The Ontario Securities Commission
OSC Bulletin
November 7, 2019
Volume 42, Issue 45
(2019), 42 OSCB
The Ontario Securities Commission administers the Securities Act of Ontario (R.S.O. 1990, c. S.5) and the Commodity Futures Act of Ontario (R.S.O. 1990, c. C.20)
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© Copyright 2019 Ontario Securities Commission ISSN 0226-9325 Except Chapter 7 ©CDS INC.
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Table of Contents
Chapter 1 Notices ...... 8639 Chapter 9 Legislation ...... (nil) 1.1 Notices ...... (nil) 1.2 Notices of Hearing ...... (nil) Chapter 11 IPOs, New Issues and Secondary 1.3 Notices of Hearing with Related Financings ...... 8741 Statements of Allegations ...... (nil) 1.4 Notices from the Office Chapter 12 Registrations ...... 8747 of the Secretary ...... 8639 12.1.1 Registrants ...... 8747 1.4.1 3iQ Corp. and The Bitcoin Fund ...... 8639 1.4.2 MOAG Copper Gold Resources Inc. et al...... 8640 Chapter 13 SROs, Marketplaces, 1.5 Notices from the Office Clearing Agencies and of the Secretary with Related Trade Repositories ...... 8749 Statements of Allegations ...... (nil) 13.1 SROs ...... (nil) 13.2 Marketplaces ...... (nil) Chapter 2 Decisions, Orders and Rulings ...... 8641 13.3 Clearing Agencies ...... 8749 2.1 Decisions ...... 8641 13.3.1 CDS Clearing and Depository Services 2.1.1 Evolve Funds Group Inc...... 8641 Inc. – Material Amendments to CDS Rules 2.1.2 FT Portfolios Canada Co. and First Trust Related to Liquidity Risk Management – Short Duration High Yield Bond ETF Notice of Request for Comment ...... 8749 (CAD-Hedged) ...... 8645 13.3.2 Canadian Derivatives Clearing Corporation 2.1.3 TD Investment Services Inc...... 8649 (CDCC) – Proposed Amendments to the 2.1.4 Triple Flag Precious Metals Corp...... 8651 Rules, Risk Manual and Operations Manual 2.1.5 TD Asset Management Inc. et al...... 8653 with Respect to Liquidity Risk Management – 2.1.6 Caldwell Investment Management Ltd. Notice of Request for Comment ...... 8749 and Clearpoint Global Dividend Fund ...... 8656 13.3.3 CDS Clearing and Depository Services Inc. – 2.2 Orders...... 8661 Material Amendments to CDS Rules Related 2.2.1 3iQ and The Bitcoin Fund – s. 8 ...... 8661 to Tiered Participation Information Sharing – 2.2.2 Portfolio 22 Multi-Family REIT LP ...... 8662 Notice of Request for Comment ...... 8750 2.2.3 Silk Road Energy Inc...... 8663 13.4 Trade Repositories ...... (nil) 2.2.4 Holloway Lodging Corporation ...... 8666 2.3 Orders with Related Settlement Chapter 25 Other Information ...... (nil) Agreements ...... (nil) 2.4 Rulings ...... 8667 Index ...... 8757 2.4.1 ICAP Securities Limited – s. 38 of the CFA and s. 6.1 of OSC Rule 91-502 Trades in Recognized Options ...... 8667
Chapter 3 Reasons: Decisions, Orders and Rulings ...... 8673 3.1 OSC Decisions ...... 8673 3.1.1 3iQ Corp. and The Bitcoin Fund – s. 8 ...... 8673 3.2 Director’s Decisions ...... (nil)
Chapter 4 Cease Trading Orders ...... 8691 4.1.1 Temporary, Permanent & Rescinding Issuer Cease Trading Orders ...... 8691 4.2.1 Temporary, Permanent & Rescinding Management Cease Trading Orders ...... 8691 4.2.2 Outstanding Management & Insider Cease Trading Orders ...... 8691
Chapter 5 Rules and Policies...... (nil)
Chapter 6 Request for Comments ...... (nil)
Chapter 7 Insider Reporting...... 8693
November 7, 2019 (2019), 42 OSCB
Chapter 1
Notices
1.4 Notices from the Office of the Secretary
1.4.1 3iQ Corp. and The Bitcoin Fund
FOR IMMEDIATE RELEASE October 30, 2019
3iQ CORP. and THE BITCOIN FUND, File No. 2019-7
TORONTO – The Commission issued its Reasons and Decision and an Order in the above named matter.
A copy of the Reasons and Decision and Order dated October 29, 2019 are available at www.osc.gov.on.ca.
OFFICE OF THE SECRETARY GRACE KNAKOWSKI SECRETARY TO THE COMMISSION
For media inquiries: [email protected]
For investor inquiries:
OSC Contact Centre 416-593-8314 1-877-785-1555 (Toll Free)
November 7, 2019 (2019), 42 OSCB 8639
Notices
1.4.2 MOAG Copper Gold Resources Inc. et al.
FOR IMMEDIATE RELEASE November 4, 2019
MOAG COPPER GOLD RESOURCES INC., GARY BROWN and BRADLEY JONES, File No. 2018-41
TORONTO – Take notice the hearing in the above named matter scheduled to be heard on November 5, 2019 at 10:00 a.m. will not proceed as scheduled.
The hearing will continue on November 6, 2019 at 9:00 a.m.
OFFICE OF THE SECRETARY GRACE KNAKOWSKI SECRETARY TO THE COMMISSION
For media inquiries: [email protected]
For investor inquiries:
OSC Contact Centre 416-593-8314 1-877-785-1555 (Toll Free)
November 7, 2019 (2019), 42 OSCB 8640
Chapter 2
Decisions, Orders and Rulings
2.1 Decisions IN THE MATTER OF EVOLVE FUNDS GROUP INC. 2.1.1 Evolve Funds Group Inc. (the Filer)
Headnote DECISION
National Policy 11-203 Process for Exemptive Relief Background Applications in Multiple Jurisdictions – relief granted to conventional mutual fund series of exchange-traded funds The principal regulator in the Jurisdiction has received an for continuous distribution of securities – relief granted to application from the Filer on behalf of the funds listed in facilitate the offering of conventional mutual fund series and Schedule A (collectively, the Existing Funds), and such exchange-traded series within same fund structure – relief other mutual funds as are managed or may be managed by granted from the requirement in NI 81-101 to prepare and the Filer now or in the future and that are structured in the file a simplified prospectus for mutual fund series provided same manner as the Existing Funds (the Future Funds, that a Long Form Prospectus is prepared and filed in and together with the Existing Funds, the Funds and each accordance with NI 41-101 – mutual fund series and individually, a Fund), for a decision under the securities exchange-traded series referable to same portfolio and legislation of the Jurisdiction (the Legislation) to permit the have substantially identical disclosure – relief permitting all Filer and each Fund to series of funds to be disclosed in same prospectus – disclosure required by NI 81-101 for mutual fund series and (a) file a prospectus for the Mutual Fund Securities not contemplated by NI 41-101 will be disclosed in (as defined below) of each Fund in accordance prospectus under relevant headings – technical relief with the provisions of National Instrument 41-101 granted to funds from Parts 9, 10 and 14 of National General Prospectus Requirements (NI 41-101) Instrument 81-102 to permit funds to treat exchange-traded and in the form prescribed by Form 41-101F2 series in a manner consistent with treatment of other Information Required in an Investment Fund exchange-traded fund securities in continuous distribution Prospectus (Form 41-101F2) (the Simplified in connection with their compliance with Parts 9, 10 and 14 Prospectus Form Requirements) instead of of NI 81-102 – relief permitting funds to treat mutual fund preparing and filing a simplified prospectus and series in a manner consistent with treatment of other annual information form for the Mutual Fund conventional mutual fund securities in connection with their Securities in accordance with the provisions of compliance with Parts 9, 10 and 14 of NI 81-102. National Instrument 81-101 Mutual Fund Prospectus Disclosure (NI 81-101) and the forms Applicable Legislative Provisions prescribed by Form 81-101F1 Contents of Simplified Prospectus (Form 81-101F1) and Form National Instrument 41-101 General Prospectus 81-101F2 Contents of Annual Information Form Requirements, s. 19.1. (Form 81-101F2); and National Instrument 81-102 – Investment Funds, Parts 9, 10 and 14 and s. 19.1. (b) permit the Filer and each Fund to treat the ETF Securities and the Mutual Fund Securities as if February 8, 2019 such securities were separate funds in connection with their compliance with the provisions of Parts IN THE MATTER OF 9, 10 and 14 of National Instrument 81-102 THE SECURITIES LEGISLATION OF Investment Funds (NI 81-102) (the Sales and ONTARIO Redemption Requirements), (the Jurisdiction) (collectively, the Exemption Sought). AND Under the Process for Exemptive Relief Applications in IN THE MATTER OF Multiple Jurisdictions (for a passport application): THE PROCESS FOR EXEMPTIVE RELIEF APPLICATIONS (a) the Ontario Securities Commission is the principal IN MULTIPLE JURISDICTIONS regulator for this application; and
AND (b) the Filer has provided notice that section 4.7(1) of Multilateral Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon in all of
November 7, 2019 (2019), 42 OSCB 8641
Decisions, Orders and Rulings
the provinces and territories of Canada other than Marketplace means a “marketplace” as defined in Ontario (together with Ontario, the Jurisdictions). National Instrument 21-101 Marketplace Operation that is located in Canada. Interpretation Mutual Fund Securities means securities of a Terms defined in National Instrument 14-101 Definitions, MI non-exchange-traded class of a Fund that are or 11-102 and National Instrument 81-102 Investment Funds will be distributed pursuant to a simplified (NI 81-102) have the same meaning if used in this decision, prospectus prepared in accordance with NI 81-101 unless otherwise defined. and Form 81-101F1.
Affiliate Dealer means a registered dealer that is Prescribed Number of ETF Securities means, in an affiliate of an Authorized Dealer or Designated relation to a Fund, the number of ETF Securities Broker and that participates in the re-sale of of the Fund determined by the Filer from time to Creation Units (as defined below) from time to time for the purpose of subscription orders, time. exchanges, redemptions or for other purposes.
