Tuesday, 14 February 2017


 The following post is a look at serious questions regarding the IIROC, the regulatory body for the Investment Dealer industry. Akin to the BCSC the IIROC is as corrupt as they come and simply covers for a wide range of financial crimes. So far the conversation is a one way street, no IIROC official will reply and answer to the public for the crimes being committed under their watch.

 The following is from the desk of Alan Blanes, Esteemed Alumni of the University of the Fraser Valley, Financial rights Activist and member of the Council Of Canadians.

 Some names have been withheld for privacy concerns.

Thanks very much for this,                 , and for making it possible to reply to the group;
I would like to ask Mr. Kriegler why IIROC continues to provide no argument - only silence - when asked to support the fact that Canaccord Capital has a duty to compensate victims of breach of contract [my dad has 2 judgements against Canaccord for this, that were rendered in 2013.] 2013 was also the year that Canaccord was convicted of failing to supervise their Kelowna and Montreal offices from 2005 to 2011 - by a decision of IIROC. Clearly the legal actions that Harold Blanes prosecuted against IIROC, would have been unnecessary, if good faith supervision had been provided to his portfolio. He wants the remaining $23,000 that the court was not able to award due to court rules, and the legal fees that amounted to $51,000. If IIROC genuinely has a concern for the public interest, it would act in accordance with its finding of failure to supervise as a unacceptable practice, that created severe harm to elderly clients - who were betrayed by an organization that they were led to believe acted in good faith toward clients. My argument is that legal expenses that were incurred due to this admitted failure to supervise, would likely never have been necessary if proper supervision were in place. IIROC has a serious obligation on this matter, due to the IDA complaint that Harold Blanes filed on this problem November 3, 2007- that was fully documented was dismissively disregarded. If  IIROC, nee IDA, had done its duty at that time, the people who were abused by the failure to supervise - continuing up to 2011 - would have likely been protected. IIROC's policy of disregard had a big price to victims.
Mr. Kriegler also has to be asked, until IIROC's ignoring act wears off, why IIROC would disregard the fact that Investors Group was masquerading as a GIC provider from 2005 until February of 2014 when it was reinstated as an issuer of GICs by the Superintendent of Financial Institutions. Why does IIROC consider the evidence of false advertising for GICs that is documented in the FALL 2009 edition of the Investors Group publication CONNECTIONS, failing to elicit even a discussion, - let alone any attempt to enforce rules against falsely claiming that GICs are available from this firm.
Why does IIROC continue to provide impunity for a company that the evidence demonstrates, contracted for GICs with Harold Blanes on March 15, 2007, yet for five years accused this client of having a faulty memory and shows signs of Alzheimer's disease. The false and predatory actions of Investors Group extended to telling the Kelowna RCMP that the client has a faulty memory and this caused the RCMP to unjustly fail to return any of his phone calls for approximately five years. I put the blame squarely on IIROC for having a policy of impunity on this matter - that created extreme torment to this client ---- and it appears that IIROC has no clue as to the human suffering that the indulgence of dishonesty in the industry imposes on the most elderly clients of such companies - who require authentic protection, not being sacrificed for short term profit.
Alan Blanes
 Further on the subject presented to Mr. Kriegler (among others) at the IIROC, pressing questions from an author who shall for the time remain anonymous.
Sent: Monday, January 30, 2017 9:52 AM
To: akriegler@iiroc.ca
Subject: What IIROC criteria constitutes violations of investment suitability requirements ?
Dear Mr Kriegler
Kindly refer to the below link to the October 31st 2016 IIROC News Release entitled, "Unsuitable Investments top Investor complaints, IIROC statistics show"
Your personal comments in the IIROC News Release emphasized an awareness of the extent of the violations of investments suitability requirements.
The News Release states that over a 2-year period, IIROC reports that 26% (222) of 838 investor complaints were determined by IIROC to be violations of suitability requirements.   The News Release also states that the majority of these cases involved elderly and/or vulnerable clients.   It also states that almost 50% of the prosecutions against individual registrants involved unsuitable investments violations.
I, along with other concerned retirees and elderly and/or vulnerable clients, would appreciate your answers to the below questions, namely -
Q1. Would you kindly supply a list of the criteria IIROC uses in defining these violations of
        suitability requirements ?     
Q2. What is the exact number of prosecutions for violations of investment suitability
        requirements related to complaints from elderly and/or vulnerable clients ?   This is
        important as IIROC reports that the majority of the suitability violation cases involved   
       elderly and/or vulnerable clients.
Q3. There is no mention in the IIROC News Release of the number of Investment Dealers who
        employed these registrants involved in the 222 IIROC determined violations of investment
        suitability requirements cases.   These Investment Dealers must be just as guilty because
        they were supposed to be supervising the Financial "Advisor" employees.  
        How many Investment Dealers were involved in these 222 cases ?
Your detailed response to this request would be appreciated.
More on the same subject, further questions for the head of the IIROC,
Sent: Friday, February 03, 2017 10:45 AM
To: akriegler@iiroc.ca

