IIROC is looking for comment on its revised consolidated disciplinary sanction guidelines, which set out general principles and key factors to be considered by hearing panels.
The proposed sanction guidelines consolidate and replace the current Dealer Member and Universal Market Integrity Rule (UMIR) sanction guidelines that are used to assist in determining appropriate sanctions in IIROC disciplinary proceedings.
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The proposed guidelines provide a more streamlined, principle-based approach to sanctioning, by eliminating the fine ranges and minimum fines that exist within IIROC’s current sanction guidelines. These revisions will ensure that the necessary factors are considered and sanctions appropriately reflect the gravity of violations.
IIROC has also developed companion policy statements which set out staff’s approach to three common issues that arise during settlement negotiations and disciplinary proceedings.
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One of staff’s proposed approaches deals with the imposition of suspensions. Where misconduct that is sufficiently egregious to warrant a suspension of five years or greater, staff will seek a permanent bar. The policy statement also provides clarification on the issue of a respondent’s cooperation. Staff will only consider “proactive and exceptional cooperation” as a mitigating circumstance.
After the public comment period, IIROC will invite those who submitted written comments to a meeting to discuss issues in greater depth.
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