Authorized Dealer means a registered dealer that Securityholders means beneficial and registered has entered, or intends to enter, into an holders of ETF Securities or Mutual Fund agreement with the manager of a Fund authorizing Securities, as applicable. the dealer to subscribe for, purchase and redeem Creation Units from one or more Funds on a TSX means the Toronto Stock Exchange. continuous basis from time to time. Representations Basket of Securities means, in relation to a Fund, a group of securities or assets representing This decision is based on the following facts represented by the constituents of the Fund. the Filer:
Designated Broker means a registered dealer The Filer that has entered, or intends to enter, into an agreement with the Filer or an affiliate of the Filer 1. The Filer is a corporation incorporated under the to perform certain duties in relation to the ETF laws of Canada, with its head office in Toronto, Securities, including the posting of a liquid two- Ontario. way market for the trading of the Fund’s ETF Securities on the TSX or another Marketplace. 2. The Filer is registered as an investment fund manager in Ontario, Québec and Newfoundland ETF Facts means a prescribed summary and Labrador and as a portfolio manager and disclosure document required pursuant to National commodity trading manager in Ontario. Instrument 41-101 General Prospectus Requirements, in respect of one or more classes 3. The Filer is or will be the investment fund manager of ETF Securities being distributed under a and portfolio manager of the Funds. The Filer has prospectus. applied, or will apply, to list the ETF Securities on the TSX or another Marketplace. ETF Securities means securities of an ETF class of a Fund that are listed or will be listed on the 4. The Filer is not in default of securities legislation in TSX or another Marketplace and that will be any of the Jurisdictions. distributed pursuant to a simplified prospectus prepared in accordance with NI 81-101 and Form The Funds 81-101F1. 5. Each Fund is, or will be, a mutual fund structured NI 41-101 means National Instrument 41-101 as a trust that is governed by the laws of the General Prospectus Requirements. Province of Ontario. The Future Funds will be either trusts or corporations or classes thereof Form 81-101F1 means Form 81-101F1 Contents governed by the laws of a Jurisdiction. Each Fund of Simplified Prospectus. is, or will be, a reporting issuer in the Jurisdiction(s) in which its securities are Form 81-101F2 means Form 81-101F2 Contents distributed. of Annual Information Form. 6. Each Fund offers, or will offer, ETF Securities, and Fund Facts means a prescribed summary may in the future also offer Mutual Fund disclosure document required pursuant to NI 81- Securities. 101, in respect of one or more classes of Mutual Fund Securities being distributed under a 7. Subject to any exemptions that have been or may prospectus. be granted by the applicable securities regulatory
November 7, 2019 (2019), 42 OSCB 8642
Decisions, Orders and Rulings
authorities, each Fund will be an open-ended dealers executing trades through the facilities of mutual fund subject to NI 81-102. the TSX or another Marketplace. ETF Securities may also be issued directly to Securityholders 8. The ETF Securities are or will be listed on the TSX upon a reinvestment of distributions of income or or another Marketplace. The Filer will not file a capital gains. final prospectus for any of the Funds in respect of the ETF Securities until the TSX or other 16. Securityholders that are not Designated Brokers applicable Marketplace has conditionally approved or Authorized Dealers that wish to dispose of their the listing of the ETF Securities. ETF Securities may generally do so by selling their ETF Securities on the TSX or other 9. Mutual Fund Securities will not be listed on the Marketplace, through a registered dealer, subject TSX or another Marketplace. only to customary brokerage commissions. A Securityholder that holds a Prescribed Number of 10. The Filer has filed or will file a long form ETF Securities or multiple thereof may exchange prospectus prepared and filed in accordance with such ETF Securities for Baskets of Securities NI 41-101 and Form 41-101F2 on behalf of the and/or cash in the discretion of the Filer. Funds in respect of the ETF Securities, subject to Securityholders may also redeem ETF Securities any exemptions that may be granted by the for cash at a redemption price equal to 95% of the applicable securities regulatory authorities. closing price of the ETF Securities on the TSX or other Marketplace on the date of redemption, 11. ETF Securities and Mutual Fund Securities, if any, subject to a maximum redemption price of the are or will be distributed on a continuous basis in applicable net asset value per ETF Security. one or more of the Jurisdictions under a prospectus. 17. Mutual Fund Securities may be subscribed for or redeemed directly from a Fund through qualified 12. ETF Securities may generally only be subscribed financial advisors or brokers. for or purchased directly from the Funds (Creation Units) by Authorized Dealers or Designated Simplified Prospectus Form Requirements Brokers. Generally, subscriptions or purchases may only be placed for a Prescribed Number of 18. Without the Exemption Sought, when the Filer ETF Securities (or a multiple thereof) on any day decides to offer Mutual Fund Securities of a Fund when there is a trading session on the TSX or that has ETF Securities, it would be required to other Marketplace. Authorized Dealers or prepare and file a prospectus pursuant to NI 81- Designated Brokers subscribe for Creation Units 101 in respect of those Mutual Fund Securities. for the purpose of facilitating investor purchases of This would be in addition to the prospectus that ETF Securities on the TSX or another would need to be filed and prepared pursuant to Marketplace. NI 41-101 in respect of the ETF Securities of the Fund. 13. In addition to subscribing for and re-selling Creation Units, Authorized Dealers, Designated 19. The Filer believes it is more efficient and Brokers and Affiliate Dealers are also generally expedient to include all of the classes of each engaged in purchasing and selling ETF Securities Fund, including ETF Securities and Mutual Fund of the same class or series as the Creation Units Securities of a Fund, in one prospectus form in the secondary market. Other Dealers may also instead of two different prospectus forms and that be engaged in purchasing and selling ETF this presentation will assist in providing full, true Securities of the same class or series as the and plain disclosure of all material facts relating to Creation Units in the secondary market despite the securities of the Funds by permitting not being an Authorized Dealer, Designated disclosure relating to all classes of securities to be Broker or Affiliate Dealer. included in one prospectus. The Filer has already filed a long form prospectus in respect of the 14. Each Fund has appointed or will appoint, at any Existing Funds, and proposes to continue to file given time, a Designated Broker to perform certain long form prospectuses in respect of Future other functions, which include standing in the Funds. market with a bid and ask price for ETF Securities for the purpose of maintaining liquidity for the ETF 20. The Filer will ensure that any additional disclosure Securities. included in the prospectus relating to the Mutual Fund Securities will not interfere with an investor’s 15. Except for Authorized Dealer and Designated ability to differentiate between the Mutual Fund Broker subscriptions for Creation Units, as Securities and the ETF Securities and their described above, ETF Securities generally are not respective attributes. Accordingly, in order to able to be purchased directly from a Fund. provide clarity to investors, the Filer will amend the Investors are generally expected to purchase and names of the Existing Funds that intend to offer sell ETF Securities, directly or indirectly, through Mutual Fund Securities by replacing the word
November 7, 2019 (2019), 42 OSCB 8643
Decisions, Orders and Rulings
“ETF” with “Fund”. In addition, the existing ETF (c) the Filer includes disclosure required Securities of the Funds will be redesignated as pursuant to Form 81-101F1 and Form “ETF Class Units” and Mutual Fund Securities, if 81-101F2 (that is not contemplated by NI any, will be designated as “Mutual Fund Class 41-101F2) in respect of the Mutual Fund Units”, as applicable. Securities in each Fund’s prospectus, as applicable; and 21. The Funds will file Fund Facts in the form prescribed by Form 81-101F3 Contents of Fund (d) the Filer includes disclosure regarding Facts Document in respect of any Mutual Fund this decision under the heading Securities, and will continue to file ETF Facts in “Exemptions and Approvals” in each the form prescribed by Form 41-101F4 in respect Fund’s prospectus. of any ETF Securities. 2. The decision of the principal regulator is that the 22. The Funds will comply with the provisions of NI Exemption Sought from the Sales and 41-101 when filing any amendment or prospectus. Redemption Requirements is granted, provided that: 23. The Mutual Fund Securities of each Fund will continue to be subject to the prospectus and Fund (e) with respect to its Mutual Fund Facts delivery obligations set out in NI 81-101. Securities, each Fund complies with the provisions of Parts 9, 10 and 14 of NI 81- Sales and Redemption Requirements 102 that apply to mutual funds that are not exchange-traded mutual funds; and 24. Parts 9, 10 and 14 of NI 81-102 do not contemplate both Mutual Fund Securities and ETF (f) with respect to its ETF Securities, each Securities being offered in a single fund structure. Fund complies with the provisions of Accordingly, without the Exemption Sought from Parts 9 and 10 of NI 81-102 that apply to the Sales and Redemption Requirements, the exchange-traded mutual funds. Filer and the Funds would not be able to technically comply with those parts of the “Stephen Paglia” Instrument. Manager, Investment Funds & Structured Products Branch Ontario Securities Commission 25. The Exemption Sought from the Sales and Redemption Requirements will permit the Filer and the Funds to treat the ETF Securities and the Mutual Fund Securities as if such securities were separate funds in connection with their compliance with Parts 9, 10 and 14 of NI 81-102. The Exemption Sought from the Sales and Redemption Requirements will enable each of the ETF Securities and Mutual Fund Securities to comply with Parts 9, 10 and 14 of NI 81-102 as appropriate for the type of security being offered.
Decision
The principal regulator is satisfied that the decision meets the test set out in the Legislation for the principal regulator to make the decision.
1. The decision of the principal regulator is that the Exemption Sought is granted, provided that :
(a) the Fund offers both Mutual Fund Securities and ETF Securities;
(b) the Filer files a long form prospectus in respect of the Mutual Fund Securities in accordance with the requirements of NI 41-101 and Form 41-101F2, other than the requirements pertaining to the filing of an ETF Facts document;
November 7, 2019 (2019), 42 OSCB 8644
Decisions, Orders and Rulings
SCHEDULE A 2.1.2 FT Portfolios Canada Co. and First Trust Short Duration High Yield Bond ETF (CAD-Hedged) FUNDS Headnote Evolve Active US Core Equity ETF National Policy 11-203 Process for Exemptive Relief Evolve Active Short Duration Bond ETF Applications in Multiple Jurisdictions – Approval of investment fund merger – approval required because Evolve Active Canadian Preferred Share ETF merger does not meet the criteria for pre-approved reorganizations and transfers – a reasonable person may Evolve Marijuana ETF not consider the Funds to have substantially similar fundamental investment objectives – merger will not be a Evolve Blockchain ETF “qualifying exchange” or a tax-deferred transaction under the Income Tax Act – meeting materials did not include Evolve Active Core Fixed Income ETF statement required by paragraph 5.6(1)(f)(iii) of NI 81-102 – merger to otherwise comply with pre-approval criteria, Evolve Active Global Fixed Income ETF including securityholder vote and IRC approval – securityholders provided with timely and adequate Evolve Cyber Security Index ETF disclosure regarding the mergers – National Instrument 81- 102 Investment Funds. Evolve North American Gender Diversity Index ETF Applicable Legislative Provisions Evolve Automobile Innovation Index ETF National Instrument 81-102 Investment Funds, ss. Evolve US Banks Enhanced Yield ETF 5.5(1)(b), 5.6(1), and 19.1.
Evolve Global Healthcare Enhanced Yield ETF October 29, 2019
Evolve Innovation Index ETF IN THE MATTER OF THE SECURITIES LEGISLATION OF Sphere FTSE Canada Sustainable Yield Index ETF ONTARIO (the Jurisdiction) Sphere FTSE Europe Sustainable Yield Index ETF AND Sphere FTSE Emerging Markets Sustainable Yield Index ETF IN THE MATTER OF THE PROCESS FOR EXEMPTIVE RELIEF APPLICATIONS IN MULTIPLE JURISDICTIONS
AND
IN THE MATTER OF FT PORTFOLIOS CANADA CO. (the Filer)
AND
FIRST TRUST SHORT DURATION HIGH YIELD BOND ETF (CAD-HEDGED) (the Terminating Fund)
DECISION
Background
The principal regulator in the Jurisdiction has received an application from the Filer on behalf of the Terminating Fund and First Trust Senior Loan ETF (CAD-Hedged) (the Continuing Fund, and together with the Terminating Fund, the Funds) for a decision of the principal regulator under the securities legislation of the Jurisdiction of the principal regulator (the Legislation) for approval of the proposed
November 7, 2019 (2019), 42 OSCB 8645
Decisions, Orders and Rulings merger of the Funds (the Merger) pursuant to subsection 8. Securities of the Continuing Fund are qualified for 5.5(1)(b) of National Instrument 81-102 Investment Funds sale in each of the Canadian Jurisdictions (NI 81-102) in connection with (the Approval Sought). pursuant to a long form prospectus and ETF facts, each dated April 26, 2019, as amended. Under the Process for Exemptive Relief Applications in Multiple Jurisdictions (for a passport application): 9. The Funds are reporting issuers as defined under the applicable securities legislation of each of the (a) the Ontario Securities Commission is the Canadian Jurisdictions and are not in default of principal regulator for this application, any of the requirements of the securities and legislation of any of the Canadian Jurisdictions.
