 4 08/05/2017 00 137,736

Cadillac Ventures Inc. Common Shares Novak, Neil 4 08/05/2017 00 63,955

Cadillac Ventures Inc. Options Novak, Neil 4 08/05/2017 00 340,000

Cadillac Ventures Inc. Common Shares O'Shaughnessy, Leo 5 08/05/2017 97 0.05 3,455,243 800,000

Callidus Capital Corporation Common Shares Callidus Capital Corporation 1 04/04/2017 38 18.032 8,998 8,998

Callidus Capital Corporation Common Shares Callidus Capital Corporation 1 04/04/2017 38 0 -8,998

Callidus Capital Corporation Common Shares Callidus Capital Corporation 1 04/04/2017 38 18.042 500 500

Callidus Capital Corporation Common Shares Callidus Capital Corporation 1 04/04/2017 38 0 -500



























Insider Reporting

May 18, 2017

(2017), 40 OSCB 4476



Acquired/ Disposed



























































Insider Reporting

May 18, 2017

(2017), 40 OSCB 4477



Acquired/ Disposed







Canadian International Minerals Inc.

Common Shares Schuss, Michael Edwin 4, 6, 5 11/05/2017 11 1,716,550 -1,000,000

Canadian Natural Resources Limited

Common Shares Fichter, Darren 5 11/05/2017 51 28.74 50,998 3,000


Common Shares Fichter, Darren 5 11/05/2017 10 43.14 47,998 -3,000


Options Fichter, Darren 5 11/05/2017 51 43.14 406,000 -3,000


Common Shares Frankiw, Allan E 5 12/05/2017 10 42.37 19,392 -1,000


Common Shares Peterson, William Robert 5 09/05/2017 51 28.06 79,690 10,000




Common Shares Peterson, William Robert 5 09/05/2017 10 42.485 79,690 -10,000








Options Peterson, William Robert 5 09/05/2017 51 28.06 482,500 -10,000





Canadian Pacific Railway Limited

Rights RSU Browning, Thompson 5 30/01/2017 30 199.16 1,226 3


Rights RSU Browning, Thompson 5 24/04/2017 30 208.21 1,229 3


Rights RSU Browning, Thompson 5 08/05/2017 59 203.56 0 -1,229


Rights RSU Clements, James Dominic Luther

5 30/01/2017 30 199.16 868 2



5 24/04/2017 30 208.21 870 2



5 08/05/2017 59 203.56 0 -870


Rights RSU Foran, Mike 5 30/01/2017 30 199.16 919 2


Rights RSU Foran, Mike 5 24/04/2017 30 208.21 921 2


Rights RSU Foran, Mike 5 08/05/2017 59 203.56 0 -921


Rights RSU Johnson, Robert Allen 5 30/01/2017 30 199.16 2,452 6


Rights RSU Johnson, Robert Allen 5 24/04/2017 30 208.21 2,457 5


Rights RSU Johnson, Robert Allen 5 08/05/2017 59 203.56 0 -2,457


Rights RSU Marquis, Tony 5 30/01/2017 30 199.16 2,452 6


Rights RSU Marquis, Tony 5 24/04/2017 30 208.21 2,458 6


Rights RSU Marquis, Tony 5 08/05/2017 59 203.56 0 -2,458


Rights RSU Redeker, Michael 5 30/01/2017 30 199.16 2,043 5

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4478



Acquired/ Disposed


Rights RSU Redeker, Michael 5 24/04/2017 30 208.21 2,048 5


Rights RSU Redeker, Michael 5 08/05/2017 59 203.56 0 -2,048


Rights RSU Velani, Nadeem 5 30/01/2017 30 199.16 817 2


Rights RSU Velani, Nadeem 5 24/04/2017 30 208.21 819 2


Rights RSU Velani, Nadeem 5 08/05/2017 59 203.56 0 -819

Canadian Tire Corporation, Limited

Non-Voting Shares Class A


1 08/05/2017 38 166.1 7,500 7,500




1 08/05/2017 38 0 -7,500




1 09/05/2017 38 164.87 7,500 7,500




1 09/05/2017 38 0 -7,500




1 10/05/2017 38 166.44 7,500 7,500




1 10/05/2017 38 0 -7,500




1 11/05/2017 38 159.88 7,500 7,500




1 11/05/2017 38 0 -7,500




1 12/05/2017 38 159.36 41,000 41,000




1 12/05/2017 38 0 -41,000



Chant, Diana Leslie 4 12/05/2017 10 159.26 1,300 300

Canadian Utilities Limited Non-Voting Shares Class A

Sembo, William, George 4 03/05/2017 30 38.52 12,786 593

Canadian Utilities Limited Non-Voting Shares Class A

Watson, Karen M 4 03/05/2017 30 38.26 32,961 156

Candelaria Mining Corp. Common Shares Martinez, Alberto Emiliano Cinta

3 14/06/2016 00 19,500,000


3 06/07/2016 10 0.15 4,000,000


3 06/07/2016 16 0.15 23,500,000 4,000,000


3 13/09/2016 16 0.15 28,166,666 4,666,666


3 15/11/2016 37 9,388,889 -18,777,777

Candelaria Mining Corp. Options Martinez, Alberto Emiliano Cinta

3 14/06/2016 00

Candelaria Mining Corp. Warrants Martinez, Alberto Emiliano Cinta

3 14/06/2016 00


3 06/07/2016 53 0.25 2,500,000 2,500,000


3 13/09/2016 53 0.25 4,833,333 2,333,333


3 15/11/2016 37 1,611,111 -3,222,222

Canfor Pulp Products Inc. Common Shares Canfor Pulp Products Inc. 1 08/05/2017 38 12 369,253 7,575

Canfor Pulp Products Inc. Common Shares Canfor Pulp Products Inc. 1 08/05/2017 38 0 -369,253

Canfor Pulp Products Inc. Common Shares Canfor Pulp Products Inc. 1 09/05/2017 38 11.949 7,575 7,575



Cannabix Technologies Inc Common Shares Malhi, Kulwant 5 31/03/2017 10 0.74 863,740 -67,000





Insider Reporting

May 18, 2017

(2017), 40 OSCB 4479



Acquired/ Disposed



Canoe EIT Income Fund Units Series 1 Preferred Units

Lake, Darcy Malcolm 5 01/05/2014 00

Canoe EIT Income Fund Units Series 1 Preferred Units

Lake, Darcy Malcolm 5 05/05/2017 10 25.58 500 500

CanWel Building Materials Group Ltd.

Common Shares Dushnisky, Kelvin Paul Michael

4 08/05/2017 57 5.95 48,383 4,832


Restricted Equity Common Share Units

Dushnisky, Kelvin Paul Michael

4 08/05/2017 56 4,832 4,832


Restricted Equity Common Share Units

Dushnisky, Kelvin Paul Michael

4 08/05/2017 57 0 -4,832

Capital DGMC Inc. Common Shares Laberge, Benoit 3 02/05/2017 10 0.04 1,740,500 50,000

Capstone Mining Corp. Common Shares Howe, Jason Paul 5 10/05/2017 10 0.91 130,000 50,000

Cardero Resource Corp. Common Shares Kopple, Robert Charles 3 15/10/2016 37 18,060,109 -5,940,986

Carl Data Solutions Inc. Common Shares Scharfe, Jason Wesley 4 10/05/2017 10 0.37 -3,000




Carl Data Solutions Inc. Common Shares Scharfe, Jason Wesley 4 10/05/2017 10 0.355 1,315,500 -9,000





Carmanah Technologies Corporation

Options Brown, Evan 5 08/05/2017 50 4.41 150,000 50,000

Carrus Capital Corporation Common Shares Fehr, Ann 5 08/05/2017 36 135,571 100,000

Carrus Capital Corporation Warrants Fehr, Ann 5 08/05/2017 36 0.05 200,000 100,000

Carrus Capital Corporation Warrants Fehr, Ann 5 08/05/2017 36 100,000 -100,000

Carrus Capital Corporation Common Shares Shynkaryk, Chester 5 05/04/2017 10 0.5 -5,000

Carrus Capital Corporation Common Shares Shynkaryk, Chester 5 05/05/2017 10 0.5 37,500 -5,000

Carrus Capital Corporation Common Shares Shynkaryk, Chester 5 09/05/2017 10 0.4 25,000 -12,500

Cascadero Copper Corporation

Common Shares Trueman, David L. 4 10/05/2017 10 0.13 787,383 -50,000

CCL Industries Inc. Non-Voting Shares Class B

Vaidyanathan, Lalitha 5 10/05/2017 51 56 24,658 6,250


Vaidyanathan, Lalitha 5 10/05/2017 10 309 24,108 -550


Vaidyanathan, Lalitha 5 10/05/2017 10 309.02 24,008 -100

























Insider Reporting

May 18, 2017

(2017), 40 OSCB 4480



Acquired/ Disposed

















































CCL Industries Inc. Options Vaidyanathan, Lalitha 5 10/05/2017 51 56 63,625 -6,250

Cenovus Energy Inc. Common Shares Delaney, Ian William 4 11/05/2017 10 13.299 250,000 25,000

Cenovus Energy Inc. Common Shares Ferguson, Brian Charles 4, 5 08/05/2017 10 13.07 161,066 5,100

Cenovus Energy Inc. Common Shares Ferguson, Brian Charles 4, 5 08/05/2017 10 13.065 161,366 300

Cenovus Energy Inc. Common Shares Ferguson, Brian Charles 4, 5 08/05/2017 10 13.06 165,966 4,600

Ceres Global Ag Corp. Common Shares Ceres Global Ag Corp. 1 03/04/2017 38 5.42 8,357 2,000

Ceres Global Ag Corp. Common Shares Ceres Global Ag Corp. 1 03/04/2017 38 5.42 8,457 100











Insider Reporting

May 18, 2017

(2017), 40 OSCB 4481



Acquired/ Disposed








































Ceres Global Ag Corp. Common Shares Ceres Global Ag Corp. 1 03/05/2017 38 5.58 47,742 -19

Ceres Global Ag Corp. Common Shares Ceres Global Ag Corp. 1 03/05/2017 38 5.58 45,942 -1,800


















Insider Reporting

May 18, 2017

(2017), 40 OSCB 4482



Acquired/ Disposed







Ceres Global Ag Corp. Common Shares Ceres Global Ag Corp. 1 05/05/2017 38 5.45 100







































CGI Group Inc. Options Gorber, Lorne Shawn 5 08/05/2017 51 37.11 38,539 -6,869

CGI Group Inc. Options Gorber, Lorne Shawn 5 08/05/2017 51 39.47 35,413 -3,126

CGI Group Inc. Subordinate Voting Shares Classe A

Gorber, Lorne Shawn 5 08/05/2017 51 37.11 6,869 6,869


Gorber, Lorne Shawn 5 08/05/2017 51 39.47 9,995 3,126


Gorber, Lorne Shawn 5 08/05/2017 10 66.197 8,495 -1,500




Gorber, Lorne Shawn 5 08/05/2017 10 66.196 6,795 -500



Insider Reporting

May 18, 2017

(2017), 40 OSCB 4483



Acquired/ Disposed














Gorber, Lorne Shawn 5 08/05/2017 10 66.183 0 -1,500

Chemtrade Electrochem Inc. (formerly, Canexus Corporation)

Convertible Debentures 5.75% Convertible Unsecured Subordinate Series IV Debentures

Bhardwaj, Rohit 8, 5 10/09/2016 00



Bhardwaj, Rohit 8, 5 10/09/2016 00



Bhardwaj, Rohit 8, 5 10/09/2016 00 $200,000



Bhardwaj, Rohit 8, 5 10/03/2017 00



Bhardwaj, Rohit 8, 5 10/03/2017 00



Bhardwaj, Rohit 8, 5 10/09/2016 00



Bhardwaj, Rohit 8, 5 10/09/2016 00



Bhardwaj, Rohit 8, 5 10/09/2016 00 $75,000



Bhardwaj, Rohit 8, 5 10/03/2017 00



Bhardwaj, Rohit 8, 5 10/03/2017 00

Chemtrade Logistics Income Fund

Trust Units Bhardwaj, Rohit 5 12/05/2017 10 18.24 60,000 10,000

Chesswood Group Limited Common Shares Obront, David Mitchell Aaron

4 11/05/2017 10 13.4 32,400 -4,600

Choice Properties Real Estate Investment Trust

Options Williams, David Evan 5 08/05/2017 51 10.61 140,904 -10,880


Options Williams, David Evan 5 08/05/2017 51 11.51 140,404 -500


Trust Units Williams, David Evan 5 08/05/2017 51 10.61 11,702 10,880


Trust Units Williams, David Evan 5 08/05/2017 51 11.51 12,202 500


Trust Units Williams, David Evan 5 08/05/2017 10 13.9 9,202 -3,000


Trust Units Williams, David Evan 5 08/05/2017 10 13.95 6,202 -3,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4484



Acquired/ Disposed


Trust Units Williams, David Evan 5 08/05/2017 10 14 1,322 -4,880


Trust Units Williams, David Evan 5 08/05/2017 10 14.15 822 -500

Chorus Aviation Inc. Class B Voting Shares Murphy, James 7 01/05/2017 00

Chorus Aviation Inc. Class B Voting Shares Murphy, James 7 01/05/2017 00 2,123

Chorus Aviation Inc. Rights (Ongoing Long-Term Incentive Plan)

Murphy, James 7 01/05/2017 00 11,230

Cineplex Inc. Deferred Share Units Munk, Anthony 4 10/05/2017 56 9,869 468

Cineplex Inc. Options Nonis, Paul 5 10/05/2017 59 53.43 28,944 -262

Cineplex Inc. Deferred Share Units Steacy, Robert Joseph 4 10/05/2017 56 9,455 281

Cipher Pharmaceuticals Inc. Common Shares Tessarolo, Robert Dean 5 17/04/2017 00 32,900

Clarocity Corporation (formerly, Zaio Corporation)

Common Shares StableView Asset Management

3 24/10/2016 99 21,342,621 -32,871



3 16/01/2017 97 0.13 20,954,017 -133,104



3 16/01/2017 16 21,695,700 741,683



3 16/01/2017 16 22,056,958 361,258



3 17/01/2017 97 0.125 22,027,105 -29,853



3 19/01/2017 10 0.115 22,078,057 50,952


Convertible Debentures StableView Asset Management

3 25/01/2016 00


Convertible Debentures StableView Asset Management

3 08/05/2017 16 0.16 $4,000,000 $4,000,000

Clearford Water Systems Inc. Options Bryden, Roderick M. 3, 4 31/07/2016 52 1,800,000 -832,186

Clearford Water Systems Inc. Options Loiselle, Kevin 5 30/11/2016 52 3,515,000 -300,000

COLLIERS INTERNATIONAL GROUP INC.

Subordinate Voting Shares

Cohen, Peter F. 4 08/05/2017 97 71.73 53,000 -7,000

COLLIERS INTERNATIONAL GROUP INC.


Cohen, Peter F. 4 08/05/2017 97 71.73 77,000 7,000

Cominar Real Estate Investment Trust

Parts différées Lépine, Johanne 4 05/05/2017 56 13.86 11,511 382

CONDOR RESOURCES INC.

Common Shares Boyd, Robert T. 4 10/05/2017 46 0.075 772,000 102,000

Constellation Software Inc. Common Shares MacKinnon, Jeffrey Raymond

7 10/03/2017 30 641.51 424 83

Continental Gold Inc. Common Shares Graham, Jon William 5 24/04/2017 00

Continental Gold Inc. Options Graham, Jon William 5 24/04/2017 00

COPPER REEF MINING CORPORATION

Common Shares Masson, Stephen Leo 3 11/05/2017 10 0.025 9,609,865 35,000

COPPER REEF MINING CORPORATION

Common Shares Masson, Stephen Leo 3 11/05/2017 10 0.03 9,612,865 3,000

Copperbank Resources Corp.

Common Shares Kovacevic, John Gianni 4, 5 12/05/2017 10 0.1 9,926,800 100,000

Copperbank Resources Corp.

Common Shares Kovacevic, John Gianni 4, 5 12/05/2017 10 0.1 10,031,800 105,000

Corazon Gold Corp. Common Shares Scharfe, Jason Wesley 4 10/05/2017 10 0.36 -7,000

Corazon Gold Corp. Common Shares Scharfe, Jason Wesley 4 10/05/2017 10 0.36 -7,000

Coro Mining Corp. Options Cortes, Marcelo Claudio 5 10/05/2017 52 0.41 5,400,000 -250,000

Coro Mining Corp. Options Fretwell, Gordon 4 23/03/2017 52 1,250,000 -150,000

Coro Mining Corp. Options Rivera, Sergio 5 10/05/2017 52 0.39 1,900,000 -550,000

Coro Mining Corp. Options Stephens, Alan J. 4, 5 10/05/2017 52 0.41 7,700,000 -1,290,000

Coro Mining Corp. Options Towns, Damian Jon 5 10/05/2017 52 0.41 6,600,000 -650,000

Coro Mining Corp. Common Shares Webster, Roderick John 4 18/10/2006 00

Coro Mining Corp. Common Shares Webster, Roderick John 4 09/08/2016 10 0.16 121,000 121,000

Coro Mining Corp. Common Shares Webster, Roderick John 4 16/08/2016 10 0.16 120,000

Coro Mining Corp. Options Webster, Roderick John 4 10/05/2017 52 0.41 -150,000

Coro Mining Corp. Options Webster, Roderick John 4 10/05/2017 52 0.41 1,250,000 -150,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4485



Acquired/ Disposed

Corus Entertainment Inc. Non-Voting Shares Class B

Shaw, JR 3 28/01/2005 00

Corus Entertainment Inc. Non-Voting Shares Class B

Shaw, JR 3 06/05/2017 97 20,000 20,000

Cott Corporation Common Shares Benadiba, Mark 4 05/05/2017 30 12.74 73,742 9,340

Cott Corporation Common Shares Gibbons, David 4 05/05/2017 30 12.74 142,851 9,340

Cott Corporation Common Shares Halperin, Stephen 4 05/05/2017 30 12.74 126,414 9,340

Cott Corporation Common Shares Hess, Betty Jane 4 05/05/2017 30 12.74 81,743 9,340

Cott Corporation Common Shares Monahan, Gregory Rush 4 05/05/2017 30 12.74 118,666 9,340

Cott Corporation Common Shares Pilozzi, Mario 4 05/05/2017 30 12.74 133,493 9,340

Cott Corporation Common Shares Prozes, Andrew 4 05/05/2017 30 12.74 93,469 9,340

Cott Corporation Common Shares Rosenfeld, Eric Stuart 4 05/05/2017 30 12.74 399,405 9,340

Cott Corporation Common Shares Savage, Graham William 4 05/05/2017 30 12.74 45,278 9,340

Craft Oil Ltd. Common Shares Ronald, Murray Brent 4 15/06/2016 00

Craft Oil Ltd. Common Shares Ronald, Murray Brent 4 15/06/2016 00 2,068,033

Crescent Point Energy Corp. Performance Share Units Borggard, Bradley Harlan 5 01/01/2010 00

Crescent Point Energy Corp. Performance Share Units Borggard, Bradley Harlan 5 05/05/2017 56 150,231 150,231

Crescent Point Energy Corp. Performance Share Units Christie, Derek Wayne 5 01/01/2010 00

Crescent Point Energy Corp. Performance Share Units Christie, Derek Wayne 5 05/05/2017 56 161,787 161,787

Crescent Point Energy Corp. Performance Share Units Eade, Mark Gordon 5 02/07/2009 00

Crescent Point Energy Corp. Performance Share Units Eade, Mark Gordon 5 05/05/2017 56 115,562 115,562

Crescent Point Energy Corp. Performance Share Units Gritzfeldt, Ryan Chad Raymond

5 01/01/2010 00

Crescent Point Energy Corp. Performance Share Units Gritzfeldt, Ryan Chad Raymond

5 05/05/2017 56 161,787 161,787

Crescent Point Energy Corp. Performance Share Units LAMONT, KENNETH 5 02/07/2009 00

Crescent Point Energy Corp. Performance Share Units LAMONT, KENNETH 5 05/05/2017 56 184,900 184,900

Crescent Point Energy Corp. Performance Share Units MacDonald, Tamara 5 02/07/2009 00

Crescent Point Energy Corp. Performance Share Units MacDonald, Tamara 5 05/05/2017 56 161,787 161,787

Crescent Point Energy Corp. Performance Share Units Saxberg, Scott 4 02/07/2009 00

Crescent Point Energy Corp. Performance Share Units Saxberg, Scott 4 05/05/2017 56 693,374 693,374

Crescent Point Energy Corp. Performance Share Units Smith, Clifford Neil 5 02/07/2009 00

Crescent Point Energy Corp. Performance Share Units Smith, Clifford Neil 5 05/05/2017 56 184,900 184,900

Crescent Point Energy Corp. Performance Share Units Toews, Steven George 5 01/01/2010 00

Crescent Point Energy Corp. Performance Share Units Toews, Steven George 5 05/05/2017 56 115,562 115,562

Currency Exchange International, Corp.

Common Shares Fitzpatrick, Stephen Michael 5 08/05/2017 00

Currency Exchange International, Corp.

Warrants Fitzpatrick, Stephen Michael 5 08/05/2017 00

CWC Energy Services Corp. Common Shares CWC Energy Services Corp.

1 08/05/2017 10 0.2 460,500 3,000

Dalradian Resources Inc. Rights Deferred Share Unit Plan

Downey, Patrick 4 31/03/2017 56 1.37 47,474 5,474

Darien Business Development Corp. (formerly Dynamic Oil & Gas Exploration Inc.)

Common Shares Nijjar, Harpreet 5 08/05/2017 00 2,000

Darnley Bay Resources Limited

Common Shares Knoll, Kerry 4 04/05/2017 54 0.05 3,408,500 760,000




Common Shares Knoll, Kerry 4 04/05/2017 11 0.12 3,708,500 -200,000






Options Knoll, Kerry 4 24/01/2017 51 -80,000


Options Knoll, Kerry 4 24/01/2017 51 1,360,000 -150,000


Options Knoll, Kerry 4 24/01/2017 52 1,280,000 -80,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4486



Acquired/ Disposed


Options Knoll, Kerry 4 17/03/2017 51 0.1 -200,000


Options Knoll, Kerry 4 17/03/2017 51 0.15 1,150,000 -130,000


Warrants Knoll, Kerry 4 04/05/2017 54 1,500,000 -760,000


Warrants Knoll, Kerry 4 04/05/2017 54 1,000,000 -500,000


Options Mannard, Patricia Grace 5 24/01/2017 51 -60,000


Options Mannard, Patricia Grace 5 24/01/2017 51 1,190,000 -60,000


Options Mannard, Patricia Grace 5 24/01/2017 52 1,130,000 -60,000


Common Shares Reford, Stephen William 4 05/05/2017 54 0.05 1,689,139 400,000


Warrants Reford, Stephen William 4 05/05/2017 54 0.05 500,000 -400,000

Data Deposit Box Inc. (formerly Coltrane Technologies Inc.)

Common Shares McBride, John David 4 09/05/2017 00 1,818,182

Data Deposit Box Inc. (formerly Coltrane Technologies Inc.)

Warrants McBride, John David 4 09/05/2017 00 1,818,182

Delphi Energy Corp. Common Shares BEHR, John 5 30/04/2017 30 1.41 94,676 3,708

Denison Mines Corp. Common Shares Cates, David Daniel 5 05/05/2017 10 0.67 317,500 7,500

Detour Gold Corporation Options Doyle, Robert Emmet 4 12/05/2017 52 28.27 69,461 -12,500

Detour Gold Corporation Options Hibbard, Ingrid Jo-Ann 4 12/05/2017 52 28.27 73,709 -12,500

Detour Gold Corporation Options Morrison, Alexander 4 12/05/2017 52 28.27 53,377 -12,500

Detour Gold Corporation Options Rubenstein, Jonathan A. 4 12/05/2017 52 28.27 70,209 -12,500

Detour Gold Corporation Options Wozniak, Graham Roy 4 12/05/2017 52 28.27 61,209 -12,500

Diagnos Inc. Common Shares Dundee Corporation 3 09/07/2012 00

Diagnos Inc. Common Shares Dundee Corporation 3 08/05/2017 54 0.06 1,000,000 1,000,000

Diagnos Inc. Warrants Dundee Corporation 3 08/05/2017 54 0.06 0 -1,000,000

DIRTT Environmental Solutions Ltd.

Common Shares Loberg, Barrie Arnold 5 12/05/2017 10 6.3 276,103 -59,500

Distinct Infrastructure Group Inc. (formerly QE2 Acquisition Corp.)

Common Shares Horner, Douglas Alan 4 28/04/2017 00


Common Shares Horner, Douglas Alan 4 04/05/2017 10 1.5 1,000 1,000





Diversified Royalty Corp. Restricted Share Units (Common Shares)

Gropper, Mitchell Harold 4 12/05/2017 56 2.573 41,023 3,031

Diversified Royalty Corp. Restricted Share Units (Common Shares)

Rogers, Paula 4 12/05/2017 56 41,248 3,274

DMD Digital Health Connections Group Inc. (Formely Aptilon Corporation)

Common Shares Benthin, Mark 4 03/05/2017 10 0.28 711,000 -5,000





Dream Hard Asset Alternatives Trust

Deferred Trust Units Bhalla, Amar 4 08/05/2017 00

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4487



Acquired/ Disposed


Deferred Trust Units Bhalla, Amar 4 08/05/2017 56 6.22 6,000 6,000


Deferred Trust Units Eaton, James George 4 08/05/2017 56 6.22 52,554 6,000


Deferred Trust Units Ferstman, Joanne Shari 7 08/05/2017 56 6.22 49,399 6,000


Deferred Trust Units GAVAN, JANE 7 10/05/2017 57 20,537 -1,275


Units GAVAN, JANE 7 10/05/2017 57 4,061 1,275


Units GAVAN, JANE 7 10/05/2017 10 6.1 3,354 -707


Deferred Trust Units Kaufman, David Richard 4 08/05/2017 56 6.22 25,949 6,000

Dream Office Real Estate Investment Trust

Trust Units Series A Dream Office Real Estate Investment Trust

1 08/05/2017 38 19.48 81,907 81,907



1 08/05/2017 38 0 -81,907



1 09/05/2017 38 19.6 1,241,000 1,241,000



1 09/05/2017 38 0 -1,241,000



1 10/05/2017 38 19.793 81,907 81,907



1 10/05/2017 38 0 -81,907



1 11/05/2017 38 19.844 81,907 81,907



1 11/05/2017 38 0 -81,907



1 12/05/2017 38 19.731 81,907 81,907



1 12/05/2017 38 0 -81,907

DREAM Unlimited Corp. Deferred Share Units Ferstman, Joanne Shari 4 09/05/2017 56 6.62 42,695 10,000

DREAM Unlimited Corp. Deferred Share Units Gateman, Richard N. 4, 7 09/05/2017 56 6.62 36,539 6,000

DREAM Unlimited Corp. Deferred Share Units Jackman, Duncan Newton Rowell

4 09/05/2017 00

DREAM Unlimited Corp. Deferred Share Units Jackman, Duncan Newton Rowell

4 09/05/2017 56 6.62 6,000 6,000

DREAM Unlimited Corp. Deferred Share Units Koss, Jennifer 4 09/05/2017 56 6.62 33,871 6,000

DREAM Unlimited Corp. Deferred Share Units Sera, Maria Vincenza 4, 7 09/05/2017 56 6.62 38,479 6,000

East Coast Investment Grade Income Fund

Units Arrow Capital Management Inc.

7 11/05/2017 15 9.8 52,500 50,000

Eco Oro Minerals Corp. Options Kay, David V. 4 26/07/2016 00

Eco Oro Minerals Corp. Options Kay, David V. 4 08/05/2017 50 0.485 400,000 400,000

Eco Oro Minerals Corp. Options Marleau, Hubert 4 08/05/2017 50 0.485 725,000 150,000

Eco Oro Minerals Corp. Options Moseley-Williams, Mark 5 08/05/2017 50 0.485 600,000 300,000

Eco Oro Minerals Corp. Options O'Halloran, Kevin 4 08/05/2017 00

Eco Oro Minerals Corp. Options O'Halloran, Kevin 4 08/05/2017 50 0.485 400,000 400,000

Eco Oro Minerals Corp. Options Robertson, Paul Harold 5 08/05/2017 50 0.485 580,000 200,000

Eco Oro Minerals Corp. Options Stylianides, Anna 4 08/05/2017 50 0.485 1,375,000 300,000

Eco Oro Minerals Corp. Options Weyrauch, Derrick Horst 4 02/06/2016 00

Eco Oro Minerals Corp. Options Weyrauch, Derrick Horst 4 08/05/2017 50 0.485 400,000 400,000

Economic Investment Trust Limited

Common Shares Canadian & Foreign Securities Co. Limited

3 25/04/2017 10 107.51 100

Economic Investment Trust Limited

Common Shares Canadian & Foreign Securities Co. Limited

3 25/04/2017 10 107.51 100

Eldorado Gold Corporation Options Stanca, Nicolae 5 08/05/2017 52 12.74 497,895 -53,334

Element Fleet Management Corp. (formerly Element Financial Corporation)

Preferred Shares Damp, Paul 4 03/10/2016 00


Preferred Shares Damp, Paul 4 05/05/2017 10 25 5,000 5,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4488



Acquired/ Disposed


Preferred Shares Jauernig, Daniel 5 05/05/2017 10 25 9,600 5,000


Preferred Shares Martin, Karen Lynne 5 05/05/2017 10 25 8,000 4,000


Preferred Shares Nullmeyer, Bradley 5 05/05/2017 10 25 63,000 11,000


Preferred Shares Zabaneh, Samir Michael 5 09/01/2017 00


Preferred Shares Zabaneh, Samir Michael 5 05/05/2017 10 25 8,000 8,000

Eloro Resources Ltd. Common Shares LARSEN, THOMAS 4, 5 02/05/2017 10 0.83 968,500 1,000



Empire Company Limited Non-Voting Shares Class A

Sood, Vivek 5 04/05/2017 00

Empire Company Limited Options Sood, Vivek 5 04/05/2017 00 44,550

Empire Company Limited Rights DSU (Deferred Share Unit)

Sood, Vivek 5 04/05/2017 00 6,110

Empire Company Limited Rights PSU (Performance Share Units)

Sood, Vivek 5 04/05/2017 00 4,827

Empire Company Limited Rights Sobeys Phantom Performance Options

Sood, Vivek 5 04/05/2017 00 7,827

Empire Company Limited Non-Voting Shares Class A

St-Laurent, Pierre 5 04/05/2017 00

Empire Company Limited Options St-Laurent, Pierre 5 04/05/2017 00 43,926

Empire Company Limited Rights DSU (Deferred Share Unit)

St-Laurent, Pierre 5 04/05/2017 00 6,762

Empire Company Limited Rights PSU (Performance Share Units)


Empire Company Limited Rights Sobeys Phantom Performance Options


enCore Energy Corp. Options Harris, William 4 11/05/2017 50 0.1 561,666 50,000

Endeavour Silver Corp. Options Iturriaga Hidalgo, Tomas 5 02/02/2017 00

Endeavour Silver Corp. Options Iturriaga Hidalgo, Tomas 5 04/05/2017 50 160,000 160,000

Endeavour Silver Corp. Rights Performance Share Units

Iturriaga Hidalgo, Tomas 5 02/02/2017 00

Endeavour Silver Corp. Rights Performance Share Units

Iturriaga Hidalgo, Tomas 5 04/05/2017 56 4.32 30,000 30,000

Endeavour Silver Corp. Options Szotlender, Mario 4 04/05/2017 50 105,000 29,500

Endeavour Silver Corp. Rights Deferred Share Unit

Szotlender, Mario 4 04/05/2017 56 122,238 15,878

Endurance Gold Corporation Common Shares Boyd, Robert T. 4, 5 04/05/2017 10 0.08 1,368,500 2,000

Energy Credit Opportunities Income Fund

Class A Units Energy Credit Opportunities Income Fund

1 03/04/2017 38 7.05 900 100



1 07/04/2017 38 7.07 1,700 800



1 10/04/2017 38 7.2 2,500 800



1 11/04/2017 38 7.17 3,300 800



1 13/04/2017 38 7.18 3,900 600



1 13/04/2017 38 7.18 600



1 13/04/2017 38 7.18 600



1 17/04/2017 38 7.25 4,700 800



1 20/04/2017 38 7.24 5,500 800

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4489



Acquired/ Disposed



1 21/04/2017 38 7.24 5,700 200



1 28/04/2017 38 0 -5,700


Class U Units Energy Credit Opportunities Income Fund

1 03/04/2017 38 7.25 600 600


Class U Units Energy Credit Opportunities Income Fund

1 28/04/2017 38 0 -600

Engagement Labs Inc. Common Shares Paterson, G. Scott 4 01/05/2017 10 0.065 2,457,041 43,000



Enterprise Group, Inc. Common Shares JAROSZUK, LEONARD 4, 5 10/05/2017 10 0.305 3,504,277 15,000

Enterprise Group, Inc. Common Shares JAROSZUK, LEONARD 4, 5 12/05/2017 10 0.305 3,514,277 10,000

Entree Resources Ltd. Common Shares LO, DUANE 5 11/05/2017 10 0.57 588,300 15,000

Environmental Waste International Inc.

Common Shares Orlin, Paul Evan 3 08/05/2017 00 968,000


Common Shares Orlin, Paul Evan 3 08/05/2017 11 26,368,849 25,400,849


Common Shares Russell, Thomas Alexander 4 05/05/2017 10 0.05 9,383,300 285,000


Convertible Debentures Savage, Robert 4 12/04/2017 00


Convertible Debentures Savage, Robert 4 04/05/2017 11 0.11 $1,350,000 $1,350,000


Promissory Notes Savage, Robert 4 04/05/2017 11 0.11 $1,350,000


Promissory Notes Savage, Robert 4 04/05/2017 11 0.11 $1,350,000

EPM Mining Ventures Inc. Common Shares Voting Botts, Theodore P. 4 24/11/2011 36 -1,191,390

EPM Mining Ventures Inc. Common Shares Voting Botts, Theodore P. 4 24/11/2011 36 -1,191,390

Epsilon Energy Ltd. Common Shares AZVALOR ASSET MANAGEMENT SGIIC

3 10/05/2017 10 1,056,165 3,200

EQ Inc. Warrants Lobo, Vernon 4, 6 10/05/2017 53 1,377,815 140,000

EQ Inc. Warrants Lobo, Vernon 4, 6 10/05/2017 53 2,353,308 1,203,308

EQ Inc. Common Shares Rotstein, Geoffrey 4, 5 04/05/2017 10 0.145 681,462 -265,625

EQ Inc. Common Shares Rotstein, Geoffrey 4, 5 04/05/2017 10 0.145 946,462 265,000

EQ Inc. Warrants Rotstein, Geoffrey 4, 5 10/05/2017 53 0.13 2,262,815 350,000

Equitorial Exploration Corp. Common Shares Bal, Jatinder Singh 1 05/05/2017 10 0.095 2,664,000 -250,000

Equitorial Exploration Corp. Common Shares Bal, Jatinder Singh 1 08/05/2017 10 0.09 2,689,000 25,000

Equitorial Exploration Corp. Common Shares Bal, Jatinder Singh 1 08/05/2017 10 0.08 2,748,000 59,000

Equity Financial Holdings Inc. (formerly, Grey Horse Corporation)

Common Shares McCarthy, Michele, Daphne 4 11/05/2017 10 8.5 7,002 2,000

Erdene Resource Development Corporation

Common Shares Webster, Philip L. 4 02/03/2017 90 0 -50,000

Euro Sun Mining Inc. (formerly Carpathian Gold Inc.)

Common Shares moore, geoffrey scott 5 12/05/2017 10 80,000 10,000

Evitrade Health Systems Corp.

Common Shares Au, Sydney Wai Kong 4 09/05/2017 11 10,658,333 3,333

Evrim Resources Corp. Common Shares Liyanage, Mahesh Nalinda 5 05/05/2017 10 0.26 34,500 2,000

Evrim Resources Corp. Common Shares Liyanage, Mahesh Nalinda 5 08/05/2017 10 0.27 35,500 1,000

Evrim Resources Corp. Common Shares Nicol, John Patrick 4 05/05/2017 10 0.265 680,127 7,500

Exchange Income Corporation

Common Shares Filmon, Gary 4 11/05/2017 10 34.734 51,296 800


Common Shares Filmon, Gary 4 11/05/2017 10 34.85 9,151 4,200


Common Shares Streuber, Donald 4 11/05/2017 10 34.95 53,846 3,000


Common Shares Warkentin, Edward 4 11/05/2017 10 35.447 22,225 1,375

Exco Technologies Limited Common Shares CARTWRIGHT, BONITA 5 08/05/2017 10 11.804 42,755 -10,000

Exco Technologies Limited Common Shares Riganelli, Paul 5 05/05/2017 10 11.583 215,300 -2,000


Insider Reporting

May 18, 2017

(2017), 40 OSCB 4490



Acquired/ Disposed




EXFO Inc. (formerly know as EXFO Electro-Optical Engineering Inc.)

Restricted Share Units Arora, Vikas 5 04/05/2017 57 6.65 23,500 -2,200


Restricted Share Units Arora, Vikas 5 04/05/2017 57 6.65 20,750 -2,750



Arora, Vikas 5 04/05/2017 57 6.65 2,200 2,200



Arora, Vikas 5 04/05/2017 57 6.65 4,950 2,750



Arora, Vikas 5 08/05/2017 10 6.35 2,750 -2,200



Arora, Vikas 5 08/05/2017 10 6.35 0 -2,750


Restricted Share Units BULL, STEPHEN 5 04/05/2017 57 6.65 103,054 -15,490



BULL, STEPHEN 5 04/05/2017 57 6.65 55,341 15,490



BULL, STEPHEN 5 08/05/2017 10 6.35 -15,490



BULL, STEPHEN 5 08/05/2017 10 6.35 39,851 -15,490


Restricted Share Units Chabot, Stéphane 5 04/05/2017 57 6.65 30,589 -1,100


Restricted Share Units Chabot, Stéphane 5 04/05/2017 57 6.65 29,489 -1,100



Chabot, Stéphane 5 04/05/2017 57 6.65 1,100 1,100



Chabot, Stéphane 5 04/05/2017 57 6.65 2,200 1,100



Chabot, Stéphane 5 08/05/2017 10 6.35 1,100 -1,100



Chabot, Stéphane 5 08/05/2017 10 6.35 0 -1,100


Restricted Share Units Fitts, Robert 5 04/05/2017 57 6.65 4,650 -825


Restricted Share Units Fitts, Robert 5 04/05/2017 57 6.65 3,825 -825



Fitts, Robert 5 04/05/2017 57 6.65 825 825



Fitts, Robert 5 04/05/2017 57 6.65 1,650 825



Fitts, Robert 5 08/05/2017 10 6.35 825 -825



Fitts, Robert 5 08/05/2017 10 6.35 0 -825

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4491



Acquired/ Disposed


Restricted Share Units Gagnon, Luc 5 04/05/2017 57 6.65 77,582 -11,311



Gagnon, Luc 5 04/05/2017 57 6.65 37,294 11,311



Gagnon, Luc 5 08/05/2017 10 6.35 25,983 -11,311


Restricted Share Units Lamonde, Germain 3, 4, 5 04/05/2017 57 6.65 0 -53,261



Lamonde, Germain 3, 4, 5 04/05/2017 57 6.65 53,261 53,261


Restricted Share Units Mazzuca, Claudio 5 04/05/2017 57 6.65 75,444 -1,429



Mazzuca, Claudio 5 04/05/2017 57 6.65 2,058 1,429



Mazzuca, Claudio 5 08/05/2017 10 6.35 629 -1,429


Restricted Share Units Ringuette, Benoit 5 04/05/2017 57 6.65 9,150 -1,100


Restricted Share Units Ringuette, Benoit 5 04/05/2017 57 6.65 8,325 -825



Ringuette, Benoit 5 04/05/2017 57 6.65 1,100 1,100



Ringuette, Benoit 5 04/05/2017 57 6.65 1,925 825



Ringuette, Benoit 5 08/05/2017 10 6.35 825 -1,100



Ringuette, Benoit 5 08/05/2017 10 6.35 0 -825


Restricted Share Units Rouleau, Sylvain 5 04/05/2017 57 6.65 82,680 -6,330



Rouleau, Sylvain 5 04/05/2017 57 6.65 6,330 6,330



Rouleau, Sylvain 5 08/05/2017 10 6.35 0 -6,330


Restricted Share Units Yearian, Dana F. 5 04/05/2017 57 4.875 116,178 -15,322



Yearian, Dana F. 5 04/05/2017 57 4.875 49,503 15,322



Yearian, Dana F. 5 08/05/2017 10 4.66 34,181 -15,322

Explorex Resources Inc. Options Mustard, James 5 10/05/2017 51 0.13 200,000 100,000

Explorex Resources Inc. Common Shares Schellenberg, Gary David Albert

4 11/05/2017 10 0.17 101,667 35,000

Explorex Resources Inc. Common Shares Schellenberg, Gary David Albert

4 11/05/2017 10 0.17 84,500 15,000

Extendicare Inc. Common Shares Harris, Michael Andrew 7 20/05/2014 00

Extendicare Inc. Common Shares Harris, Michael Andrew 7 11/05/2017 10 10.28 1,400 1,400

Extendicare Inc. Common Shares Harris, Michael Andrew 7 11/05/2017 10 10.3 1,490 90

Fairfax India Holdings Corporation


Bradstreet, F. Brian 7 30/01/2015 00

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4492



Acquired/ Disposed



Bradstreet, F. Brian 7 21/02/2017 10 12.36 4,200 4,200



Bradstreet, F. Brian 7 21/02/2017 10 12.4 7,100 2,900



Bradstreet, F. Brian 7 21/02/2017 10 12.4 7,600 500

Falcon Oil & Gas Ltd. Common Shares Sweetpea Petroleum Pty Ltd

3 02/11/2015 10 0.109 92,298,670 -30,000


3 03/11/2015 10 0.103 92,268,670 -30,000


3 13/11/2015 10 0.108 92,220,170 -48,500


3 16/11/2015 10 0.109 92,060,170 -160,000

Fandom Sports Media Corp. Options 10% rolling options plan

Helmel, Alexander 5 14/09/2015 00

Fandom Sports Media Corp. Options 10% rolling options plan

Helmel, Alexander 5 08/05/2017 50 0.1 400,000 400,000

Fiera Capital Corporation (formerly Fiera Sceptre Inc.)

