IN THE MATTER OF the Mortgage Brokerages, Lenders and Administrators Act, 2006, S.O. 2006, c.29, as amended (the “Act”), in particular sections 21, 35, 38, and 39;

AND IN THE MATTER OF Trillium Mortgage Services Inc., Frank Manzo, Paramjeet Kaur, and Vatsal Pareshkumar Khamar aka Vic Kumar

NOTICE OF PROPOSAL TO IMPOSE ADMINISTRATIVE PENALTIES
AND ISSUE COMPLIANCE ORDER

TO: Trillium Mortgage Services Inc.

AND TO: Frank Manzo

AND TO: Paramjeet Kaur

AND TO: Vatsal Pareshkumar Khamar aka Vic Kumar

TAKE NOTICE THAT pursuant to section 39 of the Act, and by delegated authority from the Chief Executive Officer of the Financial Services Regulatory Authority of Ontario (the “Chief Executive Officer”), the Director, Litigation and Enforcement (the “Director”) is proposing to impose the following administrative penalties in the total amount of $60,000 on Trillium Mortgage Services Inc.:

$20,000 for failing to take reasonable steps to ensure that any mortgage or investment in a mortgage that it presented for the consideration of a borrower was suitable for the borrower having regard to the needs and circumstances of the borrower, contrary to subsection 24(1) of Ontario Regulation 188/08;
$20,000 for failing to take reasonable steps to verify the identity of each borrower to whom it presented a mortgage or renewal for consideration, contrary to subsection 10(1) of Ontario Regulation 188/08; and
$20,000 for failing to maintain records, contrary to subsection 46(1) of Ontario Regulation 188/08.

AND TAKE NOTICE THAT pursuant to section 39 of the Act, the Director is proposing to impose an administrative penalty in the amount of $25,000 on Frank Manzo for failing to take reasonable steps to ensure that Trillium Mortgage Services Inc., and each broker and agent authorized to deal or trade in mortgages on its behalf, complies with every requirement established under the Act, contrary to subsection 2(1) of Ontario Regulation 410/07.

AND TAKE NOTICE THAT pursuant to section 39 of the Act, the Director is proposing to impose the following administrative penalties in the total amount of $85,000 on Paramjeet Kaur:

$25,000 for acting in circumstances where she ought to know that by acting, doing the thing, or omitting to do the thing, she was being used by a borrower, lender, investor or any other person to facilitate dishonesty, fraud, crime or illegal conduct, contrary to section 3.1 of Ontario Regulation 187/08;
$20,000 for giving false or deceptive information or document when dealing in mortgages in Ontario or trading in mortgages in Ontario, contrary to Subsection 43(2) of the Act;
$10,000 for failing to take reasonable steps to ensure that mortgages she presented to borrowers were suitable for them, causing her authorizing brokerage to contravene subsection 24(1) of Ontario Regulation 188/08, contrary to section 3 of Ontario Regulation 187/08;
$10,000 for failing to verify the identity of borrowers, causing her authorizing brokerage to contravene subsection 10(1) of Ontario Regulation 188/08, contrary to section 3 of Ontario Regulation 187/08;
$10,000 for failing to maintain records, causing her authorizing brokerage to contravene subsection 46(1) of Ontario Regulation 188/08, contrary to section 3 of Ontario Regulation 187/08; and
$10,000 for giving false or misleading information to the Chief Executive Officer or a person designated by the Chief Executive Officer in respect of any matter related to the Act or the regulations, contrary to section 45(1) of the Act.

AND TAKE NOTICE THAT pursuant to section 39 of the Act, Director is proposing to impose an administrative penalty of $80,000 on Vatsal Pareshkumar Khamar for dealing in mortgages for remuneration without being licensed, contrary to section 2 of the Act.

AND TAKE NOTICE THAT pursuant to section 35 of the Act, the Director is proposing to issue a compliance order requiring Vatsal Pareshkumar Khamar to:

Cease and desist from dealing in mortgages in Ontario, as defined in section 2(1) of the Act, or holding himself out as licensed to do so;
Cease and desist from trading in mortgages in Ontario, as defined in section 3(1) of the Act, or holding himself out as licensed to do so; and
Cease and desist from administering mortgages in Ontario, as defined in section 5(1) of the Act, or holding himself out as licensed to do so.

Details of these contraventions and reasons for this proposal are described below. This Notice of Proposal includes allegations that may be considered at a hearing.