(b) the Filer has provided notice that 10. The Terminating Fund offers common units and subsection 4.7(1) of Multinational advisor class units (the Terminating Fund Units), Instrument 11-102 Passport System (MI which currently trade on the Toronto Stock 11-102) is intended to be relied upon in Exchange (the TSX) under the ticker symbols FSD British Columbia, Alberta, Saskatchewan, and FSD.A. Manitoba, Quebec, New Brunswick, Nova Scotia, Prince Edward Island, 11. The Continuing Fund offers common units and Newfoundland and Labrador, Yukon, advisor class units (the Continuing Fund Units), Northwest Territories and Nunavut which currently trade on the TSX under the ticker (together with Ontario, the Canadian symbols FSL and FSL.A. Jurisdictions). 12. Other than under circumstances in which the Interpretation securities regulatory authority or securities regulator of the Canadian Jurisdictions has Terms defined in National Instrument 14-101 Definitions expressly exempted a Fund therefrom, each of the and MI 11-102 have the same meaning if used in this Funds is governed and follows the standard decision, unless otherwise defined. investment restrictions and practices established by NI 81-102. Representations Reason for Approval Sought This decision is based on the following facts represented by the Filer: 13. The Filer proposes to merge the Terminating Fund into the Continuing Fund on or about November 4, The Filer 2019 (the Effective Date).
1. The Filer is a corporation existing under the laws 14. The Approval Sought is required because the of Nova Scotia with its principal offices located in Merger does not meet all of the criteria for pre- Toronto, Ontario. approved reorganizations and transfers set out in subsection 5.6(1) of NI 81-102. In particular: 2. The Filer is the manager and trustee of the Funds. (a) a reasonable person may not consider 3. The Filer is registered as an investment fund the Funds to have substantially similar manager in Ontario. fundamental investment objectives;
4. The Filer is not in default of the securities (b) the Merger will not be a “qualifying legislation of any of the Canadian Jurisdictions. exchange” within the meaning of section 132.2 of the Income Tax Act (Canada) The Funds (the ITA) or a tax-deferred transaction under subsection 85(1), 85.1(1), 86(1) or 5. Each of the Funds is an exchange-traded mutual 87(1) of the ITA; and fund and is governed by the provisions of NI 81- 102. (c) due to inadvertence, the Meeting Materials (as defined below) did not 6. Each of the Funds is an open-ended mutual fund include the statement required by trust established under the laws of Ontario paragraph 5.6(1)(f)(iii) of NI 81-102 in pursuant to an amended and restated declaration respect of the Continuing Fund. of trust dated May 1, 2013, as amended. 15. Except as described above, the Merger will 7. Securities of the Terminating Fund are qualified otherwise comply with all other criteria for pre- for sale in each of the Canadian Jurisdictions approved reorganizations and transfers as set out pursuant to a long form prospectus and ETF facts, in section 5.6 of NI 81-102. each dated April 26, 2019, as amended.
November 7, 2019 (2019), 42 OSCB 8646
Decisions, Orders and Rulings
16. Although the investment objectives of the 24. The Circular describes all of the relevant facts Terminating Fund may not be substantially similar concerning the Merger, including a description of to the Continuing Fund, in the Filer’s view: the proposed Merger, information about the Funds, including the differences between the (a) the investment objectives and investment respective investment objectives of the Funds, strategies of the Funds are similar in that and income tax considerations for unitholders of both are designed to provide a high level the Terminating Fund, as well as the IRC’s of current income with capital recommendation of the Merger, so that unitholders appreciation as a secondary objective; of the Terminating Fund may make an informed and decision before voting on whether to approve the Merger. (b) the Terminating Fund has a similar investment mandate as the Continuing 25. The Circular also describes the various ways in Fund and would generally attract the which unitholders can obtain, at no cost, the same type of investor with a similar risk- current prospectus, most recently filed ETF Facts, return profile. most recently filed annual financial statements and most recently filed annual management report of 17. Although the Merger is being conducted on a fund performance of the Terminating Fund. The taxable basis, in the Filer’s view, it is in the best Filer will also provide the current prospectus, most interest of the unitholders of the Funds to recently filed ETF Facts, most recently filed annual complete the Merger on a taxable basis so that financial statements, most recently filed interim the capital losses in the Continuing Fund will financial reports, most recently filed annual continue to be available to the Continuing Fund. management report of fund performance and most recently filed interim management report of fund The Merger performance of the Continuing Fund upon request.
18. A press release with respect to the Merger was 26. Investors of the Terminating Fund had an issued and filed on the System for Electronic opportunity to consider this information prior to Document Analysis and Retrieval (SEDAR) on voting on the Merger at the Meeting. September 16, 2019. 27. The Merger will not be a “material change” for the 19. A material change report with respect to the Continuing Fund and accordingly, the Filer has no Merger was filed on SEDAR for the Terminating intention to convene a meeting of unitholders for Fund on September 18, 2019. the Continuing Fund to approve the Merger.
20. An amendment dated September 18, 2019 to the 28. The Filer will pay for the costs and expenses long form prospectus of the Terminating Fund associated with the Merger, including the cost of dated April 26, 2019 announcing the Merger was holding the meeting and of soliciting proxies, filed on SEDAR. including the costs of mailing the Circular and accompanying materials. Neither of the Funds will 21. Pursuant to National Instrument 81-107 bear any of the costs and expenses associated Independent Review Committee for Investment with the Merger. Funds, the independent review committee of the Terminating Fund (the IRC) reviewed the Merger 29. No fees, sales charges or expenses will be as a potential “conflict of interest matter”, and payable in connection with the acquisition by the provided its positive recommendation for the Continuing Fund of the investment portfolio of the Merger, after determining that the Merger would Terminating Fund. achieve a fair and reasonable result for the Terminating Fund. 30. No fees or sales charges will be payable by unitholders of the Funds in connection with the 22. Pursuant to paragraph 5.1(1)(f) of NI 81-102, Merger. unitholders of the Terminating Fund approved the Merger at a special meeting of unitholders held on 31. The investment portfolio and other assets of the October 25, 2019 (the Meeting), as required by NI Terminating Fund to be acquired by the 81-102. Continuing Fund in order to effect the Merger are currently, or will be on the Effective Date, 23. A notice of meeting, management information acceptable to the portfolio manager of the circular dated September 20, 2019 (the Circular) Continuing Fund and are, or will be, consistent and form of proxy in connection with the Meeting with the investment objectives of the Continuing (the Meeting Materials) were mailed to the Fund. unitholders of the Terminating Fund on October 4, 2019 and filed on SEDAR in accordance with 32. The cash and any other assets of the Terminating applicable securities laws. Fund acquired by the Continuing Fund in
November 7, 2019 (2019), 42 OSCB 8647
Decisions, Orders and Rulings
connection with the Merger will be acquired in basis up to the business day immediately prior to compliance with NI 81-102. the Effective Date, primarily through the designated broker and dealers of the Terminating 33. The Merger will be structured substantially as Fund. follows: 36. In addition, unitholders of the Terminating Fund (a) The value of the Terminating Fund’s will be able to trade their Terminating Fund Units portfolio and other assets will be on the TSX in the ordinary course at least until the determined as of the close of trading on close of business on the business day before the the business day immediately preceding Effective Date. the Effective Date. Benefits of the Merger (b) Immediately following the close of business on the Effective Date, the 37. The Filer believes that the Merger is beneficial to Terminating Fund will transfer all or unitholders of the Terminating Fund for the substantially all of its net assets to the following reasons: Continuing Fund in consideration for the issuance by the Continuing Fund to the (a) The Continuing Fund provides Terminating Fund of a number of the unitholders with greater exposure to Continuing Fund’s common units and investments in senior floating rate loans, advisor class units determined based on which includes loans of issuers with an exchange ratio calculated based on strong credit metrics such as strong cash the relative net asset values of the flows and effective management teams, Continuing Fund Units and Terminating while still maintaining some exposure to Fund Units (the Exchange Ratio). below investment grade high yield debt. The Continuing Fund’s emphasis on (c) Immediately following the transfer of senior secured loans should provide a assets of the Terminating Fund to the measure of additional protection for Continuing Fund and the issuance of unitholders of the Terminating Fund as Continuing Fund Units to the Terminating compared to investments in debt Fund, all of the Terminating Fund Units securities that are not secured. will be automatically redeemed. (b) Since the Terminating Fund has a similar (d) Each unitholder of common units of the investment mandate as the Continuing Terminating Fund will receive such Fund and would generally attract the number of common units of the same type of investor with a similar risk- Continuing Fund, and each unitholder of return profile, the Merger will contribute advisor class units of the Terminating towards reducing duplication and Funds will receive such number of redundancy across the Filer’s fund line- advisor class units of the Continuing up. Fund, as determined by the Exchange Ratio. (c) The Continuing Fund is expected to attract more assets as marketing efforts (e) The Terminating Fund Units will, subject will be concentrated on fewer funds, to the approval of the TSX, be de-listed rather than two Funds with similar from the TSX in advance of the Effective investment mandates. The ability to Date. attract assets to the Continuing Fund will benefit investors by ensuring that the (f) As soon as reasonably possible following Continuing Fund remains viable, long- the Merger, the Terminating Fund will be term, attractive investment vehicle for wound up and the Continuing Fund will existing and potential investors. continue as an ETF existing under the laws of Ontario. (d) The Continuing Fund has a larger asset base than the Terminating Fund. The 34. The result of the Merger will be that unitholders of Merger will provide unitholders of the the Terminating Fund will cease to be unitholders Terminating Fund with a much larger of the Terminating Fund and will become market capitalization and the secondary unitholders of the Continuing Fund. The market for Continuing Fund Units is Continuing Fund will continue as a publicly offered expected to be more liquid. open-end mutual fund. (e) The Continuing Fund has existing capital 35. Units of the Terminating Fund will continue to be losses that will carry forward and offered, exchanged and redeemed on a daily continue to be available to the Continuing
November 7, 2019 (2019), 42 OSCB 8648
Decisions, Orders and Rulings
Fund, which may benefit all unitholders of 2.1.3 TD Investment Services Inc. the Continuing Fund. Headnote Decision Multilateral Instrument 11-102 Passport System – National The principal regulator is satisfied that the decision meets Policy 11-203 Process for Exemptive Relief Applications in the test set out in the Legislation for the principal regulator Multiple Jurisdictions – National Instrument 33-109 to make the decision. Registration Information (NI 33-109) – relief from certain filing requirements of NI 33-109 in connection with a bulk The decision of the principal regulator is that the Approval deregistration of registered individuals in accordance with Sought is granted. section 3.4 of Companion Policy 33-109CP to NI 33-109.
“Darren McKall” October 30, 2019 Investment Funds and Structured Products Branch IN THE MATTER OF THE SECURITIES LEGISLATION OF ONTARIO (the Jurisdiction)
AND
IN THE MATTER OF THE PROCESS FOR EXEMPTIVE RELIEF APPLICATIONS IN MULTIPLE JURISDICTIONS
AND
TD INVESTMENT SERVICES INC. (the Filer)
DECISION
Background
The principal regulator in the Jurisdiction has received an application from the Filer (the Application) for a decision (the Exemption Sought) under section 7.1 of National Instrument 33-109 — Registration Information (NI 33-109) exempting the Filer from the requirement in section 4.2 of NI 33-109 to submit a completed Form 33-109F1, as defined below, on an individual basis in accordance with National Instrument 31-102 National Registration Database (NI 31-102) upon the bulk termination of registered individuals with authority to act on behalf of the Filer.
Under the Process for Exemptive Relief Applications in Multiple Jurisdictions (for a passport application):
(a) the Ontario Securities Commission (OSC) is the principal regulator for this Application; and
(b) the Filer has provided notice that section 4.7(1) of Multilateral Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon in all of the other provinces and territories of Canada (the Passport Jurisdictions, and together with the Jurisdiction, the Jurisdictions).