Options Archambault, Guy 5 28/04/2017 00 60,000

Findev Inc. (formerly, TransGaming Inc.)

Common Shares catégorie A

Weinreb, Yisroel 4, 5 08/05/2017 10 0.56 483,500 15,000



Weinreb, Yisroel 4, 5 09/05/2017 10 0.58 517,000 33,500



Weinreb, Yisroel 4, 5 10/05/2017 10 0.48 518,000 1,000

Firan Technology Group Corporation

Common Shares Beutel, Robert Jonathan 3, 4 05/05/2017 10 4.26 4,414,987 -1,600,000

Firm Capital Mortgage Investment Corporation

Common Shares Mair, Jonathon 4, 5 05/05/2017 51 11.78 40,000 20,000

Firm Capital Mortgage Investment Corporation

Options Mair, Jonathon 4, 5 05/05/2017 51 11.78 160,000 -20,000

First Capital Realty Inc. Common Shares Segal, Dori 4, 6, 5 12/05/2017 10 19.93 2,550

First Capital Realty Inc. Common Shares Segal, Dori 4, 6, 5 12/05/2017 10 19.93 2,550

First Capital Realty Inc. Common Shares Segal, Dori 4, 6, 5 12/05/2017 10 19.92 1,676,571 1,700

First Global Data Limited (formerly Rockstar Capital Corp.)

Common Shares Price, Kevin 4 08/05/2017 10 0.6 1,874,956 100,000

First Global Data Limited (formerly Rockstar Capital Corp.)

Common Shares Singh, Naresh 4 09/05/2017 10 0.54 105,000 -100,000

First Majestic Silver Corp. Common Shares Anthony, Todd Olson 5 09/05/2017 10 10.18 25,000 5,000

First Mexican Gold Corp. Common Shares Voisin, James Arthur Robert 4 09/05/2017 10 0.025 2,438,717 -15,000

First Mexican Gold Corp. Common Shares Voisin, James Arthur Robert 4 09/05/2017 10 0.025 2,318,717 -120,000

Fortify Resources Inc. Common Shares Horsley, Robert N 4 08/05/2017 30 0.12 437,500 187,500

Fortify Resources Inc. Warrants Horsley, Robert N 4 15/11/2016 00

Fortify Resources Inc. Warrants Horsley, Robert N 4 08/05/2017 30 0.12 187,500 187,500

Fortify Resources Inc. Common Shares Howe and Bay Financial Corp.

3 08/05/2017 00

Fortify Resources Inc. Common Shares Howe and Bay Financial Corp.

3 08/05/2017 30 0.12 984,242 984,242

Fortify Resources Inc. Warrants Howe and Bay Financial Corp.

3 08/05/2017 00

Fortify Resources Inc. Warrants Howe and Bay Financial Corp.

3 08/05/2017 30 0.12 984,242 984,242

Fortis Inc. Performance Share Unit Bennett, David 5 11/05/2017 59 41.46 19,341 -956

Fortune Minerals Limited Options Goad, Robin Ellis 4, 5 11/05/2017 50 0.185 3,960,000 500,000

Fortune Minerals Limited Options Massola, David 5 11/05/2017 50 0.185 1,500,000 500,000

Fortune Minerals Limited Options Naik, Mahendra 4 11/05/2017 50 2,860,000 400,000

Fortune Minerals Limited Common Shares Schryer, Richard Philippe 5 11/05/2017 00 252,000

Fortune Minerals Limited Options Schryer, Richard Philippe 5 11/05/2017 00 930,000

Fountain Asset Corp (formerly, GC-Global Capital Corp.)

Options Prychidny, Morris 4 23/01/2017 50 0.3 240,000 125,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4493



Acquired/ Disposed

Fox River Resources Corporation

Common Shares Case, Stephen Dunbar 3, 4, 5 10/05/2017 10 0.09 7,524,042 3,500

Fox River Resources Corporation

Common Shares Case, Stephen Dunbar 3, 4, 5 11/05/2017 10 0.09 7,524,292 250

Franco-Nevada Corporation Common Shares Brink, Paul 5 12/05/2017 10 96.928 3,930 -890

Franco-Nevada Corporation Common Shares Brink, Paul 5 12/05/2017 51 15.2 220,511 18,750

Franco-Nevada Corporation Common Shares Brink, Paul 5 12/05/2017 10 96.78 201,761 -18,750

Franco-Nevada Corporation Options Brink, Paul 5 12/05/2017 51 15.2 102,921 -18,750

Front Range Resources Ltd. Common Shares Cowling, Peter Richard 5 11/05/2017 10 0.16 443,703 10,000



Front Range Resources Ltd. Common Shares McAllister, Todd 4 11/05/2017 10 0.14 859,252 13,000



Front Range Resources Ltd. Common Shares Shaw, Malcolm James 4 12/05/2017 10 0.15 661,035 100,000

Front Range Resources Ltd. Common Shares Todd, Malcolm Frederick William

4 09/05/2017 10 0.15 660,000 50,000

Front Range Resources Ltd. Common Shares Todd, Malcolm Frederick William

4 09/05/2017 10 0.16 710,000 50,000

Front Range Resources Ltd. Common Shares Todd, Robert Hamish Owen 5 09/05/2017 10 0.16 90,000 50,000

Front Range Resources Ltd. Common Shares Todd, Robert Hamish Owen 5 12/05/2017 10 0.15 247,420 19,386

FRONTIER LITHIUM INC. Common Shares Barker, Bruce 4 05/05/2017 54 0.22 3,252,193 258,064

FRONTIER LITHIUM INC. Warrants Barker, Bruce 4 05/05/2017 54 0 -258,064

FRONTIER LITHIUM INC. Common Shares Drever, Garth Lloyd 5 20/06/2016 54 0.23 394,382 20,307

FRONTIER LITHIUM INC. Common Shares Drever, Garth Lloyd 5 20/06/2016 54 0.23 814,882 20,307

FRONTIER LITHIUM INC. Warrants Drever, Garth Lloyd 5 20/06/2016 54 0.23 0 -20,370

FRONTIER LITHIUM INC. Common Shares Walker, Reginald Frank 3, 4 25/05/2016 51 0.14 12,207,908 500,000

FRONTIER LITHIUM INC. Options Walker, Reginald Frank 3, 4 25/05/2016 51 0.14 1,000,000 -500,000

FRONTIER LITHIUM INC. Warrants Walker, Reginald Frank 3, 4 02/07/2016 55 0.23 0 -20,370

FRONTIER LITHIUM INC. Warrants Walker, Reginald Frank 3, 4 02/07/2016 55 0.23 0 -20,370

Fura Gems Inc. (formerly known as Fura Emeralds Inc.)

Common Shares Aberdeen International Inc. 3 23/06/2015 00


Common Shares Aberdeen International Inc. 3 05/05/2017 16 0.21 2,380,952 2,380,952


Warrants Aberdeen International Inc. 3 23/06/2015 00


Warrants Aberdeen International Inc. 3 05/05/2017 16 0.27 1,190,476 1,190,476


Common Shares Lalinde, Jaime 5 05/05/2017 16 0.21 1,035,714 285,714


Warrants Lalinde, Jaime 5 05/05/2017 16 0.27 892,857 142,857


Common Shares Leigh, Frederic 4 05/06/2014 00


Common Shares Leigh, Frederic 4 05/05/2017 16 0.21 903,607 903,607


Warrants Leigh, Frederic 4 05/06/2014 00


Warrants Leigh, Frederic 4 05/05/2017 16 0.27 236,339 236,339


Common Shares Shetty, Devidas 4, 5 23/01/2017 00


Common Shares Shetty, Devidas 4, 5 05/05/2017 16 0.21 1,147,194 1,147,194

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4494



Acquired/ Disposed


Warrants Shetty, Devidas 4, 5 23/01/2017 00


Warrants Shetty, Devidas 4, 5 05/05/2017 16 0.27 573,596 573,596

GAR Limited Common Shares 2158879 ontario limited 3 30/12/2013 00

GAR Limited Common Shares 2158879 ontario limited 3 30/12/2013 00 796,200

GAR Limited Common Shares 2158879 ontario limited 3 09/05/2017 11 -1,796,000

GAR Limited Common Shares 2158879 ontario limited 3 09/05/2017 11 1,796,200

GAR Limited Common Shares 2158879 ontario limited 3 09/05/2017 11 1,480,000 -1,796,200














GAR Limited Common Shares Rapski, John 4, 5 09/05/2017 11 7,517,200 1,796,200

Gazit-Globe Ltd. Options Segal, Dori 4, 6 16/10/2013 00

Gazit-Globe Ltd. Options Segal, Dori 4, 6 09/05/2017 50 2,965,505 2,965,505

Genesis Land Development Corp.

Common Shares Genesis Land Development Corp.

1 03/04/2017 38 3.03 5,944 1,486



1 05/04/2017 38 3.17 7,430 1,486



1 07/04/2017 38 3 8,330 900



1 10/04/2017 38 2.99 8,430 100



1 24/04/2017 38 3.18 8,630 200



1 30/04/2017 38 0 -8,630

Genius Properties Ltd. Common Shares Goulet, Guy 4, 5 04/05/2017 10 0.18 11,000 2,000

Genworth MI Canada Inc. Common Shares Levings, Stuart Kendrick 4 11/05/2017 10 34.174 14,085 1,464

George Weston Limited Common Shares Dart, Robert John 6 10/05/2017 10 124.31 4,000 -500

George Weston Limited Preferred Shares Series 1 Dart, Robert John 6 16/04/2002 00

George Weston Limited Preferred Shares Series 1 Dart, Robert John 6 10/05/2017 10 26.06 1,500 1,500

Gildan Activewear Inc. Common Shares Corsano, Anthony Frank 7 09/05/2017 57 39.021 83,876 83,873

Gildan Activewear Inc. Common Shares Corsano, Anthony Frank 7 09/05/2017 30 39.021 -44,526

Gildan Activewear Inc. Common Shares Corsano, Anthony Frank 7 09/05/2017 30 39.021 39,347 -44,529

Gildan Activewear Inc. Common Shares Corsano, Anthony Frank 7 11/05/2017 10 28.48 7,000 -32,347

Gildan Activewear Inc. Restricted Share Units Corsano, Anthony Frank 7 09/05/2017 57 39.12 -83,873

Gildan Activewear Inc. Restricted Share Units Corsano, Anthony Frank 7 09/05/2017 57 39.12 15,259 -83,873

Gildan Activewear Inc. Common Shares Cunningham, Shirley Elizabeth

4 04/05/2017 00

Gildan Activewear Inc. Deferred Share Units (DSUs)

Cunningham, Shirley Elizabeth

4 04/05/2017 00

Gildan Activewear Inc. Common Shares Frisk, Patrik 4 04/05/2017 00

Gildan Activewear Inc. Deferred Share Units (DSUs)

Frisk, Patrik 4 04/05/2017 00

Gildan Activewear Inc. Common Shares Gildan Activewear Inc. 1 03/04/2017 38 35.674 525,596 131,400




Gildan Activewear Inc. Common Shares Gildan Activewear Inc. 1 07/04/2017 38 35.484 1,052,524 131,732

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4495



Acquired/ Disposed












Gildan Activewear Inc. Common Shares Gildan Activewear Inc. 1 26/04/2017 38 99,600 -2,068,056



Gildan Activewear Inc. Common Shares Hoffman, Michael 7 08/05/2017 51 14.32 86,477 11,726

Gildan Activewear Inc. Common Shares Hoffman, Michael 7 08/05/2017 10 39.127 74,751 -11,726

Gildan Activewear Inc. Common Shares Hoffman, Michael 7 08/05/2017 10 39.1 54,751 -20,000

Gildan Activewear Inc. Options Hoffman, Michael 7 08/05/2017 51 14.32 296,455 -11,726

Gildan Activewear Inc. Common Shares Lavoie, Nicolas 5 09/05/2017 10 39.1 1,324 -2,216

Gildan Activewear Inc. Common Shares Masi, Benito 5 05/05/2017 51 14.32 161,241 12,964

Gildan Activewear Inc. Common Shares Masi, Benito 5 05/05/2017 10 39.146 148,277 -12,964

Gildan Activewear Inc. Common Shares Masi, Benito 5 05/05/2017 10 36.26 138,277 -10,000

Gildan Activewear Inc. Options Masi, Benito 5 05/05/2017 51 14.32 296,751 -12,964

Global Dividend Growers Income Fund

Trust Units Global Dividend Growers Income Fund

1 04/05/2017 10 12.55 4,260,594 -5,000

GMP Capital Inc. Common Shares WEIR, ROBERT RUSSELL 7 05/05/2017 57 3.5 653,078 45,090

GMP Capital Inc. Common Shares WEIR, ROBERT RUSSELL 7 05/05/2017 10 3.5 628,941 -24,137

GMP Capital Inc. Rights Restricted Share Units (RSU)

WEIR, ROBERT RUSSELL 7 05/05/2017 57 156,853 -45,090

goeasy Ltd. (formerly, easyhome Ltd.)

Common Shares easyhome Ltd. 1 26/04/2017 10 32.19 6,400


Common Shares easyhome Ltd. 1 26/04/2017 38 32.19 6,400 6,400










Common Shares easyhome Ltd. 1 04/05/2017 38 0 -19,388


Common Shares Ingram, David 4, 5 08/05/2017 47 33.5 374,709 -3,500

Gold Standard Ventures Corp.

Common Shares Strauss, James Digby Ronald

4 10/05/2017 10 2.12 174,300 8,300

Goldcorp Inc. Common Shares Masse, Ann 5 08/05/2017 10 18.65 15,333

Goldcorp Inc. Common Shares Masse, Ann 5 08/05/2017 10 18.65 5,784 -1,533

Golden Reign Resources Ltd.

Options Jonker, Abraham 4 14/06/2016 50 0.25 650,000 400,000

Golden Share Mining Corporation

Common Shares Zeng, Nick Nianqing 4, 5 08/05/2017 10 0.15 1,728,000 3,000

Golden Share Mining Corporation

Common Shares Zeng, Nick Nianqing 4, 5 11/05/2017 10 0.155 1,730,000 2,000

GoldQuest Mining Corp. Options Robertson, Paul Harold 5 18/04/2017 50 0.5 50,000

GoldQuest Mining Corp. Options Robertson, Paul Harold 5 18/04/2017 50 0.5 50,000

Gran Colombia Gold Corp. 2020 Debentures Gran Colombia Gold Corp. 1 04/04/2017 38 0.8199 $450,000 $450,000

Gran Colombia Gold Corp. 2020 Debentures Gran Colombia Gold Corp. 1 07/04/2017 38 $0 -$450,000

Gran Colombia Gold Corp. 2020 Debentures Gran Colombia Gold Corp. 1 27/04/2017 38 0.805 $246,831 $246,831

Gran Colombia Gold Corp. 2020 Debentures Gran Colombia Gold Corp. 1 02/05/2017 38 $0 -$246,831

Gran Colombia Gold Corp. 2020 Debentures Mann, Ian Hollis 4 14/03/2016 00 $207,797

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4496



Acquired/ Disposed

Gran Colombia Gold Corp. Options Mann, Ian Hollis 4 03/04/2017 50 0.17 1,300,000 800,000

Gran Colombia Gold Corp. Options Mann, Ian Hollis 4 25/04/2017 37 2.55 833,333 -466,667

Gran Colombia Gold Corp. Options Mann, Ian Hollis 4 25/04/2017 37 2.55 86,666 -746,667

Gran Tierra Energy Inc. Common Shares Ellson, Ryan Paul 5 05/05/2017 10 2.38 236,030 16,000

Gran Tierra Energy Inc. Common Shares GMT Capital Corp 3 04/05/2017 10 2.31 11,631,230 498,300















Gran Tierra Energy Inc. Common Shares GMT Capital Corp 3 04/05/2017 10 2.31 695,430 26,000



Gran Tierra Energy Inc. Common Shares GMT Capital Corp 3 10/05/2017 10 2.54 702,330 700







Gran Tierra Energy Inc. Common Shares Guidry, Gary Stephen 4, 5 05/05/2017 10 2.39 2,527,000 45,000

Gran Tierra Energy Inc. Common Shares Trimble, Rodger Derrick 5 05/05/2017 10 2.4 52,650 15,150

Granite Oil Corp. (formerly DeeThree Exploration Ltd.)

Common Shares Hamm, Henry Peter 4 12/05/2017 51 4.52 805,432 5,636

Granite Oil Corp. (formerly DeeThree Exploration Ltd.)

Replacement Options Hamm, Henry Peter 4 12/05/2017 51 4.52 0 -5,636

Great-West Lifeco Inc. Common Shares Barrett, Deborah Jean 4 04/05/2017 00

Great-West Lifeco Inc. Common Shares Barrett, Deborah Jean 4 09/05/2017 10 34.905 2,900 2,900

Great-West Lifeco Inc. Common Shares Plan Common Shares

Brown, Douglas A. 5 05/04/2017 30 34.618 606 149

Great-West Lifeco Inc. Common Shares Plan Common Shares

Snow, Harold Charles 8, 5 05/04/2017 30 34.618 1,739 186

Green Swan Capital Corp. Common Shares Clausi, Peter Michael 4, 5 08/05/2017 51 0.05 253,867 66,000



Green Swan Capital Corp. Common Shares Clausi, Peter Michael 4, 5 05/05/2017 10 0.09 400,000 -150,000

Green Swan Capital Corp. Common Shares Clausi, Peter Michael 4, 5 11/05/2017 10 0.09 207,000 -193,000


Green Swan Capital Corp. Options Clausi, Peter Michael 4, 5 08/05/2017 51 600,000 -66,000




Green Swan Capital Corp. Common Shares Crawford, Brian Lorne 4, 5 11/05/2017 10 0.09 479,800 -22,000

Green Swan Capital Corp. Common Shares Crawford, Brian Lorne 4, 5 12/05/2017 51 0.05 516,800 37,000

Green Swan Capital Corp. Common Shares Crawford, Brian Lorne 4, 5 12/05/2017 10 0.09 501,800 -15,000

Green Swan Capital Corp. Options Crawford, Brian Lorne 4, 5 12/05/2017 51 629,000 -37,000

Greenfields Petroleum Corporation

Common Shares - New Harkins, John Wilfrid Hugh 4, 5 08/05/2017 10 0.2 3,927,425 71,500



Insider Reporting

May 18, 2017

(2017), 40 OSCB 4497



Acquired/ Disposed


Common Shares - New Harkins, John Wilfrid Hugh 4, 5 12/05/2017 11 0.146 857,143



Guyana Goldfields Inc. Common Shares Ferry, Alan Louis Henry 4 10/05/2017 10 6.031 243,000 -27,000

H&R Finance Trust Units Hofstedter, Thomas J. 4 08/03/2017 99 16.69 2,356,085 9,497




H&R Real Estate Investment Trust

Restricted Share Units Dickson, Robert Earl 4 07/03/2017 59 23.38 -4,510


Restricted Share Units Dickson, Robert Earl 4 07/03/2017 59 23.38 15,072 -5,419


Restricted Share Units Fried, Cheryl 5 07/03/2017 59 23.38 -2,593


Restricted Share Units Fried, Cheryl 5 07/03/2017 59 23.38 11,581 -3,116


Restricted Share Units Froom, Larry 5 07/03/2017 59 23.38 -34,731


Restricted Share Units Froom, Larry 5 07/03/2017 59 23.38 38,979 -41,735


Restricted Share Units Gilbert, Edward Allen 4 07/03/2017 59 23.38 -4,510


Restricted Share Units Gilbert, Edward Allen 4 07/03/2017 59 23.38 15,072 -5,419


Restricted Share Units Hofstedter, Thomas J. 4, 5 07/03/2017 59 23.38 -58,637


Restricted Share Units Hofstedter, Thomas J. 4, 5 07/03/2017 59 23.38 45,737 -70,462


Restricted Share Units Lapointe, Philippe 4 10/01/2017 56 22.6 4,424


Restricted Share Units Lapointe, Philippe 4 10/01/2017 56 22.6 5,852 5,852


Restricted Share Units Lebovic, Laurence A. 6 07/03/2017 59 23.38 -4,510


Restricted Share Units Lebovic, Laurence A. 6 07/03/2017 59 23.38 15,072 -5,419


Restricted Share Units Rutman, Ronald C. 4 07/03/2017 59 23.38 -4,510


Restricted Share Units Rutman, Ronald C. 4 07/03/2017 59 23.38 15,072 -5,419


Restricted Share Units Sullivan, Patrick James 5 07/03/2017 59 23.38 -4,408


Restricted Share Units Sullivan, Patrick James 5 07/03/2017 59 23.38 17,511 -5,297


Restricted Share Units Uhr, Nathan 5 07/03/2017 59 23.38 -4,510


Restricted Share Units Uhr, Nathan 5 07/03/2017 59 23.38 13,899 -5,419

High Liner Foods Incorporated

Rights Deferred Share Units

Bell, Alan 4 08/05/2014 00



Bell, Alan 4 10/05/2017 56 17.97 2,782 2,782



Chow, Joan Kai 4 10/05/2017 00



Chow, Joan Kai 4 10/05/2017 56 17.97 3,808 3,808



Covelluzzi, James G 4 17/05/2011 00



Covelluzzi, James G 4 10/05/2017 56 17.97 3,808 3,808



Demone, Henry 4, 5 13/03/2003 00



Demone, Henry 4, 5 10/05/2017 56 17.97 2,782 2,782

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4498



Acquired/ Disposed



Dexter, Robert P. 4 10/05/2017 56 17.97 26,909 2,782



Hennigar, Andrew 4 05/11/2010 00



Hennigar, Andrew 4 10/05/2017 56 17.97 2,782 2,782



Hennigar, David John 4, 6 31/03/2003 00



Hennigar, David John 4, 6 10/05/2017 56 17.97 2,782 2,782



Jamieson, Shelly L. 4 18/12/2012 00



Jamieson, Shelly L. 4 10/05/2017 56 17.97 2,782 2,782



MAHODY, Jolene 4 08/05/2014 00



MAHODY, Jolene 4 10/05/2017 56 17.97 2,782 2,782



Miller, Ralph Andy 4 10/05/2017 56 17.97 14,440 2,782



Pace, Robert 4 10/05/2017 56 17.97 3,075 2,782



van Schaayk, Frank Bernard Harry

4 07/11/2014 00



van Schaayk, Frank Bernard Harry

4 10/05/2017 56 17.97 2,782 2,782

Hillcrest Petroleum Ltd. Common Shares Currie, Donald James 4, 5 11/05/2017 10 0.08 5,175,000 25,000

HOUSTON LAKE MINING INC.

Warrants Drever, Garth Lloyd 5 02/01/2015 11 0.23 20,370

HOUSTON LAKE MINING INC.

Warrants Drever, Garth Lloyd 5 20/06/2016 54 0.23 -20,370 -20,370

Hudbay Minerals Inc. (formerly HudBay Minerals Inc.)

Common Shares GMT Capital Corp 3 04/05/2017 10 5.31 7,247,490 210,200























Insider Reporting

May 18, 2017

(2017), 40 OSCB 4499



Acquired/ Disposed


Common Shares GMT Capital Corp 3 04/05/2017 10 5.31 463,300 11,000


Common Shares GMT Capital Corp 3 05/05/2017 10 5.39 464,000 700













Hydro One Limited Common Shares Vels, Michael Harold 7, 5 09/05/2017 10 23.04 31,720 5,000

IBEX TECHNOLOGIES INC. Options Bergeron, Claire 5 21/04/2017 50 0.235 135,000 35,000

IBEX TECHNOLOGIES INC. Options DeLuccia, Robert 4 21/04/2017 50 0.235 130,000 35,000

IBEX TECHNOLOGIES INC. Options HECHT, THOMAS O. 4 21/04/2017 50 0.235 120,000 35,000

IDM Mining Ltd. (Formerly Revolution Resources Corp.)

Common Shares Horsley, Nigel Alexander 8 12/05/2017 10 0.14 185,000 35,000


Common Shares McLeod, Robert John 5 09/05/2017 54 100000 1,051,632 100,000


Warrants McLeod, Robert John 5 09/05/2017 54 52,084 -100,000

Igen Networks Corp. Common Shares Chan, Neil 4 10/05/2017 10 0.13 2,489,167 -4,000

Igen Networks Corp. Common Shares Chan, Neil 4 11/05/2017 10 0.13 2,483,167 -6,000

Immunovaccine Inc. Common Shares Dawe, Wade K. 4 24/04/2017 51 10000 10,000

Immunovaccine Inc. Common Shares Dawe, Wade K. 4 24/04/2017 51 1 45,000 10,000

Immunovaccine Inc. Options Dawe, Wade K. 4 24/04/2017 51 1 -10,000

Immunovaccine Inc. Options Dawe, Wade K. 4 24/04/2017 51 1 155,000 -10,000

Imperial Metals Corporation Common Shares Imperial Metals Corporation 1 25/04/2017 38 6.025 4,542 4,400

Information Services Corporation

Class A Limited Voting Shares

Coppola, Tracy Kim 5 10/05/2017 10 0 -1,500

InMed Pharmaceuticals Inc. (formerly Cannabis Technologies Inc,)

Common Shares Hossain, Sazzad 5 05/05/2017 45 0.14 3,407,500 500,000

Intact Financial Corporation Subscription Receipts - May 2017

Anderson, Kenneth 5 28/01/2009 00


Anderson, Kenneth 5 11/05/2017 15 91.85 1,000 1,000


BLAIR, ALAN JOHN 5 10/12/2004 00


BLAIR, ALAN JOHN 5 11/05/2017 15 91.85 1,500 1,500


Cote, Sonya 5 03/11/2015 00


Cote, Sonya 5 11/05/2017 15 91.85 200 200


Cotnoir, Frédéric 5 18/01/2016 00


Cotnoir, Frédéric 5 11/05/2017 15 91.85 100 100


De Silva, Janet 4 08/05/2013 00


De Silva, Janet 4 11/05/2017 15 91.85 1,100 1,100

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4500



Acquired/ Disposed


Dionne, Michel 5 10/12/2004 00


Dionne, Michel 5 11/05/2017 15 91.85 200 200


Dussault, Claude 4, 5 10/12/2004 00


Dussault, Claude 4, 5 11/05/2017 15 91.85 2,000 2,000


Fortin, Anne 5 01/12/2013 00


Fortin, Anne 5 11/05/2017 15 91.85 544 544


Fox, Donald Arthur 5 01/01/2017 00


Fox, Donald Arthur 5 11/05/2017 15 91.85 2,500 2,500

Intact Financial Corporation Common Shares Intact Financial Corporation 1 07/04/2017 38 94.349 5,500 1,700








Intact Financial Corporation Common Shares Intact Financial Corporation 1 24/04/2017 38 94.74 18,800 200


Intact Financial Corporation Common Shares Intact Financial Corporation 1 26/04/2017 38 2,000 -18,800




Marcotte, Louis 5 16/10/2006 00


Marcotte, Louis 5 11/05/2017 15 91.85 1,000 1,000


Mercier, Eileen Ann 4 10/12/2004 00


Mercier, Eileen Ann 4 11/05/2017 15 91.85 500 500


Paquette, Sylvie 4 03/05/2017 00


Paquette, Sylvie 4 11/05/2017 15 91.85 2,000 2,000


Penner, Timothy Herbert 4 05/05/2010 00


Penner, Timothy Herbert 4 11/05/2017 15 91.85 2,200 2,200


roy, louise 4 10/12/2004 00


roy, louise 4 11/05/2017 15 91.85 500 500


Snyder, Stephen Gregory 4 13/05/2009 00


Snyder, Stephen Gregory 4 11/05/2017 15 91.85 5,000 5,000


Stephenson, Carol M. 4 15/12/2004 00


Stephenson, Carol M. 4 11/05/2017 15 91.85 200 200

Inventronics Limited Common Shares MONETTE, SERGE 3 10/05/2017 10 0.13 187,100 1,000

Invictus MD Strategies Corp. Common Shares Bowden, Aaron 4 20/08/2016 00

Invictus MD Strategies Corp. Common Shares Bowden, Aaron 4 20/08/2016 00 30,000

Invictus MD Strategies Corp. Common Shares Bowden, Aaron 4 06/12/2016 54 0.5 10,000

Invictus MD Strategies Corp. Common Shares Bowden, Aaron 4 06/12/2016 54 0.5 10,000

Invictus MD Strategies Corp. Options Bowden, Aaron 4 20/08/2016 00 215,000

Invictus MD Strategies Corp. Warrants Bowden, Aaron 4 20/08/2016 00 10,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4501



Acquired/ Disposed

Invictus MD Strategies Corp. Common Shares DIXON, Brenda Mae 3, 5 25/04/2017 00 10,000,000

Invictus MD Strategies Corp. Warrants DIXON, Brenda Mae 3, 5 25/04/2017 00 1,500,000

Ithaca Energy Inc. Common Shares Delek Group Ltd. 3 09/05/2017 22 1.95 400,852,265 64,806,680

Karmin Exploration Inc. Common Shares BRACE, DAVID WALLACE 4, 5 08/05/2017 10 0.5 632,750 5,750

Karmin Exploration Inc. Common Shares Rodríguez-Mariátegui Canny, Luis Martin

4 27/04/2017 10 0.5 97,500 -2,000


4 28/04/2017 10 0.5 96,500 -1,000


4 03/05/2017 10 0.5 96,000 -500


4 05/05/2017 10 0.5 88,000 -8,000

Kennady Diamonds Inc. Common Shares Moore, Rory 4, 5 08/05/2017 10 3.18 50,500 500

Kerr Mines Inc. Options Kostuik, Martin Leslie 4, 5 01/05/2017 00 2,000,000

Kew Media Group Inc. Class B Shares Kagan, Maurice 4 11/05/2017 90 0 -177,115

Kew Media Group Inc. Class B Shares Kagan, Maurice 4 13/06/2016 00

Kew Media Group Inc. Class B Shares Kagan, Maurice 4 11/05/2017 90 177,115 177,115

KHAN RESOURCES INC. Common Shares Sadhra, Michael 4, 5 05/05/2016 00 2,000,000

KHAN RESOURCES INC. Common Shares YERLY, Blaise F. 4 05/05/2017 00 1,500,000

Kinaxis Inc. Common Shares Colbeth, Douglas Proctor 4 09/05/2017 10 85.85 98,400 -1,600

Kinaxis Inc. Common Shares Colbeth, Douglas Proctor 4 10/05/2017 10 85.856 50,000 -48,400

Kinaxis Inc. Common Shares Erwin, John Randall 5 08/05/2017 30 86 70 -1,000

Kinaxis Inc. Common Shares Erwin, John Randall 5 09/05/2017 51 9.75 2,970 2,900

Kinaxis Inc. Common Shares Erwin, John Randall 5 09/05/2017 10 85.876 70 -2,900

Kinaxis Inc. Common Shares Erwin, John Randall 5 12/05/2017 30 78.57 164 94

Kinaxis Inc. Options Erwin, John Randall 5 09/05/2017 51 9.75 62,500 -2,900

Kinaxis Inc. Common Shares Sicard, John Ernest 4, 5 09/05/2017 10 86.4 81,789 -1,600

Kinaxis Inc. Common Shares Ticala, Vasile Gelu 5 08/05/2017 51 11.84 2,000 2,000

Kinaxis Inc. Common Shares Ticala, Vasile Gelu 5 08/05/2017 10 86.113 0 -2,000





Kinaxis Inc. Options Ticala, Vasile Gelu 5 08/05/2017 51 11.84 66,250 -2,000



Kincora Copper Limited Warrants Ivanhoe Industries, LLC 3 10/05/2017 11 0.065 2,808,420 -139,080

Kingsway Financial Services Inc.

Common Shares Stilwell, Joseph David 4 05/05/2017 10 5.9 297,032 220


Common Shares Stilwell, Joseph David 4 09/05/2017 10 6 297,252 220


Common Shares Stilwell, Joseph David 4 10/05/2017 10 6 297,472 220


Common Shares Stilwell, Joseph David 4 05/05/2017 10 5.9 2,432,225 1,780


Common Shares Stilwell, Joseph David 4 09/05/2017 10 6 2,434,005 1,780


Common Shares Stilwell, Joseph David 4 10/05/2017 10 6 2,435,785 1,780

Kinross Gold Corporation Common Shares Brough, John A. 4 05/05/2017 10 4.98 0 -13,796

Kinross Gold Corporation Common Shares Jardine, Gina Maree 5 08/05/2017 57 5.15 50,071 20,932

Kinross Gold Corporation Common Shares Jardine, Gina Maree 5 08/05/2017 10 5.15 50,065 -6

Kinross Gold Corporation Restricted Shares Jardine, Gina Maree 5 08/05/2017 59 5.15 491,718 -24,113

Kinross Gold Corporation Restricted Shares Jardine, Gina Maree 5 08/05/2017 57 5.15 470,786 -20,932

Kinross Gold Corporation Restricted Shares Longenecker, Nathan M. 5 03/04/2017 00

Kinross Gold Corporation Restricted Shares Longenecker, Nathan M. 5 05/05/2017 56 4.94 91,093 91,093

Kinross Gold Corporation Restricted Shares van Akkooi, Michiel 5 04/05/2017 00

Kinross Gold Corporation Restricted Shares van Akkooi, Michiel 5 05/05/2017 56 4.94 80,972 80,972

Kirkland Lake Gold Ltd. Common Shares Klassen, Arnold 4 08/05/2017 10 9.0232 20,000 10,000

Kirkland Lake Gold Ltd. Common Shares Yee, Philip Chow 5 30/11/2016 00 33,000

Kirkland Lake Gold Ltd. Common Shares Yee, Philip Chow 5 08/05/2017 10 9.05 65,000 32,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4502



Acquired/ Disposed

Klondex Mines Ltd. Performance Share Units Antwi, John 5 30/06/2016 00

Klondex Mines Ltd. Performance Share Units Antwi, John 5 11/05/2017 56 31,385 31,385

Klondex Mines Ltd. Restricted Share Units Antwi, John 5 11/05/2017 56 53,385 31,385

Klondex Mines Ltd. Deferred Share Units Cooper, Rodney Alexander 4 11/05/2017 56 45,046 22,523

Klondex Mines Ltd. Performance Share Units Dahl, Barry 5 11/05/2017 56 66,848 35,962

Klondex Mines Ltd. Restricted Share Units Dahl, Barry 5 11/05/2017 56 97,783 35,962

Klondex Mines Ltd. Deferred Share Units Daniel, Mark 4 11/05/2017 56 45,046 22,523

Klondex Mines Ltd. Performance Share Units Doolin, Michael Benjamin Jr.

7 11/05/2017 56 76,366 40,538

Klondex Mines Ltd. Restricted Share Units Doolin, Michael Benjamin Jr.

7 11/05/2017 56 109,966 40,538

Klondex Mines Ltd. Deferred Share Units Haggarty, James (Jamie) 4 11/05/2017 56 45,046 22,523

Klondex Mines Ltd. Deferred Share Units Hall, Richard James 4, 5 11/05/2017 56 90,090 45,045

Klondex Mines Ltd. Performance Share Units Huet, Paul André 4, 5 11/05/2017 56 220,866 123,846

Klondex Mines Ltd. Restricted Share Units Huet, Paul André 4, 5 11/05/2017 56 274,200 123,846

Klondex Mines Ltd. Deferred Share Units Matlack, William 4 11/05/2017 56 45,046 22,523

Klondex Mines Ltd. Performance Share Units Morris, Brian Wayne 5 11/05/2017 56 52,424 30,077

Klondex Mines Ltd. Restricted Share Units Morris, Brian Wayne 5 11/05/2017 56 65,090 30,077

Klondex Mines Ltd. Deferred Share Units Oliver, Charles Fergus Hoblyn

4 11/05/2017 56 45,046 22,523

Klondex Mines Ltd. Deferred Share Units Schultz, Blair 4 11/05/2017 56 45,046 22,523

Klondex Mines Ltd. Performance Share Units Seaberg, John W. 5 11/05/2017 56 59,744 33,582

Klondex Mines Ltd. Restricted Share Units Seaberg, John W. 5 11/05/2017 56 80,745 33,582

Kontrol Energy Corp. Options Bowerbank, Andrew 4 08/05/2017 50 0.8 170,000 20,000

Kontrol Energy Corp. Common Shares Del Vasto, Claudio 4 08/05/2017 46 0.8 477,160 200,000

Kontrol Energy Corp. Options Del Vasto, Claudio 4 08/05/2017 50 0.8 570,000 20,000

Kontrol Energy Corp. Options Ghezzi, Paul 6 22/07/2016 00

Kontrol Energy Corp. Options Ghezzi, Paul 6 08/05/2017 50 0.8 20,000 20,000

Kontrol Energy Corp. Options Lavereau, Kristian 5 22/07/2016 00

Kontrol Energy Corp. Options Lavereau, Kristian 5 08/05/2017 50 0.8 20,000 20,000

Labrador Iron Ore Royalty Corporation

Common Shares McNeil, William Hugh 4 10/05/2017 10 17.746 2,000 1,000

Lexington Biosciences, Inc. (formerly, Glenwood Acquisitions Corp.)

Options Disher, John Bryan 4 21/12/2016 00


Options Disher, John Bryan 4 09/05/2017 50 0.2 135,000


Options Disher, John Bryan 4 09/05/2017 50 135,000 135,000


Options Furber, Nicholas John 5 01/11/2016 00


Options Furber, Nicholas John 5 09/05/2017 50 0.2 72,000 72,000


Options JANZEN, DOUG 4 21/12/2016 00


Options JANZEN, DOUG 4 09/05/2017 50 0.2 270,000 270,000


Common Shares McInnes, Donald Arthur 5 09/05/2007 00 2,475,000


Options McInnes, Donald Arthur 5 09/05/2007 00 135,000


Common Shares Rossi, Rocco 4 16/12/2016 00


Common Shares Rossi, Rocco 4 21/12/2016 11 0.005 250,000 250,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4503



Acquired/ Disposed


Options Rossi, Rocco 4 16/12/2016 00


Options Rossi, Rocco 4 09/05/2017 50 0.2 135,000 135,000


Options Willis, Eric 4, 5 21/12/2016 00


Options Willis, Eric 4, 5 09/05/2017 50 0.2 270,000 270,000

Liberty Gold Corp. (formerly Pilot Gold Inc.)

Common Shares Everett, Calvin Clovis 5 10/05/2017 54 3,150,000 150,000

Liberty Gold Corp. (formerly Pilot Gold Inc.)

Warrants Everett, Calvin Clovis 5 10/05/2017 54 0.4 1,125,000 -150,000

Liberty Silver Corp. Common Shares DiGirolamo, Julio 5 08/05/2017 16 1 25,000 5,000

LiCo Energy Metals Inc. Common Shares HELLWARTH, JAMES 4 30/12/2016 51 0.06 1,181,818 500,000

LiCo Energy Metals Inc. Common Shares HELLWARTH, JAMES 4 08/05/2017 10 0.15 1,066,818 -30,000

LiCo Energy Metals Inc. Options HELLWARTH, JAMES 4 30/12/2016 51 0.06 0 -500,000

LiCo Energy Metals Inc. Common Shares LOEWEN, RON 3 11/05/2017 10 0.13 9,485,536 -250,000

Lifestyle Delivery Systems Inc. (formerly, Kariana Resources Inc.)

Common Shares Silina, Yanika 5 08/05/2017 10 0.6 500 -4,000

Limited Duration Investment Grade Preferred Securities Fund

Units Class A Limited Duration Investment Grade Preferred Securities Fund

1 03/04/2017 38 22.3 1,600 800



1 04/04/2017 38 22.4 2,400 800



1 06/04/2017 38 22.25 3,200 800



1 07/04/2017 38 22.25 4,000 800



1 10/04/2017 38 22.16 4,800 800



1 11/04/2017 38 22.18 5,600 800



1 13/04/2017 38 25.25 500



1 13/04/2017 38 22.25 6,100 500



1 17/04/2017 38 22.25 6,900 800



1 18/04/2017 38 22.19 7,500 600



1 19/04/2017 38 25.25 8,300 800



1 21/04/2017 38 22.3 9,100 800



1 24/04/2017 38 22.4 9,900 800



1 25/04/2017 38 22.3 10,000 100



1 26/04/2017 38 22.35 10,800 800

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4504



Acquired/ Disposed



1 27/04/2017 38 22.35 11,600 800



1 28/04/2017 38 22.39 12,000 400



1 28/04/2017 38 2,000 -10,000


Units Class U Limited Duration Investment Grade Preferred Securities Fund

1 26/04/2017 38 24.47 600 600



1 27/04/2017 38 24.39 1,200 600



1 28/04/2017 38 24.39 1,800 600

Lingo Media Corporation Common Shares Kraft, Michael 4, 5 04/05/2017 10 0.242 2,124,512 29,500




LIONS GATE ENTERTAINMENT CORP.