SI VOUS DÉSIREZ RECEVOIR CET AVIS EN FRANÇAIS, veuillez nous envoyer votre demande par courriel immédiatement à: contactcentre@fsrao.ca

YOU ARE ENTITLED TO A HEARING BY THE FINANCIAL SERVICES TRIBUNAL (THE “TRIBUNAL”) PURSUANT TO SECTIONS 21(2) AND 21(3) OF THE ACT. A hearing by the Tribunal about this Notice of Proposal may be requested by completing the enclosed Request for Hearing Form (Form 1) and delivering it to the Tribunal within fifteen (15) days after this Notice of Proposal is received by you. The Request for Hearing Form (Form 1) must be mailed, delivered, faxed or emailed to:

Address:
Financial Services Tribunal
25 Sheppard Avenue W, 7^th Floor
Toronto, Ontario
M2N 6S6

Attention: Registrar

Fax: 416-226-7750

Email: contact@fstontario.ca

TAKE NOTICE THAT if you do not deliver a written request for a hearing to the Tribunal within fifteen (15) days after this Notice of Proposal is received by you, orders will be issued as described in this Notice of Proposal.

For additional copies of the Request for Hearing Form (Form 1), visit the Tribunal's website at www.fstontario.ca

The hearing before the Tribunal will proceed in accordance with the Rules of Practice and Procedure for Proceedings before the Financial Services Tribunal ("Rules") made under the authority of the Statutory Powers Procedure Act, R.S.O. 1990, c. S.22, as amended. The Rules are available at the website of the Tribunal: www.fstontario.ca. Alternatively, a copy can be obtained by telephoning the Registrar of the Tribunal at 416-590-7294, or toll free at 1-800-668-0128 extension 7294.

At a hearing, your character, conduct and/or competence may be in issue. You may be furnished with further and/or other particulars, including further or other grounds, to support this proposal.

REASONS FOR PROPOSAL

I. INTRODUCTION

These are reasons for the proposal by the Director to:
1. Impose administrative penalties in the total amount of $60,000 on Trillium Mortgage Services Inc. (“Trillium”);
2. Impose an administrative penalty in the amount of $25,000 on Frank Manzo (“Manzo”);
3. Impose administrative penalties in the total amount of $85,000 on Paramjeet Kaur (“Kaur”);
4. Impose administrative penalties in the total amount of $80,000 on Vatsal Pareshkumar Khamar, aka Vic Kumar (“Khamar”); and
5. Impose a compliance order on Khamar.

II. BACKGROUND

A. Parties

Trillium is licensed as a Mortgage Brokerage (licence #11396) under the Act.
Manzo is licensed as a Mortgage Broker (licence #M08007466) under the Act. He has been licenced since at least 2008. Manzo is the Principal Broker of Trillium.
Kaur was previously licenced as a Mortgage Broker (licence #M11001094) under the Act. She was licensed from May 3, 2011, until her licence expired on March 31, 2026. During the relevant time, Kaur was licenced though Trillium.
Khamar has never been licensed under the Act.

B. Fronting and Unlicensed Mortgage Brokering

On May 1, 2024, FSRA received a complaint from Ontario resident “MA”.
MA alleged that Khamar had arranged a mortgage for her on a property in Hamilton, and that the registered mortgage was higher than the amount agreed.
FSRA’s subsequent investigation determined that Khamar met with MA, collected identification and financial documents, prepared a mortgage application, obtained her signatures, and forwarded this material to Kaur. Kaur then submitted MA’s mortgage application to a lender.
MA never met with Kaur in person and was unaware that Kaur was her Mortgage Broker or that Trillium was her brokerage. MA denied that the signature on the mortgage commitment documents was hers.
FSRA’s subsequent investigation determined that Khamar had referred at least seven other groups of Borrowers to Kaur: FM, VC, FAM, the Ps, the Ss, BP, and KS (together with MA, the “Borrowers”).
FSRA interviewed Kaur. Kaur admitted that in 2023 and 2024:
1. Khamar contacted her as a result of a Kijiji ad that she had placed;
2. Khamar offered to refer individuals to her who needed assistance obtaining mortgages;
3. Khamar met with the Borrowers and obtained documents such as client identification, financial documents, appraisals, and Agreements of Purchase and Sale;
4. Khamar or his assistants forwarded this information to Kaur;
5. Kaur relied on Khamar to verify the Borrowers’ identities;
6. Kaur spoke with some of the Borrowers on the telephone or over video conferencing, but never met with any of the Borrowers in person;
7. Kaur completed the mortgage applications, arranged for electronic signatures through Khamar, and submitted them to lenders via Trillium;
8. Kaur did not pay Khamar directly, and believes that he was compensated directly by the Borrowers;
9. Kaur was aware that MA was a low-income college student; and
10. Kaur knowingly provided false information to lenders. Kaur admitted that on the mortgage application Kaur indicated that FM was single when she was married. She also provided false employment and income information for FM and overstated the income of MA.
Kaur failed to complete any suitability analysis for the Borrowers. Despite the Trillium Policy and Procedures manual stating that File Check Lists and Client Risk Profile Forms were required, none were done for the Borrowers.
Kaur received approximately $90,000 in commissions as a result of the mortgages arranged for the Borrowers. Trillium received approximately $11,000 in commissions.
On July 16, 2024, FSRA sent a letter to Khamar demanding that he cease and desist his unlicensed activities. On August 28, 2024, FSRA issued a public warning notice on its website regarding Khamar’s activities.