November 7, 2019 (2019), 42 OSCB 8649
Decisions, Orders and Rulings
Interpretation 9. Effective as of on or about October 31, 2019, 723 PBAs will be deregistered from TDIS (the bulk Terms defined in National Instrument 14-101 Definitions deregistration). and MI 11-102 have the same meaning if used in this decision, unless otherwise defined. 10. The Filer seeks relief from the requirement to submit a Form 33-109F1 — Notice of Termination Representations of Registered Individuals and Permitted Individuals (Form 33-109F1) for each of its This decision is based on the following facts represented by Registered Individuals in connection with the bulk the Filer: deregistration.
Background 11. No clients and/or client accounts will be negatively impacted by Future Ready and the corresponding 1. The Filer is a corporation organized under the bulk deregistration of PBAs. The Filer anticipates laws of Ontario. The Filer’s principal place of that services will be maintained in the normal business is in Toronto, Ontario. course of business without any disruption.
2. The Filer is a subsidiary of the Toronto-Dominion 12. The Filer provided advanced notice to the MFDA Bank which, collectively with its subsidiaries, is regarding the bulk deregistration of employees. referred to as TD Bank Group (TD). The Canadian retail banking division of TD primarily operates 13. The Filer provided a spreadsheet populated with under the brand “TD Canada Trust” (TDCT). TD the applicable information required by Form 33- has more than 1100 TDCT branch locations 109F1 for each Registered Individual to be across Canada. deregistered to the OSC on September 30, 2019.
3. The Filer is registered as a dealer in the category 14. Given the number of Registered Individuals of the of mutual fund dealer in all of the Jurisdictions and Filer, the preparation and filing of Form 33-109F1s is a member of the Mutual Fund Dealers on behalf of each Registered Individual would Association of Canada (MFDA). achieve no regulatory purpose, while imposing an unwarranted administrative and compliance 4. The Filer is not in default of the securities burden on the Filer. legislation in any of the Jurisdictions. Decision 5. The Filer has approximately 7800 registered individuals (the Registered Individuals) in one or The principal regulator is satisfied that the decision would more of the provinces and territories in Canada. not be prejudicial to the public interest to make the decision. 6. All individuals who trade in securities in the Jurisdictions on behalf of the Filer have been The decision of the principal regulator under the Legislation registered as Registered Individuals in accordance is that the Exemption Sought is granted, provided that the with the registration requirement under section Filer makes acceptable arrangements with CGI Inc., as the 25(1) of the Act and the requirements of NI 31- National Registration Database vendor, for the payment of 102, by submitting a Form 33-109F4 completed the costs associated with filing the termination of with all the information required for a Registered Registered Individuals on a bulk basis, and makes such Individual. payment in advance.
Exemption Under NI 33-109 “Elizabeth King” Deputy Director, 7. In late 2018, TDCT announced a 24-month Compliance & Registrant Regulation Branch transformational plan (Future Ready). A key Ontario Securities Commission component of Future Ready is the creation of a new model for employee roles within TDCT branches.
8. As part of Future Ready, certain TDCT branch roles will see their accountabilities change. This includes employees in the role of Personal Banking Associate (PBA). Due to the changes in accountabilities, most PBAs will no longer be involved in the sale of mutual funds and therefore will no longer require mutual fund registration through TDIS.
November 7, 2019 (2019), 42 OSCB 8650
Decisions, Orders and Rulings
2.1.4 Triple Flag Precious Metals Corp. below); and (iii) the date that is 90 days from the date of this decision. Headnote Under the Process for Exemptive Relief Applications in National Instrument 43-101 Standards of Disclosure for Multiple Jurisdictions (for a passport application): Mineral Projects (NI 43-101) – relief from requirement to file technical reports granted to issuer having royalty interests (a) the Ontario Securities Commission is the or stream interests – Filer to become a reporting issuer principal regulator for this application, pursuant to a proposed initial public offering – relevant and technical disclosure for royalty interests or stream interests previously disclosed by operators or owners of the mineral (b) the Filer has provided notice that projects. subsection 4.7(1) of Multilateral Instrument 11-102 Passport System (MI Applicable Legislative Provisions 11-102) is intended to be relied upon in British Columbia, Alberta, Saskatchewan, National Instrument 43-101 Standards of Disclosure for Manitoba, Québec, New Brunswick, Mineral Projects, ss. 4.1(1) and 9.1(1). Nova Scotia, Prince Edward Island, Newfoundland and Labrador, the Yukon, October 22, 2019 the Northwest Territories and Nunavut (the Non-Principal Jurisdictions). IN THE MATTER OF THE SECURITIES LEGISLATION OF Interpretation ONTARIO (the Jurisdiction) Terms defined in National Instrument 14-101 Definitions and MI 11-102 have the same meaning if used in this AND decision, unless otherwise defined.
IN THE MATTER OF Representations THE PROCESS FOR EXEMPTIVE RELIEF APPLICATIONS This decision is based on the following facts represented by IN MULTIPLE JURISDICTIONS the Filer:
AND 1. the Filer is a corporation existing under the laws of Canada, with a head office in Toronto, Ontario; IN THE MATTER OF TRIPLE FLAG PRECIOUS METALS CORP. 2. the Filer is not a reporting issuer under the (the Filer) Legislation or applicable securities legislation in any Non-Principal Jurisdiction; DECISION 3. the Filer is not in default of the requirements of Background applicable securities legislation in the Jurisdiction or any Non-Principal Jurisdiction; The principal regulator in the Jurisdiction has received an application from the Filer for a decision under the securities 4. the Filer, at the time of the filing of the Final legislation of the Jurisdiction of the principal regulator (the Prospectus (as defined below), will hold through a Legislation) that the Filer be exempted from the wholly-owned subsidiary, Triple Flag Mining requirement in subsection 4.1(1) of National Instrument 43- Finance Bermuda Ltd. (TF Bermuda), among 101 Standards of Disclosure for Mineral Projects (NI 43- other assets, stream interests in Nexa Resources 101) to file a technical report, upon the Filer becoming a S.A.’s (Nexa) Cerro Lindo mine, Continental Gold reporting issuer, for each mineral property material to the Inc.’s (Continental) Buriticá project and Royal Filer, in the circumstances described below (the Bafokeng Platinum Limited’s (Royal Bafokeng) Exemption Sought). PGM mine (which stream transaction remains subject to certain closing conditions); Furthermore, the principal regulator in the Jurisdiction has received a request from the Filer for a decision 5. the Filer, at the time of the filing of the Final (Confidentiality Sought) that the application and this Prospectus, will hold through an indirect wholly- decision document (the Confidential Material) be kept owned subsidiary, TF Australia Holdings Ltd. confidential and not be made public until the earlier of: (i) (Australia Holdings), among other assets, a the date on which the Filer advises the principal regulator royalty interest in Kirkland Lake Gold Ltd.’s that there is no need for the Confidential Material to remain (Kirkland Lake) Fosterville mine; confidential; (ii) the date on which the Filer receives a receipt in respect of the Preliminary Prospectus (as defined 6. under subsection 4.2(1) of NI 43-101, an issuer is required to file a technical report that relates to a
November 7, 2019 (2019), 42 OSCB 8651
Decisions, Orders and Rulings
mineral project on a property material to the issuer are owned and operated directly or indirectly by upon the issuer filing certain documents, including Royal Bafokeng, whose securities trade on the a preliminary prospectus; Johannesburg Stock Exchange (the JSX) (a specified exchange under NI 43-101), and (ii) 7. the definition of mineral project under section 1.1 Royal Bafokeng would be a “producing issuer” for of NI 43-101 includes a royalty interest or similar purposes of NI 43-101 based on its gross revenue interest; derived from mining operations for the year ended December 31, 2018, as reflected in its audited 8. under subsection 4.1(1) of NI 43-101, an issuer is financial statements for that period. Royal required to file a technical report for a mineral Bafokeng is not a reporting issuer in any property material to the issuer upon becoming a jurisdiction of Canada; reporting issuer in a jurisdiction of Canada; 17. Royal Bafokeng discloses mineral resources and 9. the Filer will become a reporting issuer under the mineral reserves in accordance with the guidelines Legislation and the applicable securities legislation and principles of the SAMREC Code and in in the Non-Principal Jurisdictions following the accordance with the requirements of the JSX and filing of, and obtaining a receipt for, a final applicable corporate laws. A mineral resources prospectus (the Final Prospectus) in connection and mineral reserves statement in respect of the with a proposed initial public offering (IPO). The Royal Bafokeng PGM properties entitled Mineral Filer proposes to file a preliminary prospectus for Resources and Mineral Reserves Statement 2018 the IPO on or about October 24, 2019 (the and dated April 29, 2019 is available on Royal Preliminary Prospectus); Bafokeng’s website at bafokengplatinum.co.za;
10. the Filer anticipates that the stream interests in the 18. according to the public disclosure record of Cerro Lindo and Buriticá properties and the royalty Continental, the Buriticá property is owned and interest in the Fosterville property will make those operated directly or indirectly by Continental, properties material to the Filer; which is a reporting issuer in each of the provinces of Canada other than Quebec; 11. the Filer anticipates that, following the completion of the stream transaction, the stream interest in 19. a technical report for the Buriticá property entitled the Royal Bafokeng PGM properties will also be NI 43-101 Buriticá Mineral Resource 2019-01, material to the Filer; Antioquia, Colombia (the Buriticá Report) was filed by Continental on March 18, 2019. The 12. the Filer will make scientific and technical Buriticá Report is available on SEDAR under disclosure regarding the Cerro Lindo, Royal Continental’s profile at www.sedar.com. According Bafokeng PGM, Buriticá and Fosterville properties to the public disclosure record of Continental, the in the Preliminary Prospectus and the Final Buriticá Report was prepared in accordance with Prospectus; NI 43-101;
13. the Filer is not the owner or operator of the Cerro 20. according to the public disclosure record of Lindo property, the Royal Bafokeng PGM Kirkland Lake, the Fosterville property is owned properties, the Buriticá property or the Fosterville and operated directly or indirectly by Kirkland property; Lake, which is a reporting issuer in each of the provinces of Canada other than Quebec; 14. according to the public disclosure record of Nexa, the Cerro Lindo property is owned and operated 21. a technical report for the Fosterville property directly or indirectly by Nexa, which is a reporting entitled Updated NI 43-101 Technical Report, issuer in all of the provinces and territories of Fosterville Gold Mine in the State of Victoria, Canada; Australia (the Fosterville Report) was filed by Kirkland Lake on April 1, 2019. The Fosterville 15. a technical report for the Cerro Lindo property Report is available on SEDAR under Kirkland entitled Cerro Lindo Polymetallic Mine, Chavin Lake’s profile at www.sedar.com. According to the District, Chincha Province, Peru, NI 43-101 public disclosure record of Kirkland Lake, the Technical Report on Operations (the Cerro Lindo Fosterville Report was prepared in accordance Report) was filed by Nexa on September 21, with NI 43-101; 2017. The Cerro Lindo Report is available on SEDAR under Nexa’s profile at www.sedar.com. 22. the Filer will identify in any document that it files According to the public disclosure record of Nexa, under subsection 4.2(1) of NI 43-101 the source of the Cerro Lindo Report was prepared in the scientific and technical information it discloses accordance with NI 43-101; on the Cerro Lindo, Royal Bafokeng PGM, Buriticá and Fosterville properties; and 16. according to the public disclosure record of Royal Bafokeng, (i) the Royal Bafokeng PGM properties
November 7, 2019 (2019), 42 OSCB 8652
Decisions, Orders and Rulings
23. to the best of the Filer’s knowledge, information 2.1.5 TD Asset Management Inc. et al. and belief, the current or predecessor owners or operators of the Cerro Lindo, Royal Bafokeng Headnote PGM, Buriticá and Fosterville properties have disclosed the scientific and technical information Multilateral Instrument 11-102 Passport System – National that is material to the Filer. Policy 11-203 Process for Exemptive Relief Applications in Multiple Jurisdictions – National Instrument 33-109 Decision Registration Information (NI 33-109) – relief from certain filing requirements of NI 33-109 in connection with a bulk The principal regulator is satisfied that the decision meets transfer of business locations and registered and non- the test set out in the Legislation for the principal regulator registered individuals pursuant to an amalgamation in to make the decision. accordance with section 3.4 of Companion Policy 33- 109CP to NI 33-109. The decision of the principal regulator under the Legislation is that the Exemption Sought is granted. November 1, 2019
Furthermore, the decision of the principal regulator is that IN THE MATTER OF the Confidentiality Sought is granted. THE SECURITIES LEGISLATION OF ONTARIO “Jo-Anne Matear” Manager, Corporate Finance AND Ontario Securities Commission IN THE MATTER OF THE PROCESS FOR EXEMPTIVE RELIEF APPLICATIONS IN MULTIPLE JURISDICTIONS
AND
IN THE MATTER OF TD ASSET MANAGEMENT INC. (TDAM), GREYSTONE CAPITAL MANAGEMENT INC. (GCMI) AND GREYSTONE MANAGED INVESTMENTS INC. (collectively, the Filers)
DECISION
Background
The securities regulatory authority or regulator in Ontario has received an application from the Filers for a decision under the securities legislation of the jurisdiction of the principal regulator (the Legislation) for relief from sections 2.2, 2.3, 2.5, 3.2 and 4.2 of National Instrument 33-109 Registration Information (NI 33-109) pursuant to section 7.1 of NI 33-109 to allow the bulk transfer (the Bulk Transfer), of all of the registered and non-registered individuals and all of the locations of each of the Filers to a new amalgamated entity TD Asset Management Inc. (New TDAM) on or about November 1, 2019, in accordance with section 3.4 of the Companion Policy to NI 33-109 (the Exemption Sought).
