A hearing panel of the Canadian Investment Regulatory Organization (CIRO) has issued its reasons for fining Ryan Todd Small $20,000 and banning the former representative from conducting securities related business with any CIRO-member firm for five years.
The reasons for decision indicates that between June 2017 and December 2020, Small engaged in unapproved outside activities when he solicited clients and other individuals to invest in an investment which he had a direct interest in and which wasn’t approved for sale by Royal Mutual Funds Inc., the firm Small worked with from April 2011 until he resigned in December 2020. Small also incorporated a company and acted as a director for that company without Royal Mutual Funds’ knowledge or approval.
“The respondent admits that he solicited clients and other individuals to invest in a real estate development (the Brant and Leighland Property), in which the respondent retained a personal interest,” the reasons for decision states, adding that Small provided promotional materials, including the terms, features, rates of return and potential merits of the investment. This, they say, gave rise to a conflict of interest that he did not disclose or take steps to address.
The regulator says there is no evidence of financial loss by any of the clients or individuals solicited. In addition to the five-year ban on re-registration and the fine, Small also agreed to pay costs in the amount of $5,000.