C. Failure to Maintain Records

FSRA Investigators contacted Manzo and requested copies of Trillium’s records of the Borrowers’ transactions.
Manzo provided some mortgage-related records for the Borrowers. However, Manzo admitted that he had obtained these records from Kaur just prior to providing them to FSRA as Trillium had not maintained these records.
Manzo informed investigators that he did not have full records of the Borrowers’ transactions because he had moved Trillium several times and had shredded records.
FSRA Investigators also requested that Kaur provide her notes from her dealings with the Borrowers.
Kaur stated that she had prepared contemporaneous handwritten notes of her dealings with the Borrowers but had subsequently shredded them. Kaur provided typed notes that she claimed had been created in 2023 (the “Notes”).
However, the metadata for the Notes showed that they had been created on February 1, 2026.

D. Kaur’s Licence Renewal

Kaur was contacted by FSRA Staff on May 9, 2024, regarding the above facts. Kaur was subsequently sent an Inquiry Letter on November 29, 2024, and informed that FSRA had received a complaint and was conducting an inquiry into the circumstances surrounding the Borrowers’ mortgages.
Kaur applied to renew her licence on March 17, 2025. In this application, Kaur submitted a response of “No” to the question:

“… are you the holder of such a licence and currently the subject of an investigation or upcoming disciplinary proceeding that may result in a penalty being imposed?”

III. CONTRAVENTIONS OR FAILURES TO COMPLY WITH THE ACT

A. Failure to Take Reasonable Steps to Ensure Suitability

Subsection 24(1) of Ontario Regulation 188/08 states that a brokerage shall take reasonable steps to ensure that any mortgage or investment in a mortgage that it presents for the consideration of a borrower is suitable for the borrower having regard to the needs and circumstances of the borrower.
No steps were taken to ensure that the mortgages arranged for any of the Borrowers were suitable for their needs and circumstances. The Director is therefore satisfied that Trillium contravened subsection 24(1) of Ontario Regulation 188/08.
Section 3 of Ontario Regulation 187/08 states that a mortgage broker or agent shall not do or omit to do anything that might reasonably be expected to result in the brokerage on whose behalf he or she is authorized to deal or trade in mortgages to contravene or fail to comply with a requirement established under the Act.
Kaur, as a Mortgage Broker authorized by Trillium, failed to take any steps to ensure that the mortgages issued to the Borrowers were suitable to their needs and circumstances. The Director is therefore satisfied that Kaur caused Trillium to contravene subsection 24(1) of Ontario Regulation 188/08, and thus contravened section 3 of Ontario Regulation 187/08.

B. Failure to Verify Client Identities

Subsection 10(1) of Ontario Regulation 188/08 states that “a brokerage shall take reasonable steps to verify the identity of each borrower and lender to whom it intends to present a mortgage or renewal for consideration.”
Trillium took no steps to verify the identities of any of the Borrowers. The Director is therefore satisfied that Trillium contravened subsection 10(1) of Ontario Regulation 188/08.
Kaur, a Mortgage Broker authorized by Trillium, did not make reasonable efforts to verify the identity of the Borrowers Khamar referred to her. She relied on Khamar, an unlicensed referral source, to do so. The Director is therefore satisfied that Kaur caused Trillium to contravene subsection 10(1) of Ontario Regulation 188/08, and thus contravened section 3 of Ontario Regulation 187/08.