Under the Process for Exemptive Relief Applications in Multiple Jurisdictions:
(a) the Ontario Securities Commission is the principal regulator for this application, and
(b) the Filers have provided notice that section 4.7(1) of Multilateral Instrument
November 7, 2019 (2019), 42 OSCB 8653
Decisions, Orders and Rulings
11-102 Passport System (MI 11-102) is 10. The head office of GMI is located in Regina, intended to be relied upon in each Saskatchewan and its principal regulator is the jurisdiction of Canada outside of Ontario FCAA. (together with Ontario, the Jurisdictions). 11. GMI is currently registered in Alberta, British Interpretation Columbia, Manitoba, New Brunswick, Newfoundland and Labrador, Northwest Terms defined in MI 11-102 and National Instrument 14- Territories, Nova Scotia, Ontario, Prince Edward 101 Definitions have the same meaning in this decision, Island, Québec and Saskatchewan as an exempt unless they are otherwise defined in this decision. market dealer and portfolio manager and in Ontario, Newfoundland and Labrador, Québec Representations and Saskatchewan as an investment fund manager. This decision is based on the following facts represented by the Filers: 12. As of the date hereof, GMI has approximately 54 registered dealing representatives, advising 1. TDAM is a corporation amalgamated under the representatives and associate advising Business Corporations Act (Ontario). representatives in one or more of the Jurisdictions and four business locations in one or more of the 2. The head office of TDAM is located in Toronto, Jurisdictions. Ontario. TDAM is a subsidiary of The Toronto- Dominion Bank. 13. GMI and GCMI only have permitted clients as defined in National Instrument 31-103 Registration 3. TDAM is currently registered in all provinces and Requirements, Exemptions, and Ongoing territories of Canada as an exempt market dealer Registrant Obligations. GMI and GCMI do not and portfolio manager, in Ontario, Newfoundland have any retail clients. and Labrador and Québec as an investment fund manager, in Ontario as a commodity trading 14. The Filers, to the best of their knowledge, are not manager and in Québec as a derivatives portfolio in default of any requirements of the securities manager. legislation in the Jurisdictions.
4. As of the date hereof, TDAM has approximately 15. None of the Filers is a member of any self- 96 registered dealing representatives, advising regulatory organization. representatives and associate advising representatives in one or more of the Jurisdictions 16. It is proposed that the Filers will effect an and 7 business locations in one or more of the amalgamation (the Amalgamation) under the Jurisdictions. provisions of the Business Corporations Act (Ontario), which will involve GCMI and GMI 5. GCMI was originally incorporated pursuant to the amalgamating into TDAM, with TD Asset Canada Business Corporations Act. However, in Management Inc. (New TDAM) being the name of connection with and prior to the Amalgamation (as the amalgamated company. defined below), GCMI has been continued into Ontario under the Business Corporations Act 17. The Amalgamation is scheduled to occur on (Ontario). November 1, 2019.
6. The head office of GCMI is located in Regina, 18. Upon the Amalgamation, the shares of GCMI and Saskatchewan and its principal regulator is the GMI will be cancelled and New TDAM will accede Financial and Consumer Affairs Authority of to the assets and liabilities of GCMI and GMI. Saskatchewan (FCAA). 19. Upon Amalgamation, New TDAM will carry on the 7. GCMI is currently registered in Saskatchewan as same business operations in substantially the a portfolio manager. same manner with essentially the same personnel as the Filers. 8. As of the date hereof, GCMI has one registered advising representative in one or more of the 20. As a result of the Amalgamation, all of the current Jurisdictions and two business locations in one or registrable activities of the Filers will become the more of the Jurisdictions. responsibility of New TDAM. New TDAM will assume all of the existing registrations and 9. GMI was originally incorporated pursuant to the approvals for all of the registered individuals and Canada Business Corporations Act. However, in all of the locations of the Filers. connection with and prior to the Amalgamation, GMI has been continued into Ontario under the 21. The registered representatives transferred to New Business Corporations Act (Ontario). TDAM will carry on the same registerable activities
November 7, 2019 (2019), 42 OSCB 8654
Decisions, Orders and Rulings
at New TDAM as they conducted at TDAM, GCMI The decision of the principal regulator under the Legislation or GMI, as applicable. the Exemption Sought is granted provided that the Filers make acceptable arrangements with CDS Inc. for the 22. There will be no disruption to New TDAM’s ability payment of the costs associated with the Bulk Transfer, to advise and trade on behalf of TDAM’s clients as and make such payment in advance of the Bulk Transfer. well as GCMI and GMI clients upon the Amalgamation. GMI and GCMI clients have been “Elizabeth King” notified of the Amalgamation. Ontario Securities Commission
23. TDAM is currently registered and New TDAM will be registered in the same categories as the Filers so no new additional categories of registration will be sought.
24. As a result of the Amalgamation, all individuals currently registered with the Filers as well as branch and sub-branch locations will remain the same but will have to be transferred to New TDAM. The head office of New TDAM will be located in Toronto, Ontario.
25. Given the significant number of locations and registered and non-registered individuals that are associated on the National Registration Database with the Filers, it would be extremely difficult and unduly time-consuming to transfer each individual registration to New TDAM in accordance with the requirements set out in 33-109 in a manner so as not to interrupt the Filers’ business activities as a registrant if the Exemption Sought is not granted. Moreover, it is important that the transfer of the affected business locations and individuals occur on the same date (i.e. the date of the Amalgamation), in order to ensure that there is no lapse in registration.
26. In addition, the Exemption Sought will provide for an efficient and timely transfer of information and reduce the risk of inadvertent errors caused by a large number of separate transactions and entries on the National Registration Database, thus reducing administrative costs.
27. The Filers do not expect that any conflicts of interest will arise as a result of the Amalgamation. TDAM, GMI and GCMI currently all have procedures in place to address conflicts of interest. These procedures will be standardized as appropriate post Amalgamation for New TDAM.
28. The Bulk Transfer will not be contrary to the public interest and will have no negative consequence on the ability of the Filers to comply with all applicable regulatory requirements or the ability to satisfy obligations to their clients.
Decision
The principal regulator is satisfied that the decision meets the test set out in the Legislation for the principal regulator to make the decision.
November 7, 2019 (2019), 42 OSCB 8655
Decisions, Orders and Rulings
2.1.6 Caldwell Investment Management Ltd. and Clearpoint Global Dividend Fund
Headnote
National Policy 11-203 Process for Exemptive Relief Applications in Multiple Jurisdictions – approval of investment fund merger – approval required because merger does not meet the criteria for pre-approved reorganizations and transfers in National Instrument 81-102 Investment Funds – the terminating fund and continuing fund do not have substantially similar fundamental investment objectives – terminating fund unitholders not mailed fund facts of continuing fund – management information circular mailed to terminating fund unitholders did not include reference to fund facts of continuing fund being available at no cost – mergers otherwise comply with pre-approval criteria, including qualifying exchange under the Income Tax Act (Canada), unitholder vote, IRC approval – unitholders provided with timely and otherwise adequate disclosure regarding the merger.
Applicable Legislative Provisions
National Instrument 81-102 Investment Funds, ss. 5.5(1)(b) and 19.1.
October 25, 2019
IN THE MATTER OF THE SECURITIES LEGISLATION OF ONTARIO (the Jurisdiction)
AND
IN THE MATTER OF THE PROCESS FOR EXEMPTIVE RELIEF APPLICATIONS IN MULTIPLE JURISDICTIONS
AND
IN THE MATTER OF CALDWELL INVESTMENT MANAGEMENT LTD. (the Filer)
AND
IN THE MATTER OF CLEARPOINT GLOBAL DIVIDEND FUND
DECISION
Background
The principal regulator in the Jurisdiction has received an application from the Filer on behalf of Clearpoint Global Dividend Fund (the Terminating Fund) and Caldwell U.S. Dividend Advantage Fund (the Continuing Fund and together with the Terminating Fund, the Funds) for a decision under the securities legislation of the Jurisdiction (the Legislation) for approval of the proposed merger (the Merger) of the Terminating Fund into the Continuing Fund, pursuant to paragraph 5.5(1)(b) of National Instrument 81-102 Investment Funds (NI 81-102), (the Approval Sought).
Under the Process for Exemptive Relief Applications in Multiple Jurisdictions (for a passport application):
(a) the Ontario Securities Commission is the principal regulator for this application; and
(b) the Filer has provided notice that subsection 4.7(1) of Multilateral Instrument 11-102 Passport System (MI 11- 102) is intended to be relied upon in each of British Columbia, Alberta, Saskatchewan, Manitoba, Quebec, New Brunswick, Nova Scotia, Prince Edward Island and Newfoundland and Labrador (the Jurisdictions).
Interpretation
Terms defined in MI 11-102, National Instrument 14-101 Definitions and NI 81-102 have the same meaning if used in this decision, unless otherwise defined.
November 7, 2019 (2019), 42 OSCB 8656
Decisions, Orders and Rulings
Representations
This decision is based on the following facts represented by the Filer:
The Filer and the Funds
1. The Filer is a corporation existing under the laws of Ontario with its registered head office in Toronto, Ontario.
2. The Filer is registered in the following categories in the jurisdictions as indicated below:
(a) Ontario: Portfolio Manager (PM) and Investment Fund Manager (IFM);
(b) Alberta: PM and IFM;
(c) British Columbia: PM and IFM;
(d) Quebec: PM and IFM;
(e) Newfoundland and Labrador: IFM;
(f) Manitoba: PM and IFM; and
(g) Saskatchewan: PM and IFM.
3. The Filer is the investment fund manager and portfolio manager of the Funds.
4. Each of the Funds is an open-end mutual fund trust established under the laws of Ontario by a declaration of trust pursuant to which the Filer is the trustee.
5. The Terminating Fund is a reporting issuer under the applicable securities legislation in the Jurisdictions. The Continuing Fund is a reporting issuer under the applicable securities legislation in the Jurisdictions and the territories of Canada. Each of the Funds is subject to NI 81-102.