Common Shares Class A Voting

Beeks, Steve 7, 5 06/05/2017 30 24.89 -2,088



Beeks, Steve 7, 5 06/05/2017 30 24.89 -2,088



Beeks, Steve 7, 5 06/05/2017 30 24.89 50,595 -2,088


Non-Voting Shares Class B

Beeks, Steve 7, 5 06/05/2017 30 22.85 -2,088



Beeks, Steve 7, 5 06/05/2017 30 22.85 -2,088



Beeks, Steve 7, 5 06/05/2017 30 22.85 50,595 -2,088



Burns, Michael Raymond 4, 5 03/05/2017 16 1,040,718 3,641



Burns, Michael Raymond 4, 5 03/05/2017 30 25.75 1,039,350 -1,368






Burns, Michael Raymond 4, 5 03/05/2017 16 1,041,173 3,981







LKP Solutions Inc. Common Shares Pitman, Paul 4 28/10/2016 00 317,917

Loblaw Companies Limited Common Shares Davis, Sarah Ruth 5 04/05/2017 57 77.869 36,997 35,520

Loblaw Companies Limited Common Shares Davis, Sarah Ruth 5 04/05/2017 10 77.869 1,477 -35,520

Loblaw Companies Limited Performance Share Units Davis, Sarah Ruth 5 04/05/2017 56 70,283 11,314

Loblaw Companies Limited Performance Share Units Davis, Sarah Ruth 5 04/05/2017 57 77.869 34,763 -35,520

Loblaw Companies Limited Common Shares Dufresne, Richard 6, 5 26/03/2012 00

Loblaw Companies Limited Common Shares Dufresne, Richard 6, 5 04/05/2017 57 77.869 23,706 23,706

Loblaw Companies Limited Common Shares Dufresne, Richard 6, 5 04/05/2017 10 77.869 0 -23,706

Loblaw Companies Limited Performance Share Units Dufresne, Richard 6, 5 04/05/2017 56 46,528 7,551

Loblaw Companies Limited Performance Share Units Dufresne, Richard 6, 5 04/05/2017 57 77.869 22,822 -23,706

Loblaw Companies Limited Common Shares Motz, Michael James 7 04/05/2017 57 77.869 63,312 20,365

Loblaw Companies Limited Common Shares Motz, Michael James 7 04/05/2017 10 77.869 42,947 -20,365

Loblaw Companies Limited Performance Share Units Motz, Michael James 7 04/05/2017 56 50,107 20,365

Loblaw Companies Limited Performance Share Units Motz, Michael James 7 04/05/2017 57 77.869 29,742 -20,365

Loblaw Companies Limited Common Shares Senecal, Garry 5 04/05/2017 57 77.869 21,764 15,443

Loblaw Companies Limited Common Shares Senecal, Garry 5 04/05/2017 10 77.869 6,321 -15,443

Loblaw Companies Limited Performance Share Units Senecal, Garry 5 04/05/2017 56 43,420 4,919

Loblaw Companies Limited Performance Share Units Senecal, Garry 5 04/05/2017 57 77.869 27,977 -15,443

Lucara Diamond Corp. Common Shares Lahri, Naseem Banu 7 10/05/2017 51 2.45 20,000 20,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4505



Acquired/ Disposed

Lucara Diamond Corp. Common Shares Lahri, Naseem Banu 7 10/05/2017 10 3.25 0 -20,000

Lucara Diamond Corp. Options Lahri, Naseem Banu 7 10/05/2017 51 2.45 150,000 -20,000

Lumenpulse Inc. Options Campbell, Gregory Sullivan 5 13/12/2016 71 4.45 3,000

Lumenpulse Inc. Options Campbell, Gregory Sullivan 5 13/12/2016 51 4.45 3,000

Lumenpulse Inc. Options Campbell, Gregory Sullivan 5 13/12/2016 51 4.45 117,500 -3,000

Macarthur Minerals Limited Common Shares Cadence Minerals Plc 3 08/05/2017 54 0.05 30,000,000 7,500,000

Macarthur Minerals Limited Warrants Cadence Minerals Plc 3 08/05/2017 54 0.05 0 -7,500,000

Macarthur Minerals Limited Common Shares Fairbourn, Adrian 6 08/05/2017 54 0.05 30,000,000 7,500,000

Macarthur Minerals Limited Warrants Fairbourn, Adrian 6 08/05/2017 54 0.05 0 -7,500,000

Macarthur Minerals Limited Common Shares Morzaria, Kiran Caldas 6 08/05/2017 54 0.05 30,000,000 7,500,000

Macarthur Minerals Limited Warrants Morzaria, Kiran Caldas 6 08/05/2017 54 0.05 0 -7,500,000

Macarthur Minerals Limited Common Shares Strang, Donald Ian George Layman

6 08/05/2017 54 0.05 30,000,000 7,500,000

Macarthur Minerals Limited Warrants Strang, Donald Ian George Layman

6 08/05/2017 54 0.05 0 -7,500,000

Macarthur Minerals Limited Common Shares Suckling, Andrew Paul 6 08/05/2017 54 0.05 30,000,000 7,500,000

Macarthur Minerals Limited Warrants Suckling, Andrew Paul 6 08/05/2017 54 0.05 0 -7,500,000

Maccabi Ventures Inc. Common Shares Penn, Richard Ryan 3, 5 08/05/2017 10 0.05 1,290,000 25,000

MacDonald Mines Exploration Ltd.

Options Gilfillan, Tara Ament 4 04/05/2017 00


Options Gilfillan, Tara Ament 4 08/05/2017 50 0.175 250,000 250,000


Options Heng, Joseph, Ching-Hiang 5 28/04/2016 00


Options Heng, Joseph, Ching-Hiang 5 08/05/2017 50 200,000


Options Heng, Joseph, Ching-Hiang 5 08/05/2017 50 150,000 150,000


Common Shares Class A McKinnon, Gordon Scott Townsend

4 04/05/2017 00 142,858


Options McKinnon, Gordon Scott Townsend

4 04/05/2017 00


Options McKinnon, Gordon Scott Townsend

4 08/05/2017 50 0.175 200,000 200,000


Options Schatzker, Adam Paul 4 04/05/2017 00


Options Schatzker, Adam Paul 4 08/05/2017 50 125,000 125,000


Options Scherba, Craig 5 08/05/2017 50 1,595,000 100,000


Options Tanas, Kevin Michael 4 04/05/2017 00


Options Tanas, Kevin Michael 4 08/05/2017 50 0.175 200,000 200,000


Common Shares Class A Yarie, Quentin 4, 5 09/05/2017 10 0.135 194,460 42,000


Options Yarie, Quentin 4, 5 08/05/2017 50 2,805,000 700,000

MacDonald, Dettwiler and Associates Ltd.

(DSUs, DRSUs, SARs) Osborne, Donald 7 11/05/2017 30 65.968 323,334 -3,334

MacDonald, Dettwiler and Associates Ltd.

Common Shares Osborne, Donald 7 11/05/2017 30 65.968 6,424 1,282

Madalena Energy Inc. Common Shares Penafiel, Alejandro Augusto 4 08/05/2017 00

Madalena Energy Inc. Options Penafiel, Alejandro Augusto 4 08/05/2017 00

Madalena Energy Inc. Common Shares Penafiel, Jose David 4, 5 08/05/2017 00

Madalena Energy Inc. Options Penafiel, Jose David 4, 5 08/05/2017 00

Magellan Aerospace Corporation

Common Shares Gowan, Bruce William 4 11/05/2017 10 21 6,423 -3,000

Magna International Inc. Units Deferred Share Units

RUH, WILLIAM ANTHONY 4 11/05/2017 00 556

Malbex Resources Inc. Options Davis, Franklin Lorie 4 16/01/2017 52 4.5 150,000 -25,000

Malbex Resources Inc. Options Hamilton, Joseph Andrew 4 16/01/2017 52 4.5 200,000 -25,000

Malbex Resources Inc. Options MacGibbon, Terry 4 16/01/2017 52 4.5 150,000 -25,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4506



Acquired/ Disposed

Mandalay Resources Corporation

Common Shares Doyle, Robert Emmet 4 04/05/2017 57 852,701 35,241


Restricted Share Unit Doyle, Robert Emmet 4 04/05/2017 57 136,727 -35,241


Restricted Share Unit Doyle, Robert Emmet 4 10/05/2017 56 138,827 2,100


Restricted Share Unit Freedman, Amy Leanne 4 10/05/2017 56 170,329 2,060


Restricted Share Unit Jones, Peter Rhys 4 10/05/2017 56 138,827 2,100


Common Shares Jonker, Abraham 4 22/06/2016 10 1.12 0 -82,333


Restricted Share Unit Jonker, Abraham 4 10/05/2017 56 138,827 2,100


Restricted Share Unit Mills, Bradford 4, 5 01/12/2009 00


Restricted Share Unit Mills, Bradford 4, 5 27/03/2017 56 100,000 100,000


Restricted Share Unit Mills, Bradford 4, 5 10/05/2017 30 101,536 1,536

Manitex Capital Inc. Common Shares Saviuk, Steve 4, 6, 5 12/05/2017 10 0.5 862,000 1,500

Manitok Energy Inc. Common Shares Geremia, Massimo Mario 5 08/05/2017 30 0.1201 256,354 14,984

Manitok Energy Inc. Common Shares Jerhoff, Timothy Franklin 5 08/05/2017 30 0.1201 240,332 14,048

Manitok Energy Inc. Common Shares Martin, Donald Robert 5 08/05/2017 30 0.1201 223,408 13,111

Manitok Energy Inc. Common Shares PERRY, RODGER DEAN 5 08/05/2017 30 0.1201 197,947 11,863

Manulife Financial Corporation

Common Shares Caron, Joseph Peter 4 08/05/2017 11 24.54 3,436 2,045


Common Shares Caron, Joseph Peter 4 08/05/2017 11 24.54 2,875 -2,045


Common Shares Caron, Joseph Peter 4 09/05/2017 10 24.66 3,270 2,045


Common Shares Thomson, Warren A. 5 09/05/2017 51 12.64 74,845 64,791


Common Shares Thomson, Warren A. 5 09/05/2017 10 24.725 64,845 -10,000
















Common Shares Thomson, Warren A. 5 09/05/2017 10 24.673 34,845 -100















Insider Reporting

May 18, 2017

(2017), 40 OSCB 4507



Acquired/ Disposed






















Common Shares Thomson, Warren A. 5 10/05/2017 51 12.64 30,054 20,000














Options Thomson, Warren A. 5 09/05/2017 51 12.64 1,943,297 -64,791


Options Thomson, Warren A. 5 10/05/2017 51 12.64 1,923,297 -20,000

Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 04/05/2017 10 33.809 8,457 -700

Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 04/05/2017 10 33.878 3,357 -5,100

Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 04/05/2017 10 33.887 1,857 -1,500

Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 04/05/2017 10 33.93 1,457 -400

Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 04/05/2017 10 33.934 657 -800

Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 04/05/2017 10 33.922 57 -600

Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 04/05/2017 10 33.93 -43 -100

Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 04/05/2017 10 33.996 -843 -800

Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 04/05/2017 10 34.005 -1,943 -1,100



Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 04/05/2017 10 34.027 -9,843 -600







Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 05/05/2017 51 20.28 -5,743 13,000

Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 05/05/2017 51 22.52 2,657 8,400

Maple Leaf Foods Inc. Common Shares Brooks, Bentley Andrew 5 05/05/2017 51 22.53 9,157 6,500

Maple Leaf Foods Inc. Options Employee Brooks, Bentley Andrew 5 05/05/2017 51 57,150 -13,000



Maple Leaf Foods Inc. Common Shares Maksymetz, Gary Louis 5 02/05/2017 10 34.53 -705 -107,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4508



Acquired/ Disposed

Maple Leaf Foods Inc. Common Shares Maksymetz, Gary Louis 5 08/05/2017 51 11.85 106,295 107,000

Maple Leaf Foods Inc. Options Employee Maksymetz, Gary Louis 5 08/05/2017 51 423,200 -107,000

Marifil Mines Limited Common Shares Burnett, Gregory Clifford 4 12/05/2017 37 1,008,000 -4,032,000

Marifil Mines Limited Options Burnett, Gregory Clifford 4 12/05/2017 37 190,000 -760,000

Marifil Mines Limited Warrants Burnett, Gregory Clifford 4 12/05/2017 36 1,000,000 -4,000,000

Marifil Mines Limited Common Shares Hite, John Blanchard 3, 4, 5 12/05/2017 37 12,198,097 2,033,016

Marifil Mines Limited Warrants Hite, John Blanchard 3, 4, 5 12/05/2017 37 5,280,000 880,000

Marifil Mines Limited Common Shares Pearson, John William 4 12/05/2017 37 171,000 -684,000

Marifil Mines Limited Options Pearson, John William 4 12/05/2017 37 190,000 -760,000

Marifil Mines Limited Warrants Pearson, John William 4 12/05/2017 37 158,000 -632,000

Marifil Mines Limited Common Shares Sweatman, Michael 4 12/05/2017 37 245,000 -980,000

Marifil Mines Limited Options Sweatman, Michael 4 12/05/2017 37 120,000 -480,000

Marifil Mines Limited Warrants Sweatman, Michael 4 12/05/2017 37 225,000 -900,000

Marifil Mines Limited Common Shares Walters, Richard 4, 5 12/05/2017 37 1,041,764 -4,167,055

Marifil Mines Limited Options Walters, Richard 4, 5 12/05/2017 37 255,000 -1,020,000

Marifil Mines Limited Warrants Walters, Richard 4, 5 12/05/2017 37 467,600 -1,870,400

Martinrea International Inc. Options Options to purchase common shares

LaRosa, Andre 5 31/12/2016 52 -10,000

Martinrea International Inc. Options Options to purchase common shares

LaRosa, Andre 5 31/12/2016 52 -10,000

Martinrea International Inc. Common Shares Lyons, Terrence 4 23/11/2016 10 2,600 -9,200

Martinrea International Inc. Common Shares Lyons, Terrence 4 30/12/2016 99 0 -2,600

Martinrea International Inc. Common Shares Lyons, Terrence 4 01/02/2014 00

Martinrea International Inc. Common Shares Lyons, Terrence 4 03/02/2014 10 565 565

Martinrea International Inc. Common Shares Lyons, Terrence 4 02/05/2014 10 908 343

Martinrea International Inc. Common Shares Lyons, Terrence 4 02/07/2015 10 870 -38

Martinrea International Inc. Common Shares Lyons, Terrence 4 02/12/2015 10 1,128 258


Martinrea International Inc. Common Shares Lyons, Terrence 4 13/03/2017 10 1,459 -1


Martinrea International Inc. Common Shares Macher, Frank Edward 4 10/03/2014 00

Martinrea International Inc. Common Shares Macher, Frank Edward 4 05/05/2017 10 7.9358 15,000 15,000

Mason Graphite Inc. Common Shares Neill, Alastair 4 05/05/2017 10 1.3 22,560 -80,240

Mason Resources Corp. Common Shares Bailey, Mark 4 09/05/2017 00 221,814

Mason Resources Corp. Common Shares Harris, James Lindsay 4 09/05/2017 00 169,227



MCAN Mortgage Corporation Common Shares McIntosh, Loraine 4 09/05/2017 00

MCAN Mortgage Corporation Common Shares McIntosh, Loraine 4 11/05/2017 10 14 950 950

MCAN Mortgage Corporation Common Shares McIntosh, Loraine 4 09/05/2017 00

MCAN Mortgage Corporation Common Shares McIntosh, Loraine 4 11/05/2017 10 14 1,750 1,750

MCAN Mortgage Corporation Common Shares Sutherland, Derek 4 09/05/2017 00 30,773



MDC Partners Inc. Common Shares Class A Subordinate Voting Shares

Copeland, Clare Robert 4 05/05/2017 97 64,003 4,441


Copeland, Clare Robert 4 05/05/2017 97 61,982 -2,021

MDC Partners Inc. Restricted Stock Units Copeland, Clare Robert 4 05/05/2017 97 4,942 -4,441


Kauffman, Scott L. 4, 5 05/05/2017 97 643,324 4,441


Kauffman, Scott L. 4, 5 05/05/2017 97 645,709 2,385

MDC Partners Inc. Restricted Stock (Class A Shares)

Kauffman, Scott L. 4, 5 05/05/2017 97 7,008 -4,441


Simon, Irwin 4 05/05/2017 97 33,011 4,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4509



Acquired/ Disposed

MDC Partners Inc. Restricted Stock (US) Simon, Irwin 4 05/05/2017 97 8,000 -4,000

Medical Facilities Corporation

Options Horrar, Robert Oreon 5 05/05/2017 00 350,000

Medicure Inc. Common Shares Friesen, Albert David 4, 5 03/05/2017 10 7.06 67,867 400

Medicure Inc. Common Shares Friesen, Albert David 4, 5 03/05/2017 10 7.07 71,467 3,600

Melcor Developments Ltd. Common Shares Young, Ralph Barclay 4, 5 12/05/2017 47 123,333 -5,000

Melcor Real Estate Investment Trust

Trust Units Melton, Andrew John 6 12/05/2017 10 8.8 100,700 3,000

Metallis Resources Inc. Common Shares Aliperti, Fiore 4 11/05/2017 11 0.18 346,667 50,000

Metallis Resources Inc. Common Shares Warrants $0.35 May 9,2019 Expir

Aliperti, Fiore 4 06/02/2012 00

Metallis Resources Inc. Common Shares Warrants $0.35 May 9,2019 Expir

Aliperti, Fiore 4 11/05/2017 53 0.35 25,000 25,000

Metallis Resources Inc. Common Shares Dupre, David 5 11/05/2017 11 0.18 280,000 50,000

Metallis Resources Inc. Common Shares Warrants $0.35 May 9, 2019 Expiry

Dupre, David 5 12/02/2014 00

Metallis Resources Inc. Common Shares Warrants $0.35 May 9, 2019 Expiry

Dupre, David 5 11/05/2017 53 0.35 25,000 25,000

Metallis Resources Inc. Common Shares Sheikh, Sameen 5 11/05/2017 11 0.18 255,000 50,000

Metallis Resources Inc. Common Shares Warrants Sheikh, Sameen 5 29/03/2012 00

Metallis Resources Inc. Common Shares Warrants Sheikh, Sameen 5 29/03/2012 00

Metallis Resources Inc. Common Shares Warrants Sheikh, Sameen 5 11/05/2017 53 0.35 25,000 25,000

Metallis Resources Inc. Common Shares Sikich, Michael 4 11/05/2017 11 0.18 1,037,156 138,889

Metallis Resources Inc. Common Shares Warrants $0.35 May 9, 2019 Expir

Sikich, Michael 4 06/02/2012 00

Metallis Resources Inc. Common Shares Warrants $0.35 May 9, 2019 Expir

Sikich, Michael 4 11/05/2017 53 0.35 69,444 69,444

Metanor Resources Inc. Common Shares Wagner, Jennifer Laura 6 21/04/2017 00

Metanor Resources Inc. Common Shares Wagner, Jennifer Laura 6 09/05/2017 10 0.85 10,000 10,000

Mexican Gold Corp. Common Shares Palisade Global Investments Ltd.

3 08/05/2017 10 0.295 3,644,000 10,000


3 09/05/2017 10 0.29 3,649,000 5,000


3 09/05/2017 10 0.2776 3,691,000 42,000


3 10/05/2017 10 0.2893 3,706,000 15,000

Mexican Gold Corp. Common Shares Robertson, Brian Ernest 4, 5 09/05/2017 46 0.25 414,762 330,000

Mexican Gold Corp. Common Shares Robertson, Brian Ernest 4, 5 09/05/2017 46 0.31 1,131,639 716,877

Mexican Gold Corp. Common Shares Terris, J. Earl 4 09/05/2017 46 0.25 215,000 65,000

MGX Minerals Inc. Common Shares Reimann, Michael Andrew 5 09/05/2017 10 1.01 1,015,000 -5,000

MGX Minerals Inc. Common Shares Reimann, Michael Andrew 5 09/05/2017 16 0.9 1,070,000 55,000

Midas Gold Corp. Common Shares Labelle, Anne Marie Susan 5 05/05/2017 10 0.75 295,400 -24,600

Midas Gold Corp. Common Shares Labelle, Anne Marie Susan 5 10/05/2017 10 0.71 321,900 26,500

Midas Gold Corp. Common Shares Labelle, Anne Marie Susan 5 10/05/2017 36 0.6 60,000

Midas Gold Corp. Common Shares Labelle, Anne Marie Susan 5 10/05/2017 36 0.66 381,900 60,000

Midas Gold Corp. Options Labelle, Anne Marie Susan 5 05/01/2017 50 0.89 645,000 175,000

Midas Gold Corp. Warrants Labelle, Anne Marie Susan 5 10/05/2017 54 0.6 -60,000

Midas Gold Corp. Warrants Labelle, Anne Marie Susan 5 10/05/2017 54 0.66 0 -60,000

Middlefield Can-Global REIT Income Fund

Trust Units Middlefield Can-Global REIT Income Fund

1 04/05/2017 10 11.503 4,187,952 -14,000



1 09/05/2017 10 11.54 4,185,052 -2,900



1 10/05/2017 10 11.587 4,181,952 -3,100



1 11/05/2017 10 11.6 4,181,552 -400

Middlefield Healthcare & Wellness Dividend Fund

Trust Units Middlefield Healthcare & Wellness Dividend Fund

1 04/05/2017 38 10.208 356,200 2,300



1 09/05/2017 38 10.381 356,900 700



1 10/05/2017 38 10.359 358,800 1,900

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4510



Acquired/ Disposed



1 11/05/2017 38 10.302 360,400 1,600

Midland Exploration Inc. Common Shares Archer, Paul 4 10/05/2017 00 25,000

Midland Exploration Inc. Options Archer, Paul 4 10/05/2017 00

Midland Exploration Inc. Options Archer, Paul 4 10/05/2017 50 100,000 100,000

MINT Income Fund Trust Units MINT Income Fund 1 04/05/2017 38 6.9578 66,035,929 2,700

MINT Income Fund Trust Units MINT Income Fund 1 08/05/2017 37 6.9363 3,000





Mobi724 Global Solutions Inc.

Common Shares Beauchemin, David-Lee 7 09/05/2017 16 0.355 1,623,722 756,230


Options Beauchemin, David-Lee 7 14/01/2016 00


Options Beauchemin, David-Lee 7 09/05/2017 50 250,000 250,000


Common Shares Léger, Claude 7 09/05/2017 16 0.355 1,470,964 846,370


Common Shares Léger, Claude 7 09/05/2017 16 0.355 1,225,804 705,309


Options Léger, Claude 7 12/01/2015 00


Options Léger, Claude 7 09/05/2017 50 175,000


Options Léger, Claude 7 09/05/2017 50 175,000 175,000


Common Shares Tardif, Daniel 7 09/05/2017 16 0.355 2,642,435 1,185,049


Options Tardif, Daniel 7 22/12/2015 00


Options Tardif, Daniel 7 09/05/2017 50 175,000 175,000

Mogo Finance Technology Inc.

Common Shares Wekerle, Michael A. 3 10/05/2017 10 3.7298 2,597,500 87,400


Common Shares Wekerle, Michael A. 3 11/05/2017 10 3.9204 2,610,000 12,500


Common Shares Wekerle, Michael A. 3 13/04/2017 10 3.71 733,943 25,000


Common Shares Wekerle, Michael A. 3 18/04/2017 10 3.55 758,943 25,000


Common Shares Wekerle, Michael A. 3 01/03/2017 10 3.25 4,065


Common Shares Wekerle, Michael A. 3 01/03/2017 10 3.25 4,065

MONETA PORCUPINE MINES INC.

Common Shares Henry, Alexander David 4 10/05/2017 10 0.16 22,500 22,500


Common Shares Henry, Alexander David 4 10/05/2017 10 0.165 1,301,750 66,500


Common Shares Henry, Alexander David 4 10/05/2017 10 0.16 1,312,750 11,000

Morguard Corporation Common Shares SAHI, ANGELA 4 10/05/2017 00

Morguard Real Estate Investment Trust

Units SAHI, ANGELA 6 10/05/2017 00

Mukuba Resources Limited Common Shares Marrelli, Carmelo 3 24/01/2017 00

Mukuba Resources Limited Common Shares Marrelli, Carmelo 3 12/05/2017 10 0.075 13,598 13,598

Murchison Minerals Ltd. Common Shares Martin, Erik H. 5 12/05/2017 10 0.16 179,650 100,000

Nautilus Minerals Inc. Common Shares Joint Stock Company Holding Company METALLOINVEST

3 11/05/2017 16 0.239 118,400,889 5,598,744

Nevsun Resources Ltd. Options Engquist, Kenneth 5 03/05/2017 00

Nevsun Resources Ltd. Options Engquist, Kenneth 5 05/05/2017 50 3.04 200,000 200,000

Nevsun Resources Ltd. Common Shares Giardini, Anne Elizabeth 4 03/05/2017 00

Nevsun Resources Ltd. Common Shares Giardini, Anne Elizabeth 4 09/05/2017 10 3.09 30,000 30,000


Insider Reporting

May 18, 2017

(2017), 40 OSCB 4511



Acquired/ Disposed


Nevsun Resources Ltd. Options Giardini, Anne Elizabeth 4 03/05/2017 00

Nevsun Resources Ltd. Options Giardini, Anne Elizabeth 4 05/05/2017 50 3.04 100,000 100,000

New Dimension Resources Ltd.

Warrants Dawson, James Martin 4 04/05/2017 55 0.15 275,000 -200,000


Warrants Heffernan, Robert Scott 4 04/05/2017 55 0.15 200,000 -150,000


Warrants Johnstone, Wayne David 5 05/05/2017 55 0 -100,000

New Flyer Industries Inc. Options Smart, Ian Scott 5 28/12/2014 50 39,334

New Flyer Industries Inc. Options Smart, Ian Scott 5 28/12/2014 50 116,569 39,344

New Gold Inc. Options Estey, James 4 10/05/2017 52 8.54 198,586 -24,600

New Gold Inc. Options Konig, Martyn 4 10/05/2017 52 8.54 198,586 -24,600

New Gold Inc. Options Threlkeld, Raymond Wesley 4 10/05/2017 52 8.54 198,586 -24,600

NexC Partners Corp. Non-Voting Shares Class A

NexC Partners Corp. 1 03/04/2017 38 12.486 2,400 800


















NexC Partners Corp. 1 28/04/2017 38 0 -7,400

Nexus Gold Corp. Common Shares Klenman, Alexander 4 01/05/2017 10 0.235 1,731,075 8,000

Nexus Gold Corp. Common Shares Klenman, Alexander 4 05/05/2017 10 0.2 1,737,075 6,000

Nicola Mining Inc. Common Shares Espig, Peter Edward 4 09/05/2017 10 0.15 5,408,087 25,000

Nighthawk Gold Corp. Common Shares Cudney, Robert Douglas 3 05/05/2017 10 0.883 30,000

Nighthawk Gold Corp. Common Shares Cudney, Robert Douglas 3 05/05/2017 10 0.8778 26,595,081 30,000



North American Energy Partners Inc.

Convertible Debentures Ferron, Martin Robert 4, 5 08/05/2017 10 0.975 $1,006,000 $6,000


Convertible Debentures Ferron, Martin Robert 4, 5 08/05/2017 10 0.98 $1,230,000 $224,000


Common Shares North American Energy Partners

1 03/05/2017 10 6.41 95 95


Common Shares North American Energy Partners

1 03/05/2017 38 0 -95

Northern Blizzard Resources Inc.

Common Shares Flatt, James Gordon 6 11/05/2017 00 14,113,002


Common Shares Flatt, James Gordon 6 11/05/2017 00 53,629,343


Common Shares Waterous, Adam 4, 6 11/05/2017 00 14,113,002


Common Shares Waterous, Adam 4, 6 11/05/2017 00 53,629,343


Common Shares WEF GP (Canadian) Corp 3 11/05/2017 00 14,113,002


Common Shares WEF GP (International) Ltd. 3 11/05/2017 00 53,629,343

Northview Apartment Real Estate Investment Trust

Deferred Unit Award Plan Drimmer, Daniel 3, 4 09/05/2017 56 22.6 6,121 1,991


Deferred Unit Award Plan Hoffman, Dennis J. 4 09/05/2017 56 22.6 5,713 1,991

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4512



Acquired/ Disposed


Deferred Unit Award Plan McGinley, Christine Ellen 4 09/05/2017 56 22.6 5,713 1,991


Deferred Unit Award Plan McKibbon, Terrance Lloyd 4 09/05/2017 56 22.6 5,713 1,991


Deferred Unit Award Plan Mitchell, Douglas 4 09/05/2017 56 22.6 7,265 719


Deferred Unit Award Plan Rosenberg, Graham Lawrence

4 09/05/2017 56 22.6 6,138 1,991


Deferred Unit Award Plan Thon, Scott William 4 09/05/2017 56 22.6 7,244 3,097

Novelion Therapeutics Inc. Common Shares Buono, Linda 5 29/11/2016 00

Novelion Therapeutics Inc. Common Shares Buono, Linda 5 09/05/2017 36 274 274

Novelion Therapeutics Inc. Common Shares Buono, Linda 5 09/05/2017 11 9.42 181 -93

Novelion Therapeutics Inc. Restricted Stock Unit Buono, Linda 5 09/05/2017 36 48,526 -274

Novelion Therapeutics Inc. Common Shares Harshbarger, Benjamin 5 09/05/2017 36 819 349

Novelion Therapeutics Inc. Common Shares Harshbarger, Benjamin 5 09/05/2017 11 9.42 706 -113

Novelion Therapeutics Inc. Common Shares Harshbarger, Benjamin 5 09/05/2017 36 1,081 375

Novelion Therapeutics Inc. Common Shares Harshbarger, Benjamin 5 09/05/2017 11 9.42 960 -121

Novelion Therapeutics Inc. Restricted Stock Unit Harshbarger, Benjamin 5 09/05/2017 36 52,255 -349

Novelion Therapeutics Inc. Restricted Stock Unit Harshbarger, Benjamin 5 09/05/2017 36 51,880 -375

Novelion Therapeutics Inc. Common Shares Louis, Roger 5 29/11/2016 00

Novelion Therapeutics Inc. Common Shares Louis, Roger 5 09/05/2017 36 547 547

Novelion Therapeutics Inc. Common Shares Louis, Roger 5 09/05/2017 11 9.42 385 -162

Novelion Therapeutics Inc. Restricted Stock Unit Louis, Roger 5 09/05/2017 36 21,653 -547

Novelion Therapeutics Inc. Common Shares Perry, Gregory 5 29/11/2016 00

Novelion Therapeutics Inc. Common Shares Perry, Gregory 5 09/05/2017 36 2,393 2,393

Novelion Therapeutics Inc. Common Shares Perry, Gregory 5 09/05/2017 11 9.42 1,683 -710

Novelion Therapeutics Inc. Restricted Stock Unit Perry, Gregory 5 09/05/2017 36 86,546 -2,393

Novelion Therapeutics Inc. Common Shares Szela, Mary 4, 5 29/11/2016 00

Novelion Therapeutics Inc. Common Shares Szela, Mary 4, 5 09/05/2017 36 6,632 6,632

Novelion Therapeutics Inc. Common Shares Szela, Mary 4, 5 09/05/2017 11 9.42 4,384 -2,248

Novelion Therapeutics Inc. Restricted Stock Unit Szela, Mary 4, 5 09/05/2017 36 184,924 -6,632

Novo Resources Corp. Common Shares 2176423 Ontario Ltd. 3 04/05/2017 00 1,923,077

Novo Resources Corp. Common Shares 2176423 Ontario Ltd. 3 04/05/2017 11 0.66 7,030,977 5,107,900

Novo Resources Corp. Warrants 2176423 Ontario Ltd. 3 04/05/2017 00 1,923,077

Novo Resources Corp. Warrants 2176423 Ontario Ltd. 3 04/05/2017 11 7,030,977 5,107,900

Novo Resources Corp. Common Shares Sprott, Eric S. 3 04/05/2017 11 0.66 7,030,977 5,107,900

Novo Resources Corp. Warrants Sprott, Eric S. 3 04/05/2017 11 7,030,977 5,107,900

NUVISTA ENERGY LTD. Common Shares Deferred Share Units

MacPhail, Keith A.J. 4, 5 12/05/2017 56 25,711 3,725


Poelzer, Ronald J.M. 4 12/05/2017 56 13,357 3,725


Zawalsky, Grant A. 4 12/05/2017 56 17,279 3,725

NYX Gaming Group Limited Options O'Loughlin, Keith Thomas 5 28/04/2017 00

NYX Gaming Group Limited Options O'Loughlin, Keith Thomas 5 28/04/2017 50 1.08 300,000

NYX Gaming Group Limited Options O'Loughlin, Keith Thomas 5 02/05/2017 00

NYX Gaming Group Limited Options O'Loughlin, Keith Thomas 5 02/05/2017 50 1.08 300,000 300,000

Olympia Financial Group Inc. Common Shares Skauge, Rick 3, 4, 5 08/05/2017 10 29.5 14,145 83

ONEX CORPORATION Rights Deferred Share Units (cash settled)

Casey, Daniel C. 4 11/05/2017 56 100.74 87,359 2,579


Etherington, William 4 11/05/2017 56 100.74 60,757 2,579


Godsoe, Peter Cowperthwaite

4 11/05/2017 56 100.74 89,155 2,579


Goldhar, Mitchell 4 11/05/2017 00 4,513


Gouin, Serge 4 11/05/2017 56 100.74 89,460 2,579


Huffington, Arianna 4 11/05/2017 56 100.74 14,561 2,579

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4513



Acquired/ Disposed


McCoy, John Bonnet 4 11/05/2017 56 100.74 81,097 2,579


Prichard, John Robert Stobo 4 11/05/2017 56 100.74 83,777 2,579


Reisman, Heather M. 4 11/05/2017 56 100.74 75,460 2,579


Thorsteinson, Arni Clayton 4 11/05/2017 56 100.74 110,033 2,579

ONEX CORPORATION Options Wright, Nigel Stewart 7 05/05/2017 59 35.2 243,334 -41,666

Open Text Corporation Deferred Share Units Fowlie, Randy 4 10/05/2017 56 34.31 67,899 947

Open Text Corporation Deferred Share Units Hamilton, Gail 4 10/05/2017 56 34.31 53,673 729

Open Text Corporation Deferred Share Units Jackman, Brian 4 10/05/2017 56 34.31 43,433 729

Open Text Corporation Deferred Share Units Jenkins, P. Thomas 4 10/05/2017 56 34.31 74,119 947

Open Text Corporation Deferred Share Units Sadler, Stephen 4 10/05/2017 56 34.31 62,857 947

Open Text Corporation Deferred Share Units Slaunwhite, Michael William George

4 10/05/2017 56 34.31 78,401 1,128

Open Text Corporation Deferred Share Units Stevenson, Katharine Berghuis

4 10/05/2017 56 34.31 60,418 1,129

Open Text Corporation Deferred Share Units Tinggren, Carl Juergen 4 25/02/2017 00

Open Text Corporation Deferred Share Units Tinggren, Carl Juergen 4 10/05/2017 56 34.31 3,825 3,825

Open Text Corporation Deferred Share Units Weinstein, Deborah 4 10/05/2017 56 34.31 73,910 1,159

Orezone Gold Corporation Options Downey, Patrick 4 27/04/2017 52 1.7 425,000 -255,000

Orezone Gold Corporation Options Halvorson, Michael Henreid 4 11/05/2017 52 1.7 875,000 -85,000

Orezone Gold Corporation Options Little, Ron 4, 5 27/04/2017 52 1.7 2,100,000 -255,000

Orezone Gold Corporation Options Marquis, Pascal 5 27/04/2017 52 1.7 1,250,000 -255,000

Orezone Gold Corporation Options McCoy, Joseph 5 27/04/2017 52 1.7 405,000 -42,500

Orezone Gold Corporation Options Peck, Keith Lawrence 4 27/04/2017 52 1.7 425,000 -255,000

Organic Potash Corporation Common Shares Schwarz, Jayson Brian 4 08/05/2017 10 0.025 688,000 12,500

Organic Potash Corporation Common Shares Welner, Heather Ann 5 09/05/2017 10 0.025 688,000 12,500

Oroco Resource Corp. Common Shares Dalziel, Craig James 4, 5 12/05/2017 10 0.035 431,000 231,000

Osisko Mining Inc. (formerly Oban Mining Corporation)

Common Shares Perron, Jacques 6 12/12/2016 00

Osisko Mining Inc. (formerly Oban Mining Corporation)

Common Shares Perron, Jacques 6 12/05/2017 10 4.71 2,875 2,875

Otis Gold Corp. Common Shares Norwich, Roger 4 09/05/2017 10 36.2 65,500

Otis Gold Corp. Common Shares Norwich, Roger 4 09/05/2017 10 0.362 7,018,500 65,500

Otis Gold Corp. Common Shares Norwich, Roger 4 09/05/2017 10 35.45 35,000

Otis Gold Corp. Common Shares Norwich, Roger 4 09/05/2017 10 0.354 7,053,500 35,000

Pacgen Life Science Corporation

Common Shares Savage, Alan Clyde Hayes 4 12/05/2017 10 0.09 3,994,000 10,000

Palamina Corp. Common Shares Agro, Hugh 4 05/05/2017 10 0.195 331,500 5,500




Palamina Corp. Common Shares Thomson, Andrew 4 11/05/2017 10 0.2371 1,115,952 7,000

Pancontinental Gold Corporation (formerly, Pancontinental Uranium Corporation)

Common Shares Croft, Thomas Layton 4 09/05/2017 10 0.065 983,000 22,000

Pancontinental Gold Corporation (formerly, Pancontinental Uranium Corporation)

Common Shares Whalen, Donald Alexander 4 08/05/2017 10 0.07 3,336,000 15,000

Panoro Minerals Ltd. Common Shares Boden, William John 4 05/05/2017 10 0.175 11,338,120 3,000

Panoro Minerals Ltd. Common Shares Boden, William John 4 08/05/2017 10 0.175 11,341,120 3,000

Park Lawn Company Limited Common Shares Boland, Lawrence Allan 4, 5 04/05/2017 10 9 18,200 100

Pasinex Resources Limited Common Shares Seeley, Larry Edward 3, 4 08/05/2017 54 0.07 23,265,815 1,000,000

Pasinex Resources Limited Warrants Seeley, Larry Edward 3, 4 18/12/2016 55 0.18 1,100,000 -500,000

Pasinex Resources Limited Warrants Seeley, Larry Edward 3, 4 31/12/2016 55 0.1 500,000

Pasinex Resources Limited Warrants Seeley, Larry Edward 3, 4 31/12/2016 55 0.1 500,000

Pasinex Resources Limited Warrants Seeley, Larry Edward 3, 4 31/12/2016 55 0.1 -500,000

Pasinex Resources Limited Warrants Seeley, Larry Edward 3, 4 08/05/2017 54 0.07 100,000 -1,000,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4514



Acquired/ Disposed

Pason Systems Inc. Common Shares Elliott, David Robert 5 12/05/2017 51 28,725 20,000

Pason Systems Inc. Common Shares Elliott, David Robert 5 12/05/2017 10 20.03 8,725 -20,000

Pason Systems Inc. Options Elliott, David Robert 5 12/05/2017 51 85,969 -20,000

Pason Systems Inc. common share options Smith, Russell 5 08/05/2017 51 243,800 -200



Pason Systems Inc. common share options Smith, Russell 5 08/05/2017 51 241,400 -1,100










Pason Systems Inc. Common Shares Smith, Russell 5 08/05/2017 51 10,990 200

Pason Systems Inc. Common Shares Smith, Russell 5 08/05/2017 10 20.33 10,790 -200





Pason Systems Inc. Common Shares Smith, Russell 5 08/05/2017 51 11,890 1,100

Pason Systems Inc. Common Shares Smith, Russell 5 08/05/2017 10 20.29 10,790 -1,100



















Pathfinder Income Fund Trust Units Pathfinder Convertible Debenture Fund

1 04/05/2017 10 8.85 9,592,864 -18,000


1 08/05/2017 10 8.862 9,587,864 -5,000


1 10/05/2017 11 8.8802 -10,200


1 10/05/2017 10 8.8802 9,577,664 -10,200


1 11/05/2017 10 8.9 9,574,064 -3,600

Pelangio Exploration Inc. Options Bates, Warren Ross 5 08/05/2017 50 1,855,000 400,000

Pelangio Exploration Inc. Options Hibbard, Ingrid Jo-Ann 4, 5 08/05/2017 50 1,450,000 200,000

Pelangio Exploration Inc. Options Mosher, David Vaughn 4 08/05/2017 50 0.05 600,000 75,000

Pelangio Exploration Inc. Options Nurmi, Carl 4 08/05/2017 50 725,000 100,000

Pelangio Exploration Inc. Options Olson, Philip Eugene 4 08/05/2017 50 825,000 100,000

Pelangio Exploration Inc. Options Rokeby, Paul 5 08/05/2017 50 470,000 20,000

Pelangio Exploration Inc. Options Shaw, Ian 4 08/05/2017 50 675,000 75,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4515



Acquired/ Disposed

Pelangio Exploration Inc. Options Todd, Andrew Geoffrey Murray

5 22/09/2016 00

Pelangio Exploration Inc. Options Todd, Andrew Geoffrey Murray

5 08/05/2017 50 50,000 50,000

Pembina Pipeline Corporation

Common Shares Andersen, Harold 5 19/12/2011 00


Common Shares Andersen, Harold 5 12/05/2017 10 43.574 755 755


Common Shares Rubin, Bruce D. 4 05/05/2017 00


Common Shares Smith, Jeffrey T. 4 09/05/2017 10 43.59 2,200 1,030

Perpetual Energy Inc. Common Shares Green, Jeff 5 10/05/2017 57 0.01 79,383 29,977

Perpetual Energy Inc. Common Shares Green, Jeff 5 10/05/2017 10 1.8 49,406 -29,977

Perpetual Energy Inc. Restricted Rights Green, Jeff 5 10/05/2017 38 0.01 29,977 -166

Perpetual Energy Inc. Restricted Rights Green, Jeff 5 10/05/2017 57 0.01 0 -29,977

Polaris Infrastructure Inc. Common Shares Goodwood Inc. 3 05/05/2017 10 15.26 1,761,984 -200



Polaris Infrastructure Inc. Common Shares Goodwood Inc. 3 05/05/2017 10 15.21 1,750,884 -10,200

Polaris Infrastructure Inc. Common Shares Goodwood Inc. 3 05/05/2017 10 15.2 1,742,184 -8,700

Polaris Materials Corporation (formerly Polaris Minerals Corporation)

Common Shares Van Dyk, Nicholas Matthew 5 12/05/2017 10 1.08 8,400 7,900

Potash Corporation of Saskatchewan Inc.