C. Failure to Comply with Record Keeping Requirements

Subsection 46(1) of Ontario Regulation 188/08 states that a brokerage shall maintain records, including “complete and accurate records of all documents or written information given to or obtained from a borrower or prospective borrower, a lender or prospective lender, an investor or prospective investor or any other person or entity pursuant to a requirement established under the Act.”
Trillium failed to maintain complete and accurate records of the documents received from the Borrowers and the mortgages presented to them. The Director is therefore satisfied that Trillium contravened subsection 46(1) of Ontario Regulation 188/08.
Kaur, as a mortgage broker for Trillium, failed to maintain records in the form of notes, Client Risk Profile forms, File Check Lists, income and employment records regarding the Borrowers.
The Director is therefore satisfied that Kaur caused Trillium to contravene subsection 46(1) of Ontario Regulation 188/08, and thus contravened section 3 of Ontario Regulation 187/08.

D. Failure to Carry Out Principal Broker Duties

Subsection 2(1) of Ontario Regulation 410/07 states that “the principal broker of a brokerage shall take reasonable steps to ensure that the brokerage, and each broker and agent authorized to deal or trade in mortgages on its behalf, complies with every requirement established under the Act.”
The Director is satisfied that Manzo, as Principal Broker of Trillium, contravened subsection 2(1) of Ontario Regulation 410/07 by failing to take reasonable steps to ensure that Trillium and Kaur complied with every requirement established under the Act.

E. Facilitating Dishonesty, Fraud, Crime, or Illegal Conduct

Section 3.1 of Ontario Regulation 187/08 states that “A mortgage broker or agent shall not act, or do anything or omit to do anything, in circumstances where he or she ought to know that by acting, doing the thing or omitting to do the thing, he or she is being used by a borrower, lender, investor or any other person to facilitate dishonesty, fraud, crime or illegal conduct.”
The Director is satisfied that Kaur contravened section 3.1 of Ontario Regulation 187/08 by facilitating Khamar’s dishonesty and illegal conduct of dealing in mortgages without a licence. Kaur relied on Khamar to meet with the Borrowers, verify their identities, obtain their financial and personal information, assess their needs and circumstances and recommend mortgages to them. Kaur knew that Khamar was unlicensed, and yet relied on him to complete some of the fundamental obligations of a Mortgage Broker and facilitated his conduct.

F. False or Deceptive Information

Subsection 43(2) of the Act states that “no mortgage broker or agent shall give, assist in giving or induce or counsel another person or entity to give or assist in giving any false or deceptive information or document when dealing in mortgages in Ontario or trading in mortgages in Ontario.”
Kaur admitted to FSRA that she knowingly provided misleading marital information for FM to a lender when on the mortgage application Kaur indicated that FM was single when she was married. She also provided false employment and income information for FM and overstated the income of MA
Accordingly, the Director is satisfied that Kaur breached subsection 43(2) of the Act.

G. False or Misleading Information

Section 45(1) of the Act prohibits a person from giving false or misleading information to the Chief Executive Officer or a person designated by the Chief Executive Officer in respect of any matter related to the Act or the regulations.
Kaur knew she was under investigation by FSRA in May of 2024 and yet failed to disclose this investigation on her subsequent licence renewal application.
Furthermore, Kaur provided false information to a FSRA Investigator, a person designated by the Chief Executive Officer, when she misrepresented the date of the creation of the Notes.
The Director is therefore satisfied that Kaur contravened section 45(1) of the Act by providing false information on her licence renewal application dated March 17, 2025, and false information regarding the date of creation of the Notes.

H. Dealing in Mortgages for Remuneration Without Being Licensed

Section 2 of the Act defines dealing in mortgages to include soliciting another person to borrow money on real property, providing information about a prospective borrower to a prospective mortgage lender, assessing a prospective borrower on behalf of a mortgage lender, and negotiating or arranging mortgages on behalf of another person or entity.
The Director is satisfied that Khamar contravened section 2 of the Act by dealing in mortgages for remuneration on behalf of the Borrowers without being licensed. Khamar collected extensive financial and personal information from the Borrowers and dealt with Kaur on their behalf to arrange mortgages.