6. Securities of the Terminating Fund are currently qualified for distribution in the Jurisdictions pursuant to the simplified prospectus, annual information form and fund facts documents dated February 28, 2019, as amended on June 24, 2019, July 18, 2019, August 28, 2019 and September 27, 2019 (the Terminating Fund Offering Documents).
7. Securities of the Continuing Fund are currently qualified for distribution in the Jurisdictions and the territories of Canada pursuant to the simplified prospectus, annual information form and fund facts documents dated July 19, 2019 (the Continuing Fund Offering Documents and together with the Terminating Fund Offering Documents, the Offering Documents).
8. The net asset value for each series of the Funds is calculated on a daily basis in accordance with the Funds’ valuation policy and as described in the Offering Documents.
9. Neither the Filer nor the Funds are in default of securities legislation in the Jurisdictions.
Reason for Approval Sought
10. Regulatory approval of the Merger is required because the Merger does not satisfy all of the criteria for pre-approved reorganizations and transfers set out in section 5.6 of NI 81-102. In particular:
(a) the investment objectives of the Continuing Fund are not, or may not be considered to be, “substantially similar” to the investment objectives of the Terminating Fund;
(b) due to inadvertence, the Meeting Materials (as defined below) did not include the most recently filed fund facts of the Continuing Fund, as required by 5.6(1)(f)(ii) of NI 81-102; and
(c) due to inadvertence, the Meeting Materials did not include the statement required by paragraph 5.6(1)(f)(iii)(A)(III) of NI 81-102 in respect of the Continuing Fund.
11. The investment objectives of the Terminating Fund and the Continuing Fund are as follows:
November 7, 2019 (2019), 42 OSCB 8657
Decisions, Orders and Rulings
Terminating Fund Continuing Fund
Seeks to provide Unitholders with long-term capital Seeks to provide its unitholders with (a) monthly growth by investing primarily in equity securities of distributions and (b) the potential for capital companies around the world. appreciation and enhanced long-term risk adjusted returns by investing primarily in dividend-paying equity securities of U.S. domiciled issuers or issuers that derive a significant portion of their revenue or earnings from the U.S.
12. Except as described in this decision, the Merger complies with all of the other criteria for pre-approved reorganizations and transfers set out in section 5.6 of NI 81-102.
The Proposed Merger
13. In its capacity as manager of the Funds, the Filer proposes to merge the Terminating Fund into the Continuing Fund.
14. In accordance with National Instrument 81-106 Investment Fund Continuous Disclosure, a press release describing the proposed Merger has been issued and the press release, material change report, each dated September 26, 2019, amendment to the simplified prospectus of the Terminating Fund, amendment to the annual information form of the Terminating Fund and the amended and restated fund facts documents of the Terminating Fund, all dated September 27, 2019, and which give notice of the proposed Merger, have been filed via the System for Electronic Document Analysis and Retrieval (SEDAR).
15. The unitholders of the Terminating Fund approved the Merger at a meeting of the unitholders of the Terminating Fund held on October 18, 2019.
16. Subject to receipt of the Approval Sought, the Merger is expected to occur on or about October 25, 2019, or as soon as practicable thereafter (the Effective Date).
17. The proposed Merger does not require approval of existing unitholders of the Continuing Fund as the Filer has determined that the proposed Merger does not constitute a material change to the Continuing Fund.
18. As required by National Instrument 81-107 Independent Review Committee for Investment Funds (NI 81-107), the Independent Review Committee (IRC) has been appointed for the Funds. The Filer presented the terms of the Merger to the IRC for a recommendation. The IRC reviewed the proposed Merger and provided a positive recommendation for the Merger, having determined that the Merger, if implemented, would achieve a fair and reasonable result for each of the Funds and their respective unitholders. A summary of the IRC’s recommendation has been included in the notice of special meeting sent to unitholders of the Terminating Fund as required by subsection 5.1(2) of NI 81-107.
19. A notice of meeting, a management information circular dated September 24, 2019 (the Circular) and a proxy in connection with the Merger (the Meeting Materials) were mailed to the unitholders of the Terminating Fund in accordance with applicable securities laws, both of which have been filed on SEDAR. The Circular contains a description of the proposed Merger, information about the Terminating Fund and the Continuing Fund, the IRC’s recommendation regarding the Merger, and the income tax considerations for unitholders of the Terminating Fund. The Circular discloses that unitholders of the Terminating Fund may obtain at no cost, the following documents of the Continuing Fund by contacting the Filer or by accessing the website of the Filer or SEDAR: the most recent comparative financial statements, the management report of fund performance for its most recently completed financial year, the current simplified prospectus, and current annual information form. The Filer will also provide the fund facts in respect of the Continuing Fund upon request.
20. In light of the disclosure in the Circular, unitholders of the Terminating Fund would have had all the information necessary to determine whether the proposed Merger is appropriate for them.
21. Costs and expenses associated with the Merger will be borne by the Filer and will not be charged to the Funds. The costs of the Merger include legal, printing, mailing and regulatory fees, as well as proxy solicitation and brokerage costs.
22. Subject to receiving the necessary approvals, effective as of the close of business on the date before the Effective Date, the Terminating Fund will cease distribution of securities and any new purchases of securities will not be allowed. The Terminating Fund will remain closed to purchase-type transactions, except pursuant to the Terminating Fund’s monthly investment program, until it is merged with the Continuing Fund on the Effective Date. All monthly investment programs shall remain unaffected until the business day immediately before the Effective Date.
November 7, 2019 (2019), 42 OSCB 8658
Decisions, Orders and Rulings
23. Unitholders in the Terminating Fund will continue to have the right to redeem their securities up to the close of business on the last business day before the effective date of the Merger.
24. Following the Merger, all optional services (such as monthly investment programs) will continue to be available to investors. Unitholders of the Terminating Fund will be automatically enrolled in comparable plans with respect to their corresponding securities of the Continuing Fund unless they advise otherwise.
25. Unitholders may change or cancel any monthly investment programs at any time and unitholders of the Terminating Fund who wish to establish one or more monthly investment programs in respect of their holdings in the Continuing Fund may do so following the Merger.
26. Unitholders of the Terminating Fund who elected to receive distributions in cash from the Terminating Fund before the Merger will receive distributions in cash from the Continuing Fund after the Merger.
27. No sales charges will be payable by unitholders of the Funds in connection with the Merger.
28. The Merger will be completed as a “qualifying exchange” or a tax-deferred transaction under the Income Tax Act (Canada) (the Tax Act).
29. The Terminating Fund and the Continuing Fund are, and are expected to continue to be at all material times, mutual fund trusts under the Tax Act and, accordingly, units of both Funds are "qualified investments" under the Tax Act for registered retirement savings plans, registered retirement income funds, deferred profit sharing plans, registered education savings plans, registered disability savings plans and tax free savings accounts.
Proposed Merger Steps
30. Any investment held by the Terminating Fund that is not consistent with the investment objective of the Continuing Fund or acceptable to the portfolio manager of the Continuing Fund will be sold prior to the Effective Date. As a result, the Terminating Fund may temporarily hold cash and may not be fully invested in accordance with its investment objectives for a brief period of time prior to the Merger. The value of any investment sold prior to the Effective Date will depend on prevailing market conditions.
31. Under the Merger, the Terminating Fund will transfer all or substantially all of its net assets to the Continuing Fund in consideration for the issuance by the Continuing Fund to the Terminating Fund of a number of Series A units and Series F units of the Continuing Fund determined based on an exchange ratio established as of the close of trading on the business day immediately preceding the effective date of the Merger (the Exchange Ratio).
32. The Exchange Ratio will be calculated based on the relative net asset values of the Series A Units or Series F Units of the Terminating Fund and the Series A units or Series F units of the Continuing Fund.
33. Immediately following the transfer of assets of the Terminating Fund to the Continuing Fund and the issuance of the Series A units and Series F units of the Continuing Fund to the Terminating Fund, all of the Units of the Terminating Fund will be automatically redeemed. Each unitholder will receive such number of Series A units and/or Series F units, as applicable, of the Continuing Fund as is equal to the number of Series A Units and/or Series F Units, as applicable, held by such unitholder as of the close of trading on the business day immediately preceding the effective date of the Merger multiplied by the Exchange Ratio of such units.
34. Units of the Terminating Fund will continue to be offered and redeemed on a daily basis up to the business day immediately prior to the effective date of the Merger.
35. The cash and any other assets of the Terminating Fund acquired by the Continuing Fund in connection with the Merger will be acquired in compliance with NI 81-102.
36. As soon as reasonably possible following the Merger, the Terminating Fund will be wound up and the Continuing Fund will continue as a mutual fund existing under the laws of Ontario.
Benefits of the Merger
37. The Filer believes that the Merger is in the best interests of the Terminating Fund and the Continuing Fund and their unitholders and will be beneficial to unitholders of the Terminating Fund and the Continuing Fund for the following reasons:
November 7, 2019 (2019), 42 OSCB 8659
Decisions, Orders and Rulings
(a) as part of a broader reorganization, the Manager has lowered the management fees charged on the Continuing Fund to 1.75% and 0.75% per annum of net asset value for the Series A and Series F units, respectively, which represents a reduction of 0.25% per annum relative to the 2.0% and 1.0% per annum of net asset value, respectively charged on the Series A and Series F units of the Terminating Fund;
(b) merging the Terminating Fund into the Continuing Fund will provide unitholders with the opportunity to invest in a single fund that will have a larger market capitalization, which is expected to reduce fund administration and regulatory costs on a per unit basis for unitholders;
(c) the Continuing Fund will be significantly larger than the Terminating Fund, offering the potential for increased portfolio diversification; and
(d) the Merger is expected to be implemented on a tax deferred basis to unitholders, and accordingly, the Merger as well as issuance of Series A units and Series F units of the Continuing Fund should not result in a taxable event to unitholders.
Decision
The principal regulator is satisfied that the decision meets the test set out in the Legislation for the principal regulator to make the decision.
The decision of the principal regulator is that the Approval Sought is granted.
“Neeti Varma” Manager Investment Funds and Structured Products Branch Ontario Securities Commission
November 7, 2019 (2019), 42 OSCB 8660
Decisions, Orders and Rulings
2.2 Orders
2.2.1 3iQ and The Bitcoin Fund – s. 8
FILE NO.: 2019-7
IN THE MATTER OF 3iQ CORP. and THE BITCOIN FUND
Lawrence P. Haber, Commissioner and Chair of the Panel
October 29, 2019
ORDER (Section 8 of the Securities Act, RSO 1990, c. S.5)
WHEREAS on June 3, 6, 7 and July 24, 2019, the Ontario Securities Commission held a hearing at 20 Queen Street West, 17th Floor, Toronto, Ontario, to consider the Application for hearing and review filed by 3iQ Corp. and The Bitcoin Fund (the “Applicants”) on March 15, 2019 to review a decision of the Director of the Investment Funds & Structured Products branch of the Commission dated February 15, 2019 (the “Director’s decision”);
ON READING the materials filed and on hearing the submissions of the representatives for the Applicants and for Staff of the Commission;
IT IS ORDERED THAT:
1. the Director’s decision is set aside; and
2. the Director shall issue a receipt for a final prospectus of The Bitcoin Fund, provided the Director is satisfied that there are no grounds under subsection 61 of the Act for the Director to refuse to issue a receipt for any such prospectus, other than the grounds set out in the Director’s decision dated February 15, 2019 or in the Reasons and Decision issued on October 29, 2019 in this proceeding.