Common Shares Martell, Keith 4 10/05/2017 10 22.85 10,000 -1,000


Common Shares Martell, Keith 4 10/05/2017 10 22.831 10,320 320


Common Shares Martell, Keith 4 10/05/2017 10 22.82 10,750 430

Premier Diversified Holdings Inc.

Common Shares Tusar, Denis 3, 7 12/05/2017 10 0.11 9,906,857 -100,000

ProMIS Neurosciences Inc. Common Shares Geffken, Daniel 5 22/03/2017 00 226,138

ProMIS Neurosciences Inc. Options Geffken, Daniel 5 01/03/2017 50 500,000 500,000

ProMIS Neurosciences Inc. Options Geffken, Daniel 5 22/03/2017 00

Prosper Gold Corp. (formerly Lander Energy Corporation)

Warrants Bernier, Peter 4 30/08/2015 55 0.6 -150,000


Warrants Bernier, Peter 4 30/08/2015 55 0.6 376,500 -150,000


Warrants Bernier, Peter 4 08/05/2017 55 0.75 0 -376,500


Warrants Hynes, Jason Franklin 4 30/08/2015 55 0.6 50,000 -50,000


Warrants Hynes, Jason Franklin 4 08/05/2017 55 0.75 0 -50,000


Warrants Miller-tait, James 4 30/08/2015 55 0.6 0 -15,000


Warrants Tempelman-Kluit, Dirk 4 30/08/2015 55 0.6 300,000 -142,857


Warrants Tempelman-Kluit, Dirk 4 08/05/2017 55 0.75 0 -300,000

Prospero Silver Corp. Common Shares Fortuna Silver Mines Inc. 3 10/05/2017 00 5,357,142

Prospero Silver Corp. Warrants Fortuna Silver Mines Inc. 3 10/05/2017 00 5,357,142

Prospero Silver Corp. Common Shares Rushton, Ralph 5 02/03/2017 11 0.1 180,500 80,000

PUDO Inc. Common Shares Bijou, Thomas Frank 4 04/05/2017 10 1 268,000 1,000

PUDO Inc. Common Shares Bijou, Thomas Frank 4 04/05/2017 10 1.1038 269,000 1,000

PUDO Inc. Common Shares Bijou, Thomas Frank 4 05/05/2017 10 1.0524 270,000 1,000

PUF Ventures Inc. Common Shares Hornung, Christopher Paul 4 08/05/2017 16 0.4 287,500 71,429

Pulse Seismic Inc. Common Shares Crilly, Paul Alexander 4 10/05/2017 00 10,000

Pulse Seismic Inc. Common Shares Crilly, Paul Alexander 4 10/05/2017 56 2.53 20,199 10,199

Puma Exploration Inc. Common Shares Cordick, Arness William Ross

3, 4 04/05/2017 10 0.06 13,613,000 15,000

Puma Exploration Inc. Common Shares Cordick, Arness William Ross

3, 4 05/05/2017 10 0.06 13,619,000 6,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4516



Acquired/ Disposed

QMX Gold Corporation (formerly Alexis Minerals Corporation)

Common Shares Leigh, Frederic 4 08/05/2017 10 0.22 5,250,000 -250,000

Quantum International Income Corp.

Options Bouskill, Ryan Charles 5 11/11/2016 00


Options Bouskill, Ryan Charles 5 04/05/2017 50 1,169,475 1,169,475


Options Lerohl, Mark 4 31/01/2017 00


Options Lerohl, Mark 4 04/05/2017 50 200,000 200,000


Options Ogilvie-Harris, Sheila 4 04/05/2017 50 1,225,000 100,000


Options Sekhri, Manu 4, 5 04/05/2017 50 9,463,234 463,234

Rainy Mountain Royalty Corp. (formerly East West Resource Corporation)

Common Shares Mason, Douglas Lawrence 4, 5 09/05/2017 10 0.11 1,350,000 100,000

Rainy Mountain Royalty Corp. (formerly East West Resource Corporation)

Common Shares Mason, Douglas Lawrence 4, 5 09/05/2017 10 0.11 1,450,000 100,000

Ravensource Fund (formerly The First Asia Income Fund)

Trust Units Reid, Scott 3 10/05/2017 10 14.5 161,900 5,000

Real Matters Inc. Common Shares Altus Group Limited 3 05/05/2017 00

Real Matters Inc. Common Shares Altus Group Limited 3 05/05/2017 00 10,458,142

Real Matters Inc. Common Shares Bartolini, Angelo 6 05/05/2017 00

Real Matters Inc. Common Shares Bartolini, Angelo 6 05/05/2017 00 10,458,142

Real Matters Inc. Common Shares Brown, Angela Louise 6 05/05/2017 00

Real Matters Inc. Common Shares Brown, Angela Louise 6 05/05/2017 00 10,458,142

Real Matters Inc. Common Shares COURTEAU, Robert G 6 05/05/2017 00

Real Matters Inc. Common Shares COURTEAU, Robert G 6 05/05/2017 00 10,458,142

Real Matters Inc. Common Shares FARRELL, CARL 6 05/05/2017 00

Real Matters Inc. Common Shares FARRELL, CARL 6 05/05/2017 00 10,458,142

Real Matters Inc. Common Shares Gaffney, Thomas Anthony 6 05/05/2017 00

Real Matters Inc. Common Shares Gaffney, Thomas Anthony 6 05/05/2017 00 10,458,142

Real Matters Inc. Common Shares MacDiarmid, Diane 6 05/05/2017 00

Real Matters Inc. Common Shares MacDiarmid, Diane 6 05/05/2017 00 10,458,142

Real Matters Inc. Common Shares Mikulich, Raymond 6 05/05/2017 00

Real Matters Inc. Common Shares Mikulich, Raymond 6 05/05/2017 00 10,458,142

Real Matters Inc. Common Shares Slavens, Eric W. 6 05/05/2017 00

Real Matters Inc. Common Shares Slavens, Eric W. 6 05/05/2017 00 10,458,142

Real Matters Inc. Common Shares Woodruff, Janet Patricia 6 05/05/2017 00 10,458,142

Red Pine Exploration Inc. Common Shares Bonner, Rickey 7 05/05/2017 46 0.12 1,605,164 517,406

Red Pine Exploration Inc. Common Shares John, Dexter 7 05/05/2017 46 0.12 1,150,093 524,312

Red Pine Exploration Inc. Common Shares Newman, G. Michael 4 05/05/2017 46 0.12 639,584

Red Pine Exploration Inc. Common Shares Newman, G. Michael 4 05/05/2017 46 0.12 3,887,463 639,584

Red Pine Exploration Inc. Common Shares Sadowski, John 7 05/05/2017 46 0.12 998,508 587,500

Redknee Solutions Inc. Subordinate Voting Shares (Common shares redesignated-Apr/17)

Kothari, Vishal 5 13/04/2017 30 1.06 27,723 6,366

REIT INDEXPLUS Income Fund

Trust Units REIT INDEXPLUS Income Fund

1 05/05/2017 10 12.8 9,748,479 -5,600

REIT INDEXPLUS Income Fund

Trust Units REIT INDEXPLUS Income Fund

1 11/05/2017 10 12.8 9,739,779 -8,700

RESAAS Services Inc. Options Haddad, Marwan 5 12/12/2016 38 351,000 -65,000

RESAAS Services Inc. Options Haddad, Marwan 5 20/12/2016 50 500,000 149,000

RESAAS Services Inc. Options Rossiter, Thomas 4, 5 12/12/2016 38 237,750 -50,000

Restaurant Brands International Inc.

Options Granat, Jill 5 05/05/2017 50 753,106 50,000


Options Kobza, Joshua 5 05/05/2017 50 1,069,261 200,000


Options Santoro, Alexandre 7 05/05/2017 50 411,667 125,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4517



Acquired/ Disposed

Richelieu Hardware Ltd. Common Shares Auclair, Antoine 5 10/05/2017 30 30.11 7,858 73

Richelieu Hardware Ltd. Common Shares Auclair, Antoine 5 10/05/2017 35 30 7,871 13

Richelieu Hardware Ltd. Unités d'actions différées Chicoyne, Denyse 4 04/05/2017 35 30.24 54,853 103

Richelieu Hardware Ltd. Unités d'actions différées Courteau, Robert 4, 5 04/05/2017 35 30.24 55,483 104

Richelieu Hardware Ltd. Common Shares Dion, Christian 5 10/05/2017 30 30.11 5,214 13

Richelieu Hardware Ltd. Common Shares Dion, Christian 5 10/05/2017 35 30 5,215 1

Richelieu Hardware Ltd. Unités d'actions différées Gauvin, Mathieu 4 04/05/2017 35 30.24 62,594 117

Richelieu Hardware Ltd. Common Shares Grenier, Guy 5 10/05/2017 30 30.11 41,993 32

Richelieu Hardware Ltd. Common Shares Grenier, Guy 5 10/05/2017 30 30.11 74,447 48

Richelieu Hardware Ltd. Common Shares Grenier, Guy 5 10/05/2017 35 30 74,455 8

Richelieu Hardware Ltd. Common Shares Lord, Richard 4, 5 10/05/2017 30 30.11 4,202,397 64

Richelieu Hardware Ltd. Common Shares Lord, Richard 4, 5 10/05/2017 35 30 4,202,495 98

Richelieu Hardware Ltd. Unités d'actions différées Pomerleau, Pierre 4 04/05/2017 35 30.24 2,155 4

Richelieu Hardware Ltd. Unités d'actions différées Poulin, Marc 4 04/05/2017 35 30.24 12,078 23

Richelieu Hardware Ltd. Unités d'actions différées Proteau, Jocelyn 4 04/05/2017 35 30.24 32,328 60

Richelieu Hardware Ltd. Common Shares Quevillon, Geneviève 5 10/05/2017 30 30.11 5,655 24

Richelieu Hardware Ltd. Common Shares Quevillon, Geneviève 5 10/05/2017 35 30 5,666 11

Richelieu Hardware Ltd. Unités d'actions différées Vachon, Sylvie 4 04/05/2017 35 30.24 2,303 4

Ridgewood Canadian Investment Grade Bond Fund

Units Ridgewood Capital Asset Management

3 04/05/2017 10 14.71 5,221,065 75



3 04/05/2017 10 14.71 5,220,982 -83



3 05/05/2017 10 14.71 5,221,627 645



3 11/05/2017 10 14.8 5,222,767 1,140



3 11/05/2017 10 14.8 5,222,718 -49



3 11/05/2017 10 14.8 5,222,237 -481



3 11/05/2017 10 14.8 5,221,530 -707


Units Simpson, John H. 5 11/05/2017 10 14.8 -1,180


Units Simpson, John H. 5 11/05/2017 10 14.8 19,548 -1,188

Rio2 Limited Common Shares Black, Alexander 4, 5 05/05/2017 10 1.65 21,520,000 20,000

Rio2 Limited Common Shares Black, Alexander 4, 5 08/05/2017 10 1.7 21,530,000 10,000

Rockcliff Copper Corporation (formerly Solvista Gold Corporation)

Common Shares Durham, Robert Bruce 4 05/05/2017 50 0.075 1,700,558 67,000

Rocky Mountain Dealerships Inc.

Common Shares Crawford, Cameron Walter 4 10/05/2017 10 9.951 4,000 2,000


Common Shares Ganden, Garrett Andrew Wyatt

4, 5 20/12/2007 00


Common Shares Ganden, Garrett Andrew Wyatt

4, 5 10/05/2017 10 9.55 4,600 4,600

Royal Bank of Canada Rights RBC Share Units Dobbins, Michael 5 10/05/2017 59 93.282 9,192 -7,612

Royal Sapphire Corp. Common Shares NSP Consulting Inc. 6 20/04/2017 00 2,000,000

Royal Sapphire Corp. Common Shares Warren, Eric 6 20/04/2017 00 2,000,000

Royalty North Partners Ltd. Common Shares BUSS, CHRISTOPHER A. 4, 5 05/05/2017 16 0.17 1,281,861 300,000

Royalty North Partners Ltd. Warrants BUSS, CHRISTOPHER A. 4, 5 05/05/2017 16 877,841 150,000

Royalty North Partners Ltd. Common Shares CURRIE, JUSTIN LENNOX 4, 5 05/05/2017 16 0.17 990,000 150,000

Royalty North Partners Ltd. Warrants CURRIE, JUSTIN LENNOX 4, 5 05/05/2017 16 915,000 75,000

Royalty North Partners Ltd. Common Shares HOLLANDS, H. CLARK 4 01/02/2016 00

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4518



Acquired/ Disposed

Royalty North Partners Ltd. Common Shares HOLLANDS, H. CLARK 4 05/05/2017 16 0.17 600,000 600,000

Royalty North Partners Ltd. Common Shares HOLLANDS, H. CLARK 4 21/04/2017 16 5,198,661 89,285

Royalty North Partners Ltd. Warrants HOLLANDS, H. CLARK 4 01/02/2016 00

Royalty North Partners Ltd. Warrants HOLLANDS, H. CLARK 4 05/05/2017 16 300,000 300,000

Royalty North Partners Ltd. Common Shares Krause, Steven Karl 5 01/02/2016 00

Royalty North Partners Ltd. Common Shares Krause, Steven Karl 5 21/04/2017 16 35,714 35,714

Royalty North Partners Ltd. Common Shares Watson, Nolan Allan 4 05/05/2017 16 0.17 7,127,708 1,765,000

Royalty North Partners Ltd. Warrants Watson, Nolan Allan 4 05/05/2017 16 4,573,375 882,500

RTG Mining Inc. Common Shares Magee, Justine Alexandria 4, 5 28/03/2013 00

RTG Mining Inc. Common Shares Magee, Justine Alexandria 4, 5 08/05/2017 10 0.1873 244,895 244,895

SAGE GOLD INC. Common Shares Puppendahl, Thomas 4 20/04/2017 00

SAGE GOLD INC. Options Puppendahl, Thomas 4 20/04/2017 00 300,000

SAGE GOLD INC. Warrants Common Share Purchase Warrants

Puppendahl, Thomas 4 20/04/2017 00


Puppendahl, Thomas 4 20/04/2017 00 665,000





Sandvine Corporation Rights Share Units Bowman, Don 5 08/05/2017 30 3.1669 164,848 1,032

Sandvine Corporation Rights Share Units Caputo, David 4 08/05/2017 30 3.1669 369,533 2,317

Sandvine Corporation Rights Share Units Colman, Chris 5 08/05/2017 30 3.1669 35,087 217

Sandvine Corporation Rights Share Units Compagnoni, Angelo 5 08/05/2017 30 3.1669 36,877 229

Sandvine Corporation Rights Share Units Donnelly, Tom 5 08/05/2017 30 3.1669 164,848 1,032

Sandvine Corporation Rights Share Units Hamilton, Scott 4 08/05/2017 30 3.1669 164,848 1,032

Sandvine Corporation Rights Share Units Miller, David 5 08/05/2017 30 3.1669 55,696 347

Sandvine Corporation Common Shares Sandvine Corporation 1 03/04/2017 38 3.1049 86,300 86,300

Sandvine Corporation Common Shares Sandvine Corporation 1 03/04/2017 38 3.1049 0 -86,300

















Sandvine Corporation Common Shares Sandvine Corporation 1 14/04/2017 38 3.116 75,000

Sandvine Corporation Common Shares Sandvine Corporation 1 14/04/2017 38 3.116 -75,000













Insider Reporting

May 18, 2017

(2017), 40 OSCB 4519



Acquired/ Disposed









Sandvine Corporation Rights Share Units Siim, Brad 5 08/05/2017 30 3.1669 164,848 1,032

Sandvine Corporation Rights Share Units Spracklin, Stephen Garrett 5 08/05/2017 30 3.1669 112,038 701

Sandvine Corporation Rights Share Unit Whitney, Stephen 5 08/05/2017 30 3.1669 28,744 180

ScoZinc Mining Ltd. (formerly Selwyn Resources Ltd.)

Common Shares RCF Management LLC 8 11/05/2017 37 4,889 -84,001

SEMAFO INC. Common Shares Desormeaux, Benoit 4, 5 12/05/2017 10 3.11 227,400 15,000

Sernova Corp. Warrants Toleikis, Philip Michael 4, 5 14/05/2015 16 60,000

Sernova Corp. Warrants Toleikis, Philip Michael 4, 5 14/05/2015 16 60,000 60,000

Seven Generations Energy Ltd.

Common Shares Class A Brown, Kevin Jack 4 30/10/2014 00


Common Shares Class A Brown, Kevin Jack 4 09/05/2017 51 2.5 100,000 100,000








Common Shares Class A Brown, Kevin Jack 4 09/05/2017 54 6 260,000 40,000










Common Shares Class A Brown, Kevin Jack 4 09/05/2017 54 6 340,000 10,000




Common Shares Class A Brown, Kevin Jack 4 09/05/2017 11 0 -350,000


Options Pre-IPO Brown, Kevin Jack 4 09/05/2017 51 2.5 70,704 -80,000


Options Pre-IPO Brown, Kevin Jack 4 09/05/2017 51 2.5 50,704 -20,000


Warrants Performance Brown, Kevin Jack 4 09/05/2017 54 3.75 247,760 -40,000






Warrants Performance Brown, Kevin Jack 4 09/05/2017 54 6 127,760 -40,000










Warrants Performance Brown, Kevin Jack 4 09/05/2017 54 6 47,760 -10,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4520



Acquired/ Disposed




Rights Performance Share Units

Brunner, Kyle 5 05/05/2017 56 17,214 7,214


Common Shares Class A Carlson, Patrick Beverley 5 08/05/2017 54 6 2,789,526 106,668


Common Shares Class A Carlson, Patrick Beverley 5 08/05/2017 54 6.75 2,856,191 66,665


Common Shares Class A Carlson, Patrick Beverley 5 08/05/2017 10 25.973 2,732,794 -123,397














Warrants Performance Carlson, Patrick Beverley 5 08/05/2017 54 6 2,378,824 -106,668


Warrants Performance Carlson, Patrick Beverley 5 08/05/2017 54 6.75 2,312,159 -66,665











Feltin, Christopher Wade 5 26/10/2016 00



Feltin, Christopher Wade 5 05/05/2017 56 4,509 4,509



Hnatuik, Randall Nickolas Bruce

5 05/05/2017 56 26,657 7,214



Hucik, Barry John 5 05/05/2017 56 29,239 7,214



Johnston, Kevin James 5 05/05/2017 56 22,121 7,214



Law, Christopher Tudor 5 05/05/2017 56 44,937 18,036



Nevokshonoff, Glen Allen 5 05/05/2017 56 39,890 18,036



Newmarch, Brian John 5 05/05/2017 56 17,214 7,214



Proctor, Marty Leigh 4, 5 05/05/2017 56 66,161 24,048



Raggett, Charlotte Sarah Jane

5 05/05/2017 56 14,810 4,810


Common Shares Class A SHEPPARD, Mary Jacqueline

4 08/05/2017 10 26.05 3,500 1,000



4 08/05/2017 10 25.75 4,500 1,000



4 08/05/2017 10 25.9 6,500 2,000



4 08/05/2017 10 25.85 7,000 500



4 09/05/2017 10 25.5 7,500 500



4 09/05/2017 10 25.75 8,000 500

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4521



Acquired/ Disposed



Stauft, Timothy Lauer 5 14/11/2016 00



Stauft, Timothy Lauer 5 05/05/2017 56 4,208 4,208



Targett, Susan Elizabeth Mabel

5 05/05/2017 56 36,781 18,036

SHAW COMMUNICATIONS INC.

Non-Voting Shares Class "B"

Shaw, JR 3, 4, 5 31/03/2003 00


Non-Voting Shares Class "B"

Shaw, JR 3, 4, 5 06/05/2017 97 462,130 462,130


Options Shaw, JR 3, 4, 5 31/03/2003 00


Options Shaw, JR 3, 4, 5 06/05/2017 97 24.52 146,500 146,500


Options Shaw, JR 3, 4, 5 06/05/2017 97 19.54 546,500 400,000

ShawCor Ltd. Common Shares Reizer, Kevin Dominic 5 01/01/2014 00

ShawCor Ltd. Common Shares Reizer, Kevin Dominic 5 05/04/2017 57 39.01 168 168



ShawCor Ltd. Common Shares Reizer, Kevin Dominic 5 05/04/2017 57 39.092 1,053 333

ShawCor Ltd. Common Shares Reizer, Kevin Dominic 5 05/04/2017 10 39.01 168

ShawCor Ltd. Common Shares Reizer, Kevin Dominic 5 05/04/2017 10 39.01 885 -168






ShawCor Ltd. Employee Share Unit Reizer, Kevin Dominic 5 05/04/2017 57 39.01 18,412 -168




Shopify Inc. Multiple Voting Shares Class B Multiple Voting Shares

Frasca, Joseph Andrew 5 08/05/2017 51 4.22 3,000 3,000


Frasca, Joseph Andrew 5 08/05/2017 36 0 -3,000

Shopify Inc. Options Frasca, Joseph Andrew 5 08/05/2017 51 4.22 80,335 -3,000

Shopify Inc. Subordinate Voting Shares Class A Subordinate Voting Shares

Frasca, Joseph Andrew 5 08/05/2017 36 3,000 3,000


Frasca, Joseph Andrew 5 08/05/2017 30 86.261 0 -3,000


Lutke, Tobias Albin 4, 5 08/05/2017 30 86.364 297,000 -9,000


Miller, Craig Stuart 5 11/05/2017 51 0.152 16,250 16,250


Miller, Craig Stuart 5 11/05/2017 36 0 -16,250

Shopify Inc. Options Miller, Craig Stuart 5 11/05/2017 51 0.152 595,996 -16,250


Miller, Craig Stuart 5 11/05/2017 36 16,250 16,250


Miller, Craig Stuart 5 11/05/2017 30 92.587 0 -16,250

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4522



Acquired/ Disposed

Sierra Wireless, Inc. Common Shares Link, Rene Fernando 5 09/05/2017 57 9,520 2,520

Sierra Wireless, Inc. Common Shares Link, Rene Fernando 5 09/05/2017 10 28.4 8,393 -1,127

Sierra Wireless, Inc. Restricted Share Units Link, Rene Fernando 5 09/05/2017 57 13,342 -2,520

Sierra Wireless, Inc. Common Shares Sieber, Thomas 4 05/05/2017 57 32,238 1,051

Sierra Wireless, Inc. Restricted Share Units Sieber, Thomas 4 05/05/2017 57 8,563 -1,051

Silver Standard Resources Inc.

Common Shares Anglin, Mike Arthur E. 4 09/05/2017 10 9.07 13,726 3,726


Common Shares Anglin, Mike Arthur E. 4 09/05/2017 10 9.08 20,300 6,574


Common Shares Anglin, Mike Arthur E. 4 09/05/2017 10 9.065 21,000 700

Slate Office REIT Subscription Receipts Mawani, Al 4 25/04/2017 36 10,000 -10,000

Slate Office REIT Trust Units Mawani, Al 4 25/04/2017 36 29,800 10,000

Sleep Country Canada Holdings Inc.

Common Shares Howcroft, Dave 5 12/05/2017 10 39 9,357 -22,985

SNC-Lavalin Group Inc. Common Shares Courville, Isabelle 4 04/05/2017 00 1,655

SNC-Lavalin Group Inc. Equity Swap-Long Position 123,933 Com Shares/Exp:May 8, 2020

Groupe SNC-Lavalin inc. 1 01/06/2003 00


Groupe SNC-Lavalin inc. 1 08/05/2017 70 1 1













Solegear Bioplastic Technologies Inc. (formerly Rodeo Capital III Corp.)

Common Shares Antoniadis, Paul John 4 05/05/2017 11 0.15 2,422,602 100,000


Warrants Antoniadis, Paul John 4 05/05/2017 11 0.2 735,357 100,000


Common Shares Harvey, James Noel 5 05/05/2017 11 0.15 129,550 86,666


Warrants Harvey, James Noel 5 05/05/2017 11 0.2 129,550 86,666


Common Shares Pichon, Emily Ethel 3 26/05/2016 00


Common Shares Pichon, Emily Ethel 3 05/05/2017 11 0.15 43,333 43,333


Warrants Pichon, Emily Ethel 3 26/05/2016 00


Warrants Pichon, Emily Ethel 3 05/05/2017 11 0.2 43,333 43,333


Common Shares Pichon, Laura Helen 3 26/05/2016 00

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4523



Acquired/ Disposed


Common Shares Pichon, Laura Helen 3 05/05/2017 11 0.15 8,866 8,866


Warrants Pichon, Laura Helen 3 26/05/2016 00


Warrants Pichon, Laura Helen 3 05/05/2017 11 0.2 8,866 8,866


Common Shares Zadra, Jim 4 05/05/2017 11 0.15 268,568 66,666


Warrants Zadra, Jim 4 05/05/2017 11 0.2 163,568 66,666

Southern Arc Minerals Inc. Common Shares Southern Arc Minerals Inc. 1 01/05/2017 38 0.62 22,000 1,500





Sphere 3D Corp. Common Shares MacFarlane, Thaderine 3 03/05/2017 10 0.18 16,508,791 -24,991





Sphere 3D Corp. Common Shares MacFarlane, Thaderine 3 03/05/2017 10 0.1811 16,482,117 -700














Sphere 3D Corp. Common Shares MacFarlane, Thaderine 3 03/05/2017 10 0.18 -24,991










Sphere 3D Corp. Common Shares MacFarlane, Thaderine 3 03/05/2017 10 0.1816 -400












Insider Reporting

May 18, 2017

(2017), 40 OSCB 4524



Acquired/ Disposed



























































Insider Reporting

May 18, 2017

(2017), 40 OSCB 4525



Acquired/ Disposed



























































Insider Reporting

May 18, 2017

(2017), 40 OSCB 4526



Acquired/ Disposed



























































Insider Reporting

May 18, 2017

(2017), 40 OSCB 4527



Acquired/ Disposed















































Sphere 3D Corp. Common Shares MacFarlane, Victor 3 03/05/2017 10 0.18 16,508,791 -24,991





Sphere 3D Corp. Common Shares MacFarlane, Victor 3 03/05/2017 10 0.1811 16,482,117 -700







Insider Reporting

May 18, 2017

(2017), 40 OSCB 4528



Acquired/ Disposed



























































Insider Reporting

May 18, 2017

(2017), 40 OSCB 4529



Acquired/ Disposed



























































Insider Reporting

May 18, 2017

(2017), 40 OSCB 4530



Acquired/ Disposed












































Sphere 3D Corp. Common Shares MF Ventures, LLC 3 03/05/2017 10 0.18 15,508,791 -24,991





Sphere 3D Corp. Common Shares MF Ventures, LLC 3 03/05/2017 10 0.1811 15,482,117 -700










Insider Reporting

May 18, 2017

(2017), 40 OSCB 4531



Acquired/ Disposed



























































Insider Reporting

May 18, 2017

(2017), 40 OSCB 4532



Acquired/ Disposed



























































Insider Reporting

May 18, 2017

(2017), 40 OSCB 4533



Acquired/ Disposed









































Spot Coffee (Canada) Ltd. Common Shares AYOUB, ANTON MICHEL 4, 5 08/05/2017 10 0.215 1,583,958 2,000

Spot Coffee (Canada) Ltd. Common Shares AYOUB, ANTON MICHEL 4, 5 09/05/2017 10 0.21 1,584,958 1,000

Spot Coffee (Canada) Ltd. Options Stapell, Raymond 4, 5 10/05/2017 51 0.05 75,000

Spot Coffee (Canada) Ltd. Options Stapell, Raymond 4, 5 10/05/2017 51 0.05 75,000

Spot Coffee (Canada) Ltd. Options Stapell, Raymond 4, 5 10/05/2017 52 502,764

Spot Coffee (Canada) Ltd. Options Stapell, Raymond 4, 5 10/05/2017 52 502,764

Spot Coffee (Canada) Ltd. Options Stapell, Raymond 4, 5 10/05/2017 52 0.05 747,764 -75,000

Spot Coffee (Canada) Ltd. Options Stapell, Raymond 4, 5 10/05/2017 52 245,000 -502,764

Sprott Resource Holdings Inc. (formerly Adriana Resources Inc. )

Common Shares Class "A"

Boggio, Lenard 4 09/02/2017 00



Boggio, Lenard 4 20/04/2017 15 0.25 95,548



Boggio, Lenard 4 20/04/2017 15 0.25 95,548 95,548


Warrants Boggio, Lenard 4 09/02/2017 00

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4534



Acquired/ Disposed


Warrants Boggio, Lenard 4 20/04/2017 15 0.25 95,548 95,548


EPSP Designation Einav, Arthur Avi 5 04/05/2017 56 17 462,999 58,824


EPSP Designation Staresinic, Michael 5 04/05/2017 56 0.17 465,411 29,412


EPSP Designation Stronach, Andrew James 5 04/05/2017 56 0.17 462,999 58,824


EPSP Designation Yuzpe, Stephen Mark 4, 5 04/05/2017 56 0.17 1,623,803 152,941

SQI Diagnostics Inc. Common Shares Connor, Gerald R. 4 04/05/2017 97 3,709,902 -25,426

SQI Diagnostics Inc. Common Shares Connor, Gerald R. 4 09/05/2017 97 3,695,303 -14,599

Strata Minerals Inc. Common Shares Agro, Hugh 3, 4, 5 08/05/2017 16 0.2 3,368,708 50,000

Strata Minerals Inc. Common Shares Birak, Donald James 4 08/05/2017 16 0.2 25,000 25,000

Strata Minerals Inc. Common Shares Mansfield, Michael 4 08/05/2017 16 0.2 908,000 50,000

Strata Minerals Inc. Common Shares Marrelli, Carmelo 4 08/05/2017 16 0.2 50,000 50,000

Street Capital Group Inc. Common Shares Lalonde, Ronald Anthony Marshall

7 12/05/2017 10 1.25 15,200 12,700

Sun Life Financial Inc. Common Shares Powers, Scott F. 4 12/07/2016 30 32.197 223

Sun Life Financial Inc. Common Shares Powers, Scott F. 4 12/07/2016 30 32.197 368 223

Supremex Inc. Common Shares Johnston, Robert Bruce 4 09/05/2017 10 4.85 26,800 1,800

Supremex Inc. Common Shares Johnston, Robert Bruce 4 10/05/2017 10 4.81 30,000 3,200

Surge Energy Inc. Common Shares Brown, Daniel Curt 5 17/04/2017 30 2.71 527,838 427

Surge Energy Inc. Common Shares Brown, Daniel Curt 5 01/05/2017 30 2.47 528,307 469

Surge Energy Inc. Common Shares de Leeuw, Gerard A. 5 17/04/2017 30 2.71 189,896 395

Surge Energy Inc. Common Shares de Leeuw, Gerard A. 5 01/05/2017 30 2.47 190,170 274

Surge Energy Inc. Common Shares Elekes, Margaret Ann 5 17/04/2017 30 2.71 31,024 369

Surge Energy Inc. Common Shares Elekes, Margaret Ann 5 01/05/2017 30 2.47 31,429 405

Surge Energy Inc. Common Shares Ferguson, Gordon Paul 5 17/04/2017 30 2.71 7,949 224




Synex International Inc. Options DeAngelis, Tanya Luba 4 15/04/2017 52 0.52 400,000 -70,000

Synex International Inc. Options O'Sullivan, Paul J. 4 15/04/2017 52 210,000 -70,000

Synex International Inc. Options Rennison, Elizabeth Lee 4 15/04/2017 52 0.52 210,000 -70,000

Synex International Inc. Options Russell, Daniel 3 15/04/2017 52 0.52 350,000 -70,000

Synex International Inc. Options sunell, gregory jack 3, 4, 7, 1 08/05/2017 52 0.52 470,000 -70,000

Tahoe Resources Inc. Common Shares Jakusconek, Tanya 4 05/05/2017 57 9000 9,000

Tahoe Resources Inc. Common Shares Jakusconek, Tanya 4 05/05/2017 57 10.65 9,000

Tahoe Resources Inc. Common Shares Jakusconek, Tanya 4 05/05/2017 57 11.65 54,000 9,000

Tahoe Resources Inc. Restricted Share Awards Jakusconek, Tanya 4 05/05/2017 56 9,000

Tahoe Resources Inc. Restricted Share Awards Jakusconek, Tanya 4 05/05/2017 56 9,000 9,000

Tahoe Resources Inc. Restricted Share Awards Jakusconek, Tanya 4 05/05/2017 57 -9,000

Tahoe Resources Inc. Restricted Share Awards Jakusconek, Tanya 4 05/05/2017 57 0 -9,000

Tahoe Resources Inc. Common Shares Jeannes, Charles A. 4 05/05/2017 57 10.65 9,000

Tahoe Resources Inc. Common Shares Jeannes, Charles A. 4 05/05/2017 57 11.65 27,750 9,000

Tahoe Resources Inc. Restricted Share Awards Jeannes, Charles A. 4 05/05/2017 56 9,000

Tahoe Resources Inc. Restricted Share Awards Jeannes, Charles A. 4 05/05/2017 56 9,000 9,000

Tahoe Resources Inc. Restricted Share Awards Jeannes, Charles A. 4 05/05/2017 57 -9,000

Tahoe Resources Inc. Restricted Share Awards Jeannes, Charles A. 4 05/05/2017 57 0 -9,000

Tahoe Resources Inc. Common Shares Kisic, Drago Guillermo 4 05/05/2017 57 10.65 9,000

Tahoe Resources Inc. Common Shares Kisic, Drago Guillermo 4 05/05/2017 57 11.65 30,762 9,000

Tahoe Resources Inc. Restricted Share Awards Kisic, Drago Guillermo 4 05/05/2017 56 9,000

Tahoe Resources Inc. Restricted Share Awards Kisic, Drago Guillermo 4 05/05/2017 56 9,000 9,000

Tahoe Resources Inc. Restricted Share Awards Kisic, Drago Guillermo 4 05/05/2017 57 -9,000

Tahoe Resources Inc. Restricted Share Awards Kisic, Drago Guillermo 4 05/05/2017 57 0 -9,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4535



Acquired/ Disposed

Tahoe Resources Inc. Common Shares MOON, ALAN CLIFFORD 4 04/04/2016 00

Tahoe Resources Inc. Common Shares MOON, ALAN CLIFFORD 4 04/04/2016 00

Tahoe Resources Inc. Common Shares MOON, ALAN CLIFFORD 4 05/05/2017 57 11.65 9,000



Tahoe Resources Inc. Common Shares MOON, ALAN CLIFFORD 4 05/05/2017 57 11.65 51,517 9,000

Tahoe Resources Inc. Restricted Share Awards MOON, ALAN CLIFFORD 4 05/05/2017 56 9,000 9,000

Tahoe Resources Inc. Restricted Share Awards MOON, ALAN CLIFFORD 4 05/05/2017 57 0 -9,000

Tahoe Resources Inc. Common Shares Rovig, A. Dan 4, 6 05/05/2017 57 11.65 144,000 9,000

Tahoe Resources Inc. Restricted Share Awards Rovig, A. Dan 4, 6 05/05/2017 56 9,000 9,000

Tahoe Resources Inc. Restricted Share Awards Rovig, A. Dan 4, 6 05/05/2017 57 0 -9,000

Tahoe Resources Inc. Deferred Share Awards Stieber, Jeffrey Allan 5 03/05/2017 00 9,000

Tahoe Resources Inc. Options Stieber, Jeffrey Allan 5 03/05/2017 00 60,000

Tahoe Resources Inc. Common Shares Sweeney, Paul Bristol 4 05/05/2017 57 244,000 9,000

Tahoe Resources Inc. Deferred Share Awards Sweeney, Paul Bristol 4 04/06/2010 00

Tahoe Resources Inc. Deferred Share Awards Sweeney, Paul Bristol 4 05/05/2017 56 9,000 9,000

Tahoe Resources Inc. Deferred Share Awards Sweeney, Paul Bristol 4 05/05/2017 57 0 -9,000

Tahoe Resources Inc. Common Shares Voorhees, James 5 05/05/2017 57 10.65 9,000

Tahoe Resources Inc. Common Shares Voorhees, James 5 05/05/2017 57 11.65 154,000 9,000

Tahoe Resources Inc. Restricted Share Awards Voorhees, James 5 05/05/2017 56 9,000

Tahoe Resources Inc. Restricted Share Awards Voorhees, James 5 05/05/2017 56 9,000 9,000

Tahoe Resources Inc. Restricted Share Awards Voorhees, James 5 05/05/2017 57 -9,000

Tahoe Resources Inc. Restricted Share Awards Voorhees, James 5 05/05/2017 57 0 -9,000

Tahoe Resources Inc. Common Shares Williamson, Kenneth Frank 4, 6 05/05/2017 57 11.65 104,000 9,000

Tahoe Resources Inc. Restricted Share Awards Williamson, Kenneth Frank 4, 6 05/05/2017 56 11.65 9,000 9,000

Tahoe Resources Inc. Restricted Share Awards Williamson, Kenneth Frank 4, 6 05/05/2017 57 11.65 0 -9,000

Tamarack Valley Energy Ltd. Common Shares GMT Capital Corp 3 03/05/2017 10 1.82 7,354,040 19,600















Tamarack Valley Energy Ltd. Common Shares GMT Capital Corp 3 03/05/2017 10 1.82 463,940 1,000










Tartisan Resources Corp. Common Shares Appleby, D. Mark 4, 5 11/05/2017 16 0.15 4,227,200 100,000

Tartisan Resources Corp. Warrants For a full share at $0.20 expiring Nov 11 2018

Appleby, D. Mark 4, 5 21/12/2010 00 100,000

Tartisan Resources Corp. Common Shares Palisade Global Investments Ltd.

3 12/05/2017 16 0.15 11,109,000 1,000,000

Tartisan Resources Corp. Warrants Palisade Global Investments Ltd.