IV. GROUNDS FOR IMPOSING ADMINISTRATIVE PENALTIES

The Director is satisfied that imposing administrative penalties on Trillium, Manzo, Kaur, and Khamar under section 39 of the Act will satisfy one or both of the following purposes under section 38(1) of the Act:
1. To promote compliance with the requirements established under the Act.
2. To prevent a person or entity from deriving, directly or indirectly, any economic benefit as a result of contravening or failing to comply with a requirement established under the Act.
Administrative penalties in the present circumstances will encourage brokers, principal brokers, brokerages, and non-licensees to comply with their obligations under the Act.
The imposition of administrative penalties also prevents Trillium, Manzo, Kaur, and Khamar from benefiting economically from their non-compliance with the Act.
In determining the amount of the administrative penalties, the Director has considered the following criteria as required by section 3 of Ontario Regulation 192/08:
1. The degree to which the contravention or failure was intentional, reckless or negligent.
2. The extent of the harm or potential harm to others resulting from the contravention or failure.
3. The extent to which the person or entity tried to mitigate any loss or take other remedial action.
4. The extent to which the person or entity derived or reasonably might have expected to derive, directly or indirectly, any economic benefit from the contravention or failure.
5. Any other contraventions or failures to comply with a requirement established under the Act or with any other financial services legislation of Ontario or of any jurisdiction during the preceding five years by the person or entity.
The Director is satisfied, having regard to all the circumstances, that the proposed amounts of the administrative penalties are not punitive in nature as required by section 3(2) of Ontario Regulation 192/08, and that the amounts are consistent with one or both purposes of section 38 of the Act.

(i) Trillium

The Director is satisfied that administrative penalties in the total amount of $60,000 should be imposed on Trillium.
In respect of the first criterion, the Director has determined that Trillium’s actions were negligent. A mortgage brokerage has significant obligations under the Act, including duties to ensure suitability, verify identity of borrowers, and maintain records. Trillium simply failed to do so, contrary to its own policies and procedures.
In respect of the second criterion, the harm to the public was substantial. Trillium’s failures allowed Khamar to continue his unlicensed activities. Furthermore, Trillium’s failures placed the Borrowers in mortgages that may have been unsuitable for them. FSRA’s ability to conduct oversight of the mortgage sector was hampered by Trillium’s failure to maintain appropriate records.
In respect of the third criterion, the Director is unaware of any efforts by Trillium to mitigate any loss or take other remedial action.
In respect of the fourth criterion, Trillium received approximately $11,000 in commissions as a result of the mortgages arranged for the Borrowers.
In respect of the fifth criterion, the Director is unaware of any further contraventions or failures to comply in the preceding five years by Trillium.

(ii) Manzo

The Director is satisfied that an administrative penalty in the amount of $25,000 should be imposed on Manzo.
In respect of the first criterion, the Director is satisfied that Manzo was negligent. He failed to take reasonable steps to ensure that Trillium and Kaur complied with every requirement established under the Act, even though Trillium’s policies and procedures supported those requirements. As the principal broker of Trillium, Manzo had a heightened responsibility to be aware of his regulatory obligations.
In respect of the second criterion, the harm to the public was significant. Khamar was able to present as a mortgage agent or broker and conduct mortgage business without a licence because of Manzo’s failures to properly supervise Kaur. His failures also resulted in Borrowers being placed in mortgages that may not be suitable for them. FSRA’s ability to investigate the mortgages arranged for the Borrowers was hampered by Manzo’s failure to maintain appropriate records.
In respect of the third criterion, the Director is unaware of any efforts by Manzo to mitigate any loss or take other remedial action.
In respect of the fourth criterion, Manzo, as principal broker, benefitted from the commissions received by Trillium.
In respect of the fifth criterion, the Director is unaware of any further contraventions or failures to comply in the preceding five years by Manzo.

