Hearing panel accepts settlement with advisor and Cumberland Private Wealth Management after compliance breaches
The Canadian Investment Regulatory Organization (CIRO) accepted a settlement agreement with sanctions between Enforcement Staff and the respondents, Gary Edmond Perron and Cumberland Private Wealth Management Inc. (CPWM), on March 21, following a hearing panel decision.
The hearing was held pursuant to the Investment Dealer and Partially Consolidated Rules and the Dealer Member Rules.
According to the settlement, Gary Perron admitted to failing to disclose and seek pre-approval for activities related to the transfer of shares and control of an offshore corporation, Keynard Limited, to himself.
CPWM admitted to failing to adequately address red flags and questions about the transfer, while continuing to allow Perron's trading activity despite the presence of indicators that warranted further inquiry.
Pursuant to the settlement agreement, Gary Perron agreed to pay a fine of $200,000 and costs of $50,000. CPWM agreed to pay a fine of $150,000.
The settlement details outline that Perron began planning to acquire Keynard’s shares from February 2020, incorporating Akala Ltd. in the Bahamas for this purpose.
The transaction was formalized with documents dated June 29, 2020, but final steps were completed in early 2021.
Perron did not disclose this activity to CPWM, despite regulatory requirements mandating pre-approval for outside business activities.
Cumberland continued to service the Butterfield Trust account, which held Keynard assets, despite several red flags.
The firm's internal investigation, launched after being alerted to Perron's interest in Keynard in March 2021, revealed that Perron had failed to seek approval for his beneficial ownership.
Cumberland reported its findings to CIRO and imposed restrictions on Perron, including treating the Keynard accounts as proprietary accounts.
Despite previously acknowledging in signed documents that he was the beneficiary, Perron later disputed ownership, asserting Keynard was an administrator for the Silene Foundation.
Documents provided by Perron’s counsel in December 2024 and February 2025 did not clearly establish the ultimate beneficiary to Cumberland’s satisfaction.
Cumberland subsequently directed Perron to transfer the Keynard account to another registered dealer within 60 days or face account freezing.
CIRO found that Perron contravened Dealer Member Rule 18.14, while CPWM breached Investment Dealer Rule 3200 (Dealer Member Rule 1300.1(a) prior to January 1, 2022) by not adequately addressing the raised concerns.
The settlement process involved cooperation from both parties, including mediation.
CPWM was credited for self-identifying the misconduct, conducting a thorough internal review, and providing their findings to CIRO.
At the time of the contraventions, Perron conducted business at CPWM from the Bahamas.
He continues to work as a Registered Representative with CPWM, which is a CIRO-regulated Dealer Member based in Toronto, Ontario.