3 12/05/2017 16 1,000,000 1,000,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4536



Acquired/ Disposed

Tembo Gold Corp. Common Shares Benstead, Simon Charles 3 11/05/2017 10 0.025 21,125,000 100,000

Temple Hotels Inc. Common Shares SAHI, ANGELA 6 10/05/2017 00

Teranga Gold Corporation Restricted Share Units Chawrun, William Paul 5 05/05/2017 59 0.6652 683,334 -31,539

Teranga Gold Corporation Restricted Share Units Dyal, Navin 5 05/05/2017 59 0.6652 516,667 -31,539

Teranga Gold Corporation Common Shares Mimran, David Jacques 3, 4 21/12/2016 10 0.743 925,000

Teranga Gold Corporation Common Shares Mimran, David Jacques 3, 4 21/12/2016 10 0.743 101,924,500 925,500

Teranga Gold Corporation Common Shares Mimran, David Jacques 3, 4 05/05/2017 37 -82,625,200

Teranga Gold Corporation Common Shares Mimran, David Jacques 3, 4 05/05/2017 37 20,656,400 -82,625,600





Teranga Gold Corporation Restricted Share Units Savarie, David Roger 5 05/05/2017 59 0.6652 516,667 -31,539

Teranga Gold Corporation Common Shares Tablo Corporation 3 21/12/2016 10 0.743 925,000

Teranga Gold Corporation Common Shares Tablo Corporation 3 21/12/2016 10 0.743 101,924,500 925,500

Teranga Gold Corporation Common Shares Tablo Corporation 3 03/05/2017 37 -82,625,200

Teranga Gold Corporation Common Shares Tablo Corporation 3 03/05/2017 37 20,656,400 -82,625,600





Teranga Gold Corporation Restricted Share Units Young, Richard Scott 4, 5 05/05/2017 59 0.6652 933,334 -63,079

Terra Firma Capital Corporation


3 05/05/2017 10 0.64 7,151,918 100,000

Terrace Energy Corp. Common Shares Gibbs, Dave 4 10/05/2017 10 0.02 1,004,915 4,915

TerrAscend Corp. Options HUDSON, REBECCA 5 05/05/2017 00

TerrAscend Corp. Options HUDSON, REBECCA 5 08/05/2017 50 0.95 200,000 200,000

THC BIOMED INTL LTD. Common Shares Chun, Hee Jung 3, 4, 5 09/05/2017 10 0.61 18,330,368 -7,000



The Toronto-Dominion Bank Common Shares CUSIP 891160 50 9

The Toronto-Dominion Bank 1 03/04/2017 38 58.63 1,050,000








The Toronto-Dominion Bank 1 03/04/2017 38 58.63 -1,050,000




The Toronto-Dominion Bank 1 03/04/2017 38 58.63 1,050,000 1,050,000


The Toronto-Dominion Bank 1 03/04/2017 38 58.63 0 -1,050,000

















Insider Reporting

May 18, 2017

(2017), 40 OSCB 4537



Acquired/ Disposed






























































The Toronto-Dominion Bank 1 20/04/2017 38 58.18 653,700 653,700


The Toronto-Dominion Bank 1 20/04/2017 38 58.18 0 -653,700



Insider Reporting

May 18, 2017

(2017), 40 OSCB 4538



Acquired/ Disposed

Thomson Reuters Corporation

Common Shares Sider, Vance A. 5 16/03/2017 30 43.63 122 1


Common Shares Sider, Vance A. 5 31/03/2017 30 36.746 360 238


Common Shares Sider, Vance A. 5 05/05/2017 10 44.75 242 -118


Common Shares Thomson Reuters Corporation

1 27/03/2017 38 59.346 30,100



1 27/03/2017 38 59.346 30,100



1 27/03/2017 38 43.546 29,900



1 27/03/2017 38 43.546 29,900



1 28/03/2017 38 62.067 27,500



1 28/03/2017 38 62.067 27,500



1 03/04/2017 38 57.542 208,800 31,800



1 03/04/2017 38 42.97 237,000 28,200



1 04/04/2017 38 57.733 268,200 31,200



1 04/04/2017 38 43.003 297,000 28,800



1 05/04/2017 38 57.787 328,400 31,400



1 05/04/2017 38 43.074 358,000 29,600



1 06/04/2017 38 57.71 389,500 31,500



1 06/04/2017 38 43.02 419,000 29,500



1 07/04/2017 38 57.546 273,300 31,300



1 07/04/2017 38 42.953 303,000 29,700



1 07/04/2017 38 183,000 -120,000



1 10/04/2017 38 57.459 213,700 30,700



1 10/04/2017 38 43.047 243,000 29,300



1 11/04/2017 38 57.086 273,600 30,600



1 11/04/2017 38 42.794 303,000 29,400



1 12/04/2017 38 57.022 336,900 33,900



1 12/04/2017 38 42.881 370,100 33,200



1 13/04/2017 38 58.991 400,700 30,600



1 13/04/2017 38 42.913 431,100 30,400



1 13/04/2017 38 188,100 -243,000



1 17/04/2017 38 57.223 221,300 33,200



1 17/04/2017 38 43.062 255,200 33,900



1 18/04/2017 38 57.764 282,800 27,600



1 18/04/2017 38 43.161 315,200 32,400

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4539



Acquired/ Disposed



1 19/04/2017 38 58.356 340,200 25,000



1 19/04/2017 38 43.345 369,200 29,000



1 20/04/2017 38 58.071 393,800 24,600



1 20/04/2017 38 43.078 423,200 29,400



1 21/04/2017 38 57.573 453,600 30,400



1 21/04/2017 38 42.621 490,300 36,700



1 21/04/2017 38 -308,200



1 21/04/2017 38 -308,200



1 21/04/2017 38 175,100 -315,200



1 24/04/2017 38 58.193 207,800 32,700



1 24/04/2017 38 43.123 242,200 34,400



1 25/04/2017 38 58.38 275,000 32,800



1 25/04/2017 38 42.945 308,200 33,200



1 26/04/2017 38 58.29 338,500 30,300



1 26/04/2017 38 42.892 369,200 30,700



1 27/04/2017 38 59.346 399,300 30,100



1 27/04/2017 38 43.546 429,200 29,900



1 28/04/2017 38 43.395 455,700 26,500



1 28/04/2017 38 62.067 483,200 27,500



1 28/04/2017 38 175,000 -308,200



1 05/05/2017 38 0 -175,000

Timbercreek Financial Corp. Common Shares Morris, Carrie 5 12/05/2017 10 9.14 8,716 3,350

Timbercreek Financial Corp. Common Shares Tamblyn, Robert Blair 4, 5 09/05/2017 10 9.05 34,578 300

Timbercreek Financial Corp. Common Shares Tamblyn, Robert Blair 4, 5 10/05/2017 10 9.05 35,678 1,100

TMX Group Limited Common Shares Bertrand, Luc 4 11/05/2017 10 72.394 590,000 11,741

Top 20 U.S. Dividend Trust Units Class U Units Top 20 U.S. Dividend Trust 1 13/04/2017 38 10.49 1,000 1,000

Top 20 U.S. Dividend Trust Units Class U Units Top 20 U.S. Dividend Trust 1 13/04/2017 38 10.49 0 -1,000

Torstar Corporation Options Class B non-voting shares

Boynton, John 4 31/03/2017 00

Torstar Corporation Options Class B non-voting shares

Boynton, John 4 09/05/2017 50 1.59 1,428,571 1,428,571

Torstar Corporation Rights Restricted Share Units

Boynton, John 4 31/03/2017 00


Boynton, John 4 09/05/2017 56 295,858


Boynton, John 4 09/05/2017 56 295,858 295,858

Tower One Wireless Corp Options Abdiye, Abbey 5 30/03/2016 00

Tower One Wireless Corp Options Abdiye, Abbey 5 04/05/2017 50 50,000 50,000

TrackX Holdings Inc. Common Shares Harvie, Tim 4, 5 26/05/2016 00

TrackX Holdings Inc. Common Shares Harvie, Tim 4, 5 26/05/2016 00

Trakopolis IoT Corp. Common Shares Cataford, Paul G. 4 04/05/2017 46 199,543 27,753

Trakopolis IoT Corp. Common Shares Clarke, Richard Mark 5 04/05/2017 46 333,333 13,889

Trakopolis IoT Corp. Common Shares Duffield, Edward Logan 5 04/05/2017 46 302,447 11,342

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4540



Acquired/ Disposed

Trakopolis IoT Corp. Common Shares Hotte, Laine Blair 5 04/05/2017 46 63,742 10,957

Trakopolis IoT Corp. Common Shares Moore, Brent 4, 5 04/05/2017 46 827,334 20,833

TransAlta Corporation Options Chakravarti, Nipa 5 07/03/2017 50 7.19 29,545

TransAlta Corporation Options Chakravarti, Nipa 5 07/03/2017 50 7.25 29,545 29,545

TransAlta Renewables Inc. Common Shares Ward, Brent Vincent 5 04/05/2017 00

TransCanada Corporation Common Shares Bowman, Norm Russell 7 01/05/2013 00

TransCanada Corporation Common Shares Bowman, Norm Russell 7 09/05/2017 51 49.03 11,793 11,793

TransCanada Corporation Common Shares Bowman, Norm Russell 7 09/05/2017 10 64.32 10,193 -1,600

TransCanada Corporation Common Shares Bowman, Norm Russell 7 09/05/2017 10 64.31 10,093 -100











TransCanada Corporation Common Shares Bowman, Norm Russell 7 09/05/2017 10 64.16 600 -400





TransCanada Corporation Options Granted Feb. 25, 2014 @ $49.03 CDN Expiry Feb. 25, 2021

Bowman, Norm Russell 7 09/05/2017 51 0 -11,793

TransCanada Corporation Options Granted May 10, 2017 @ $63.83 CDN (expire May 10, 2024)

Chapman III, Stanley G. 5 01/07/2016 00

TransCanada Corporation Options Granted May 10, 2017 @ $63.83 CDN (expire May 10, 2024)

Chapman III, Stanley G. 5 10/05/2017 50 63.83 100,000 100,000

TransCanada Corporation Common Shares Crétier, Stéphan 4 17/02/2017 00

TransCanada Corporation Common Shares Crétier, Stéphan 4 09/05/2017 10 64.14 15,380 15,380

TransCanada Corporation Common Shares Ferguson, Dean K. 7 10/05/2017 51 37.93 9,528 9,228

TransCanada Corporation Common Shares Ferguson, Dean K. 7 10/05/2017 10 64.02 7,428 -2,100

TransCanada Corporation Common Shares Ferguson, Dean K. 7 10/05/2017 10 64.01 7,328 -100

TransCanada Corporation Common Shares Ferguson, Dean K. 7 10/05/2017 51 64 300 -7,028

TransCanada Corporation Options Granted Feb. 18, 2011 @ $37.93 CDN Expiry Feb. 18, 2018

Ferguson, Dean K. 7 10/05/2017 51 0 -9,228

TransCanada Corporation Common Shares Goulet, Corey J. 7 09/05/2017 51 47.09 20,116 18,293

TransCanada Corporation Common Shares Goulet, Corey J. 7 09/05/2017 10 64.17 13,016 -7,100

TransCanada Corporation Common Shares Goulet, Corey J. 7 09/05/2017 10 64.18 2,516 -10,500

TransCanada Corporation Common Shares Goulet, Corey J. 7 09/05/2017 10 64.15 1,823 -693

TransCanada Corporation Common Shares Goulet, Corey J. 7 09/05/2017 30 62.28 4,074 88

TransCanada Corporation Common Shares Goulet, Corey J. 7 09/05/2017 30 62.34 4,151 77

TransCanada Corporation Common Shares Goulet, Corey J. 7 09/05/2017 10 64.18 0 -4,151

TransCanada Corporation Options Granted February 15, 2013 @ $47.09 CDN

Goulet, Corey J. 7 09/05/2017 51 0 -18,293

TransCanada Corporation Common Shares Hanrahan, Wendy 5 11/05/2017 10 63.26 80

TransCanada Corporation Common Shares Hanrahan, Wendy 5 11/05/2017 10 63.26 80

TransCanada Corporation Common Shares Hanrahan, Wendy 5 11/05/2017 10 63.26 9,142 300

TransCanada Corporation Common Shares Hanrahan, Wendy 5 11/05/2017 10 63.29 9,222 80

TransCanada Corporation Common Shares SOINI, JOHN F. 7 09/05/2017 52 56.58 9,767 9,767

TransCanada Corporation Common Shares SOINI, JOHN F. 7 09/05/2017 10 64.14 2,567 -7,200

TransCanada Corporation Common Shares SOINI, JOHN F. 7 09/05/2017 10 64.12 2,467 -100

TransCanada Corporation Common Shares SOINI, JOHN F. 7 09/05/2017 10 64.11 0 -2,467

TransCanada Corporation Common Shares SOINI, JOHN F. 7 09/05/2017 51 48.44 6,070 6,070


Insider Reporting

May 18, 2017

(2017), 40 OSCB 4541



Acquired/ Disposed





TransCanada Corporation Common Shares SOINI, JOHN F. 7 09/05/2017 10 64.04 737 -700







TransCanada Corporation Options Granted Feb 19, 2015 @ $56.58 CDN (expire Feb 19, 2022)

SOINI, JOHN F. 7 09/05/2017 51 4,884 -9,767

TransCanada Corporation Options Granted March 22, 2016 @ $48.44 CDN (expire March 22, 2023)

SOINI, JOHN F. 7 09/05/2017 51 12,141 -6,070

Transition Metals Corp. Options Hart, Thomas Robert 5 02/05/2017 50 0.15 212,500 25,000

Tricon Capital Group Inc. Common Shares Gluskin, Ira 4 10/05/2017 36 331,250 50,000

Tricon Capital Group Inc. Subscription Receipts Gluskin, Ira 4 10/05/2017 36 0 -50,000

Trinidad Drilling Ltd. Common Shares Conway, Brent John 5 12/05/2017 10 125,700 100,000

TriStar Gold Inc. Common Shares Jones, III, Mark E. 4 08/05/2017 10 0.2197 9,875,346 10,000

TriStar Gold Inc. Common Shares Jones, III, Mark E. 4 10/05/2017 10 0.34 9,882,346 7,000

Triumph Gold Corp. Common Shares ANDERSON, JOHN 4 08/05/2017 10 0.39 2,488,000 49,000

Triumph Gold Corp. Common Shares Palisade Global Investments Ltd.

3 08/05/2017 10 0.3815 7,108,000 38,000


3 08/05/2017 10 0.3933 7,138,000 30,000


3 09/05/2017 10 0.37 7,174,500 36,500


3 10/05/2017 10 0.395 7,225,000 50,500


3 12/05/2017 10 0.38 7,228,500 3,500


3 12/05/2017 10 0.395 7,248,500 20,000

True Leaf Medicine International Ltd.

Common Shares Bomford, Darcy E 3, 4, 5 17/03/2017 51 0.1 24,841,347 500,000


Options Bomford, Darcy E 3, 4, 5 17/03/2017 51 328,575 -500,000


Options Spooner, Christopher 4 19/03/2017 52 328,570 -160,000

TSO3 inc. Common Shares Beaudry, Josianne 5 10/05/2017 00

TSO3 inc. Unités d'actions différées/Deferred Share Units

Carrière, Germain 4 11/05/2017 56 2.96 37,467 20,000


Désy, Pierre 4 11/05/2017 56 2.96 21,400 12,666


Lamarre, Jean 4 11/05/2017 56 2.96 21,400 12,666


Michaud, Claude 4 11/05/2017 56 2.96 21,400 12,666

TSO3 inc. Options POMPEO, JEFFREY R. 4 13/02/2017 00

TSO3 inc. Options POMPEO, JEFFREY R. 4 11/05/2017 50 21,875 21,875


POMPEO, JEFFREY R. 4 13/02/2017 00

TSO3 inc. Options Précourt, Karine 5 08/05/2017 00

TSO3 inc. Options Précourt, Karine 5 11/05/2017 50 150,000 150,000


Robert, Jean-Pierre 4 11/05/2017 56 2.96 21,400 12,666

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4542



Acquired/ Disposed

TSO3 inc. Options ROSENSTOCK, LINDA 4 13/02/2017 00

TSO3 inc. Options ROSENSTOCK, LINDA 4 11/05/2017 50 21,875 21,875


West, Steven 4 11/05/2017 56 2.96 21,400 12,666

Tudor Gold Corp. Common Shares Morfopoulos, Aris 5 02/05/2017 10 0.64 34,000 -1,500

UpSnap, Inc. Common Shares UFPB VoodooVox LLC 3 10/05/2017 36 0.02 108,648,751 7,148,750

UpSnap, Inc. Debentures 13.5% coupon UFPB VoodooVox LLC 3 10/05/2017 36 $0 -$100,000

Urbana Corporation Non-Voting Shares Class A

Urbana Corporation 1 19/04/2017 38 3.31 250,000 250,000


Urbana Corporation 1 19/04/2017 38 0 -250,000


Urbana Corporation 1 24/04/2017 38 3.48 86,200 86,200


Urbana Corporation 1 24/04/2017 38 0 -86,200

Valeant Pharmaceuticals International, Inc.

Common Shares DE SCHUTTER, Richard Urbain

4 08/05/2017 57 9.66 25,190 11,190


Common Shares DE SCHUTTER, Richard Urbain

4 08/05/2017 97 9.66 23,042 -2,148


Rights Restricted Share Units (RSUs)

DE SCHUTTER, Richard Urbain

4 05/05/2017 56 38,720 25,406



DE SCHUTTER, Richard Urbain

4 08/05/2017 57 27,530 -11,190


Common Shares Eshelman, Fredric 4 03/05/2017 57 9.66 17,796 16,726


Common Shares Eshelman, Fredric 4 03/05/2017 97 9.66 12,892 -4,904



Eshelman, Fredric 4 03/05/2017 57 16,726



Eshelman, Fredric 4 03/05/2017 57 0 -16,726



Eshelman, Fredric 4 05/05/2017 56 25,406 25,406



Hale, David Robert 4 05/05/2017 56 25,406 25,406



Karabelas, Argeris 4 05/05/2017 56 42,132 25,406



Kavanagh, Sarah Baldwin 4 05/05/2017 56 39,864 25,406



Power, Robert Noel 4 05/05/2017 56 51,627 25,406



Robertson, Russel Clark 4 05/05/2017 56 49,271 25,406



Ross Sr., Thomas 4 05/05/2017 56 25,046



Ross Sr., Thomas 4 05/05/2017 56 43,228 25,406



Wechsler, Amy 4 05/05/2017 56 47,556 25,406

Vermilion Energy Inc. Rights Share Awards Roby, William 4 09/05/2017 56 47.743 7,620 7,620

VIQ Solutions Inc. Common Shares Taylor, Larry Douglas 4 10/05/2017 10 0.2 6,130,200 10,000

VIQ Solutions Inc. Common Shares Taylor, Larry Douglas 4 12/05/2017 10 0.2 6,135,200 5,000

Wallbridge Mining Company Limited

Rights DSU Ellingham, Elaine 4 09/05/2017 56 0.08 988,050 75,000


Rights DSU Farsangi, Parviz 4 09/05/2017 56 0.08 1,181,275 79,688


Rights DSU Galipeau, René Réal 4 09/05/2017 56 0.08 1,551,861 95,313


Rights DSU HOLMES, WILLIAM WARREN

4 09/05/2017 56 0.08 1,860,578 98,438


Rights DSU Horst, Roland 4 09/05/2017 56 0.08 1,365,065 71,875


Rights DSU Sittler, Darryl 4 09/05/2017 56 0.08 1,332,097 59,375

Wescan Goldfields Inc. Options Bay, Harvey James 4, 6 05/05/2017 50 0.08 280,000 80,000

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4543



Acquired/ Disposed

Wescan Goldfields Inc. Options Billingsley, Gary 4 05/05/2017 50 0.08 240,000 80,000

Wescan Goldfields Inc. Options MacNeill, Kenneth Earl 4, 6 05/05/2017 50 0.08 1,750,000 500,000

Wescan Goldfields Inc. Options Michasiw, Val 4 05/05/2017 50 0.8 240,000 80,000

Wescan Goldfields Inc. Options Shimell, Mark 5 05/05/2017 50 0.08 290,000 100,000

Wescan Goldfields Inc. Options Shyluk, Greg 5 05/05/2017 50 0.08 570,000 150,000

Wesdome Gold Mines Ltd. Common Shares Ng, Philip 5 11/05/2017 10 3.33 48,300 -1,700

West Fraser Timber Co. Ltd. Common Shares Pattison, James A. 3 05/05/2017 00 7,926,000

West Kirkland Mining Inc. Common Shares Sun Valley Gold LLC 3 08/05/2017 10 0.08 109,682,400 49,000

West Kirkland Mining Inc. Common Shares Sun Valley Gold Master Fund, Ltd.

3 08/05/2017 10 0.08 109,682,400 49,000

Western Energy Services Corp.

Options Trann, David George 5 10/05/2017 52 273,834 -3,333

Western Forest Products Inc. Deferred Share Units (Cash Settled)

Bird, Jane Marie 4 31/12/2016 56 370


Bird, Jane Marie 4 31/12/2016 30 370


Bird, Jane Marie 4 31/12/2016 30 18,827 370


Cass, Michael 5 31/12/2016 56 667


Cass, Michael 5 31/12/2016 30 667


Cass, Michael 5 31/12/2016 30 17,797 667

Western Forest Products Inc. Performance Share Units (Cash Settled)

Cass, Michael 5 31/12/2016 56 1,449


Cass, Michael 5 31/12/2016 30 1,449


Cass, Michael 5 31/12/2016 30 103,206 1,449


Cass, Michael 5 31/12/2016 56 2,491


Cass, Michael 5 31/12/2016 30 2,491


Cass, Michael 5 31/12/2016 30 105,697 2,491


Demens, Donald Eugene 5 31/12/2016 56 8,314




Demens, Donald Eugene 5 31/12/2016 30 221,827 8,314














Doney, Robert Lee 4 31/12/2016 56 33,823


Doney, Robert Lee 4 31/12/2016 30 33,823


Doney, Robert Lee 4 31/12/2016 30 674,835 33,823


Forgaard, Richard Orval 5 31/12/2016 56 2,267




Forgaard, Richard Orval 5 31/12/2016 30 128,128 2,267

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4544



Acquired/ Disposed






Forgaard, Richard Orval 5 31/12/2016 30 130,735 2,607


Foster, Jennifer Eileen 5 31/12/2016 56 1,875


Foster, Jennifer Eileen 5 31/12/2016 30 1,875


Foster, Jennifer Eileen 5 31/12/2016 30 50,301 1,875


Janzen, Shannon 5 31/12/2016 56 1,287


Janzen, Shannon 5 31/12/2016 30 1,287


Janzen, Shannon 5 31/12/2016 30 78,403 1,287


Janzen, Shannon 5 31/12/2016 56 1,699


Janzen, Shannon 5 31/12/2016 30 1,699


Janzen, Shannon 5 31/12/2016 30 80,102 1,699


Kirkbride, Bradley Dean 5 08/05/2017 56 33,488 33,488

Western Forest Products Inc. Common Shares Nocente, Daniel Louis 4 08/05/2017 10 2.14 50,000

Western Forest Products Inc. Common Shares Nocente, Daniel Louis 4 08/05/2017 10 2.1455 75,000 50,000


Nocente, Daniel Louis 4 31/12/2016 56 1,324


Nocente, Daniel Louis 4 31/12/2016 30 1,324


Nocente, Daniel Louis 4 31/12/2016 30 54,678 1,324


Turnbull, Frank James 5 31/12/2016 56 1,415


Turnbull, Frank James 5 31/12/2016 30 1,415


Turnbull, Frank James 5 31/12/2016 30 37,963 1,415

Western Forest Products Inc. Common Shares Waites, Michael T. 4 09/05/2017 10 2.14 60,000 20,000


Waites, Michael T. 4 31/12/2016 56 2,559


Waites, Michael T. 4 31/12/2016 30 2,559


Waites, Michael T. 4 31/12/2016 30 84,253 2,559


Williams, Stephen D.A. 5 31/12/2016 56 3,006




Williams, Stephen D.A. 5 31/12/2016 30 170,157 3,006






Williams, Stephen D.A. 5 31/12/2016 30 173,626 3,469

WesternOne Inc. Common Shares Greig, Andrew David Gilmour

5 04/05/2017 30 1.4 2,859 15

WesternOne Inc. Common Shares Matheson, Joseph Lee Grant

4 11/08/2016 00


4 11/08/2016 00


4 02/05/2017 97 1,435,287 1,435,287

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4545



Acquired/ Disposed

WesternOne Inc. Convertible Debentures Matheson, Joseph Lee Grant

4 11/08/2016 00

WesternOne Inc. Convertible Debentures Matheson, Joseph Lee Grant

4 02/05/2017 97 $12,561,500 $12,561,500

WestJet Airlines Ltd. Common Shares - Voting Menard, L. Jacques 4 08/05/2017 10 22.38 15,000 5,000

WestJet Airlines Ltd. Common Shares - Voting Menard, L. Jacques 4 12/05/2017 10 22.68 20,000 5,000

WestJet Airlines Ltd. Common Shares - Voting WestJet Airlines Ltd 1 03/05/2017 38 21.726 102,684 102,684

WestJet Airlines Ltd. Common Shares - Voting WestJet Airlines Ltd 1 04/05/2017 38 21.898 193,172 90,488

WestJet Airlines Ltd. Common Shares - Voting WestJet Airlines Ltd 1 12/05/2017 38 0 -193,172

Westshore Terminals Investment Corporation

Common Shares Pattison, James A. 3 04/05/2017 10 23.119 8,821,300 315,200









Wheaton Precious Metals Corp. (formerly Silver Wheaton Corp.)

Common Shares Brough, John 4 12/05/2017 10 27.75 10,325 -425


Common Shares Brough, John 4 12/05/2017 10 27.74 8,825 -1,500


Common Shares Brough, John 4 12/05/2017 10 27.73 8,125 -700


Common Shares Brough, John 4 12/05/2017 10 28.23 5,500 -2,625

White Metal Resources Corp. Common Shares Strashin, Elliot Phillip 3, 4, 5 05/05/2017 16 0.05 3,417,847 200,000

White Metal Resources Corp. Warrants Strashin, Elliot Phillip 3, 4, 5 05/05/2017 16 500,000 100,000

Wi-LAN Inc. Common Shares McEwan, Michael Shaun 5 08/05/2017 10 2.23 71,200 5,200

Wi-LAN Inc. Common Shares McEwan, Michael Shaun 5 08/05/2017 10 2.24 5,600



Wi-LAN Inc. Common Shares Skippen, James 4, 5 11/05/2017 10 2.1 341,800 3,000

Wi-LAN Inc. Common Shares Watchmaker, Prashant 5 08/05/2017 10 2.18 50,100 2,000

WSP Global Inc. Common Shares Carrière, Louis-Philippe 4 10/05/2017 00 1,100

Ximen Mining Corp. Common Shares Warthe-Anderson, Wesley 4 09/05/2017 10 0.055 1,270,500 200,000

Xtreme Drilling Corp. (formerly Xtreme Drilling and Coil Services Corp.)

Options Burnett, Colin 4 08/05/2017 56 2.31 37,409 19,481


Options Charron, Randolph M 4 08/05/2017 56 2.31 37,409 19,481


Options Dafoe, Douglas Allan 4 08/05/2017 56 2.31 107,409 19,481


Options Franklin, Jack William 4 08/05/2017 56 2.31 37,409 19,481


Options Renfroe, James Byron Jr. 4 08/05/2017 56 2.31 97,409 19,481


Options Wehlmann, David Wayne 4 08/05/2017 56 2.31 97,409 19,481

Yamana Gold Inc. Common Shares LeBlanc, Jason 5 05/05/2017 10 3.4196 27,462 21,400

Yamana Gold Inc. Common Shares Racine, Daniel 5 08/05/2017 10 3.4 48,781 20,000

Yamana Gold Inc. Common Shares Tsakos, Sofia 5 05/05/2017 10 3.37 126,530 25,000

Yangaroo Inc. Common Shares Hunt, Clifford Gordon 4, 5 12/05/2017 10 0.155 661,790 30,000

Yangaroo Inc. Common Shares Moss, Gary 5 10/05/2017 10 0.16 258,000 78,000

Yellow Pages Limited Performance Share Unit Billot, Julien 4, 5 10/05/2017 56 7.681 148,092

Insider Reporting

May 18, 2017

(2017), 40 OSCB 4546



Acquired/ Disposed

Yellow Pages Limited Performance Share Unit Billot, Julien 4, 5 10/05/2017 56 7.681 247,348 148,092

Yellow Pages Limited Restricted Share Unit Billot, Julien 4, 5 10/05/2017 56 7.681 119,444 79,742

Yellow Pages Limited Performance Share Unit D'Escrivan, Nathalie 7 10/05/2017 56 7.681 11,197 8,592

Yellow Pages Limited Restricted Share Unit D'Escrivan, Nathalie 7 10/05/2017 56 7.681 11,197 8,592

Yellow Pages Limited Performance Share Unit Gowett, Alexandre 5 10/05/2017 56 7.681 3,188 1,952

Yellow Pages Limited Restricted Share Unit Gowett, Alexandre 5 10/05/2017 56 7.681 3,188 1,952

Yellow Pages Limited Performance Share Unit Paradis, Dany 5 10/05/2017 56 7.681 40,199 22,679

Yellow Pages Limited Restricted Share Unit Paradis, Dany 5 10/05/2017 56 7.681 19,207 12,211

Yellow Pages Limited Performance Share Unit Ramsay, François 5 10/05/2017 56 7.681 63,483 37,403

Yellow Pages Limited Restricted Share Unit Ramsay, François 5 10/05/2017 56 7.681 30,576 20,140

Yellow Pages Limited Performance Share Unit Sciannamblo, Franco 5 10/05/2017 56 7.681 16,319 8,983

Yellow Pages Limited Restricted Share Unit Sciannamblo, Franco 5 10/05/2017 56 7.681 16,684 8,983

Yellow Pages Limited Performance Share Unit Taylor, Kenneth James 5 27/03/2017 00

Yellow Pages Limited Performance Share Unit Taylor, Kenneth James 5 10/05/2017 56 7.681 25,218 25,218

Yellow Pages Limited Restricted Share Unit Taylor, Kenneth James 5 27/03/2017 00

Yellow Pages Limited Restricted Share Unit Taylor, Kenneth James 5 10/05/2017 56 7.681 13,578 13,578

Yellow Pages Limited Performance Share Unit Thomas, Pascal 5 10/05/2017 56 7.681 41,330 25,218

Yellow Pages Limited Restricted Share Unit Thomas, Pascal 5 10/05/2017 56 7.681 20,017 13,578

Yellow Pages Limited Performance Share Unit Vallée, Dominique 7 10/05/2017 56 7.681 38,936 25,387

Yellow Pages Limited Restricted Share Unit Vallée, Dominique 7 10/05/2017 56 7.681 27,219 13,670

Zargon Oil & Gas Ltd. Common Shares Burden, Leslie Edward 5 28/04/2017 30 0.6352 18,725 755

Zargon Oil & Gas Ltd. Common Shares Burden, Leslie Edward 5 28/04/2017 30 0.6352 60,577 1,762

Zargon Oil & Gas Ltd. Common Shares Doetzel, Randolph John 5 28/04/2017 30 0.6352 10,989 2,859

Zargon Oil & Gas Ltd. Common Shares Hansen, Craig Henry 4, 5 28/04/2017 30 0.6352 1,268,510 2,089

Zargon Oil & Gas Ltd. Common Shares Hansen, Craig Henry 4, 5 28/04/2017 30 0.6352 659,947 1,125

Zargon Oil & Gas Ltd. Common Shares Hustad, Christopher Michael 5 28/04/2017 30 0.6352 119,490 2,615

ZipLocal Inc. Common Shares Albright, John 3, 4 18/08/2006 00 16,899,585

ZipLocal Inc. Common Shares Albright, John 3, 4 09/05/2017 37 1,689,959 -15,209,626

ZipLocal Inc. Common Shares Albright, John 3, 4 10/05/2017 36 6,269,532 4,579,573

ZipLocal Inc. Common Shares Inwentash, Sheldon 4 03/12/2007 00

ZipLocal Inc. Common Shares Inwentash, Sheldon 4 10/05/2017 36 0.044 5,723,237 5,723,237

ZipLocal Inc. Convertible Debentures maturing April 5, 2014

Inwentash, Sheldon 4 10/05/2017 36 0 -250

ZipLocal Inc. Common Shares Relay Ventures Fund LP 3 09/05/2017 37 1,689,959 -15,209,626

ZipLocal Inc. Common Shares Relay Ventures Fund LP 3 10/05/2017 00 16,899,585

ZipLocal Inc. Common Shares Relay Ventures Fund LP 3 10/05/2017 36 6,269,532 4,579,573

May 18, 2017

(2017), 40 OSCB 4547

Chapter 11

IPOs, New Issues and Secondary Financings

INVESTMENT FUNDS

Issuer Name: Global REIT Leaders Income ETF Tech Achievers Growth & Income ETF Principal Regulator - Ontario Type and Date: Combined Preliminary and Pro Forma Long Form Prospectus dated May 11, 2017 NP 11-202 Preliminary Receipt dated May 12, 2017 Offering Price and Description: Class A and Class U Units Underwriter(s) or Distributor(s): - Promoter(s): Harvest Portfolios Group Inc. Project #2625876 _______________________________________________ Issuer Name: First Trust AlphaDEX U.S. Consumer Discretionary Sector Index ETF. First Trust AlphaDEX U.S. Consumer Staples Sector Index ETF First Trust AlphaDEX U.S. Energy Sector Index ETF First Trust AlphaDEX U.S. Financial Sector Index ETF First Trust AlphaDEX U.S. Health Care Sector Index ETF First Trust AlphaDEX U.S. Industrials Sector Index ETF First Trust AlphaDEX U.S. Materials Sector Index ETF First Trust AlphaDEX U.S. Technology Sector Index ETF First Trust AlphaDEX U.S. Utilities Sector Index ETF Principal Regulator - Ontario Type and Date: Combined Preliminary and Pro Forma Long Form Prospectus dated May 8, 2017 NP 11-202 Preliminary Receipt dated May 9, 2017 Offering Price and Description: Hedged Units Underwriter(s) or Distributor(s): - Promoter(s): FT Portfolios Canada CO. Project #2623461 _______________________________________________

Issuer Name: Gateway Low Volatility U.S. Equity Fund Loomis Sayles Strategic Monthly Income Fund Oakmark International Natixis Registered Fund Oakmark International Natixis Tax Managed Fund Oakmark Natixis Registered Fund Oakmark Natixis Tax Managed Fund Loomis Sayles Global Diversified Corporate Bond Fund Loomis Sayles Global Diversified Corporate Bond Tax Managed Fund Natixis Strategic Balanced Registered Fund Natixis Strategic Balanced Tax Managed Fund NexGen Canadian Bond Fund NexGen Canadian Bond Tax Managed Fund NexGen Canadian Cash Fund NexGen Canadian Dividend Registered Fund NexGen Canadian Dividend Tax Managed Fund NexGen Canadian Preferred Share Registered Fund NexGen Canadian Preferred Share Tax Managed Fund NexGen Global Equity Registered Fund NexGen Global Equity Tax Managed Fund NexGen Intrinsic Balanced Registered Fund NexGen Intrinsic Balanced Tax Managed Fund NexGen Intrinsic Growth Registered Fund NexGen Intrinsic Growth Tax Managed Fund NexGen U.S. Dividend Plus Registered Fund NexGen U.S. Dividend Plus Tax Managed Fund NexGen U.S. Growth Registered Fund NexGen U.S. Growth Tax Managed Fund Principal Regulator - Ontario Type and Date: Combined Preliminary and Pro Forma Simplified Prospectus dated May 9, 2017 NP 11-202 Preliminary Receipt dated May 15, 2017 Offering Price and Description: Series A Securities Underwriter(s) or Distributor(s): NGAM Canada LP Promoter(s): NGAM Canada LP Project #2625118 _______________________________________________


May 18, 2017

(2017), 40 OSCB 4548

Issuer Name: INVESCO CANADIAN BALANCED FUND INVESCO CANADIAN BOND CLASS INVESCO CANADIAN BOND FUND INVESCO CANADIAN PREMIER GROWTH CLASS INVESCO CANADIAN PREMIER GROWTH FUND INVESCO CORE CANADIAN BALANCED CLASS INVESCO EMERGING MARKETS DEBT FUND INVESCO EUROPEAN GROWTH CLASS INVESCO FLOATING RATE INCOME FUND INVESCO GLOBAL BOND FUND INVESCO GLOBAL GROWTH CLASS INVESCO GLOBAL HIGH YIELD BOND FUND INVESCO GLOBAL REAL ESTATE FUND INVESCO INDO-PACIFIC FUND INVESCO INTACTIVE 2023 PORTFOLIO INVESCO INTACTIVE 2028 PORTFOLIO INVESCO INTACTIVE 2033 PORTFOLIO INVESCO INTACTIVE 2038 PORTFOLIO INVESCO INTACTIVE BALANCED GROWTH PORTFOLIO INVESCO INTACTIVE BALANCED GROWTH PORTFOLIO CLASS INVESCO INTACTIVE BALANCED INCOME PORTFOLIO INVESCO INTACTIVE BALANCED INCOME PORTFOLIO CLASS INVESCO INTACTIVE DIVERSIFIED INCOME PORTFOLIO INVESCO INTACTIVE DIVERSIFIED INCOME PORTFOLIO CLASS INVESCO INTACTIVE GROWTH PORTFOLIO INVESCO INTACTIVE GROWTH PORTFOLIO CLASS INVESCO INTACTIVE MAXIMUM GROWTH PORTFOLIO INVESCO INTACTIVE MAXIMUM GROWTH PORTFOLIO CLASS INVESCO INTACTIVE STRATEGIC YIELD PORTFOLIO INVESCO INTERNATIONAL GROWTH CLASS INVESCO INTERNATIONAL GROWTH FUND INVESCO SELECT CANADIAN EQUITY FUND INVESCO SHORT-TERM BOND FUND INVESCO SHORT-TERM INCOME CLASS TRIMARK CANADIAN CLASS TRIMARK CANADIAN ENDEAVOUR FUND TRIMARK CANADIAN FUND TRIMARK CANADIAN OPPORTUNITY CLASS TRIMARK CANADIAN OPPORTUNITY FUND TRIMARK CANADIAN PLUS DIVIDEND CLASS TRIMARK CANADIAN SMALL COMPANIES FUND ( TRIMARK DIVERSIFIED YIELD CLASS TRIMARK EMERGING MARKETS CLASS TRIMARK ENERGY CLASS TRIMARK EUROPLUS FUND TRIMARK FUND TRIMARK GLOBAL BALANCED CLASS TRIMARK GLOBAL BALANCED FUND TRIMARK GLOBAL DIVERSIFIED INCOME FUND TRIMARK GLOBAL DIVIDEND CLASS TRIMARK GLOBAL ENDEAVOUR CLASS TRIMARK GLOBAL ENDEAVOUR FUND TRIMARK GLOBAL FUNDAMENTAL EQUITY CLASS TRIMARK GLOBAL FUNDAMENTAL EQUITY FUND TRIMARK GLOBAL SMALL COMPANIES CLASS TRIMARK INCOME GROWTH FUND

TRIMARK INTERNATIONAL COMPANIES CLASS TRIMARK INTERNATIONAL COMPANIES FUND TRIMARK RESOURCES FUND TRIMARK SELECT BALANCED FUND TRIMARK U.S. COMPANIES CLASS TRIMARK U.S. COMPANIES FUND TRIMARK U.S. SMALL COMPANIES CLASS INVESCO ADVANTAGE BOND FUND Principal Regulator - Ontario Type and Date: Amendment #3 to Final Simplified Prospectus dated May 9, 2017 Receipt dated on May 12, 2017 Offering Price and Description: - Underwriter(s) or Distributor(s): N/A Promoter(s): - Project #2494482 _______________________________________________ Issuer Name: Timbercreek Global Real Estate Income Fund Principal Regulator - Ontario Type and Date: Combined Preliminary and Pro Forma Simplified Prospectus dated May 9, 2017 NP 11-202 Preliminary Receipt dated May 10, 2017 Offering Price and Description: Series AX, Series FX, Series I, Series AY, Series FY, Series A and Series F Underwriter(s) or Distributor(s): - Promoter(s): - Project #2623910 _______________________________________________


May 18, 2017

(2017), 40 OSCB 4549

Issuer Name: BMO Private Canadian Core Equity Portfolio (formerly, BMO Private Canadian Conservative Equity Portfolio) BMO Private Canadian Corporate Bond Portfolio BMO Private Canadian Income Equity Portfolio BMO Private Canadian Mid-Term Bond Portfolio BMO Private Canadian Money Market Portfolio BMO Private Canadian Short-Term Bond Portfolio BMO Private Canadian Special Equity Portfolio BMO Private Diversified Yield Portfolio BMO Private Emerging Markets Equity Portfolio BMO Private International Equity Portfolio BMO Private U.S. Equity Portfolio BMO Private U.S. Growth Equity Portfolio BMO Private U.S. Special Equity Portfolio Principal Regulator - Ontario Type and Date: Final Simplified Prospectus dated May 5, 2017 NP 11-202 Receipt dated May 11, 2017 Offering Price and Description: Units Underwriter(s) or Distributor(s): BMO Private Investment Counsel Inc. Promoter(s): BMO PRIVATE INVESTMENT COUNSEL INC. Project #2608471 _______________________________________________

Issuer Name: Brandes Canadian Equity Fund Brandes Canadian Money Market Fund Brandes Corporate Focus Bond Fund Brandes Emerging Markets Value Fund (formerly Brandes Emerging Markets Equity Fund) Brandes Global Balanced Fund Brandes Global Equity Fund Brandes Global Opportunities Fund Brandes Global Small Cap Equity Fund Brandes International Equity Fund Brandes U.S. Equity Fund Brandes U.S. Small Cap Equity Fund Greystone Canadian Bond Fund Greystone Canadian Equity Income & Growth Fund Greystone Global Equity Fund Lazard Emerging Markets Multi Asset Fund Lazard Global Balanced Income Fund Lazard Global Equity Income Fund Lazard Global Low Volatility Fund Morningstar Aggressive Portfolio Morningstar Balanced Portfolio Morningstar Conservative Portfolio Morningstar Growth Portfolio Morningstar Moderate Portfolio Morningstar Strategic Canadian Equity Fund Sionna Canadian Balanced Fund (formerly Brandes Sionna Canadian Balanced Fund) Sionna Canadian Equity Fund (formerly Brandes Sionna Canadian Equity Fund) Sionna Canadian Small Cap Equity Fund (formerly Brandes Sionna Canadian Small Cap Equity Fund) Sionna Diversified Income Fund (formerly Brandes Sionna Diversified Income Fund) Sionna Monthly Income Fund (formerly Brandes Sionna Monthly Income Fund) Sionna Opportunities Fund Principal Regulator - Ontario Type and Date: Final Simplified Prospectus dated May 2, 2017 NP 11-202 Receipt dated May 12, 2017 Offering Price and Description: - Underwriter(s) or Distributor(s): - Promoter(s): Brandes Investment Partners & Co. Project #2596252 _______________________________________________