“Lawrence P. Haber”
November 7, 2019 (2019), 42 OSCB 8661
Decisions, Orders and Rulings
2.2.2 Portfolio 22 Multi-Family REIT LP (c) this order is the order of the principal regulator and evidences Headnote the decision of the securities regulatory authority or regulator in National Policy 11-206 Process for Cease to be a Ontario. Reporting Issuer Applications – The issuer ceased to be a reporting issuer under securities legislation. ¶ 2 Interpretation
Applicable Legislative Provisions Terms defined in National Instrument 14-101 Definitions and MI 11-102 have the same meaning Securities Act, R.S.O. 1990, c. S.5, as am., s. 1(10)(a)(ii). if used in this order, unless otherwise defined.
October 29, 2019 ¶ 3 Representations
IN THE MATTER OF This order is based on the following facts THE SECURITIES LEGISLATION OF represented by the Filer: BRITISH COLUMBIA AND ONTARIO (THE JURISDICTIONS) 1. the Filer is not an OTC reporting issuer under Multilateral Instrument 51-105 AND Issuers Quoted in the U.S. Over-the- Counter Markets; IN THE MATTER OF THE PROCESS FOR CEASE TO BE 2. the outstanding securities of the Filer, A REPORTING ISSUER APPLICATION including debt securities, are beneficially owned, directly or indirectly, by fewer AND than 15 securityholders in each of the jurisdictions of Canada and fewer than 51 IN THE MATTER OF securityholders in total worldwide; PORTFOLIO 22 MULTI-FAMILY REIT LP (the Filer) 3. no securities of the Filer, including debt securities, are traded in Canada or ORDER another country on a marketplace as defined in National Instrument 21-101 ¶ 1 Background Marketplace Operation or any other facility for bringing together buyers and The securities regulatory authority or regulator in sellers of securities where trading data is each of the Jurisdictions (Decision Maker) have publicly reported; received an application from the Filer for an order under the securities legislation of the Jurisdictions 4. the Filer is applying for an order that the (the Legislation) that the Filer has ceased to be a Filer has ceased to be a reporting issuer reporting issuer in all jurisdictions of Canada in in all of the jurisdictions of Canada in which it is a reporting issuer (the Order Sought). which it is a reporting issuer; and
Under the Process for Cease to be a Reporting 5. the Filer is not in default of securities Issuer Applications (for a dual application): legislation in any jurisdiction.
(a) the British Columbia Securities ¶ 4 Order Commission is the principal regulator for this application, Each of the Decision Makers is satisfied that the order meets the test set out in the Legislation for (b) the Filer has provided notice that the Decision Maker to make the order. subsection 4C.5(1) of Multilateral Instrument 11-102 Passport The decision of the Decision Makers under the System (MI 11-102) is intended to Legislation is that the Order Sought is granted. be relied upon in Alberta, Saskatchewan, Manitoba, New “John Hinze” Brunswick, Nova Scotia, Prince Director, Corporate Finance Edward Island and Newfoundland British Columbia Securities Commission and Labrador, and
November 7, 2019 (2019), 42 OSCB 8662
Decisions, Orders and Rulings
2.2.3 Silk Road Energy Inc.
Headnote
Section 144 of the Securities Act (Ontario) – application for a partial revocation of a cease trade order – issuer cease traded due to failure to file audited annual financial statements – issuer has applied for a partial revocation of the cease trade order to permit the issuer to proceed with a private placement under prospectus exemptions – issuer will use proceeds from private placement to prepare and file continuous disclosure documents and pay related fees – partial revocation granted subject to conditions.
Applicable Legislative Provisions
Securities Act, R.S.O. 1990, c.S.5, as am., ss. 127 and 144. National Policy 11-207 Failure-to-File Cease Trade Orders and Revocations in Multiple Jurisdictions.
ALBERTA SECURITIES COMMISSION
PARTIAL REVOCATION ORDER Under the securities legislation of Alberta and Ontario (the Legislation)
Citation: Re Silk Road Energy Inc., 2019 ABASC 162
October 24, 2019
Silk Road Energy Inc.
Background
1. Silk Road Energy Inc. (the Issuer) is subject to a failure-to-file cease trade order (the FFCTO) issued by the regulator or securities regulatory authority in each of Alberta (the Principal Regulator) and Ontario (each a Decision Maker) respectively on February 1, 2019.
2. The Issuer has applied to each of the Decision Makers for a partial revocation of the FFCTO.
3. This order is the order of the Principal Regulator and evidences the decision of the Decision Maker in Ontario.
Interpretation
Terms defined in National Instrument 14-101 Definitions or in National Policy 11-207 Failure-to-File Cease Trade Orders and Revocations in Multiple Jurisdictions have the same meaning if used in this order, unless otherwise defined.
Representations
4. This decision is based on the following facts represented by the Issuer:
(a) the Issuer was incorporated on November 9, 2010 by Certificate of Incorporation issued pursuant to the Business Corporations Act (Alberta);
(b) the Issuer’s head office is located at 229, 52477 Highway 21 Sherwood Park, Alberta T8A 6K2;
(c) the Issuer is a reporting issuer in the provinces of Alberta, British Columbia and Ontario. The Issuer is not a reporting issuer in any other jurisdiction;
(d) the Issuer is listed on the TSX Venture Exchange under the stock symbol SLK;
(e) the authorized share capital of the Issuer is comprised of an unlimited number of common shares without par value (Common Shares) and an unlimited number of preferred shares (Preferred Shares) of which, as of the date hereof, there are 12,012,788 Common Shares issued and outstanding and no Preferred Shares outstanding;
(f) the FFCTO was issued by the Decision Makers due to the failure of the Issuer to file its annual audited financial statements, annual management’s discussion and analysis and certification of annual filings for the year ended September 30, 2018 (the CD Materials);
November 7, 2019 (2019), 42 OSCB 8663
Decisions, Orders and Rulings
(g) Subsequent to the failure to file the CD Materials, the Issuer has not filed any further financial statements or any continuous disclosure documents required by applicable securities legislation (the Subsequent Filings);
(h) other than the failure to file the CD Materials and Subsequent Filings, the Issuer is not in default of the securities legislation in any jurisdiction and the Issuer’s SEDAR and SEDI filings are up-to-date;
(i) the Issuer seeks to vary the FFCTO to permit the Issuer to complete a private placement (the Private Placement) of units of the Issuer (Units), each Unit consisting of one Preferred Share and one Preferred Share purchase warrant, for gross proceeds of up to $185,000, to one or more subscribers, solely in order to cover all costs and fees (which includes audit fees, professional fees, late filing fees and any other applicable fees) that are related to the fulfillment by the Issuer of all of its disclosure obligations and in order to file all the financial statements and related certifications for all previously ended financial years and interim periods since the date of the FFCTO as required by applicable law and to provide it with sufficient working capital to continue its operations until it can apply for and receive a full revocation of the FFCTO;
(j) the Private Placement will be conducted on a prospectus exemption basis with investors in the United States, offshore jurisdictions and in Ontario who satisfy the accredited investor exemption contained in Section 2.3 of National Instrument 45-106 Prospectus Exemptions;
(k) the Issuer reasonably expects the proceeds from the Private Placement will be used in a manner consistent with the table below:
Legal Fees $70,000
Audit Fees $50,000
Late Filing and Participation Fees $15,000
Accounting Fees $30,000
Registrar and Transfer Agent Fees $10,000 General and Unallocated Working Capital $10,000
Total $185,000
(l) as the Private Placement will involve trades in securities of the Issuer (including, for greater certainty, acts in furtherance of trades in securities of the Issuer), the Private Placement cannot be completed without a variation of the FFCTO;
(m) the Issuer reasonably expects that the proceeds raised from the Private Placement will be sufficient to bring its continuous disclosure up to date and to apply for a full revocation of the FFCTO and pay all outstanding related fees;
(n) within a reasonable time following the completion of the Private Placement, the Issuer intends to apply for a full revocation of the FFCTO.
(o) Upon issuance of this order the Issuer will issue a press release announcing the order and the intention to complete the Private Placement. Upon completion of the Private Placement, the Issuer will issue a press release and file a material change report. As other material events transpire, the Issuer will issue appropriate press releases and material change reports as applicable.
Order
5. Each of the Decision Makers is satisfied that a partial revocation of the FFCTO meets the test set out in the Legislation for the Decision Maker to make the decision.
6. The decision of the Decision Makers under the Legislation is that the FFCTO is partially revoked as it applies to the Issuer solely to permit the Private Placement, provided that prior to completion of the Private Placement, each investor will receive:
(a) a copy of the FFCTO;
(b) a copy of this partial revocation order; and
November 7, 2019 (2019), 42 OSCB 8664
Decisions, Orders and Rulings
(c) written notice from the Issuer, to be acknowledged by each investor in writing, that all of the Issuer’s securities, including the securities issued in connection with the Private Placement, will remain subject to the FFCTO until such orders are revoked and that the issuance of the partial revocation order does not guarantee the issuance of a full revocation in the future.
24 October 2019
“Timothy Robson” Manager, Legal Corporate Finance Alberta Securities Commission
November 7, 2019 (2019), 42 OSCB 8665
Decisions, Orders and Rulings
2.2.4 Holloway Lodging Corporation Interpretation
Headnote Terms defined in National Instrument 14-101 – Definitions and MI 11-102 have the same meaning if used in this order, National Policy 11-206 Process for Cease to be a unless otherwise defined. Reporting Issuer Applications – the issuer ceased to be a reporting issuer under securities legislation. Representations
Applicable Legislative Provisions This order is based on the following facts represented by the Filer: Securities Act, R.S.O. 1990, c. S.5, as am., s. 1(10)(a)(ii). 1. the Filer is not an OTC reporting issuer under November 1, 2019 Multilateral Instrument 51-105 – Issuers Quoted in the U.S. Over-the-Counter Markets; IN THE MATTER OF THE SECURITIES LEGISLATION OF 2. the outstanding securities of the Filer, including NOVA SCOTIA AND ONTARIO debt securities, are beneficially owned, directly or (the Jurisdictions) indirectly, by fewer than 15 securityholders in each of the jurisdictions of Canada and fewer than 51 AND securityholders in total worldwide;
IN THE MATTER OF 3. no securities of the Filer, including debt securities, THE PROCESS FOR CEASE TO BE are traded in Canada or another country on a A REPORTING ISSUER APPLICATIONS marketplace as defined in National Instrument 21- 101 – Marketplace Operation or any other facility AND for bringing together buyers and sellers of securities where trading data is publicly reported; IN THE MATTER OF HOLLOWAY LODGING CORPORATION 4. the Filer is applying for an order that the Filer has (the Filer) ceased to be a reporting issuer in all of the jurisdictions of Canada in which it is a reporting ORDER issuer; and
Background 5. the Filer is not in default of securities legislation in any jurisdiction. The securities regulatory authority or regulator in each of the Jurisdictions (Decision Maker) has received an Order application from the Filer for an order under the securities legislation of the Jurisdictions (the Legislation) that the Each of the Decision Makers is satisfied that the order Filer has ceased to be a reporting issuer in all jurisdictions meets the test set out in the Legislation for the Decision of Canada in which it is a reporting issuer (the Order Maker to make the order. Sought). The decision of the Decisions Makers under the Legislation Under the Process for Cease to be a Reporting Issuer is that the Order Sought is granted. Applications (for a dual application): “Paul E. Radford a) the Nova Scotia Securities Commission Chair is the principal regulator for this Nova Scotia Securities Commission application, “Shirley P. Lee” b) the Filer has provided notice that Vice-chair subsection 4C.5(1) of Multilateral Nova Scotia Securities Commission Instrument 11-102 – Passport System (MI 11-102) is intended to be relied upon in in British Columbia, Alberta, Saskatchewan, Manitoba, Québec, New Brunswick, Prince Edward Island, and Newfoundland and Labrador; and
c) this order is the order of the principal regulator and evidences the decision of the securities regulatory authority or regulator in Ontario.
