In a settlement agreement with Daniel George Gordon, a former registered representative with Harbourfront Wealth Management Inc., the Investment Industry Regulatory Organization of Canada (IIROC) has fined Gordon $80,000, assessed costs, barred the former representative from registration for three months and required that he rewrite the Conduct and Practices Handbook Course before reregistering with any IIROC firm.
Gordon retired in April 2020 and is not currently registered.
According to the settlement agreement, the Burlington, Ontario former representative engaged in undisclosed outside business activity between March 2016 and March 2020 when he provided financial management advisory services both directly and through a consulting business he owned and controlled, to a corporate client in the pharmaceutical industry. During that time, Gordon was aware that his firm had specifically directed him to not engage in the outside activity.
After completing a disclosure form indicating that he was to be the chief financial officer of the corporate client’s company – Gordon had provided business advisory services to the company since 2014 – Harbourfont issued a memo, which Gordon signed, to confirm that his involvement with the company was strictly prohibited.
Three months later, Harbourfront issued a further memo advising Gordon that compliance identified an email address for Gordon with the corporate client’s domain. Harbourfront required that he close the email address or transfer the corporate client’s accounts to another advisor. In March 2016 the corporate client signed a letter confirming that the email address had been terminated. The compliance department tested and confirmed that the account had been deactivated.
Despite this, Gordon continued in the outside business activity. His activities included negotiating corporate loans, negotiating mortgages for various properties, discussing contract details for entering into a business partnership with another party, issuing shares of the proposed company and generally advising on financial matters for the corporate client. Between August 2017 and December 2019, he received payments from the client totalling $670,000. He did not inform Harbourfront about his consulting services until the company’s principal filed a complaint with the planning firm in March 2020.
During the time he was engaged in the outside business activity, he also signed annual declarations in 2018 and 2019 indicating that he had reported all outside activity to the firm’s compliance department.
In addition to the $80,000 fine and training, Gordon was also ordered to pay costs in the amount of $20,000.