May 18, 2017

(2017), 40 OSCB 4550

Issuer Name: Canadian Scholarship Trust Family Savings Plan Canadian Scholarship Trust Individual Savings Plan Canadian Scholarship Trust Group Savings Plan 2001 Principal Regulator - Ontario Type and Date: Final Long Form Prospectus dated May 9, 2017 NP 11-202 Receipt dated May 11, 2017 Offering Price and Description: Units Underwriter(s) or Distributor(s): C.S.T. CONSULTANTS INC. Promoter(s): - Project #2596415 _______________________________________________ Issuer Name: Canadian Scholarship Trust Group Savings Plan 2001 Canadian Scholarship Trust Family Savings Plan Canadian Scholarship Trust Individual Savings Plan Principal Regulator - Ontario Type and Date: Final Long Form Prospectus dated May 9, 2017 NP 11-202 Receipt dated May 11, 2017 Offering Price and Description: Units Underwriter(s) or Distributor(s): C.S.T. CONSULTANTS INC. Promoter(s): - Project #2596418 _______________________________________________ Issuer Name: Canadian Scholarship Trust Individual Savings Plan Canadian Scholarship Trust Group Savings Plan 2001 Canadian Scholarship Trust Family Savings Plan Principal Regulator - Ontario Type and Date: Final Long Form Prospectus dated May 9, 2017 NP 11-202 Receipt dated May 11, 2017 Offering Price and Description: - Underwriter(s) or Distributor(s): C.S.T. CONSULTANTS INC. Promoter(s): - Project #2596417 _______________________________________________

Issuer Name: Educators Balanced Fund Educators Bond Fund Educators Dividend Fund Educators Growth Fund Educators Money Market Fund Educators Monthly Income Fund Educators Mortgage & Income Fund Educators North American Diversified Fund Principal Regulator - Ontario Type and Date: Final Simplified Prospectus dated May 12, 2017 NP 11-202 Receipt dated May 15, 2017 Offering Price and Description: Class A units Underwriter(s) or Distributor(s): Educators Financial Group Inc. Promoter(s): - Project #2609937 _______________________________________________ Issuer Name: Excel India Balanced Fund Principal Regulator - Ontario Type and Date: Amendment #1 dated April 17, 2017 to Final Simplified Prospectus NP 11-202 Receipt dated May 8, 2017 Offering Price and Description: Series A, Series F, Series N and Series X Units Underwriter(s) or Distributor(s): Excel Funds Management Inc. Promoter(s): Excel Funds Management Inc. Project #2530422 _______________________________________________ Issuer Name: Excel Emerging Markets Fund Principal Regulator - Ontario Type and Date: Amendment #2 dated April 28, 2017 to Final Simplified Prospectus NP 11-202 Receipt dated May 9, 2017 Offering Price and Description: Series A, Series F, Series D, Series N and Institutional Series Units @ Net Asset Value Underwriter(s) or Distributor(s): Excel Funds Management Inc. Promoter(s): Excel Funds Management Inc. Project #2530422 ______________________________________________


May 18, 2017

(2017), 40 OSCB 4551

Issuer Name: First Asset Long Duration Fixed Income ETF First Asset Preferred Share ETF Principal Regulator - Ontario Type and Date: Final Long Form Prospectus dated May 10, 2017 NP 11-202 Receipt dated May 11, 2017 Offering Price and Description: Units Underwriter(s) or Distributor(s): - Promoter(s): FIRST ASSET INVESTMENT MANAGEMENT INC. Project #2608447 to Final Simplified Prospectus _______________________________________________ Issuer Name: Oakmark International Natixis Registered Fund Oakmark International Natixis Tax Managed Fund Principal Regulator - Ontario Type and Date: Amendment #4 to Final Simplified Prospectus dated April 24, 2017 NP 11-202 Receipt dated May 15, 2017 Offering Price and Description: - Underwriter(s) or Distributor(s): NGAM Canada LP Promoter(s): - Project #2516019 _______________________________________________ Issuer Name: GOODWOOD CAPITAL FUND Principal Regulator - Ontario Type and Date: Final Simplified Prospectus dated May 12, 2017 NP 11-202 Receipt dated May 15, 2017 Offering Price and Description: Class A and F units Underwriter(s) or Distributor(s): - Promoter(s): - Project #2601833 _______________________________________________ Issuer Name: MM Fund Type and Date: Final Simplified Prospectus dated May 12, 2017 Receipted on May 15, 2017 Offering Price and Description: Series A, Series D and Series F Units Underwriter(s) or Distributor(s): Spartan Fund Management Inc. Promoter(s): - Project #2609016 _______________________________________________


May 18, 2017

(2017), 40 OSCB 4552

NON-INVESTMENT FUNDS

Issuer Name: Enbridge Inc. Principal Regulator - Alberta Type and Date: Preliminary Shelf Prospectus dated May 12, 2017 NP 11-202 Preliminary Receipt dated May 12, 2017 Offering Price and Description: $3,000,000,000.00 - MEDIUM TERM NOTES (UNSECURED) Underwriter(s) or Distributor(s): - Promoter(s): - Project #2626637 _______________________________________________ Issuer Name: Firm Capital American Realty Partners Corp. (formerly Delavaco Residential Properties Corp.) Principal Regulator - Ontario Type and Date: Preliminary Short Form Prospectus dated May 10, 2017 NP 11-202 Preliminary Receipt dated May 10, 2017 Offering Price and Description: Price: U.S.$7.50 per Unit C$10.24 per Unit Offering Price: U.S. $7.50 per Offered Unit C$10.24 per Offered Unit Underwriter(s) or Distributor(s): Canaccord Genuity Corp. Promoter(s): - Project #2624585 _______________________________________________ Issuer Name: Glacier Credit Card Trust Principal Regulator - Ontario Type and Date: Preliminary Shelf Prospectus dated May 12, 2017 NP 11-202 Preliminary Receipt dated May 15, 2017 Offering Price and Description: Up to $2,000,000,000.00 Credit Card Asset-Backed Notes Underwriter(s) or Distributor(s): BMO NESBITT BURNS INC. CIBC WORLD MARKETS INC. CITIGROUP GLOBAL MARKETS CANADA INC. DESJARDINS SECURITIES INC. HSBC SECURITIES (CANADA) INC. MUFG SECURITIES (CANADA), LTD. NATIONAL BANK FINANCIAL INC. RBC DOMINION SECURITIES INC. SCOTIA CAPITAL INC.. TD SECURITIES INC. Promoter(s): Canadian Tire Bank Project #2626460 _______________________________________________

Issuer Name: goeasy Ltd. (formerly, easyhome Ltd.) Principal Regulator - Ontario Type and Date: Preliminary Shelf Prospectus dated May 12, 2017 NP 11-202 Preliminary Receipt dated May 12, 2017 Offering Price and Description: $200,000,000.00 - Debt Securities, Preference Shares, Common Shares, Subscription Receipts, Warrants, Units Underwriter(s) or Distributor(s): - Promoter(s): - Project #2626254 _______________________________________________ Issuer Name: Industrial Alliance Insurance and Financial Services inc. Principal Regulator - Quebec Type and Date: Preliminary Shelf Prospectus dated May 11, 2017 NP 11-202 Preliminary Receipt dated May 11, 2017 Offering Price and Description: $2,000,000,000.00 - , Debt Securities, Class A Preferred Shares, Common Shares, Subscription Receipts, Warrants, Share Purchase Contracts, Units Underwriter(s) or Distributor(s): - Promoter(s): - Project #2625564 _______________________________________________ Issuer Name: Kinder Morgan Canada Limited Principal Regulator - Alberta Type and Date: Amended and Restated Preliminary Long Form Prospectus dated May 10, 2017 NP 11-202 Preliminary Receipt dated May 10, 2017 Offering Price and Description: $1,750,000,000.00 - * Restricted Voting Shares Price: $* per Restricted Voting Share Underwriter(s) or Distributor(s): TD Securities Inc. RBC Dominion Securities Inc. CIBC WORLD MARKETS INC. SCOTIA CAPITAL INC. BMO NESBITT BURNS INC. NATIONAL BANK FINANCIAL INC. BARCLAYS CAPITAL CANADA INC. CREDIT SUISSE SECURITIES (CANADA) INC. J.P. MORGAN SECURITIES CANADA INC. MERRILL LYNCH CANADA INC. MUFG SECURITIES (CANADA), LTD. SOCIETE GENERALE CAPITAL CANADA INC. Promoter(s): Kinder Morgan, Inc. Project #2614242 _______________________________________________


May 18, 2017

(2017), 40 OSCB 4553

Issuer Name: Marathon Gold Corporation Principal Regulator - Ontario Type and Date: Preliminary Short Form Prospectus dated May 9, 2017 NP 11-202 Preliminary Receipt dated May 9, 2017 Offering Price and Description: $16,180,000.00 - 6,000,000 Common Shares; Price $1.03 per Offered Share 8,000,000 Flow-Through Common Shares; Price $1.25 per FT Share Underwriter(s) or Distributor(s): RBC DOMINION SECURITIES INC. HAYWOOD SECURITIES INC. BEACON SECURITIES LIMITED CANACCORD GENUITY CORP. PARADIGM CAPITAL INC. RAYMOND JAMES LTD. Promoter(s): - Project #2621650 _______________________________________________ Issuer Name: Value Capital Trust Principal Regulator - Alberta Type and Date: Preliminary CPC Prospectus dated May 12, 2017 NP 11-202 Preliminary Receipt dated May 15, 2017 Offering Price and Description: $500,000.00 - 5,000,000 Trust Units Price: $0.10 per Trust Unit Underwriter(s) or Distributor(s): Echelon Wealth Partners Inc. Promoter(s): Nathan Smith Project #2626737 _______________________________________________ Issuer Name: Gibraltar Growth Corporation Principal Regulator - Ontario Type and Date: Final Long Form Prospectus dated May 12, 2017 NP 11-202 Receipt dated May 12, 2017 Offering Price and Description: - Underwriter(s) or Distributor(s): - Promoter(s): Gibraltar Opportunity, Inc. Fred Mannella Kei Izawa Project #2612002 _______________________________________________

Issuer Name: iLOOKABOUT Corp. Principal Regulator - Ontario Type and Date: Final Short Form Prospectus dated May 10, 2017 NP 11-202 Receipt dated May 11, 2017 Offering Price and Description: $5,000,000.00 - 20,000,000 Common Shares, Price: $0.25 per Common Share Underwriter(s) or Distributor(s): Canaccord Genuity Corp. Beacon Securities Limited Desjardins Securities Inc. Promoter(s): - Project #2621212 _______________________________________________ Issuer Name: Nevada Zinc Corporation Principal Regulator - Ontario Type and Date: Final Short Form Prospectus dated May 15, 2017 NP 11-202 Receipt dated May 15, 2017 Offering Price and Description: CDN $2,000,000.00 - 5,714,286 Units, CDN $0.35 per Unit Underwriter(s) or Distributor(s): Canaccord Genuity Corp. Promoter(s): - Project #2610039 _______________________________________________ Issuer Name: TransCanada Trust Principal Regulator - Alberta Type and Date: Final Short Form Prospectus dated May 12, 2017 NP 11-202 Receipt dated May 15, 2017 Offering Price and Description: $1,250,000,000.00 - Trust Notes —Series 2017-B Due ●, 2077 (Trust Notes — Series 2017-B) Underwriter(s) or Distributor(s): TD Securities Inc. BMO Nesbitt Burns Inc. CIBC World Markets Inc. RBC Dominion Securities Inc. Scotia Capital Inc. National Bank Financial Inc. Promoter(s): - Project #2623252 _______________________________________________


May 18, 2017

(2017), 40 OSCB 4554

Issuer Name: Treasury Metals Inc. Principal Regulator - Ontario Type and Date: Final Short Form Prospectus dated May 10, 2017 NP 11-202 Receipt dated May 10, 2017 Offering Price and Description: Offering: $8,060,000.00 or 12,400,000 Units, Price: $0.65 per Unit Underwriter(s) or Distributor(s): Haywood Securities Inc. PI Financial Corp. Promoter(s): - Project #2613300 _______________________________________________ Issuer Name: Trisura Group Ltd. Principal Regulator - Ontario Type and Date: Final Long Form Prospectus dated May 12, 2017 NP 11-202 Receipt dated May 15, 2017 Offering Price and Description: 5,800,000 Common Shares Underwriter(s) or Distributor(s): - Promoter(s): - Project #2583257 _______________________________________________

May 18, 2017

(2017), 40 OSCB 4555

Chapter 12

Registrations 12.1.1 Registrants

Type Company Category of Registration Effective Date

Name Change

From: Front Street Capital 2004 To: LOGiQ Capital 2016

Investment Fund Manager, Portfolio Manager and Exempt Market Dealer

December 19, 2016

Name Change

From: Federal Way Asset Management LP To: Aptitude Investment Management LP

Investment Fund Manager, Portfolio Manager and Exempt Market Dealer

April 7, 2017

Registrations

May 18, 2017

(2017), 40 OSCB 4556


May 18, 2017

(2017), 40 OSCB 4557

Chapter 13

SROs, Marketplaces, Clearing Agencies and Trade Repositories

13.1 SROs 13.1.1 IIROC – Amendments to Dealer Member Rules and Form 1 Relating to the Futures Market Segregation and

Portability Customer-Protection Regime – Request for Comment

REQUEST FOR COMMENT

INVESTMENT INDUSTRY REGULATORY ORGANIZATION OF CANADA (IIROC)

AMENDMENTS TO DEALER MEMBER RULES AND FORM 1 RELATING TO THE FUTURES MARKET SEGREGATION AND PORTABILITY CUSTOMER-PROTECTION REGIME

IIROC is publishing for public comment amendments to its Dealer Member Rules (DMR) and Form 1 relating to futures markets’ segregation and portability customer-protection regimes (the Proposed Amendments). The Proposed Amendments are intended to facilitate the adoption of a gross customer margin (GCM) segregation and portability regime by central clearing counterparties (CCPs) that serve the domestic futures markets. The primary objective of the Proposed Amendments is to codify DMR requirements that restrict linkages between a Dealer Member’s futures business and its other business lines that are not subject to the futures markets’ GCM segregation and portability regimes. A copy of the IIROC Notice and Request for Comment (IIROC Notice), which includes the text of the Proposed Amendments, was also published on our website at http://www.osc.gov.on.ca. Among other things, the IIROC Notice provides background to the futures markets’ GCM segregation and portability regimes and the policy rationale for the Proposed Amendments. It also describes possible subsequent DMR amendments for future rule-making phases in response to ongoing development and implementation of GCM segregation and portability regimes by the CCPs serving the domestic futures markets and related policy issues. The IIROC comment period ends on August 16, 2017. For additional context, please also see CSA Staff Notice 24-315 Update on Enhanced Segregation and Portability Initiatives for Clearing Agencies Serving the Domestic Futures Markets dated February 9, 2017 available on our website at https://www.osc.gov.on.ca/en/SecuritiesLaw_csa_20170209_24-315_enhanced-segregation.htm.


May 18, 2017

(2017), 40 OSCB 4558

13.2 Marketplaces 13.2.1 NEX SEF Limited – Application for Exemption from Recognition as an Exchange – Notice and Request for

Comment

NOTICE AND REQUEST FOR COMMENT

APPLICATION BY NEX SEF LIMITED FOR EXEMPTION FROM RECOGNITION AS AN EXCHANGE A. Background NEX SEF Limited (NEX SEF) has applied to the Commission for an exemption from the requirement to be recognized as an exchange pursuant to section 21 of the Securities Act (Ontario) (OSA). NEX SEF operates a marketplace for trading swaps that is regulated by the Financial Conduct Authority of the United Kingdom (FCA) and the United States Commodity Futures Trading Commission (CFTC). NEX SEF offers trading of foreign exchange (FX) non-deliverable forwards which are regulated as swaps by the CFTC. NEX SEF will enable clients to access its trading platform directly to either enter transactions on their behalf or on behalf of a participant as an introducing broker. In addition, NEX SEF intends to provide direct access to trading on its marketplace to participants located in Ontario, and therefore are considered to be carrying on business in Ontario (Ontario Participants). As NEX SEF will be carrying on business in Ontario, it is required to be recognized as an exchange under the OSA or apply for an exemption from this requirement. NEX SEF has applied for an exemption from the recognition requirements on the basis that it is already subject to regulatory oversight by the CFTC. B. Application and Draft Exemption Order In the application, NEX SEF has outlined how it meets the criteria for exemption from recognition. The specific criteria can be found in Appendix 1 of the draft exemption order. Subject to comments received, staff intend to recommend that the Commission grant an exemption order with terms and conditions based on the draft exemption order. The application and draft exemption order are available on our website at www.osc.gov.on.ca. D. Comment Process The Commission is publishing for public comment the NEX SEF application and the draft exemption order. We are seeking comment on all aspects of the application and draft exemption order. Please provide your comments in writing, via e-mail, on or before June 19, 2016, to the attention of: Ontario Securities Commission 20 Queen Street West 22nd Floor Toronto, Ontario M5H 3S8 Fax: 416-593-2318 Email: [email protected] The confidentiality of submissions cannot be maintained as the comment letters and a summary of written comments received during the comment period will be published. Questions on may be referred to: Louis-Philippe Pellegrini Legal Counsel, Market Regulation Email: [email protected] Timothy Baikie Senior Legal Counsel, Market Regulation Email: [email protected] Jalil El Moussadek Risk Specialist, Market Regulation Email: [email protected]


May 18, 2017

(2017), 40 OSCB 4559

ANNEX I

NEX SEF LIMITED

APPLICATION FOR EXEMPTION FROM RECOGNITION AS AN EXCHANGE May 1, 2017 Ontario Securities Commission 20 Queen Street West, 19th Floor Toronto, Ontario M5H 3S8 Attention: Secretary Re: NEX SEF Limited – Application for Exemption from Recognition as an Exchange Dear Sirs and Mesdames Pursuant to section 147 of the Securities Act (Ontario) (the “Act”), NEX SEF Limited (the “Applicant”) is requesting a decision exempting the Applicant from the requirement to be recognized as an exchange under subsection 21(1) of the Act (the “Exchange Relief”) in relation to its operations in the province. This application is divided into the following Parts I to V, Part III of which describes how the Applicant satisfies criteria for exemption of a foreign exchange that allows customers to trade OTC derivatives from recognition as an exchange set by staff of the Ontario Securities Commission (the “Commission”). Part I Introduction

1. Services to Ontario Residents

Part II Background to the Applicant

1. Ownership of the Applicant

2. Products Traded on the Applicant’s Swap Execution Facility

3. Participants

Part III Application of Exemption Criteria to the Applicant

1. Regulation of the Exchange

2. Governance

3. Regulation of Products

4. Access

5. Regulation of Participants on the Exchange

6. Rulemaking

7. Due Process

8. Clearing and Settlement

9. Systems and Technology

10. Financial Viability

11. Trading Practices

12. Compliance, Surveillance and Enforcement

13. Record Keeping

14. Outsourcing

15. Fees

16. Information Sharing and Oversight Arrangements

17. IOSCO Principles

Part IV Submissions

Part V Consent to Publication


May 18, 2017

(2017), 40 OSCB 4560

PART I INTRODUCTION 1. Description of the Applicant’s Services 1.1 The Applicant operates a marketplace (the “Facility”) for trading swaps that is regulated by the Financial Conduct

Authority of the United Kingdom (the “FCA”) and the Commodity Futures Trading Commission (“CFTC”). The Applicant’s Facility offers trading of foreign exchange (“FX”) non-deliverable forwards which are regulated as swaps by the CFTC. Additional products may be added in the future, subject to obtaining any required regulatory approvals. The Applicant’s Facility enables participants to engage in transactions using the trading methodologies described in Chapter 3 of the Applicant’s rulebook (the “Rulebook”), available online at www.nexsef.com. Transactions can occur using the Applicant’s order book, which functions as an electronic central limit order book and provides the highest priority to bids/offers. Additional trading functionality may be added in the future, subject to obtaining any required regulatory approvals.

1.2 The Applicant will offer direct access to trading on its Facility to participants that are located in Ontario (“Ontario

Participants”) and that satisfy criteria for an “eligible contract participants” (“ECP”) as defined in section 1a(18) of the U.S. Commodity Exchange Act (the “CEA”) and qualify as an “eligible counterparty” (“EC”) or “professional customer” (“PC”) as defined in sections 3.5 and 3.6, respectively, of the FCA Conduct of Business Sourcebook and as further described in Part III below. Ontario Participants may include Canadian financial institutions, registered dealers and advisers, government entities, pension funds and other well capitalized non-regulated entities.

1.3 The Applicant has no physical presence in Ontario and does not otherwise carry on business in Ontario except as

described herein. PART II BACKGROUND TO THE APPLICANT 1. Ownership of the Applicant 1.1 The Applicant is a limited company organized under the laws of England and Wales. The ultimate parent company of

the Applicant is NEX Group plc, a company listed on the London Stock Exchange (“LSE”). 1.2 NEX Group plc is a leading provider of electronic markets and post-trade risk mitigation businesses. NEX Group plc is

the result of a merger transaction between ICAP plc and Tullett Prebon plc announced on November 11, 2015 and completed on December 30, 2016. In the transaction, ICAP plc transferred its global broking business to Tullet Prebon, while the remaining ICAP entities, including the Applicant, re-branded as NEX Group.

2. Products Traded on the Applicant’s Facility 2.1 The Applicant will provide its customers with trading and execution services for non-deliverable forwards. A full list of

the products traded on the Applicant’s Facility can be found on the Applicant’s website, at www.nexsef.com. 3. Participants 3.1 The Applicant’s Facility will enable clients to access the Facility directly either to enter transactions on their own behalf

or on behalf of other participants as an introducing broker. Clients seeking direct access to the Facility as a participant , including those who want to trade on behalf of their Customers, must apply to become a “Trading Privilege Holder” on the Facility and enter into a Trading Privilege Holder Agreement with the Applicant. For the purposes of this application, Trading Privilege Holders will be referred to as “participants”.

3.2 Participants include a wide range of sophisticated customers, including commercial and investment banks,

corporations, proprietary trading firms, hedge funds and other institutional customers. Each customer of the Applicant that wishes to trade directly on the Applicant’s Facility must qualify as an ECP and qualify as an EC or PC.

3.3 Facility participant criteria is described more fully in Part III, Section 4.1 below. PART III APPLICATION OF EXEMPTION CRITERIA TO THE APPLICANT The following is a discussion of how the Applicant meets the criteria of the Commission for exemption of a foreign exchange that allows participants to trade OTC derivatives from recognition as an exchange.


May 18, 2017

(2017), 40 OSCB 4561

1. Regulation of the Exchange 1.1 Regulation of the Exchange – The exchange is regulated in an appropriate manner in another jurisdiction by a

foreign regulator (Foreign Regulator). 1.1.1 The Applicant is regulated by the FCA and is authorised, among other things, to carry on activities of a derivatives

exchange, including: (i) arrange (bring about) deals in investments (ii) deal in investments as agent (iii) make arrangements with a view to transactions in investments; and (iv) operate a multilateral trading facility (“MTF”). The Applicant also has passporting rights under the European Markets in Financial Instruments Directive 2004/39/EC (“MiFID”) which allows the applicant to provide services throughout the European Economic Area (“EEA”).

1.1.2 The Applicant is registered with the CFTC to operate a SEF in the U.S. pursuant to the CEA effective April 20, 2017.

The Applicant is subject to regulatory supervision by the CFTC. The Applicant is obligated to give the CFTC access to all records unless prohibited by law or such records are subject to solicitor-client privilege. The CFTC reviews, assesses and enforces the Applicant’s adherence to the CEA and the regulations thereunder on an ongoing basis, including the core principle requirements for SEFs (“SEF Core Principles”) required by Section 5h of the CEA. The SEF Core Principles relate to the operation and oversight of the Facility, including financial resources, systems and controls, maintenance of an orderly market, execution and settlement of transactions, rule-making and investor protection.

1.2 Authority of the Foreign Regulator – The Foreign Regulator has the appropriate authority and procedures for

oversight of the exchange. This includes regular, periodic oversight reviews of the exchange by the Foreign Regulator.

1.2.1 The Applicant is subject to regulatory supervision by the FCA in conducting its activities for which it is permissioned as

set out in paragraph 1.1.1 above. In undertaking those activities, the Applicant is required to comply with the FCA’s Handbook which include, amongst other things, rules on (i) the Conduct of Business (including rules regarding client categorisation, communication with clients and other investor protections, firm remuneration and client agreements) (ii) Market Conduct (including rules applicable to firms operating an MTF) and (iii) Systems and Controls (including rules on outsourcing, governance, record-keeping and conflicts of interest, appointing a Head of Compliance and Oversight).

1.2.2 The CFTC carries out the regulation of U.S. SEFs in accordance with certain provisions of the CEA. To implement SEF

regulation, the CFTC has promulgated regulations and guidelines (“CFTC Regulations”) that further interpret the SEF Core Principles and govern the conduct of SEFs. The CFTC also undertakes periodic in-depth audits or rule reviews of a SEF’s compliance with certain of the SEF Core Principles.

1.2.3 The Applicant is required to demonstrate its compliance with the SEF Core Principles applicable to all U.S. SEFs.

Among other things, the SEF Core Principles and CFTC Regulations require SEFs to have a rulebook and a compliance program, including a Chief Compliance Officer and a compliance manual. A SEF's participant access criteria must be impartial and transparent and must be applied in a fair and non-discriminatory manner. The CFTC requires each SEF to have certain required trading protocols. A SEF must publish on its website certain daily trading data for each swap contract listed on the SEF and must report all transactions executed on the SEF to a swap data repository. The CFTC reviews, assesses and enforces a SEF's adherence to CFTC regulations on an ongoing basis.

1.2.4 A SEF is a self-regulatory organization under CFTC rules. A SEF is obliged under CFTC rules to have requirements

governing the conduct of participants, to monitor compliance with those requirements and to discipline participants, including by means other than exclusion from the marketplace. The Applicant is contracting with the U.S. National Futures Association (the “NFA”) as its regulatory service provider (“Regulatory Services Provider”) to conduct market surveillance of trades on its Facility for potential violations of the Facility’s rules. The Applicant is retaining ultimate decision-making authority with respect to any regulatory services to be provided by NFA.

2. Governance 2.1 Governance – The governance structure and governance arrangements of the exchange ensure:

(a) effective oversight of the Exchange,

2.1.1 The board of directors of the Applicant (the “Board”), has the power to manage, operate and set policies for the Applicant. The Board has the power to appoint such officers of the Applicant as it may deem necessary or appropriate from time to time.

2.1.2 The Board has the power by itself or through agents, and is authorized and empowered on behalf and in the name of

the Applicant, to perform all acts and enter into other undertakings that it may in its discretion deem necessary or


May 18, 2017

(2017), 40 OSCB 4562

advisable in order to promote the sound and efficient operation of the Facility (except such as otherwise required by applicable law), including, but not limited to, the following: (a) ensuring that the Facility complies with all statutory, regulatory and self-regulatory responsibilities under the

CEA; (b) reviewing, approving and monitoring major strategic, financial and business activities, the Applicant’s budget

and financial performance; (c) evaluating risks and opportunities facing the Applicant and proposing options for addressing such issues; (d) overseeing and reviewing recommendations from the Applicant’s committees and the Chief Compliance

Officer; and (e) having the sole power to set the payment dates and amounts of any dues, assessments or fees to be levied

on Trading Privilege Holders.

2.1.3 Each director is expected to comply with all applicable law and Applicant policies, and promote compliance by the Applicant and all of its employees. The Board discharges its responsibilities and exercise its authority in a manner, consistent with applicable legal and regulatory requirements that promotes the sound and efficient operation of the Applicant and its swap execution activities. The Board must, to the extent consistent with such responsibilities and as long as the Applicant remains an indirect subsidiary of NEX Group plc, operate within the restraints and delegated authorities set by NEX Group plc.

2.1.4 The Board provides effective oversight of the Facility as described in greater detail below.

Fitness Standards 2.1.5 The Applicant has established fitness standards for the Board as part of its Corporate Governance Principles (the

“Governance Principles”). The Governance Principles have been adopted by the Board to assist the Board in the exercise of its responsibilities. The Governance Principles are not intended to supersede or interpret any applicable law, and operate in conjunction with the Applicant’s articles of association. The standards set for the Board reflect the Applicant’s commitment to its shareholders and to the institutions and individuals who rely on it to provide swap execution services, and to comply with its role as a swap execution facility (“SEF”) subject to oversight by the FCA and CFTC. The Applicant’s Senior Management are also “Approved Persons” under the FCA’s Approved Persons regime, occupying regulated functions within the business and are subject to certain requirements including Fitness and Propriety as well as the “Code of Practice for Approved Persons”, ensuring the Applicant, its personnel and activities are conducted with due skill, care and diligence, and has adequate resources.

2.1.6 The Board is committed to conducting itself in a legal and ethical manner in fulfilling its responsibilities. Each director is

expected to comply with all applicable laws, rules and regulations, and Applicant policies, and promote compliance by the Applicant and all of its employees. The Board discharges its responsibilities and exercise its authority in a manner, consistent with applicable legal and regulatory requirements, that promotes the sound and efficient operation of the Applicant and its swap execution activities. Composition

2.1.7 The Board may consist of no less than two, and up to twelve, directors from time to time designated by the Board or the Applicant’s shareholder. The identities of all directors are published on the Applicant’s website and are available to the public.

2.1.8 The Board currently consists of five directors, one of which is a Public Director. At such time as determined in the

discretion of the Board (or at such time as may otherwise be required by applicable law), at least thirty-five percent (35%), but no less than two, of the directors must be Public Directors, as such term is defined from time to time in the rules, regulations, orders, directives or any interpretation thereof promulgated by the FCA or CFTC.

2.1.9 Each director serves a one year term, and may be reappointed to one or more successive one-year terms. Directors

must be approved by the Applicant’s shareholders in order to assume office. Any vacancies caused by death, resignation or any other reason may be immediately filled by the Applicant’s shareholders without a proposal from the Nomination Committee with any qualified person, who shall hold office for the unexpired term and until his or her successor shall be duly chosen. Any director may be removed either for or without cause at any time by the affirmative vote of a majority of the directors or by the affirmative vote of a majority interest of the shareholders entitled to vote, at


May 18, 2017

(2017), 40 OSCB 4563

the annual meeting or at a special meeting called for that purpose. Director appointments may be terminated as soon as: (a) That person ceases to be a director by virtue of any provision of the Companies Act 2006 or is prohibited from

being a director by law; (b) a bankruptcy order is made against that person; (c) a composition is made with that person’s creditors generally in satisfaction of that person’s debts; (d) a registered medical practitioner who is treating that person gives a written opinion to the Applicant stating that

that person has become physically or mentally incapable of acting as a director and may remain so for more than three months;

(e) by reason of that person’s mental health, a court makes an order which wholly or partly prevents that person

from personally exercising any powers or rights which that person would otherwise have; (f) notification is received by the Company from the director that the director is resigning from office, and such

resignation has taken effect in accordance with its terms; (g) the shareholder removes the director in accordance with the Applicant’s articles of association. Qualifications

2.1.10 In order to fulfill their responsibilities, directors (including Public Directors) are selected based on their experience,

qualifications, attributes and skills and the understanding that their leadership will play an integral role in fulfilling the Applicant’s business objectives and legal obligations. In particular, directors should: (a) Demonstrate sufficient experience in the Applicant’s scope or intended scope of financial services (including

ancillary services valuable for the Applicant to fulfill its business purposes); and (b) All directors shall be of sufficiently good repute, including the absence of (i) disciplinary offenses that would be

disqualifying under Section 1.63(c) of the CFTC’s regulations, and (ii) any felony conviction in the last 10 years, and (iii) any grounds for refusal to register under Section 8a(2) of the CEA. At least twenty percent of the directors must meet the criteria of Section 1.64(b)(1) of the CFTC’s regulations, which generally requires that the person have knowledge of financial regulation or the capability of contributing to governing board deliberations, not be a member of or employed by the Applicant and, together with the other directors, represent a diversity of membership interests.

Verification of Qualifications

2.1.11 In order to verify that each director is qualified to serve, the Applicant requires:

(a) a written statement from each prospective director containing biographical information and related background information; and

(b) Each director must inform the Applicant’s Chief Compliance Officer in writing if any of the information in the

statement materially changes thereafter. Upon receipt of the written statement, the Applicant’s Chief Compliance Officer will conduct a search on NFA BASIC to determine whether there is anything contradictory to the prospective director’s statement, and will attempt to resolve any inconsistencies. The Chief Compliance Officer will report the results of this review to the shareholders and the Board prior to the election of the prospective director. See also paragraph 2.2.1 below for a discussion of fitness requirements. Conflicts of interest

2.1.12 Each director is required to act in the best interests of the Applicant and to refrain from any conduct that would be, or gives the appearance of being, a conflict of interest. Generally, a “conflict of interest” exists when a director's private interest, including those of his or her immediate family, is inconsistent with or opposed to, or appears to be inconsistent with or opposed to, the Applicant’s interests. This includes a personal interest in an Applicant member (as defined in Section 1a(34) of the CEA), vendor or other person that could be significantly and disproportionately impacted by a decision of the Board.


May 18, 2017

(2017), 40 OSCB 4564

2.1.13 No director, member of any committee or oversight panel, or officer or other person authorized to exercise authority on behalf of the Applicant, including the Compliance Function (as defined below), will knowingly participate in such body’s deliberations or voting, including in any inquiry, investigation or any disciplinary proceeding, suspension, emergency or other executive action (each, an “Executive Proceeding”) if such person has a conflict of interest between such person's position acting on behalf of the Applicant and such person's personal interests (each, an “Interested Person”), unless deliberations are permitted as set forth below . Material conflicts of interest include, but are not limited to, instances where an Interested Person (a) is a named party in interest in an Executive Proceeding, (b) is an employer, employee or fellow employee of a named party in interest or potential named party in interest

in an Executive Proceeding, (c) has any other significant, ongoing business relationship with a named party in interest or potential named

party in interest in an Executive Proceeding, excluding relationships limited to executing transactions opposite each other or to clearing transactions through the same clearing members,

(d) has a family relationship with a named party in interest or potential named party in interest in an Executive

Proceeding (each of (a) through (d) being a “Relationship Conflict of Interest”) or (e) has a direct and substantial financial interest in the result of the deliberations or vote of any Executive

Proceeding based upon either Applicant or non-Applicant positions (a “Financial Conflict of Interest”). A “family relationship” exists between a named party in interest or potential named party in interest in an Executive Proceeding and a potential Interested Person if one person is the other’s spouse (including a domestic partner or partner in a civil union), co-habitator, former spouse, parent, stepparent, child or other legal dependent, sibling, stepbrother, stepsister, grandparent, grandchild, uncle, aunt, nephew, niece or in-law.

2.1.14 Prior to the consideration of any matter or significant action that will be considered by the Board or a committee of the Board in an Executive Proceeding, each potential Interested Person must disclose the existence of any potential conflict of interest, including any potential Relationship Conflict of Interest and/or Financial Conflict of Interest, to the Chairman of the Board or the chairman of the relevant committee and may choose to abstain and recuse himself or herself from the deliberations and voting. The potential Interested Person is encouraged to consult with the Applicant’s Secretary and any necessary internal or external advisors in advance of the topic being discussed or voted upon. If a potential Interested Person fails to disclose the existence of any potential conflict of interest that he or she knows of, or reasonably should know of, such potential Interested Person will be deemed an Interested Person prohibited from participation in an Executive Proceeding by the Board or committee of the Board, as applicable. If the Board or committee of the Board, as applicable, discovers that such a potential Interested Person participated in an Executive Proceeding without having made the disclosure of a potential conflict of interest, the determination of such Executive Proceeding shall be null and void, unless, in the case of an Emergency action, the potential Interested Person makes the disclosures described in the following paragraph 2.1.15 and the Board or committee thereof determines that such potential Interested Person would have been permitted to participate in the Executive Proceeding pursuant to the procedures described in paragraphs 2.1.16 and 2.1.17 below.

2.1.15 If disclosure of a potential conflict of interest is required, a potential Interested Person must disclose all information

required under applicable law in relation to any conflict of interest, including: (a) In the case of any potential Relationship Conflict of Interest, such disclosure must include the specific type of

Relationship Conflict of Interest based on the categories (a) through (d) above; and/or (b) In the case of any potential Financial Conflict of Interest, such disclosure must include the financial interest

and related position information (including information regarding positions held by such person, positions held by individuals of such person’s family and positions held by a firm with which such person is affiliated) that is known to such person with respect to any particular month or months that are under consideration, and any other positions which the deliberating body reasonably expects could be affected by the significant action, including but not limited to: (A) gross positions held in such person’s personal accounts or “controlled accounts,” as defined in CFTC

Regulation § 1.3(j); (B) gross positions held in proprietary accounts, as defined in CFTC Regulation § 1.17(b)(3), at such

person’s affiliated firm;


May 18, 2017

(2017), 40 OSCB 4565

(C) gross positions held in accounts in which such person is a principal, as defined in CFTC Regulation § 3.1(a);

(D) net positions held in customer accounts, as defined in CFTC § 1.17(b)(2), at such person’s affiliated

firm; and (E) any other types of positions, held in such person’s personal accounts or the proprietary accounts of

such person’s affiliated firm, that the Applicant reasonably expects could be affected by the significant action.

(c) Notwithstanding (b) above, in the case of a potential Financial Conflict of Interest, no such disclosure is

required by a potential Interested Person if such person chooses to abstain from deliberations and voting on the relevant Executive Proceeding.

2.1.16 If a potential Interested Person who discloses a potential material conflict of interest does not choose to abstain and

recuse himself or herself from deliberations and voting in any Executive Proceeding, the directors, or committee or oversight panel, as applicable, will determine whether such person is an Interested Person prohibited from participation in the Executive Proceeding. Such determination will be made by a majority vote in accordance with the procedures in the Articles of Association governing decision-making by directors and will be based upon a review of: (a) the information provided by such potential Interested Person; (b) any other source of information that is held by or reasonably available to the Applicant; (c) in the case of a Financial Conflict of Interest, the most recent large trader reports and clearing records

available to the Applicant; and (d) any applicable law.

2.1.17 With respect to Financial Conflicts of Interest only, and save for where applicable law prohibits it, any person determined to be an Interested Person who would otherwise be required to abstain from deliberations and voting pursuant to this policy, may participate in deliberations, but not in voting, if the Board, or committee or oversight panel, as applicable, determines by a majority vote (excluding all relevant Interested Persons) that such participation would be consistent with the public interest after considering the following factors : (a) whether such Interested Person’s participation in the deliberations is necessary to achieve a quorum; (b) whether the Interested Person has unique or special expertise, knowledge or experience in the matter being

considered; and (c) the position information which is the basis for the Interested Person’s Financial Conflict of Interest.

2.1.18 In addition to the general restrictions against conflicts of interest, all Public Directors are prohibited from having “material relationships” (as defined from time to time in the rules, regulations, orders, directives or any interpretation thereof promulgated by the CFTC) with the Applicant which reasonably could affect the independent judgment or decision-making of such director. “Material relationships” are defined to include the following: (a) The director, or an immediate family member of the director, may not be an officer or employee of the

Applicant or its affiliate. (b) The director, or an immediate family member of the director, may not be a member of the Applicant, or a

director, officer or employee of an Applicant member (as defined in Section 1a(34) of the CEA and any regulation promulgated thereunder).

(c) The director, or an immediate family member of the director, may not be an officer of another entity, which

entity has a compensation committee (or similar body) on which any officer of the Applicant serves. (d) The director, or an immediate family member of the director, or an entity with which the director or such

immediate family member is a partner, an officer, an employee or a director, may not receive more than $100,000 in combined annual payments for legal, accounting, or consulting services from the Applicant, any affiliate thereof, any member of the Applicant or any affiliate of such member.


May 18, 2017

(2017), 40 OSCB 4566

2.1.19 Notwithstanding the foregoing, (a) compensation for services as a director of the Applicant or as a director of an affiliate of the Applicant shall not count toward the $100,000 threshold specified in clause (d) of the above definition, nor shall compensation for services rendered by such individual prior to becoming a director of the Applicant, so long as such compensation is or was in no way contingent, conditioned or revocable; and (b) a Public Director may also serve as a director of an affiliate of the Applicant if he or she otherwise meets the requirements set forth in clauses (a) through (d) of the above definition.

2.1.20 Each of the preceding disqualifying circumstances is subject to a one-year look back. Public Directors have an

affirmative duty to investigate from time to time, and promptly disclose, the existence and nature of any such material relationships to the Board. The Board must make such findings of any material relationship upon the nomination or appointment of the proposed Public Director and as often as necessary in light of all circumstances relevant to such director, but in no case less than annually.

Compensation

2.1.21 Compensation awarded to Public Directors and other nonexecutive directors is not linked to the Applicant’s business

performance.

Certification and Compliance 2.1.22 Each director must become familiar with, and abide by, the Governance Principles. Each prospective director and

director must, before taking office, acknowledge his or her receipt and understanding of the Governance Principles, as well as upon any publication of a revised set of Governance Principles or amendment thereto. In addition, (i) upon request from the Applicant, the director shall certify that the qualification information he/she provided to the Applicant before being elected as a director has not changed materially, and (ii) from time to time the director shall provide an updated statement of qualification information that reflects any material changes.