(iii) Kaur

The Director is satisfied that administrative penalties in the total amount of $85,000 should be imposed on Kaur.
In respect of the first criterion, the Director is satisfied that Kaur’s actions were intentional with respect to facilitating Khamar’s unlicensed work. She was aware of the requirement to be licensed, knew that Khamar was unlicensed, and facilitated his conduct regardless.
Kaur acted recklessly in not verifying the identities of the Borrowers, who she did not meet in person. Further, she acted recklessly in not maintaining the records that Trillium is required to keep. She acted intentionally in creating the Notes after the fact, and lying to FSRA Investigators about when these Notes were created.
In respect of the second criterion, the harm to the Borrowers was significant. Khamar was able to present as a mortgage agent or broker and conduct mortgage business repeatedly without a licence because of Kaur’s facilitation.
Furthermore, confidence in the sector and licensing system were undermined by Kaur allowing Khamar to work as a Mortgage Agent or Broker without the regulatory supervision that comes with being a licensee. Without the facilitation provided by Kaur, Khamar would not have been able to work as an unlicensed individual.
Kaur’s false statements in her licence renewal applications prevented FSRA from making an accurate determination of whether her licence should be renewed. The questions posed to those who apply for licences or renewals under the Act are vitally important to FSRA in assessing the suitability and qualifications of applicants. These questions are a necessary screening tool to protect the public from unqualified, unsuitable and unscrupulous persons.
In respect of the third criterion, the Director is unaware of any efforts by Kaur to mitigate any loss or take other remedial action.
In respect of the fourth criterion, Kaur received approximately $90,000 in commissions as a result of the mortgages arranged for the Borrowers.
In respect of the fifth criterion, the Director is unaware of any further contraventions or failures to comply in the preceding five years by Kaur.

(iv) Khamar

The Director is satisfied that administrative penalties in the total amount of $80,000 should be imposed on Khamar.
In respect of the first criterion, the Director is satisfied that Khamar acted intentionally. Despite his unlicensed status, he acted as a Mortgage Broker or Mortgage Agent. He led clients and others to believe that he was licensed, and dealt in mortgages despite his unlicensed status.
In respect of the second criterion, the harm to the public was significant. Khamar’s actions deprived the Borrowers of the protections of the Act, including errors and omissions insurance, which put them at risk.
The public may engage Khamar to provide mortgage services under the misapprehension that he is licensed to do so. This will deprive individuals of the ability to rely on a suitable, licensed individual and may pose harm if the services are provided without regard to the requirements of the Act and Regulations.
In addition, the harm to the sector and licensing regime were significant. Confidence in the licensing system was undermined by a non-licensee posing as a Mortgage Broker and arranging mortgages. Consumers need to be able to trust that those holding themselves out as mortgage agents or brokers in Ontario are licensed and meet the accompanying requirements, like suitability, insurance, and education.
In respect of the third criterion, the Director is unaware of any efforts by Khamar to mitigate any loss or take other remedial action.
In respect of the fourth criterion, it is reasonable to infer that Khamar received fees directly from the Borrowers, in addition to the funds he misappropriated from MA.
In respect of the fifth criterion, the Director is unaware of any further contraventions or failures to comply in the preceding five years by Khamar.

V. GROUNDS FOR IMPOSING A COMPLIANCE ORDER ON KHAMAR

Section 35(1) of the Act provides that a compliance order can be issued on a person if the Chief Executive Officer or his delegate is satisfied that the person:
1. is committing any act or pursuing any course of conduct that contravenes or does not comply with a requirement established under this Act;
2. is pursuing any course of conduct that might reasonably be expected to result in a state of affairs that would contravene or not comply with a requirement established under this Act; or
3. has committed any act or pursued any course of conduct that contravenes or does not comply with a requirement established under this Act.
The Director is satisfied that (a) and (c) are applicable in the present circumstances.
As described above, Khamar has contravened the Act. Khamar acted as an unlicensed agent with the Borrowers in contravention of section 2(3).
The public may engage Khamar to provide mortgage services under the misapprehension that he is licensed to do so. This will deprive individuals of the ability to rely on a suitable, licensed individual and may pose harm if the services are provided without regard to the requirements of the Act and Regulations.
The requirement for licensing to deal in mortgages is essential to the integrity of the Act and its regime which operates to protect the public from fraudulent activity and misconduct.
The public remains at risk. The proposed compliance order will help protect the public from future harm from Khamar’s unlicensed conduct.
Such further and other reasons as may come to my attention.

DATED at Toronto, Ontario, April 16, 2026

Original signed by

Elissa Sinha
Director, Litigation & Enforcement

By delegated authority from the Chief Executive Officer

Si vous desirez recevoir cet avis en français, veuillez nous envoyer votre demande par courriel immediatement a : contactcentre@fsrao.ca.

NOTICE OF PROPOSAL TO IMPOSE ADMINISTRATIVE PENALTIES AND ISSUE COMPLIANCE ORDER