A CIRO hearing panel approved a settlement imposing an $18,000 fine for Mutual Fund Dealer violations
A hearing panel of the Canadian Investment Regulatory Organization (CIRO) found that Jordan Michael Snitzler violated the Mutual Fund Dealer Rules by obtaining, possessing, and using three pre-signed account forms for three clients.
Additionally, he altered and used 30 account forms for 26 clients without having them initial the changes to confirm authorization.
The hearing panel confirmed a fine of $18,000 and costs of $2,500 as part of a settlement agreement. Snitzler did business in the Regina, Saskatchewan area during the infractions.
He is currently registered as a dealing representative with Designed Securities Ltd. in Saskatchewan, Alberta, British Columbia, and Ontario.
Snitzler has been registered in the securities industry since August 2009. Between July 1, 2021, and December 27, 2023, he was registered with Investia Financial Services Inc., a CIRO Dealer Member.
Investia designated him as a branch manager. On December 27, 2023, he resigned from Investia, and by January 25, 2024, he had joined Designed Securities Ltd.
At the time of these infractions, Investia’s policies prohibited dealing representatives from obtaining, possessing, or using incomplete pre-signed account forms.
Despite this, between June 3, 2019, and June 2, 2021, Snitzler obtained, possessed, and used three pre-signed account forms, including one transfer form and two fund application forms.
Investia also required that any alterations to account forms be initialed by clients to confirm authorization. Between December 6, 2016, and June 28, 2021, Snitzler altered and used 30 account forms without obtaining client initials.
These forms included systematic instruction forms, account application forms, transfer forms, order instruction forms, order entry forms, Know-Your-Client (KYC) update forms, subscription forms, reinvestment forms, and confirmation of identity forms.
The unauthorized alterations involved changes to investment instructions, transfer amounts, contribution amounts, fund names, clients’ net worth, load types, risk tolerance, plan types, beneficiary designations, account numbers, and dates.
Investia discovered these infractions during a branch review in October 2022. The firm conducted a full review of Snitzler’s client files and identified additional pre-signed and altered account forms.
As part of the investigation, Investia sent audit letters to affected clients, providing transaction histories and KYC information to verify accuracy and authorization. No clients reported concerns regarding these transactions.
Following the discovery, Investia placed Snitzler under strict supervision from November 21, 2022, to January 31, 2023. The firm identified no further issues during this period. On May 5, 2023, Investia issued Snitzler a warning letter regarding his conduct.
By November 8, 2023, the Financial and Consumer Affairs Authority of Saskatchewan (FCAA) imposed terms and conditions on Snitzler’s registration, requiring Investia to place him under close supervision and submit monthly reports on his sales activities and client interactions.
The hearing panel considered whether accepting the settlement agreement was in the public interest and whether the penalty would serve as a deterrent. The panel reviewed precedent cases and CIRO’s primary goal of protecting investors while maintaining confidence in the securities industry.
The penalties must be sufficient to reinforce public trust in mutual fund regulation and deter similar misconduct.
Mitigating factors in this case included the fact that Snitzler remains under FCAA-imposed conditions at Designed Securities Ltd. There was no evidence that he gained financially beyond what he would have earned through legitimate transactions.
He has no prior disciplinary history with the Mutual Fund Dealers Association of Canada (MFDA) or CIRO.
Additionally, no clients suffered financial losses or reported concerns to CIRO, Investia, or his current employer. By settling the case, Snitzler also avoided a contested hearing, saving CIRO resources and expenses.
At the conclusion of the hearing, the panel determined that the agreed-upon penalty was reasonable and that the settlement served the public interest.
Snitzler must pay the $18,000 fine and $2,500 in costs and comply with Mutual Fund Dealer Rule 2.1.1 in the future.
The hearing took place on December 30, 2024, and CIRO released its reasons for the decision on January 29.