2.1.23 Directors are required to report suspected violations of the Governance Principles or of any applicable law, rule or

regulation by any director to the Board, the Regulatory Oversight Committee or the Chief Compliance Officer (who will subsequently relay any such suspected violations to the Board or the Regulatory Oversight Committee, unless such reported violation is proven incorrect after a prompt initial review of its merits). The Board or the Regulatory Oversight Committee, as applicable, shall determine whether to conduct an investigation and what appropriate action should be taken. Directors may consult with the Applicant’s General Counsel if there is any doubt as to whether a particular transaction or course of conduct complies with or is subject to the Governance Principles. Self-Review

2.1.24 The Board reviews its performance and that of its individual directors on an annual basis, before the expiration of each one year term of office for the directors. The Board, or a committee delegated such responsibility, shall establish criteria for the Board’s evaluation, shall conduct the evaluation in accordance with such criteria, and shall make recommendations to improve deficiencies. Removal for Cause

2.1.25 Any director failing to comply with, or certify compliance with, the Governance Principles, or whose conduct otherwise is likely to be prejudicial to the sound and prudent management of the Applicant, may be removed for cause at any time by the affirmative vote of a majority of the directors, other than the director whose conduct is at issue, or by the affirmative vote of a majority interest of the shareholders, at the annual meeting or at a special meeting called for that purpose. Board Committees

2.1.26 The Applicant’s Governance Policy contemplates three committees of the Board: a Nomination Committee, a Participation Committee and a Regulatory Oversight Committee. Currently, only the Regulatory Oversight Committee is a standing committee of the Board. The Board may from time to time constitute and appoint additional standing committees as it may deem necessary or advisable. The Applicant may also from time to time establish one or more special committees as it may deem necessary or advisable.

2.1.27 The Regulatory Oversight Committee consists of those directors designated by the Board from time to time; provided,

however, that at such time as is determined in the discretion of the Board (or at and for such other time as may otherwise be required by the CFTC Regulations), the Regulatory Oversight Committee shall consist only of Public Directors. Each member of the Regulatory Oversight Committee shall serve until the due appointment of his or her successor, or until his or her earlier resignation or removal, with or without cause, as a member of the Regulatory


May 18, 2017

(2017), 40 OSCB 4567

Oversight Committee or as a Public Director. A member of the Regulatory Oversight Committee may serve for multiple terms. The Regulatory Oversight Committee has responsibility to: (i) Monitor the Facility’s self-regulatory program for sufficiency, effectiveness, and independence; (ii) Oversee all facets of the Facility’s self-regulatory program, including trade practice, market surveillance,

audits, examinations and other regulatory responsibilities with respect to participants, and the conduct of investigations;

(iii) Review the size and allocation of the Facility’s regulatory budget and resources; and the number, hiring and

termination, and compensation of regulatory personnel; (iv) Review the performance of the Compliance Function, and make recommendations with respect to such

performance to the Board; (v) Review all regulatory proposals prior to implementation and advise the Board as to whether and how such

changes may impact regulation; (vi) Regularly monitor for conflicts of interest in accordance with the procedures described above under “Conflicts

of interest;” (vii) Recommend changes to the Facility’s self-regulatory program that would ensure fair, vigorous, and effective

regulation; (viii) Prepare an annual report to the Board and the CFTC assessing the self-regulatory program of the Facility and

including a description of the program, the expenses of the program, the staffing and structure of the program, a catalog of investigations and disciplinary actions taken during the year, and a review of the performance of the Review Panel, Hearing Panel, and Chief Compliance Officer; and

(ix) Perform such other duties as the Board may delegate to it from time to time. In addition, the Regulatory Oversight Committee may impose controls on the Facility to reduce the potential risk of market disruption, including but not limited to market restrictions that pause or halt trading in specified market conditions. (b) that business and regulatory decisions are in keeping with its public interest mandate,

2.1.28 The Applicant is committed to ensuring the integrity of its Facility and the stability of the financial system, in which market infrastructure plays an important role. The Applicant must ensure the integrity of a transaction that occurs on the Facility and the protection of customer funds under Core Principle 7 – Financial Integrity of Transactions (“Core Principle 7”). The Applicant fulfills this requirement in part through compliance with other SEF Core Principles, such as Core Principle 3 – Swaps Not Readily Subject to Manipulation (“Core Principle 3”). Stability of the market infrastructure is enhanced through compliance with Core Principle 13 – Financial Resources (“Core Principle 13”). Core Principle 13 requires the Facility to maintain adequate financial resources to discharge its responsibilities and ensure orderly operation of the market. The rules, policies and activities of the Applicant are designed and focused on ensuring that they maintain best practices and fulfil this public interest mandate. The Applicant operates on a basis consistent with applicable laws and regulations, and best practices of other SEFs and derivatives trading facilities.

(c) fair, meaningful and diverse representation on the board of directors (Board) and any committees of

the Board, including: (i) appropriate representation of independent directors, and (ii) a proper balance among the interests of the different persons or companies using the

services and facilities of the exchange,

2.1.29 At such time as determined in the discretion of the Board (or at and for such other time as may otherwise be required by the CFTC Regulations), the Board shall be composed of at least 35%, but no less than two, Public Directors, or such other percentage of Public Directors as may be required to comply with the CEA and CFTC Regulations. The Board has one (1) Public Director. Also, at such time as is determined in the discretion of the Board (or at and for such other time as may otherwise be required by the CFTC Regulations), the Regulatory Oversight Committee shall consist only of Public Directors. Paragraph 2.1.18 above contains a discussion of the criteria for Public Director independence. Paragraph 2.1.10 above contains a discussion of director qualification, including compliance with Section 1.64(b)(3) of


May 18, 2017

(2017), 40 OSCB 4568

the CFTC’s regulations, which requires that a minimum number of board members represent a diversity of membership interests. (d) the exchange has policies and procedures to appropriately identify and manage conflicts of interest

for all officers, directors and employees, and

2.1.30 The Applicant, through its conflicts of interest rules, policies and procedures, as well as its compliance with Core Principle 12 – Conflicts of Interest (“Core Principle 12”), has established a robust set of safeguards designed to ensure that the Facility operates free from conflicts of interest or inappropriate influence as described above. The FCA and CFTC also conduct their own surveillance of the markets and market participants and actively enforce compliance with applicable regulations. In addition to this regulatory oversight, the Applicant separately establishes and enforces rules governing the activity of all market participants in its market. The Applicant’s conflict of interest policies are described in greater detail in paragraphs 2.1.12 through 2.1.20 above. (e) there are appropriate qualifications, remuneration, limitation of liability and indemnity provisions for

directors, officers and employees of the exchange.

2.1.31 See paragraph 2.1.10 above for information on the director qualifications. Members of the Applicant’s Management Team are recruited for their particular position based upon their skills and expertise. Their individual goals and performance are regularly assessed by their direct manager as part of the Applicant’s performance management process.

2.1.32 Pursuant to the Applicant’s Rulebook, the liability of each employee of the Applicant to third parties for obligations of

the Applicant is limited to the fullest extent provided in the CEA and other applicable law. The Applicant’s articles of association provide for the indemnification by the Applicant against losses or damages sustained by a person with respect to third-party actions or proceedings due to the fact that such person is a Director or other officer of the Applicant.

2.2 Fitness – The exchange has policies and procedures under which it will take reasonable steps, and has taken

such reasonable steps, to ensure that each director and officer is a fit and proper person and past conduct of each officer or director affords reasonable grounds for belief that the officer or director will perform his or her duties with integrity.

2.2.1 See paragraphs 2.1.5 and 2.1.6 above for a description of the Applicant’s fitness standards for the Board as a whole.

See paragraph 2.1.11 above for a description of the Applicant’s policies and procedures for ensuring that each director is a fit and proper person.

3. Regulation of Products 3.1 Review and Approval of Products – The products traded on the exchange and any changes thereto are

submitted to the Foreign Regulator, and are either approved by the Foreign Regulator or are subject to requirements established by the Foreign Regulator that must be met before implementation of a product or changes to a product.

3.1.1 The CFTC core principles relevant to products traded on the Facility include: Core Principle 2 – Compliance with Rules

(“Core Principle 2”), Core Principle 3, Core Principle 4 – Monitoring of Trading and Trade Processing (“Core Principle 4”), Core Principle 6 – Positions Limits or Accountability, Core Principle 7 and Core Principle 9 – Timely Publication of Trading Information (“Core Principle 9”). In addition to compliance with these SEF Core Principles, the CFTC requires SEFs to demonstrate that new products are not susceptible to manipulation (see Core Principle 3).

3.1.2 Specifications for swaps that trade on the Applicant’s Facility are set forth in Chapter 8 of the Applicant’s Rulebook.

When the Applicant wishes to add or change a product, the Applicant files changes to its Rulebook with the CFTC. In order to submit a swap to the CFTC as self-certified, the Facility must (i) meet the submission criteria contained in CFTC Rule 40.2, (i) determine that the swap is not readily susceptible to manipulation in accordance with Core Principle 3 and CFTC Rules 37.300 and 37.301; and (iii) include in the self-certified submission the information required by Appendix C to Part 38 of the CFTC Regulations. The Applicant would request prior CFTC approval of a swap pursuant to CFTC Rule 40.3 where the swap was a new or novel product or where it was unclear whether the CFTC or the U.S. Securities and Exchange Commission (the “SEC”) would have jurisdiction over the swap, including situations where the CFTC and SEC may have joint jurisdiction over the swap.

3.1.3 It is the Applicant’s policy not to make a product “available to trade” under Section 5c(c) of the CEA and CFTC

Regulation 37.10.


May 18, 2017

(2017), 40 OSCB 4569

3.2 Product Specifications – The terms and conditions of trading the products are in conformity with the usual commercial customs and practices for the trading of such products.

3.2.1 Among other things, the requirement that new swaps comply with FCA requirements and the SEF Core Principles

means that they contain an analysis of the underlying cash market and the deliverable supply of the underlying product. In response to the Applicant’s process for introducing a new product or changing an existing product, as described above, the FCA and CFTC have the right to follow up with questions requesting additional information on the underlying market including, but not limited to: supply and demand characteristics, participant composition, market concentration, deliverable supply estimates, the relation of the swap size to the underlying market, the quality of the product across various delivery facilities and the delivery facilities used for the product. If the Applicant is unable to provide satisfactory answers to the FCA’s CFTC’s questions, they may require the Facility to withdraw the proposed product addition or change. It is the Applicant’s experience that the terms and conditions of swaps that trade on the Facility are standardized, generally accepted and understood by participants.

3.3 Risks Associated with Trading Products – The exchange maintains adequate provisions to measure, manage

and mitigate the risks associated with trading products on the exchange that may include, but are not limited to, daily trading limits, price limits, position limits, and internal controls.

3.3.1 Section 9.3 of this application covers the way that the Applicant measures, manages and mitigates the trading risk

associated with products traded on the Facility. 3.3.2 The Applicant’s compliance function is responsible for ensuring that surveillance systems monitor trading by

Participants to prevent manipulation, price distortion and other violations of Facility rules and applicable law. Pursuant to a Regulatory Services Agreement (“RSA”), the Applicant has contracted with the NFA as a Regulatory Services Provider for the purposes of monitoring the Facility’s markets. As part of the market surveillance provided, the NFA uses an automated system to detect, among other things, (a) disruptions of the deliverable supplies underlying a swap, (b) market manipulation of the references price and (c) also monitors the orderly liquidation of physically deliverable expiring swaps. Consistent with other SEFs, the Applicant has determined that it is not necessary and appropriate to set position limits or position accountability levels for swaps at this time.

4. Access 4.1 Fair Access

(a) The exchange has established appropriate written standards for access to its services including

requirements to ensure (i) participants are appropriately registered as applicable under Ontario securities laws, or

exempted from these requirements, (ii) the competence, integrity and authority of systems users, and (iii) systems users are

adequately supervised.

(b) The access standards and the process for obtaining, limiting and denying access are fair, transparent and applied reasonably.

(c) The exchange does not unreasonably prohibit, condition or limit access by a person or company to

services offered by it. (d) The exchange does not

(i) permit unreasonable discrimination among participants, or (ii) impose any burden on competition that is not reasonably necessary and appropriate.

(e) The exchange keeps records of each grant and each denial or limitation of access, including reasons for granting, denying or limiting access.

4.1.1 Consistent with applicable law, including FCA requirements and SEF Core Principles, the Facility provides access to

participants on a fair, non-discriminatory and open basis. Participant status, and access to, and usage of, the Facility in such capacity is available to all market participants that meet the criteria set forth by the Applicant and engage in transactions on the Facility in accordance with the Facility’s rules. Chapter 2 of the Rulebook set out the admission and


May 18, 2017

(2017), 40 OSCB 4570

eligibility criteria that participants must meet. Among other requirements, Rulebook standards require that participants must: • be of good financial standing and meet the financial and related reporting requirements set forth in Chapter 2

of the Rulebook. • upon initial application for trading privileges, represent to the Applicant that it is an ECP and EC or PC. In

addition, at least annually, the participant must represent that it has been and continues to be as of such date, an ECP and EC or PC;

• notify the Applicant’s Chief Compliance Officer immediately upon becoming aware that it fails to meet its

minimum financial requirements; and • demonstrate a capacity to adhere to all applicable rules of the Facility, rules of any clearing agency to which

the participant submits swaps for clearing, FCA regulations, CFTC regulations and SRO regulations, including those concerning record-keeping, reporting, financial requirements and trading procedures.

4.1.2 Ontario participants must be registered under Ontario securities laws, exempt from the registration requirements or not

subject to the registration requirements. 4.1.3 Core Principle 11 requires that, unless necessary or appropriate to achieve the purposes of applicable law, a SEF

should avoid (a) adopting any rules or taking any actions that result in any unreasonable restraints of trade; or (B) imposing any material anticompetitive burden on trading. As such, the Applicant does not implement rules that would impose any burden on competition that is not reasonably necessary and appropriate because such rules would not meet SEF Core Principle requirements.

4.1.4 The Applicant may deny the grant of trading privileges, prevent a person from becoming or remaining a participant if it

would cause the Applicant to be in violation of any applicable law. The Applicant keeps records of each grant and each denial or limitation of access, including reasons for granting, denying or limiting access.

4.1.5 Pursuant to the procedures set forth in Rule 205(e) of the Rulebook, any applicant who is denied trading privileges or

any participant who has privileges removed may request, in writing within 7 days of receiving written notice of the Applicant’s decision, reasons for the Applicant’s decision. The Applicant must provide such reasons in writing within 14 days of receiving the request. Within 14 days of receiving the Applicant’s written response, the applicant or participant, as the case may be, may request, in writing, that the Board (or the Participation Committee, if established) reconsider the Applicant’s initial decision and may provide any written representations or other information that the applicant or participant, as the case may be, believes is relevant to the reconsideration. The Board (or Participation Committee) must then, within 28 days of receiving the applicant or participant’s appeal request, confirm, reverse or modify the initial decision and will promptly notify the applicant or participant as the case may be, accordingly. The Board (or Participation Committee) may in its discretion schedule a hearing or establish any other process that it believes is necessary and appropriate to consider the request for reconsideration. Any decision by the Board (or Participation Committee) then made constitutes the final action of the Facility with respect to the matter in question. In the event that the Board (or Participation Committee) upholds the decision to deny access, the applicant may then appeal to the CFTC in the manner provided in CFTC Rule 9.20.

4.1.6 No determination to discontinue a person’s trading privileges take effect until the review procedures hereunder have

been exhausted or the time for review has expired. 5. Regulation of Participants on the Exchange 5.1 Regulation – The exchange has the authority, resources, capabilities, systems and processes to allow it to

perform its regulation functions, whether directly or indirectly through a regulation services provider, including setting requirements governing the conduct of its participants, monitoring their conduct, and appropriately disciplining them for violations of exchange requirements.

5.1.1 A SEF is a self-regulatory organization under CFTC rules. A SEF is obliged under CFTC rules to have requirements

governing the conduct of participants, to monitor compliance with those requirements and to discipline participants, including by means other than exclusion from the marketplace. Participants are required to comply with a significant number of rules governing trading on the Facility pursuant to the Rulebook. The applicable rules are primarily located in Chapter 3 (Trading Procedures) and Chapter 4 (Trading Standards) of the Rulebook.

5.1.2 The Applicant is contracting with the NFA for the NFA to conduct market surveillance of its Facility trades. The NFA

staff are responsible for conducting trade practice surveillance and market surveillance for the Applicant. This includes


May 18, 2017

(2017), 40 OSCB 4571

reviewing messages and deals on an ongoing basis to determine if there are any potential violations of the Applicant’s Rulebook and monitoring compliance with market manipulation rules and the orderly liquidation of physically delivered expiring swaps. NFA has developed an automated surveillance system known as Sophisticated Warning Analysis Profiling System, or “SWAPS”. The NFA staff uses SWAPS to effectively and efficiently profile markets and Participants, query the Applicant’s audit trail, generate automated trade exception reports and conduct daily monitoring of prices, volume and market news. In addition to the information collected automatically by SWAPS, information is gathered by NFA staff from a variety of other sources to perform surveillance. NFA investigators are grouped into Investigation Teams organized by the Applicant and by asset class to ensure that the NFA provides adequate staff with sufficient expertise to oversee the Applicant’s market.

5.1.3 The Applicant expends considerable human, technological and financial resources that are focused on the

maintenance of fair, efficient, competitive and transparent markets, and the protection of all Facility participants from fraud, manipulation and other abusive trading practices. The Applicant’s market surveillance activities include a broad range of interconnected efforts that include trade practice reviews, data quality assurance audits and enforcement activities. To fulfill its mandate to effectively monitor and enforce the Facility’s rules, the Applicant has established an automated trade surveillance system capable of detecting potential trade practice and violations of the Applicant’s Rulebook. Participants are required to comply with a significant number of rules governing trading on the Facility pursuant to the Facility’s rules. The applicable rules are primarily located in Chapter 4 (Trading Standards) of the Rulebook.

5.1.4 Investigating and enforcing rule violations are necessary components of regulatory safeguards. The Facility’s

disciplinary rules, including the establishment of panels, conducting of investigations, prosecution of violations and imposition of sanctions are described in Chapter 5 (Rule Enforcement) of the Rulebook and are described in Part 7 below.

5.1.5 The Applicant is dedicated to safeguarding the integrity of its Facility, and ensuring that it is free from manipulation and

other abusive practices. These efforts are a necessary component of efficiently working markets, and so it is committed to ensuring that participants are able to use the Facility with the knowledge that it remains open and transparent.

5.1.6 Specifically with reference to regulatory technology, the Applicant has made significant investments in this area,

including staff dedicated solely to the support and continuous development of its regulatory technology infrastructure, ensuring that the Applicant’s regulatory and market protection capabilities anticipate and evolve with the changing dynamics of the marketplace. The Applicant has developed an audit trail of market activity and powerful and flexible data query and analytical tools that allow its regulatory staff to examine real-time and historical order, transaction data, maintain profiles of markets and participants, and to detect trading patterns potentially indicative of market abuses.

6. Rulemaking 6.1 Purpose of Rules

(a) The exchange has rules, policies and other similar instruments (Rules) that are designed to

appropriately govern the operations and activities of participants and do not permit unreasonable discrimination among participants or impose any burden on competition that is not reasonably necessary or appropriate.

6.1.1 Pursuant to its obligations under the regulatory oversight of the FCA, under the CEA and under CFTC Regulations, the

Applicant has implemented rules, policies and other similar instruments that govern the operations and activities of its participants. The Applicant’s rules are covered in Chapters 1 through 8 of its Rulebook, which include: Chapter 1 (Market Governance), Chapter 2 (Trading Privileges), Chapter 3 (Trading Procedures), Chapter 4 (Trading Standards), Chapter 5 (Rule Enforcement), Chapter 6 (Contracts to be Traded), Chapter 8 (Contract Specifications) and Confidential Chapter 9 (Trading Protocols). The Applicant believes that its rules and policies that govern the activities of Participants are consistent with the rules and policies of other derivatives marketplaces and therefore do not impose any burden on competition that is not reasonably necessary or appropriate. (b) The Rules are not contrary to the public interest and are designed to

(i) ensure compliance with applicable legislation, (ii) prevent fraudulent and manipulative acts and practices, (iii) promote just and equitable principles of trade,


May 18, 2017

(2017), 40 OSCB 4572

(iv) foster co-operation and co-ordination with persons or companies engaged in regulating, clearing, settling, processing information with respect to, and facilitating transactions in the products traded on the exchange,

(v) provide a framework for disciplinary and enforcement actions, and (vi) ensure a fair and orderly market.

6.1.2 The Applicant’s Rulebook is subject to the standards and requirements outlined by FCA regulations and the SEF Core Principles. At a high level, the Applicant’s Rulebook seeks to ensure fair and orderly markets accessible to all eligible participants. This aim is accomplished by establishing rules that reflect the FCA regulations and SEF Core Principle criteria, that are not contrary to the public interest, and are designed to: (i) ensure compliance with applicable legislation. The Applicant is obligated to comply with FCA regulations.

Also, the Applicant is obligated to comply with the CEA, the SEF Core Principles and the CFTC Regulations (collectively, the “U.S. SEF Regulations”). As a result, the Applicant must implement rules that require compliance with FCA regulations and the U.S. SEF Regulations by its participants. SEF Core Principle 1 – Compliance with Core Principles requires a swaps trading facility to comply with all applicable CFTC requirements and CEA core principles to be designated a SEF and maintain such designation. The Applicant proactively ensures compliance with all applicable laws and regulations, evidenced in part by its regular dialogue with the CFTC, including public commenting on proposed regulations. Core Principle 2 requires SEFs to ensure participants consent to SEF rules and jurisdiction prior to accessing its markets. Chapter 2 of the Applicant’s Rulebook governs membership requirements and establishes compliance with the rules that brings market participants within the jurisdiction of the CFTC and the scope of the SEF Core Principles.

(ii) prevent fraudulent and manipulative acts and practices. Core Principle 2 requires a SEF to collect

information, examine members’ records, direct supervision of the market, maintain sufficient compliance staff, establish procedures for and conduct audit trail reviews, perform real-time market monitoring and market surveillance and establish an automated trade surveillance system. The Applicant has instituted all these controls. Core Principle 3 requires a SEF to ensure the swaps it trades are not readily susceptible to manipulation. The Applicant complies with this Core Principle by including narrative descriptions of the product terms and conditions of every swap and by certifying in its CFTC Rule 40.2 submission that each swap is not readily susceptible to manipulation in accordance with Core Principle 3 and the criteria set forth in Appendix C to Part 38 of the CFTC regulations. Also, Chapters 3 and 4 of the Applicant’s Rulebook prescribes trading practices and trading conduct requirements, including prohibited trading activities and prohibitions on fictitious trades, fraudulent activity and manipulation.

(iii) promote just and equitable principles of trade. Core Principle 9 requires a SEF to promote transparency by

making timely public disclosures of trading information. The Applicants conforms to this Core Principle by publishing daily information on settlement prices, volume, open interests, and opening and closing ranges for actively traded swaps. Core Principle 7 requires a SEF to ensure the financial integrity of transactions entered into on its markets. The Applicant’s data and order entry feed systems offer simultaneous and equivalent access to all market participants. Core Principle 11 prohibits the imposition of unreasonable restraints or uncompetitive burdens on trade. Throughout its rulebook, the Applicant has established transparent and objective standards to prevent unreasonable restraints on trade and foster competitive and open market participation. Additionally, section 25 of the Applicant’s compliance manual requires that compliance personnel ensure the Applicant does not adopt any rule or take any action that would result in any unreasonable restraint of trade or impose any material anticompetitive burden on trading or clearing. The Applicant believes that compliance with these Core Principles, which require transparency, financial integrity, fair access and fair competition among participants, promotes just and equitable principles of trade.

(iv) foster co-operation and co-ordination with persons or companies engaged in regulating, clearing,

settling, processing information with respect to, and facilitating transactions in the products traded on the exchange. Rule 206 of the Rulebook authorizes the Applicant to enter into information-sharing arrangements as it determines necessary or advisable to obtain any necessary information, to perform any monitoring of trading or trade processing, to provide information to the CFTC upon request and to carry out such international information-sharing agreements as the CFTC may require. Furthermore, the Applicant may enter into any arrangement with any other person (including any governmental authority (such as the Ontario Securities Commission), trading facility or clearing organization) where the Applicant determines such person exercises a legal or regulatory function under any applicable law or considers the arrangement to be in furtherance of the operation or duties of the Applicant under applicable law.


May 18, 2017

(2017), 40 OSCB 4573

(v) promote a framework for disciplinary and enforcement actions. Core Principle 2 requires a SEF to adopt a rule enforcement program, disciplinary procedures and sanctions. In response to this requirement, Chapter 5 of the Applicant’s Rulebook sets describes the Facility’s rules for rule enforcement and Chapter 7 prescribes the Applicant’s procedures for dispute resolution.

(vi) ensure a fair and orderly market. Core Principle 2 requires a SEF to establish rules governing the operation

of the SEF, including orderly trading procedures and rule enforcement programs. Core Principle 3 requires a SEF to ensure that swaps traded on the facility are not readily subject to manipulation. Core Principle 4 requires a SEF to establish procedures for monitoring of trading and trade process. The Applicant complies with these Core Principles by prescribing trading rules, collecting and evaluating market activity data, by maintaining and auditing its real-time monitoring program, and by auditing historical data to detect trading abuses. Core Principle 9 requires timely public disclosure of trade information, all of which is published daily. SEF Core Principle 14 – System Safeguards requires a SEF to establish and maintain risk analysis, emergency procedure, and periodic systems testing programs. The Applicant periodically reviews its programs and procedures, including risk analysis, emergency planning, and systems testing. The Applicant regularly audits systems and technology tests both for technical and regulatory compliance. The Applicant believes that compliance with these Core Principles, which require effective trading rules, real-time and post-trade monitoring, public data dissemination and risk management procedures and testing, ensure a fair and orderly market.

7. Due Process 7.1 Due Process – For any decision made by the exchange that affects a participant, or an applicant to be a

participant, including a decision in relation to access, exemptions, or discipline, the exchange ensures that: (a) parties are given an opportunity to be heard or make representations, and (b) it keeps a record of, gives reasons for, and provides for appeals or reviews of its decisions.

7.1.1 SEF Core Principle 2 require the Applicant to adopt a rule enforcement program, disciplinary procedures and sanctions. In response to this requirement, Chapter 5 of the Applicant’s Rulebook sets out the Applicant’s rules for rule enforcement and Chapter 7 prescribes the Applicant’s dispute resolution procedures.

7.1.2 The Applicant has the authority to initiate and conduct investigations, and enforce remedial action for breaches, and to

impose sanctions for such violations. It is the duty of the Applicant’s Chief Compliance Officer to enforce the rules, but the Chief Compliance Officer may also delegate such authority to market regulation staff, which consists of employees of the Applicant and the NFA (“Market Regulation Staff”).

7.1.3 The Market Regulation Staff have the authority to conduct investigations of possible violations of the Rulebook, prepare

written reports respecting such investigations, furnish such reports to the Applicant’s review panel (the “Review Panel”)1 and conduct the prosecution of such violations. An investigation must be commenced upon receipt of a request from CFTC staff or receipt of information by the Facility that, in the judgment of the Market Regulation Staff, indicates a reasonable basis for finding that a violation has occurred or will occur. The Applicant maintains records of all investigations conducted by the Applicant in accordance with its recordkeeping policy.

7.1.4 If it is concluded that a violation may have occurred, the participant may be issued a warning letter or an investigation

report concerning the matter may be filed with the Review Panel. No more than one warning letter may be issued to the same person found to have committed the same violation more than once in a rolling 12-month period. The investigation report must include the reason the investigation was initiated; a summary of the complaint, if any; the relevant facts; Market Regulation Staff’s analysis and conclusions; and a recommendation as to whether disciplinary action should be pursued. The report may also include the participant’s disciplinary history at the Facility, including copies of any warning letters.

7.1.5 The Review Panel has the power to direct that an investigation of any suspected violation be conducted by the Market

Regulation Staff, and shall hear any matter referred to it by the Market Regulation Staff regarding a suspected violation. Upon receipt of an investigation report, the Review Panel shall promptly review the report and, within thirty (30) days of receipt, take one of the following actions:

1 The Review Panel is appointed by the Board, and must be comprised of five persons, including at least two participants and at least two

non-participants. The Board must appoint as chairman (the “Review Panel Chairman”) of the Review Panel a person who qualifies as a “Public Director” (i.e. an independent person).


May 18, 2017

(2017), 40 OSCB 4574

(a) If the Review Panel determines that additional investigation or evidence is needed, it shall promptly direct the Market Regulation Staff to conduct further investigation;

(b) If the Review Panel determines that no reasonable basis exists for finding a violation or that prosecution is

otherwise unwarranted, it may direct that no further action be taken. Such determination must be in writing and must include a written statement setting forth the facts and analysis supporting the decision; or

(c) If the Review Panel determines that a reasonable basis exists for finding a violation and adjudication is

warranted, it must direct that the participant alleged to have committed the violation be served with a notice of charges (as set forth in Rule 504 of the Rulebook).

7.1.6 If the Review Panel determines that there may have been a violation but that no adjudication is warranted, the Review

Panel may issue a warning letter to the participant informing it that there may have been a violation and that such continued activity may result in disciplinary sanctions. Where a violation is determined to have occurred, no more than one warning letter for the same potential violation may be issued to the same person during a rolling 12 month period.

7.1.7 If the Review Panel determines that a reasonable basis exists for finding a violation and adjudication is warranted, the

Chief Compliance Officer shall serve a notice of charges (a “Notice”) on the participant alleged to have been responsible for the violation (such participant, the “Respondent”).

7.1.8 The Respondent shall serve on the Chief Compliance Officer a written answer (an “Answer”) to the Notice and a

written request for a hearing on the charges within thirty (30) days of the date of service of the Notice. The Answer must include a statement that the Respondent admits, denies, or does not have and is unable to obtain sufficient information to deny each allegation.

7.1.9 Formal hearings on any Notice shall be conducted by the “Hearing Panel” selected by the Board. The Hearing Panel

may not include any members of the Market Regulation Staff, or any person involved in adjudicating any other stage of the same proceeding. The Hearing Panel must meet the composition detailed in CFTC Regulation 1.64(c), which requires that whenever the Hearing Panel is acting with respect to a disciplinary action in which the Respondent is a member of the Board, the Review Panel or the Hearing Panel or when the suspected violation involves manipulation (or attempted manipulation) of the price of a Contract or conduct which directly results in financial harm to a non-member of the Applicant that: (a) at least one member of the Hearing Panel is not a member of the Facility; ; and (b) the Hearing Panel include sufficient different membership interests so as to ensure fairness and to prevent special treatment or preference for any person in the conduct of the Hearing Panel’s responsibilities.

7.1.10 Prior to the commencement of the hearing, the Hearing Panel may accept a written offer of settlement from the

Respondent, whereby the Respondent, without either admitting or denying any violations, may agree to: (1) a cease and desist order; (2) a fine for each violation plus the monetary value of any benefit received as a result of the violation (provided that in no case shall any fine exceed $100,000 per violation); (3) restitution of any counterparty harm; and/or (4) revocation or suspension of trading privileges.

7.1.11 Rule 510 sets out the Applicant’s procedures for holding a hearing. After the hearing is complete, the Hearing Panel

must render a written decision based upon the weight of evidence and must provide a copy to the Respondent. There is no right of a Respondent to appeal a decision by the Hearing Panel to the Facility. However, a disciplinary action may be appealed to the CFTC pursuant to Part 9 of the CFTC Regulations.

8. Clearing and Settlement 8.1 Clearing Arrangements – The exchange has or requires its participants to have appropriate arrangements for

the clearing and settlement of transactions for which clearing is mandatory through a clearing house. 8.1.1 A SEF must submit all trades that are required to be cleared to a clearing house for clearing. In the future, upon

additional products being added to the Applicant’s SEF, the exact date of which is not yet known, the Applicant will provide direct connectivity for clearing to LCH.Clearnet Limited, which operates under a recognition order in Ontario and is registered as a derivatives clearing organization (“DCO”) with the CFTC. The Applicant does not currently require that Ontario-based participants become clearing members of a clearing house or rely on another clearing member for clearing because the products traded on the Applicant’s SEF are not currently subject to a mandatory clearing requirement.

8.1.2 Any cleared swap that is rejected for clearing by a clearing house for any reason is treated as void ab initio and is

canceled by the Facility. Participants may attempt to re-execute such transactions on the Facility after the cleared swap is canceled. Component legs of package transactions that are rejected for clearing are also treated as void ab initio and are canceled by the Facility. However, such rejected legs of a Package Transaction may be resubmitted for clearing


May 18, 2017

(2017), 40 OSCB 4575

without re-execution on the Facility pursuant to the “new trade/old terms” procedures set forth in Rule 204 of the Rulebook.

8.2 Risk Management of Clearing House – The exchange has assured itself that the clearing house has

established appropriate risk management policies and procedures, contingency plans, default procedures and internal controls.

8.2.1 The Applicant has assured itself that LCH.Clearnet Limited has established appropriate risk management policies and

procedures, contingency plans, default procedures and internal controls. As noted above, the clearing house is registered as a DCO with the CFTC and regulated in Ontario. As a DCO, the clearing house must comply with the DCO Core Principles, including CFTC Regulation 39.13 – Risk management (“CFTC Regulation 39.13”), CFTC Regulation 39.10 – Compliance with rules (“CFTC Regulation 39.10”), and CFTC Regulation 39.18 – System safeguards (“CFTC Regulation 39.18”).

8.2.2 CFTC Regulation 39.13 mandates the appointment by a DCO of a chief risk officer whose duties include implementing

a Board-approved written risk management framework. CFTC Regulation 39.10 mandates the appointment by a DCO of a chief compliance officer (“CCO”) whose duties include review of the DCO’s written policies and procedures and compliance with each DCO Core Principle, including the risk management framework implemented by the CRO under CFTC Regulation 39.13. The CCO’s review of the DCO’s policies and procedures is included in an annual compliance report submitted to the CFTC.

8.2.3 CFTC Regulation 39.18(b) mandates the establishment and maintenance of a program of risk analysis and oversight

with respect to the DCO’s operations and automated systems. CFTC Regulation 39.18(j) further requires that a DCO’s automated systems and business continuity and disaster recovery capabilities be tested by objective, independent and qualified professionals on a periodic basis. Service Organization Control 1 and 2 audits that meet the requirements of CFTC Regulation 39.18(j) are conducted annually.

9. Systems and Technology 9.1 System and Technology – Each of the exchange’s critical systems has appropriate internal controls to ensure

completeness, accuracy, integrity and security of information, and, in addition, has sufficient capacity and business continuity plans to enable the exchange to properly carry on its business. Critical systems are those that support the following functions: (a) order entry, (b) order routing, (c) execution, (d) trade reporting, (e) trade comparison, (f) data feeds, (g) market surveillance, (h) trade clearing, and (i) financial reporting.

9.1.1 The Applicant’s Facility has appropriate internal controls to ensure completeness, accuracy, integrity and security of information, and, in addition, has sufficient capacity and business continuity plans to enable the exchange to properly carry on its business.

9.1.2 The Applicant has put safeguards and security tools in place to protect the critical data and system components of its

Facility. As discussed in paragraph 5.1.3 above, the Applicant outsources its automated trade surveillance capable of detecting potential trade practice and violations of the Applicant’s Rulebook to the NFA, while maintaining full responsibility for compliance obligations.

9.1.3 The Applicant captures and retains all audit trail data necessary to detect, investigate, and prevent customer and

market abuses. Such data shall be sufficient to reconstruct all trades and trade-related activity within a reasonable


May 18, 2017

(2017), 40 OSCB 4576

period of time and to provide evidence of any violations of the rules of the Applicant. The Applicant has also developed risk monitoring tools and risk controls to prevent and reduce the potential risk of market disruptions, including but not limited to market restrictions that could pause or halt trading under market conditions prescribed by the Applicant.

9.1.4 The Applicant has established a Business Continuity Plan and Disaster Recovery document with respect to the Facility.

The plan describes the Applicant’s response to and address both small-scale and wide-scale service disruptions to the Applicant’s Facility. The main objectives of the Applicant’s Business Continuity Plan and Disaster Recovery document is to enable timely recovery and resumption of the Facility’s operation and the resumption of the Applicant’s fulfillment of its responsibilities and obligations following any disruptions to Facility operations, including: order processing and trade matching; transmission of matched orders to DCOs for clearing; price reporting; market surveillance; and maintenance of a comprehensive audit trail.

9.1.5 The Applicant operates and provides to participants a robust and scalable platform. Standard system monitoring

metrics include capacity and performance level alerts. In addition to system level monitoring of capacity and performance of resources, the Applicant also conducts standardized application or platform capacity tests on a regular basis. This ensures the platform is well positioned to provide adequate responsiveness to customers. The data generated from these tests are used to establish present and historical benchmarks to identify performance and/or capacity hot spots or deficiencies. Additional resources are deployed where appropriate to resolve performance or capacity issues outside of the benchmark to bring performance back in line with benchmark expectation.

9.1.6 Please see Section 8 with respect to the Applicant’s clearing and settlement arrangements. 9.2 Without limiting the generality of section 9.1, for each of its systems supporting order entry, order routing,

execution, data feeds, trade reporting and trade comparison, the exchange: (a) makes reasonable current and future capacity estimates; (b) conducts capacity stress tests to determine the ability of those systems to process transactions in an

accurate, timely and efficient manner; (c) reviews the vulnerability of those systems and data centre computer operations to internal and

external threats, including physical hazards and natural disasters; (d) ensures that safeguards that protect a system against unauthorized access, internal failures, human

errors, attacks and natural catastrophes that might cause improper disclosures, modification, destruction or denial of service are subject to an independent and ongoing audit which should include the physical environment, system capacity, operating system testing, documentation, internal controls and contingency plans;

(e) ensures that the configuration of the system has been reviewed to identify potential points of failure,

lack of back-up and redundant capabilities; (f) maintains reasonable procedures to review and keep current the development and testing

methodology of those systems; and (g) maintains reasonable back-up, contingency and business continuity plans, disaster recovery plans

and internal controls.

9.2.1 The Applicant’s Facility uses technology that is used for electronic trading platforms operated by affiliates of the Applicant (see discussion of outsourcing in paragraph 14.1.1 below).

9.2.2 The Applicant’s Facility makes capacity estimates by regularly monitoring its systems usage as well as maintaining

constant communications between internal parties whenever new business or possible changes in the market may increase capacity on the systems.

9.2.3 The Applicant conducts regular performance and capacity tests in a production test environment which matches

production in its size, scope and infrastructure. Testing is described in paragraph 9.1.5 above. 9.2.4 The Applicant has internal policies and controls that govern system access, failures, and errors. Also, the Applicant

and/or its service providers periodically conduct risk audits, internal physical security compliance inspections and covert internal and external intrusion tests. Additionally, the Applicant performs cybersecurity vulnerability testing weekly. Such tests are designed to periodically assess the operating effectiveness of security controls as well as to


May 18, 2017

(2017), 40 OSCB 4577

monitor internal compliance with security policies and procedures. External threats such as physical hazards and natural disasters are addressed in the Applicant’s Business Continuity Plan and Disaster Recovery document.

9.2.5 The Applicant and/or its service providers review the configuration of its systems as part of its regular control

procedures and conducts reviews as needed when issues are identified and resolved through is Information Technology Service Management protocols. Configuration management is the subject of internal audits and is also included in the Applicant’s Disaster Recovery tests.

9.2.6 The Applicant reviews and keeps current the development and testing methodology of the Systems pursuant to

procedures contained in the Applicant’s Compliance Manual, and Business Continuity Plan and Disaster Recovery document. The Applicant’s Business Continuity Plan and Disaster Recovery document is designed to allow for the recovery and resumption of operations and the fulfillment of the duties and obligations of the Applicant following a disruption. The Applicant performs periodic tests to verify that the resources outlined in the Business Continuity Plan and Disaster Recovery document are sufficient to ensure continued fulfillment of all duties of the Applicant under FCA regulations, the CEA and CFTC Regulations.

9.2.7 Complete backups are stored in an approved off-site storage facility pursuant to the Applicant’s Business Continuity

Plan and Disaster Recovery document. This data is retained off-site for an appropriate amount of time (daily, weekly, or monthly), depending on the specific need of the application.

9.3 Information Technology Risk Management Procedures – The exchange has appropriate risk management

procedures in place including those that handle trading errors, trading halts and respond to market disruptions and disorderly trading.

9.3.1 The Applicant provides extensive market integrity controls to ensure fair and efficient markets. The Applicant uses risk

monitoring tools and risk controls to prevent and reduce the potential risk of market disruptions, including the following: (i) price outlier detection tool; (ii) pricing change monitoring tool; (iii) trading kill switch; (iv) notional outlier size limitations; (v) authorized trader lists and asset class limitations; (vi) trade rejection capability; and (vii) trade cancellation capability.

10. Financial Viability 10.1 Financial Viability – The exchange has sufficient financial resources for the proper performance of its

functions and to meet its responsibilities. 10.1.1 The Applicant has adequate financial and staff resources to carry on its activities in full compliance with its regulatory

requirements and with best practices. Under U.S. SEF Regulations, a SEF must submit financial statements to the CFTC and maintain adequate financial resources to cover its operating costs for a period of at least one year, calculated on a rolling basis. A SEF must also hold liquid financial assets equal to at least six months’ operating costs. The Applicant maintains the current minimum capital amounts needed, and will maintain any future minimum capital amounts needed, to meet CFTC requirements.