Subject: FW: #2 What IIROC criteria constitutes violations of investment suitability requirements ?
Dear Mr Kriegler,
Shortly after you took the reins at IIROC, you had an interview with Barbara Shecter of the National Post, which was reported in their May 6th 2015 issue.   In the interview you said that you were impressed by the culture you found at IIROC that compared well with what you previously experienced at the OSFI.    In the article, you are reported to have said, "There's a sense within both organizations that people there are doing important work on behalf of the public".   You are also reported to have said that, "IIROC is guided by recognition orders from provincial securities commissions that compel it to act in the public interest, which goes far beyond industry concerns or preferences".
Here is the National Post article -
Your philosophical perspective of what drives the IIROC operations is to be commended.  However, there is a great anomaly between the IIROC philosophical culture as you see it and the real life experiences of investors when trying to get straight forward answers to straight forward questions from IIROC, taking into account the actual IIROC practices.   
You say that IIROC is compelled to act in the public interest.    As you say this is a mandated obligation of IIROC, it would be helpful for IIROC to respond with answers to questions that are in the public's interest, when they are asked.   Instead, the requests to IIROC are responded with either Tour de France explanations with no answers to the questions or are completely ignored and go unanswered.   
It seems that certain members of your staff have been instructed to ignore my communication for fear of opening up the barn door.  Well, the barn door is now open.
In this connection, would you kindly respond with an answer to the below #1 question I asked of you which reads,  Q1. Would you kindly supply a list of the criteria IIROC uses when defining the violations of suitability requirements ?
As the other two below listed questions to you are also in the public interest, answers to those questions would also be appreciated.
After providing the requested information, you might also ask Ms Farrell to provide answers to the three questions I asked of her in my December 16th 2016 letter that she has ignored and has not responded to.   Those questions relate to IIROC using statistics to inform the public of the details in the IIROC handling of investor complaints.   However, those quoted statistics used do not disclose how few of the IIROC registered complaints related to violations of suitability requirements came directly from Investment Dealers via the ComSet reporting process and how many came directly to IIROC from aggrieved investors.  In other words, just how many investment Dealers admitted to the investor complaints related to violations of suitability requirements.   Ms Farrell has also ignored repeated requests for answers.
After that you may want to speak to Mr Piroli and ask him to respond to my January 18th 2017 email requesting he come forward with the names of the "groups", including "investor advocacy groups", that IIROC claimed they consulted in connection with their "IIROC Guidance on proposed Order Execution Only Services and Activities (OEO)".    Without these names being divulged, one has to question the veracity of the IIROC published claims.   Again, repeated requests to Mr Piroli have been ignored.
All of these requests clearly fall under your definition of compelling IIROC "to act in the public interest, which goes far beyond industry concerns or preferences".
I would hope that my request to you gets a better treatment.
Its time for our public officials to be held accountable to the rule of law.

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