Spongetech Delivery Systems, Inc. (fka SPNGQ)

[scion]

THE PURPOSE OF THE HEARING is to determine whether Douglas Terrence Steer (the Respondent), who at all material times was a Registered Representative (RR) working at Canaccord Capital Corporation (Canaccord) in Vancouver, British Columbia, committed the following contraventions that are alleged by the Staff of IIROC (Staff):

Count 1

From April to September 2009, the Respondent facilitated the deposit of share certificates in six client accounts, and the subsequent sale of those securities and withdrawal of the proceeds of sale:

(a) Without using due diligence to learn essential facts relative to his clients and / or their orders contrary to IIROC Dealer Member Rule 1300.1 (a); and
(b) Without properly acting as a gatekeeper to the capital markets by making diligent inquiries to reasonably assure himself that the transactions were being made for legitimate investment purposes, in circumstances which necessitated such inquiry, contrary to IIROC Dealer Member Rule 29.1.

Count 2

From April to September 2009, the Respondent acted contrary to IIROC Dealer Member Rule 29.1 by effecting transactions in his clients’ accounts based on instructions that he accepted from an individual who was not authorized to give instructions on the account.

PARTICULARS
TAKE FURTHER NOTICE that the following is a summary of the facts
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http://www.iiroc.ca/Documents/2015/fd8c8911-0900-4359-8430-5198bca9eb3d_en.pdf