11. Transparency 11.1 Trading Practices – Trading Practices are fair, properly supervised and not contrary to the public interest. 11.1.1 The Applicant is obligated to comply with U.S. SEF Regulations, which, as described in 6.1.2 above, require trading

practices that are fair, properly supervised and not contrary to the public interest. The U.S. SEF Regulations also require that the Applicant implements rules that require compliance with the U.S. SEF Regulations by its participants. The Applicant’s Rulebook, which address SEF trading practices, are subject to the standards and requirements outlined by the SEF Core Principles. At a high level, the SEF Core Principles and Applicant’s Rulebook both seek to ensure fair and orderly markets accessible to all eligible participants that are properly supervised and operated in a manner consistent with the public interest.

11.2 Orders – Rules pertaining to order size and limits are fair and equitable to all market participants and the

system for accepting and distinguishing between and executing different types of orders is fair, equitable and transparent.

11.2.1 Rules pertaining to order size and limits are set forth in Chapter 4 of the Rulebook. As noted in 11.1.1 above, the

Applicant’s Rulebook is subject to the standards and requirements outlined by the SEF Core Principles, and are subject to periodic review by the Applicant to ensure that the limits are fair, equitable and appropriate for the market. The Applicant submits that its rules for accepting and distinguishing between and executing different types of orders is fair, equitable and transparent.


May 18, 2017

(2017), 40 OSCB 4578

11.3 Transparency – The exchange has adequate arrangements to record and publish accurate and timely information as required by the Foreign Regulator. This information is also provided to all participants on an equitable basis.

11.3.1 Core Principle 9 requires a SEF to make public timely information concerning swaps transactions executed on the SEF.

The Applicant fulfills Core Principle 9 by posting trade data to its website daily, including previous day high, low, open and close price and total volume, and by reporting swaps data to DTCC, the swaps data repository for the Applicant’s Facility.

12. Compliance, Surveillance and Enforcement 12.1 Jurisdiction – The exchange or the Foreign Regulator has the jurisdiction to perform member and market

regulation, including the ability to set rules, conduct compliance reviews and perform surveillance and enforcement.

12.1.1 The Applicant operates a Facility that is regulated by the FCA (as an MTF) and the CFTC as a SEF. A SEF is a self-

regulatory organization under CFTC rules and has certain obligations to monitor participants' trading activity on the Facility under Sections 37.203(e), 37.401, 37.402 and 37.403 of the CEA.

12.2 Member and Market Regulation – The exchange or the Foreign Regulator maintains appropriate systems,

resources and procedures for evaluating compliance with exchange and legislative requirements and for disciplining participants.

12.2.1 Core Principle 2 requires a SEF to collect information, examine members’ records, direct supervision of the market,

maintain sufficient compliance staff, establish procedures for and conduct audit trail reviews, perform real-time market monitoring and market surveillance and establish an automated trade surveillance system. The Applicant has instituted all these controls and has adequate resources available to ensure that controls are properly applied. Principle 2 also requires a SEF to adopt a rule enforcement program, disciplinary procedures and sanctions. Section 7 of this application describes the resources available to the Facility to investigate and discipline participants for rule violations. Also, Chapter 5 of the Applicant’s Rulebook sets out the Applicant’s disciplinary rules and Chapter 7 prescribes the Applicant’s dispute resolution procedures.

12.2.2 The CCO and the Head of Compliance and Oversight (the “CF10”) are both appointed by the Board and assist the

Applicant in meeting its regulatory obligations, as set out by the CFTC and the FCA, respectively. References by the Applicant to the “Compliance Function” is intended to mean, for CFTC related considerations, the CCO and, for FCA related considerations, the CF10. To the extent that any of the activities concern both the CFTC and FCA, the CCO and the CF10 co-operate to ensure compliance with the respective regulations.

12.2.3 It is the duty of the Compliance Function to enforce the Facility’s rules and to assess the quality of its compliance

oversight and disciplinary policies and procedures. As noted in this application, the Applicant’s market regulation staff, under the direction and direct supervision of the Compliance Function, is responsible for conducting investigations of possible violations of any of the Applicant’s rules (“Violations”), preparing written reports with respect to such investigations, furnishing such reports to the Facility’s disciplinary panels and conducting the prosecution of any Violations in accordance with Chapter 5 of the Rulebook. The Compliance Function, on an ongoing basis, reviews the performance of staff and, where necessary, establishes procedures for the remediation of noncompliance issues. The Compliance Function (including the CCO and the CF10) reports directly to the Board. The CCO is supervised by the Board’s Regulatory Oversight Committee. The Compliance Function is required to meet with the committee at least quarterly and review the Facility’s self-regulatory program, including compliance oversight and disciplinary processes. The Regulatory Oversight Committee reviews the performance of the Compliance Function and prepares an annual report to the Board and the CFTC assessing the self-regulatory programs of the Facility, including a description of the program, the expenses of the program, the staffing and structure of the program, a catalog of investigations and disciplinary actions taken during the year, and a review of the performance of the disciplinary panels and the CCO.

12.3 Availability of Information to Regulators – The exchange has mechanisms in place to ensure that the

information necessary to conduct adequate surveillance of the system for supervisory or enforcement purposes is available to the relevant regulatory authorities, including the Commission, on a timely basis.

12.3.1 Please see paragraph 16.1.1 below.


May 18, 2017

(2017), 40 OSCB 4579

13. Record Keeping 13.1 Record Keeping – The exchange has and maintains adequate systems in place for the keeping of books and

records, including, but not limited to, those concerning the operations of the exchange, audit trail information on all trades, and compliance with, and/or violations of exchange requirements.

13.1.1 The Applicant collects data on a daily basis related to its regulated activity in compliance with Core Principle 10 –

Recordkeeping and Reporting. The Applicant is required to maintain records of all activities relating to its business, including data related to order messaging, order execution and pricing. Data is collected from across the Facility, independent of whether the transaction was privately negotiated or matched in the central limit order book. The Applicant maintains a precise and complete data history, referred to as the audit trail, for every order entered and transaction executed across the Facility. Audit trail information for each transaction includes the order instructions, entry time, modification time, execution time, price, quantity, account identifier and parties to the transaction. On a daily basis, files of all electronic order and cleared trade information are archived to non-rewritable media, and copies are stored at multiple locations to ensure redundancy and critical safeguarding of the data. Furthermore, as a safeguard, the CFTC and the Applicant require participants to maintain all audit trail data for a minimum of five years.

14. Outsourcing 14.1 Outsourcing – Where the exchange has outsourced any of its key services or systems to a service provider, it

has appropriate and formal arrangements and processes in place that permit it to meet its obligations and that are in accordance with industry best practices.

14.1.1 The Applicant has entered into several licensing and services agreements with affiliates and unaffiliated third parties for

the use of (i) credit checking and trade reporting technology, (ii) the Facility’s matching engine, (iii) front, middle and back office functionality (including trade input and execution, booking and confirmation, monitoring, invoicing and billing), (iv) software and (v) various support services, including operations and compliance support, trade reporting, books and records, on-boarding of clients, telecommunications and information technology. These agreements permit the Applicant to meet its obligations and are in accordance with industry best practices. The outsourcing arrangements have terms that allow the Applicant to monitor the services provided to ensure that the Applicant meets its regulatory obligations with respect to the outsourced service and that the any services are provided in accordance with industry best practices. The Applicant at all times retains responsibility for any functions delegated to any service provider, including the NFA, and the ultimate decision making authority.

14.1.2 As described more fully in paragraph 5.1.2 above, the Applicant has contracted with the NFA to perform certain

surveillance, investigative and regulatory functions under the Applicant’s Rulebook. 15. Fees 15.1 Fees

(a) All fees imposed by the exchange are reasonable and equitably allocated and do not have the effect of creating an unreasonable condition or limit on access by participants to the services offered by the exchange.

15.1.1 The CFTC requires that the Applicant must charge comparable fees for participants receiving comparable access to, or

services from, the Facility. The Applicant complies with this requirement and therefore fees charged by the Applicant do not create an unreasonable condition or limit on access by participants. (b) The process for setting fees is fair and appropriate, and the fee model is transparent.

15.1.2 The Applicant is required by CFTC Regulations and the FCA to charge all Participants fees that are impartial, transparent and applied in a fair and non-discriminatory manner. The Board of the Applicant has the sole authority to set the times and amounts of any assessments or fees to be paid by participants. All fee changes must be submitted to the CFTC for certification or approval under Part 40 of the CFTC Regulation prior to their implementation. The Applicant provides its fee schedule to each participant.


May 18, 2017

(2017), 40 OSCB 4580

16. Information Sharing and Oversight Arrangements 16.1 Information Sharing and Regulatory Cooperation – The exchange has mechanisms in place to enable it to

share information and otherwise cooperate with the Commission, self-regulatory organizations, other exchanges, clearing agencies, investor protection funds, and other appropriate regulatory bodies.

16.1.1 It is the Applicant’s policy to respond promptly and completely, through the legal and compliance departments, to any

proper regulatory inquiry or request for documents. All inquiries and other communications from the Commission will be referred immediately to the Applicant’s legal and compliance departments.

16.1.2 Rule 206 of the Rulebook authorizes the Applicant to enter into information-sharing agreements or other arrangements

or procedures necessary to allow the Applicant to obtain any necessary information to perform any monitoring of trading and trade processing, provide information to other markets, the CFTC, the FCA, the Ontario Securities Commission or any other governmental body with jurisdiction over the Applicant upon request and which allow the Applicant to carry out such international information-sharing agreements as may be required. Also, the Applicant may enter into any information-sharing arrangement with any person or body (including the CFTC, the FCA, the Ontario Securities Commission, the NFA, any self-regulatory organization, any SEF, DCM, market, clearing organization or any Governmental Body). The Applicant shares or will share information with DTCC (as a designated swap repository) and LCH (as clearing agency for cleared trades).

16.2 Oversight Arrangements – Satisfactory information sharing and oversight agreements exist between the

Ontario Securities Commission and the Foreign Regulator. 16.2.1 The FCA and CFTC have entered into memorandum of understanding (“MOU”) arrangements for co-operative

enforcements with foreign regulatory authorities in numerous jurisdictions. The MOUs typically provide for access to non-public documents and information already in the possession of the regulatory authorities, and often include undertakings to obtain documents and to take testimony of, or statements from, witnesses on behalf of a requesting regulatory authority. The FCA, the Bank of England and the Commission are parties to an MOU that came into effect on August 21, 2013. The CFTC and the Commission are parties to an MOU that was entered into by the parties on March 25, 2014. The MOU is available at: https://www.osc.gov.on.ca/en/About_mou_20140327_nmou-covered-entities.htm.

17. IOSCO Principles 17.1 IOSCO Principles – To the extent it is consistent with the laws of the foreign jurisdiction, the exchange adheres

to the standards of the International Organisation of Securities Commissions (IOSCO) including those set out in the “Principles for the Regulation and Supervision of Commodity Derivatives Markets” (2011).

17.1.1 The Applicant adheres to the standards of IOSCO by virtue of the fact that it must comply with the CEA and CFTC

Regulations, which reflect the IOSCO standards. The Applicant is regularly examined by the FCA and CFTC and during these examinations the IOSCO standards to which they are subject are taken into account.

PART IV SUBMISSIONS BY THE APPLICANT 1.1 The swaps that trade on the Applicant’s Facility fall under the definition of “derivative” set out in subsection 1(1) of the

Act. The Facility operated by the Applicant falls under the definition of “marketplace” set out in subsection 1(1) of the Act because it brings together buyers and sellers of derivatives and uses established, non-discretionary methods under which orders interact with each other.

1.2 An “exchange” is not defined under the Act; however, subsection 3.1(1) of the companion policy to National Instrument

21-101 – Marketplace Operation provides that a “marketplace” is considered to be an “exchange” if it, among other things, sets requirements governing the conduct of marketplace participants or disciplines marketplace participants. A SEF is a self-regulatory organization under CFTC rules and has certain obligations to monitor participants’ trading activity. Because a SEF regulates the conduct of its participants, it is considered by the Commission to be an exchange for purposes of the Act.

1.3 Pursuant to OSC Staff Notice 21-702 – Regulatory Approach for Foreign-Based Stock Exchanges, the Commission

considers an exchange located outside Ontario to be carrying on business as an exchange in Ontario if it provides Ontario Participants with direct access to the exchange. Since the Applicant provides Ontario Participants with direct access to trading derivatives on its Facility, it is considered by the Commission to be “carrying on business as an exchange” in Ontario and therefore must either be recognized or exempt from recognition by the Commission.


May 18, 2017

(2017), 40 OSCB 4581

1.4 The Applicant satisfies all the criteria for exemption from recognition as an exchange set out by Commission Staff, as described under Part III of this application. Ontario market participants that trade in swaps would benefit from the ability to trade on the Applicant’s Facility, as they would have access to a range of swaps and swap counterparties that otherwise may not be available in Ontario. Stringent FCA and CFTC oversight of the Applicant’s Facility as well as the sophisticated information systems, regulations and compliance functions that have been adopted by the Applicant will ensure that Ontario users of the Facility are adequately protected in accordance with international standards set by IOSCO.

1.5 Based on the foregoing, we submit that it would not be prejudicial to the public interest to grant the Requested Relief. PART V CONSENT TO PUBLICATION The Applicant consents to the publication of this application for public comment. Yours very truly, “Steven Bartfield” Chief Compliance Officer c. Blair Wiley, Osler, Hoskin & Harcourt LLP


May 18, 2017

(2017), 40 OSCB 4582

ANNEX II

DRAFT ORDER


R.S.O. 1990, CHAPTER S. 5, AS AMENDED (THE ACT)

AND

IN THE MATTER OF NEX SEF LIMITED

ORDER

(Section 147 of the Act)

WHEREAS NEX SEF Limited (Applicant) has filed an application dated May 1, 2017 (Application) with the Ontario Securities Commission (Commission) requesting an order pursuant to section 147 of the Act exempting the Applicant from the requirement to be recognized as an exchange under subsection 21(1) of the Act (Exchange Relief); AND WHEREAS the United States Commodity Futures Trading Commission (CFTC) granted the Applicant permanent registration as a swap execution facility (SEF) on April 20, 2017; AND WHEREAS the Applicant has represented to the Commission that: 1.1 The Applicant is a limited liability company organized under the laws of England and Wales. The ultimate parent

company of the Applicant is NEX Group plc, a company listed on the London Stock Exchange; 1.2 The Applicant is regulated by the Financial Conduct Authority of the United Kingdom (the FCA) and is authorised,

among other things, to (i) arrange (bring about) deals in investments (ii) deal in investments as agent (iii) make arrangements with a view to transactions in investments; and (iv) operate a multilateral trading facility (MTF). The Applicant also has passporting rights under the European Markets in Financial Instruments Directive 2004/39/EC (MiFID) which allows the applicant to provide services throughout the European Economic Area (EEA);

1.3 The Applicant is a marketplace for trading derivatives that are regulated as swaps by the CFTC. The Applicant's SEF

supports order book functionality. Additional trading functionality may be added in the future, subject to obtaining any required regulatory approvals;

1.4 In the United States, the Applicant operates under the jurisdiction of the CFTC and obtained registration with the CFTC

to operate a SEF on April 20, 2017; 1.5 The Applicant is obliged under CFTC rules to have requirements governing the conduct of participants, to monitor

compliance with those requirements and to discipline participants, including by means other than exclusion from the marketplace;

1.6 The Applicant has retained the National Futures Association to be a regulatory services provider (RSP); 1.7 Because the Applicant regulates the conduct of its participants, it is considered by the Commission to be an exchange; 1.8 Because the Applicant has participants located in Ontario, it is considered by the Commission to be carrying on

business as an exchange in Ontario and is required to be recognized as such or exempted from recognition pursuant to section 21 of the Act;

1.9 The Applicant provides connectivity to LCH.Clearnet Limited; 1.10 The Applicant has no physical presence in Ontario and does not otherwise carry on business in Ontario except as

described above; and 1.11 The Applicant satisfies all the SEF Criteria as described in Appendix 1 to Schedule “A”.


May 18, 2017

(2017), 40 OSCB 4583

AND WHEREAS the products traded on the Applicant are not commodity futures contracts as defined in the Commodity Futures Act (Ontario) and the Applicant is not considered to be carrying on business as a commodity futures exchange in Ontario; AND WHEREAS the Applicant has acknowledged to the Commission that the scope of the Exchange Relief and the terms and conditions imposed by the Commission attached hereto as Schedule “A” to this order, or the determination whether it is appropriate that the Applicant continue to be exempted from the requirement to be recognized as an exchange, may change as a result of the Commission’s monitoring of developments in international and domestic capital markets or the Applicant’s activities, or as a result of any changes to the laws in Ontario affecting trading in derivatives or securities; AND WHEREAS based on the Application, together with the representations made by and acknowledgements of the Applicant to the Commission, the Commission has determined that the Applicant satisfies the criteria set out in Appendix 1 to Schedule “A” and that the granting of the Exchange Relief would not be prejudicial to the public interest; IT IS HEREBY ORDERED by the Commission that, pursuant to section 147 of the Act, the Applicant is exempt from recognition as an exchange under subsection 21(1) of the Act, PROVIDED THAT the Applicant complies with the terms and conditions contained in Schedule “A.” DATED ______________, 2017. __________________________________ __________________________________


May 18, 2017

(2017), 40 OSCB 4584

SCHEDULE “A”

TERMS AND CONDITIONS

Meeting Criteria for Exemption 1. The Applicant will continue to meet the criteria for exemption included in Appendix 1 to this Schedule. Regulation and Oversight of the Applicant 2. The Applicant will maintain its registration as a swap execution facility (SEF) with the Commodity Futures Trading

Commission (CFTC) and will continue to be subject to the regulatory oversight of the CFTC. 3. The Applicant will continue to comply with the ongoing requirements applicable to it as a SEF registered with the

CFTC. 4. The Applicant will promptly notify the Commission if its registration as a SEF has been revoked, suspended, or

amended by the CFTC, or the basis on which its registration as a SEF has been granted has significantly changed. 5. The Applicant must do everything within its control, which includes cooperating with the Commission as needed, to

carry out its activities as an exchange exempted from recognition under subsection 21(1) of the Act in compliance with Ontario securities law.

Access 6. The Applicant will not provide direct access to a participant in Ontario (Ontario User) unless the Ontario User is

appropriately registered as applicable under Ontario securities laws or is exempt from or not subject to those requirements, and qualifies as an “eligible contract participant” under the United States Commodity Exchange Act, as amended (CEA).

7. For each Ontario User provided direct access to its SEF, the Applicant will require, as part of its application

documentation or continued access to the SEF, the Ontario User to represent that it is appropriately registered as applicable under Ontario securities laws or is exempt from or not subject to those requirements.

8. The Applicant may reasonably rely on a written representation from the Ontario User that specifies either that it is

appropriately registered as applicable under Ontario securities laws or is exempt from or not subject to those requirements, provided the Applicant notifies such Ontario User that this representation is deemed to be repeated each time it enters an order, request for quote or response to a request for quote on the Applicant.

9. The Applicant will require Ontario Users to notify the Applicant if their registration as applicable under Ontario securities

laws has been revoked, suspended, or amended by the Commission or if they are no longer exempt from or become subject to those requirements and, following notice from the Ontario User and subject to applicable laws, the Applicant will promptly restrict the Ontario User’s access to the Applicant if the Ontario User is no longer appropriately registered or exempt from those requirements.

10. The Applicant must make available to Ontario Users appropriate training for each person who has access to trade on

the Applicant’s facilities. Trading by Ontario Users 11. The Applicant will not provide access to an Ontario User to trading in products other than swaps, as defined in section

1a(47) of the CEA (and for greater certainty, excluding security-based swaps), without prior Commission approval. Submission to Jurisdiction and Agent for Service 12. With respect to a proceeding brought by the Commission arising out of, related to, concerning or in any other manner

connected with the Commission’s regulation and oversight of the activities of the Applicant in Ontario, the Applicant will submit to the non-exclusive jurisdiction of (i) the courts and administrative tribunals of Ontario and (ii) an administrative proceeding in Ontario.

13. The Applicant will file with the Commission a valid and binding appointment of an agent for service in Ontario upon

whom the Commission may serve a notice, pleading, subpoena, summons or other process in any action, investigation


May 18, 2017

(2017), 40 OSCB 4585

or administrative, criminal, quasi-criminal, penal or other proceeding arising out of, related to, concerning or in any other manner connected with the Commission’s regulation and oversight of the Applicant’s activities in Ontario.

Disclosure 14. The Applicant will provide to its Ontario Users disclosure that states that:

(a) rights and remedies against the Applicant may only be governed by the laws of the U.S., rather than the laws

of Ontario and may be required to be pursued in the U.S. rather than in Ontario; and (b) the rules applicable to trading on the Applicant may be governed by the laws of the U.S., rather than the laws

of Ontario.

Prompt Reporting 15. The Applicant will notify staff of the Commission promptly of:

(a) any material change to its business or operations or the information provided in the Application, including, but

not limited to: (i) changes to the regulatory oversight by the CFTC; (ii) the corporate governance structure of the Applicant; (iii) the access model, including eligibility criteria, for Ontario Users; (iv) systems and technology; and (v) the clearing and settlement arrangements for the Applicant;

(b) any change in the Applicant’s regulations or the laws, rules and regulations in the U.S. relevant to swaps where such change may materially affect its ability to meet the criteria set out in Appendix 1 to this Schedule;

(c) any condition or change in circumstances whereby the Applicant is unable or anticipates it will not be able to

continue to meet the SEF Core Principles established in section 5h of the CEA and Part 37 of the CFTC’s regulations or any other applicable requirements of the CEA or CFTC regulations;

(d) any known investigations of, or any disciplinary action against the Applicant by the CFTC or any other

regulatory authority which it is subject to; (e) any matter known to the Applicant that may materially and adversely affect its financial or operational viability,

including, but not limited to, any declaration of an emergency pursuant to the Applicant’s rules; (f) any default, insolvency, or bankruptcy of a participant of the Applicant known to the Applicant or its

representatives that may have a material, adverse impact upon the Applicant; and (g) any material systems outage, malfunction or delay.

16. The Applicant will promptly provide staff of the Commission with notice of any made available to trade determination that it files with the CFTC under the regulations pertaining to self-certification and/or approval.

17. The Applicant will promptly provide staff of the Commission with the following information to the extent it is required to

provide to or file such information with the CFTC: (a) details of any material legal proceeding instituted against the Applicant; (b) notification that the Applicant has instituted a petition for a judgment of bankruptcy or insolvency or similar

relief, or to wind up or liquidate the Applicant or has a proceeding for any such petition instituted against it; and

(c) the appointment of a receiver or the making of any voluntary arrangement with creditors.


May 18, 2017

(2017), 40 OSCB 4586

18. The Applicant will promptly file with staff of the Commission copies of any Rule Enforcement Review report regarding the Applicant once issued as final by the CFTC.

Quarterly Reporting 19. The Applicant will maintain the following updated information and submit such information in a manner and form

acceptable to the Commission on a quarterly basis (within 30 days of the end of each calendar quarter), and at any time promptly upon the request of staff of the Commission: (a) a current list of all Ontario Users and whether the Ontario User is registered under Ontario securities laws or is

exempt from or not subject to registration, and, to the extent known by the Applicant, other persons or companies located in Ontario trading as customers of participants (Other Ontario Participants);

(b) the legal entity identifier assigned to each Ontario User, and, to the extent known by the Applicant, to Other

Ontario Participants in accordance with the standards set by the Global Legal Entity Identifier System; (c) a list of all Ontario Users against whom disciplinary action has been taken in the last quarter by the Applicant

or its RSP acting on its behalf, or, to the best of the Applicant’s knowledge, by the CFTC with respect to such Ontario Users’ activities on the Applicant and the aggregate number of disciplinary actions taken against all participants in the last quarter by the Applicant or its RSP acting on its behalf;

(d) a list of all active investigations during the quarter by the Applicant or its RSP acting on its behalf relating to

Ontario Users and the aggregate number of active investigations during the quarter relating to all participants undertaken by the Applicant;

(e) a list of all Ontario applicants for status as a participant who were denied such status or access to the

Applicant during the quarter, together with the reasons for each such denial; (f) copies of all amendments to the Applicant’s Form SEF filed with the CFTC during the quarter, including, but

not limited to, any amendments to the Applicant’s trading rules; (g) a list of all additions, deletions, or changes to the products available for trading since the prior quarter; (h) for each product,

(i) the total trading volume and value originating from Ontario Users, and, to the extent known by the

Applicant, from Other Ontario Participants, presented on a per Ontario User or per Other Ontario Participant basis; and

(ii) the proportion of worldwide trading volume and value on the Applicant conducted by Ontario Users,

and, to the extent known by the Applicant, by Other Ontario Participants, presented in the aggregate for such Ontario Users and Other Ontario Participants;

provided in the required format; and

(i) a list outlining each incident of a security breach, systems failure, malfunction or delay (including cyber security breaches, systems failures, malfunctions or delays reported under section 15(g) of this Schedule) that occurred at any time during the quarter for any system relating to trading activity, including trading, routing or data, specifically identifying the date, duration and reason, to the extent known or ascertainable by the Applicant, for the failure, malfunction or delay, and noting any corrective action taken.

Annual Reporting 20. The Applicant will file with the Commission any annual report or annual financial statements (audited or unaudited) of

the Applicant provided to or filed with the CFTC promptly after filing with the CFTC. 21. The Applicant will arrange to have any annual “Service Organization Controls 1” report prepared for the Applicant filed

with the Commission promptly after the report is issued as final by its independent auditor.


May 18, 2017

(2017), 40 OSCB 4587

Information Sharing 22. The Applicant will provide and cause its RSP to provide such information as may be requested from time to time by,

and otherwise cooperate with, the Commission or its staff, subject to any applicable privacy or other laws (including solicitor-client privilege) governing the sharing of information and the protection of personal information.


May 18, 2017

(2017), 40 OSCB 4588

APPENDIX 1

CRITERIA FOR EXEMPTION OF A FOREIGN EXCHANGE TRADING OTC DERIVATIVES FROM RECOGNITION AS AN EXCHANGE

PART 1 REGULATION OF THE EXCHANGE 1.1 Regulation of the Exchange The exchange is regulated in an appropriate manner in another jurisdiction by a foreign regulator (Foreign Regulator). 1.2 Authority of the Foreign Regulator The Foreign Regulator has the appropriate authority and procedures for oversight of the exchange. This includes regular, periodic oversight reviews of the exchange by the Foreign Regulator. PART 2 GOVERNANCE 2.1 Governance The governance structure and governance arrangements of the exchange ensure:

(a) effective oversight of the exchange, (b) that business and regulatory decisions are in keeping with its public interest mandate, (c) fair, meaningful and diverse representation on the board of directors (Board) and any committees of the

Board, including: (i) appropriate representation of independent directors, and (ii) a proper balance among the interests of the different persons or companies using the services and

facilities of the exchange,

(d) the exchange has policies and procedures to appropriately identify and manage conflicts of interest for all officers, directors and employees, and

(e) there are appropriate qualifications, remuneration, limitation of liability and indemnity provisions for directors,

officers and employees of the exchange.

2.2 Fitness The exchange has policies and procedures under which it will take reasonable steps, and has taken such reasonable steps, to ensure that each director and officer is a fit and proper person and past conduct of each officer or director affords reasonable grounds for belief that the officer or director will perform his or her duties with integrity. PART 3 REGULATION OF PRODUCTS 3.1 Review and Approval of Products The products traded on the exchange and any changes thereto are submitted to the Foreign Regulator, and are either approved by the Foreign Regulator or are subject to requirements established by the Foreign Regulator that must be met before implementation of a product or changes to a product. 3.2 Product Specifications The terms and conditions of trading the products are in conformity with the usual commercial customs and practices for the trading of such products. 3.3 Risks Associated with Trading Products The exchange maintains adequate provisions to measure, manage and mitigate the risks associated with trading products on the exchange that may include, but are not limited to, daily trading limits, price limits, position limits, and internal controls.


May 18, 2017

(2017), 40 OSCB 4589

PART 4 ACCESS 4.1 Fair Access

(a) The exchange has established appropriate written standards for access to its services including requirements

to ensure (i) participants are appropriately registered as applicable under Ontario securities laws, or exempted

from these requirements, (ii) the competence, integrity and authority of systems users, and (iii) systems users are adequately supervised.

(b) The access standards and the process for obtaining, limiting and denying access are fair, transparent and applied reasonably.

(c) The exchange does not unreasonably prohibit, condition or limit access by a person or company to services

offered by it. (d) The exchange does not

(i) permit unreasonable discrimination among participants, or (ii) impose any burden on competition that is not reasonably necessary and appropriate.

(e) The exchange keeps records of each grant and each denial or limitation of access, including reasons for granting, denying or limiting access.

PART 5 REGULATION OF PARTICIPANTS ON THE EXCHANGE 5.1 Regulation The exchange has the authority, resources, capabilities, systems and processes to allow it to perform its regulation functions, whether directly or indirectly through a regulation services provider, including setting requirements governing the conduct of its participants, monitoring their conduct, and appropriately disciplining them for violations of exchange requirements. PART 6 RULEMAKING 6.1 Purpose of Rules

(a) The exchange has rules, policies and other similar instruments (Rules) that are designed to appropriately

govern the operations and activities of participants and do not permit unreasonable discrimination among participants or impose any burden on competition that is not reasonably necessary or appropriate.

(b) The Rules are not contrary to the public interest and are designed to

(i) ensure compliance with applicable legislation, (ii) prevent fraudulent and manipulative acts and practices, (iii) promote just and equitable principles of trade, (iv) foster co-operation and co-ordination with persons or companies engaged in regulating, clearing,

settling, processing information with respect to, and facilitating transactions in the products traded on the exchange,

(v) provide a framework for disciplinary and enforcement actions, and (vi) ensure a fair and orderly market.


May 18, 2017

(2017), 40 OSCB 4590

PART 7 DUE PROCESS 7.1 Due Process For any decision made by the exchange that affects a participant, or an applicant to be a participant, including a decision in relation to access, exemptions, or discipline, the exchange ensures that:

(a) parties are given an opportunity to be heard or make representations, and (b) it keeps a record of, gives reasons for, and provides for appeals or reviews of its decisions.

PART 8 CLEARING AND SETTLEMENT 8.1 Clearing Arrangements The exchange has or requires its participants to have appropriate arrangements for the clearing and settlement of transactions for which clearing is mandatory through a clearing house.1 8.2 Risk Management of Clearing House The exchange has assured itself that the clearing house has established appropriate risk management policies and procedures, contingency plans, default procedures and internal controls. PART 9 SYSTEMS AND TECHNOLOGY 9.1 Systems and Technology Each of the exchange’s critical systems has appropriate internal controls to ensure completeness, accuracy, integrity and security of information, and, in addition, has sufficient capacity and business continuity plans to enable the exchange to properly carry on its business. Critical systems are those that support the following functions:

(a) order entry, (b) order routing, (c) execution, (d) trade reporting, (e) trade comparison, (f) data feeds, (g) market surveillance, (h) trade clearing, and (i) financial reporting.

9.2 System Capability/Scalability Without limiting the generality of section 9.1, for each of its systems supporting order entry, order routing, execution, data feeds, trade reporting and trade comparison, the exchange:

(a) makes reasonable current and future capacity estimates; (b) conducts capacity stress tests to determine the ability of those systems to process transactions in an

accurate, timely and efficient manner; (c) reviews the vulnerability of those systems and data centre computer operations to internal and external

threats, including physical hazards and natural disasters;

1 For the purposes of these criteria, “clearing house” also means a “clearing agency”.


May 18, 2017

(2017), 40 OSCB 4591

(d) ensures that safeguards that protect a system against unauthorized access, internal failures, human errors, attacks and natural catastrophes that might cause improper disclosures, modification, destruction or denial of service are subject to an independent and ongoing audit which should include the physical environment, system capacity, operating system testing, documentation, internal controls and contingency plans;

(e) ensures that the configuration of the system has been reviewed to identify potential points of failure, lack of

back-up and redundant capabilities; (f) maintains reasonable procedures to review and keep current the development and testing methodology of

those systems; and (g) maintains reasonable back-up, contingency and business continuity plans, disaster recovery plans and

internal controls. 9.3 Information Technology Risk Management Procedures The exchange has appropriate risk management procedures in place including those that handle trading errors, trading halts and respond to market disruptions and disorderly trading. PART 10 FINANCIAL VIABILITY 10.1 Financial Viability The exchange has sufficient financial resources for the proper performance of its functions and to meet its responsibilities. PART 11 TRADING PRACTICES 11.1 Trading Practices Trading practices are fair, properly supervised and not contrary to the public interest. 11.2 Orders Rules pertaining to order size and limits are fair and equitable to all market participants and the system for accepting and distinguishing between and executing different types of orders is fair, equitable and transparent. 11.3 Transparency The exchange has adequate arrangements to record and publish accurate and timely information as required by applicable law or the Foreign Regulator. This information is also provided to all participants on an equitable basis. PART 12 COMPLIANCE, SURVEILLANCE AND ENFORCEMENT 12.1 Jurisdiction The exchange or the Foreign Regulator has the jurisdiction to perform member and market regulation, including the ability to set rules, conduct compliance reviews and perform surveillance and enforcement. 12.2 Member and Market Regulation The exchange or the Foreign Regulator maintains appropriate systems, resources and procedures for evaluating compliance with exchange and legislative requirements and for disciplining participants. 12.3 Availability of Information to Regulators The exchange has mechanisms in place to ensure that the information necessary to conduct adequate surveillance of the system for supervisory or enforcement purposes is available to the relevant regulatory authorities, including the Commission, on a timely basis.


May 18, 2017

(2017), 40 OSCB 4592

PART 13 RECORD KEEPING 13.1 Record Keeping The exchange has and maintains adequate systems in place for the keeping of books and records, including, but not limited to, those concerning the operations of the exchange, audit trail information on all trades, and compliance with, and/or violations of exchange requirements. PART 14 OUTSOURCING 14.1 Outsourcing Where the exchange has outsourced any of its key services or systems to a service provider, it has appropriate and formal arrangements and processes in place that permit it to meet its obligations and that are in accordance with industry best practices. PART 15 FEES 15.1 Fees

(a) All fees imposed by the exchange are reasonable and equitably allocated and do not have the effect of creating an unreasonable condition or limit on access by participants to the services offered by the exchange.

(b) The process for setting fees is fair and appropriate, and the fee model is transparent.

PART 16 INFORMATION SHARING AND OVERSIGHT ARRANGEMENTS 16.1 Information Sharing and Regulatory Cooperation The exchange has mechanisms in place to enable it to share information and otherwise co-operate with the Commission, self-regulatory organizations, other exchanges, clearing agencies, investor protection funds, and other appropriate regulatory bodies. 16.2 Oversight Arrangements Satisfactory information sharing and oversight agreements exist between the Commission and the Foreign Regulator. PART 17 IOSCO PRINCIPLES 17.1 IOSCO Principles To the extent it is consistent with the laws of the foreign jurisdiction, the exchange adheres to the standards of the International Organisation of Securities Commissions (IOSCO) including those set out in the “Principles for the Regulation and Supervision of Commodity Derivatives Markets” (2011).

May 18, 2017 (2017), 40 OSCB 4593

Index

1727350 Ontario Limited Notice from the Office of the Secretary ..................... 4428 Oral Reasons for Approval of a Settlement ............... 4455 Agueci, Eda Marie Notice of Hearing – s. 144......................................... 4424 Notice from the Office of the Secretary ..................... 4429 Aptitude Investment Management LP Name Change ........................................................... 4555 CHC Student Housing Corp. Cease Trading Order ................................................ 4463 Cheng, Benedict Notice from the Office of the Secretary ..................... 4428 Reasons and Decision on Settlement – s. 127 ......... 4451 Craig, Dave Garnet Notice from the Office of the Secretary ..................... 4428 Oral Reasons for Approval of a Settlement ............... 4455 CSA Staff Notice 31-350 Guidance on Small Firms Compliance and Regulatory Obligations Notice ........................................................................ 4417 Davis, Larry Keith Notice from the Office of the Secretary ..................... 4431 Order – ss. 127(1), 127(10) ....................................... 4449 Reasons – ss. 127(1), 127(10) .................................. 4462 Dhanani, Ayaz Notice from the Office of the Secretary ..................... 4430 Order – ss. 127(1), 127(10) ....................................... 4444 Decision and Reasons – ss. 127(1), 127(10) ............ 4457 Dhanani, Paul Notice from the Office of the Secretary ..................... 4430 Order – ss. 127(1), 127(10) ....................................... 4444 Decision and Reasons – ss. 127(1), 127(10) ............ 4457 Dundee Acquisition Ltd. Order – s. 1(6) of the OBCA ...................................... 4441 Order ......................................................................... 4443 Ellipsiz Communications Ltd. Cease Trading Order ................................................ 4463 Federal Way Asset Management LP Name Change ........................................................... 4555 Fiorillo, Henry Notice of Hearing – s. 144......................................... 4424 Notice from the Office of the Secretary ..................... 4429

Fiorini, Giuseppe (Joseph) Notice of Hearing – s. 144 ........................................ 4424 Notice from the Office of the Secretary .................... 4429 Front Street Capital 2004 Name Change .......................................................... 4555 Genus Capital Management Inc. Decision .................................................................... 4433 Godwin, Marianne Notice from the Office of the Secretary .................... 4428 Oral Reasons for Approval of a Settlement .............. 4455 Gornitzki, Jacob Notice of Hearing – s. 144 ........................................ 4424 Notice from the Office of the Secretary .................... 4429 Halogen Software Inc. Order – s. 1(6) of the OBCA ..................................... 4445 Order ........................................................................ 4446 Iacono, Santo Notice of Hearing – s. 144 ........................................ 4424 Notice from the Office of the Secretary .................... 4429 IIROC SROs – Amendments to Dealer Member Rules and Form 1 Relating to the Futures Market Segregation and Portability Customer-Protection Regime – Request for Comment .............................. 4557 INFOR Acquisition Corp. Order ........................................................................ 4439 Jiwa, Rahim Notice from the Office of the Secretary .................... 4430 Order – ss. 127(1), 127(10) ...................................... 4444 Decision and Reasons – ss. 127(1), 127(10) ........... 4457 Jordan, Haiyan (Helen) Gao Notice from the Office of the Secretary .................... 4428 Oral Reasons for Approval of a Settlement .............. 4455 Katebian, Morteza Notice from the Office of the Secretary .................... 4429 Order – ss. 127(7), 127(8) ........................................ 4440 Katebian, Payam Notice from the Office of the Secretary .................... 4429 Order – ss. 127(7), 127(8) ........................................ 4440 Lee, Michael Notice from the Office of the Secretary .................... 4430 Order – ss. 127(1), 127(10) ...................................... 4444 Decision and Reasons – ss. 127(1), 127(10) ........... 4457

Index

May 18, 2017 (2017), 40 OSCB 4594

Lexam VG Gold Inc. Order ......................................................................... 4440 Order – s. 1(6) of the OBCA ...................................... 4447 LOGiQ Capital 2016 Name Change ........................................................... 4555 MM Café Franchise Inc. Notice from the Office of the Secretary ..................... 4428 Oral Reasons for Approval of a Settlement ............... 4455 Money Gate Corp. Notice from the Office of the Secretary ..................... 4429 Order – ss. 127(7), 127(8)......................................... 4440 Money Gate Mortgage Investment Corporation Notice from the Office of the Secretary ..................... 4429 Order – ss. 127(7), 127(8)......................................... 4440 Nebris, Alex Notice from the Office of the Secretary ..................... 4430 Order – ss. 127(1), 127(10) ....................................... 4444 Decision and Reasons – ss. 127(1), 127(10) ............ 4457 Neher, Jorge Notice of Hearing with Related Statement of Allegations – ss. 127, 127.1 ...................................... 4425 Notice from the Office of the Secretary ..................... 4430 NEX SEF Limited Marketplaces – Application for Exemption from Recognition as an Exchange – Notice and Request for Comment ............................................... 4558 Performance Sports Group Ltd. Cease Trading Order ................................................ 4463 Pollen Services Limited Notice of Hearing – s. 144......................................... 4424 Notice from the Office of the Secretary ..................... 4429 Ramos, Samuel Notice from the Office of the Secretary ..................... 4430 Order – ss. 127(1), 127(10) ....................................... 4444 Decision and Reasons – ss. 127(1), 127(10) ............ 4457 Raponi, Josephine Notice of Hearing – s. 144......................................... 4424 Notice from the Office of the Secretary ..................... 4429 Rothstein, John David Notice from the Office of the Secretary ..................... 4428 Reasons and Decision on Settlement – s. 127 ......... 4451 Serpa, John Notice of Hearing – s. 144......................................... 4424 Notice from the Office of the Secretary ..................... 4429 Soave, Frank Notice from the Office of the Secretary ..................... 4428 Reasons and Decision on Settlement – s. 127 ......... 4451

Stephany, Kimberley Notice of Hearing – s. 144 ........................................ 4424 Notice from the Office of the Secretary .................... 4429 Stompy Bot Corporation Cease Trading Order ................................................ 4463 Techocan International Co. Ltd. Notice from the Office of the Secretary .................... 4428 Oral Reasons for Approval of a Settlement .............. 4455 Telfer, Ian Notice of Hearing – s. 144 ........................................ 4424 Notice from the Office of the Secretary .................... 4429 Tremblay, Eric Notice from the Office of the Secretary .................... 4428 Reasons and Decision on Settlement – s. 127 ......... 4451 Virani, Azim Notice from the Office of the Secretary .................... 4430 Order – ss. 127(1), 127(10) ...................................... 4444 Decision and Reasons – ss. 127(1), 127(10) ........... 4457 Wing, Dennis Notice of Hearing – s. 144 ........................................ 4424 Notice from the Office of the Secretary .................... 4429