November 7, 2019 (2019), 42 OSCB 8666
Decisions, Orders and Rulings
2.4 Rulings
2.4.1 ICAP Securities Limited – s. 38 of the CFA and s. 6.1 of OSC Rule 91-502 Trades in Recognized Options
Headnote
Application to the Commission pursuant to section 38 of the Commodity Futures Act (Ontario) (CFA) for a ruling that the Applicant be exempted from the dealer registration requirement in paragraph 22(1)(a) and the prohibition against trading on non- recognized exchanges in section 33 of the CFA. As an introducing broker, the Applicant will offer the ability to trade in commodity futures contracts and commodity futures options that trade on exchanges located outside of Canada and that are cleared through clearing corporations located outside of Canada, including block trades, to certain of its clients in Ontario who meet the definition of "permitted client" in National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations.
Application to the Director for an exemption, pursuant to section 6.1 of OSC Rule 91-502 Trades in Recognized Options (OSC Rule 91-502) exempting the Applicant and its Representatives from the proficiency requirements in section 3.1 of OSC Rule 91- 502 for trades in commodity futures options on exchanges located outside of Canada.
Applicable Legislative Provisions
Acts Cited
Commodity Futures Act, R.S.O. 1990, c. C.20, as am., ss. 22, 33 and 38. Securities Act, R.S.O. 1990, c. S.5, as am.
Instrument Cited
National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations, s. 8.18.
Rule Cited
Ontario Securities Commission Rule 91-502 Trades in Recognized Options, ss. 3.1 and 6.1.
IN THE MATTER OF THE COMMODITY FUTURES ACT, R.S.O. 1990, c. C.20, AS AMENDED (the CFA)
AND
IN THE MATTER OF THE SECURITIES ACT, R.S.O. 1990, c. S.5, AS AMENDED (the OSA)
AND
IN THE MATTER OF ONTARIO SECURITIES COMMISSION RULE 91-502 TRADES IN RECOGNIZED OPTIONS (Rule 91-502)
AND
IN THE MATTER OF ICAP SECURITIES LIMITED
RULING & EXEMPTION (Section 38 of the CFA and Section 6.1 of Rule 91-502)
UPON the application (the Application) of ICAP Securities Limited (the Applicant) to the Ontario Securities Commission (the Commission) for:
November 7, 2019 (2019), 42 OSCB 8667
Decisions, Orders and Rulings
(a) a ruling of the Commission, pursuant to section 38 of the CFA, that the Applicant is not subject to the dealer registration requirements in the CFA (as defined below) or the trading restrictions in the CFA (as defined below) in connection with trades in Exchange-Traded Futures (as defined below) on exchanges located outside of Canada (Non-Canadian Exchanges) where the Applicant is acting as principal or agent in such trades to, from or on behalf of Permitted Clients (as defined below);
(b) a ruling of the Commission, pursuant to section 38 of the CFA, that a Permitted Client is not subject to the dealer registration requirements in the CFA or the trading restrictions in the CFA in connection with trades in Exchange- Traded Futures on Non-Canadian Exchanges, where the Applicant acts in respect of the trades in Exchange-Traded Futures on behalf of the Permitted Client pursuant to the above ruling; and
(c) a decision of the Director, pursuant to section 6.1 of Rule 91-502, exempting the Applicant and its salespersons, directors, officers and employees (the Representatives) from section 3.1 of Rule 91-502 in connection with trades in Exchange-Traded Futures (collectively, the Requested Relief);
AND WHEREAS for the purposes of this ruling and exemption (collectively, the Decision):
(i) “CFTC” means the U.S. Commodity Futures Trading Commission;
“dealer registration requirements in the CFA” means the provisions of section 22 of the CFA that prohibit a person or company from trading in Exchange-Traded Futures unless the person or company satisfies the applicable provisions of section 22 of the CFA;
“EEA” means the European Economic Area;
“EEA Member States” means Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Gibraltar, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the U.K.;
“Exchange-Traded Futures” means a commodity futures contract or a commodity futures option that trades on one or more organized exchanges located outside of Canada and that is cleared through one or more clearing corporations located outside of Canada;
“FCA” means the Financial Conduct Authority in the U.K.;
“NFA” means the National Futures Association in the U.S.;
“NI 31-103” means National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations;
“Permitted Client” means a client in Ontario that is a “permitted client” as that term is defined in section 1.1 of NI 31- 103;
“PRA” means the Prudential Regulation Authority in the U.K.;
“SEC” means the U.S. Securities and Exchange Commission;
“specified affiliate” has the meaning ascribed to that term in Form 33-109F6 to National Instrument 33-109 Registration Information;
“trading restrictions in the CFA” means the provisions of section 33 of the CFA that prohibit a person or company from trading in Exchange-Traded Futures unless the person or company satisfies the applicable provisions of section 33 of the CFA;
“U.K.” means the United Kingdom;
“U.S.” means the United States of America; and
(ii) terms used in this Decision that are defined in the OSA, and not otherwise defined in this Decision or in the CFA, shall have the same meaning as in the OSA, unless the context otherwise requires;
November 7, 2019 (2019), 42 OSCB 8668
Decisions, Orders and Rulings
AND UPON considering the Application and the recommendation of staff of the Commission;
AND UPON the Applicant having represented to the Commission and the Director as follows:
1. The Applicant is a company incorporated under the laws of England and Wales. Its head office is located in London in the U.K.
2. The Applicant acts as a broker for customers buying and selling equity and/or debt securities and as a broker for futures and options on futures contracts. Its clients include corporations, financial institutions and investment funds.
3. The Applicant is an indirect, wholly owned subsidiary of TP ICAP plc (TP ICAP). TP ICAP’s shares are listed on the London Stock Exchange and it is a FTSE 250 company. TP ICAP is registered in England no. 05807599.
4. The Applicant relies on the international dealer exemption in section 8.18 of NI 31-103 (the IDE) in British Columbia, Nova Scotia, Ontario and Québec, and is not registered in any capacity under the CFA or the OSA.
5. The Applicant is authorized by the FCA to carry on a range of regulated activities within the U.K. and is subject to regulation by the FCA. The Applicant is currently licensed in the U.K. to deal with eligible counterparties and professional clients with respect to its permitted activities. The Applicant is currently authorized to carry on certain regulated activities in the U.K. in relation to certain specified investments, including the following: (a) arranging (bringing about) deals in futures; (b) arranging safeguarding and administration of assets in relation to futures; (c) dealing in futures as agent; (d) dealing in futures as principal; (e) making arrangements with a view to transactions in futures; and (f) safeguarding and administration of assets in relation to futures (without arranging). As is the case with all firms authorized in the U.K., the Applicant’s current U.K. regulatory status remains subject to variation and the possible imposition of regulatory limitations or requirements and is described as at the date of the Application.
6. The Applicant has “passported” its U.K. registration into the EEA Member States. In relation to the Applicant’s futures services, the Applicant utilizes its EEA passport to the extent that it may provide commodity futures services into other EEA Member States.
7. The Applicant is an exempt foreign broker under CFTC rules (17 CFR 30) and is able to conduct brokerage activities for U.S. customers on non-U.S. exchanges without having to register with the CFTC as a futures commission merchant (FCM). As a result, the Applicant is approved by the NFA as an exempt foreign firm under CFTC Regulation 30.10 under the U.S. Commodity Exchange Act.
8. The Applicant is a member of major international securities and commodity futures exchanges, including but not limited to ICE Europe, Euronext (Amsterdam and Paris), Eurex, Nasdaq OMX. The Applicant is not a member of any clearing houses but uses the services of a General Clearing Member (Citibank and ABN Amro).
9. The Applicant is not in default of securities or commodity futures legislation in any jurisdiction in Canada, subject to the matter to which this Decision relates. The Applicant is in compliance in all material respects with U.K. and U.S. securities and commodity futures laws, as applicable.
10. Pursuant to its authorizations and approvals, the Applicant may (inter alia) trade in securities and Exchange-Traded Futures in the U.K. and, in all EEA Member States, and conduct brokerage activities for U.S. customers on non-U.S. exchanges without having to register with the CFTC as a FCM. Rules of the FCA require the Applicant to maintain adequate capital levels, make and keep specified types of records relating to customer accounts and transactions, and comply with other forms of customer protection rules, including rules respecting: know-your-customer obligations, client identification and account-opening requirements, suitability requirements, anti-money laundering checks, credit checks, delivery of confirmation statements, clearing deposits, dealing and handling customer order obligations including managing conflicts of interests and best execution rules. These rules require the Applicant to treat Permitted Clients materially the same as the Applicant’s U.K., EEA and U.S. customers with respect to transactions made on exchanges in the U.K. and the EEA Member States. In order to protect customers in the event of insolvency or financial instability of the Applicant, the Applicant is required to ensure that customer securities and monies be separately accounted for and segregated from the securities and monies of the Applicant. The Applicant is subject to the FCA’s Client Asset Rules, which impose a general duty to segregate client assets and require the Applicant to place client money exclusively with counterparties selected and approved in compliance with the criteria set out in the FCA’s Client Asset Rules.
11. The Applicant proposes to offer Permitted Clients in Ontario the ability to trade in Exchange-Traded Futures through the Applicant.
November 7, 2019 (2019), 42 OSCB 8669
Decisions, Orders and Rulings
12. The Applicant will solicit and accept orders for trades in Exchange-Traded Futures on behalf of Permitted Clients in Ontario in the same manner that it solicits and accepts orders for trades in Exchange-Traded Futures on behalf of its U.K. clients, EEA clients and U.S. clients. The Applicant will follow the same know-your-customer and segregation of assets procedures that it follows in respect of its U.K. clients, EEA clients and U.S. clients. Permitted Clients will be afforded the benefits of compliance by the Applicant with the statutory and other requirements of the FCA, recognised investment exchanges and applicable European law and regulations. Permitted Clients in Ontario will have the same contractual rights against the Applicant as U.K. clients of the Applicant.
13. The Applicant is required under U.K. securities laws to categorise its clients using three categories (who are afforded a descending level of regulatory protection): (1) retail clients; (2) professional clients; and (3) eligible counterparties. Permitted Clients would generally fall into the categories of ‘professional clients’ and ‘eligible counterparties’. The levels of regulatory protection afforded to these categories of clients are substantially similar to those afforded to Permitted Clients.
14. The Applicant will not maintain an office, sales force or physical place of business in Ontario.
15. The Applicant will solicit and accept orders for trades in Exchange-Traded Futures in Ontario only from persons who qualify as Permitted Clients.
16. Permitted Clients of the Applicant will only be offered the ability to effect trades in Exchange-Traded Futures on Non- Canadian Exchanges.
17. The Exchange-Traded Futures to be traded by Permitted Clients will include, but will not be limited to, Exchange- Traded Futures for equity index and single name stocks, interest rate, foreign exchange, bond, energy, agricultural and other commodity products.
18. Permitted Clients of the Applicant will be able to execute Exchange-Traded Futures orders through the Applicant by contacting the Applicant’s global execution desks. Permitted Clients may also be able to self-execute Exchange-Traded Futures orders electronically via an independent service vendor and/or other electronic trading order routing systems.
19. The Applicant may execute a Permitted Client’s order on the relevant Non-Canadian Exchange in accordance with the rules and customary practices of the exchange, or engage another broker to assist in the execution of orders. The Applicant will remain responsible for all executions when the Applicant is listed as the executing broker of record on the relevant Non-Canadian Exchange.
20. As the Applicant will only perform the execution of a Permitted Client’s contract order and “give-up” the transaction for clearance to the Permitted Client’s carrying broker or clearing broker (each, a Clearing Broker), such broker will also be required to comply with any relevant regulatory requirements, including requirements under the CFA, as applicable. Each Clearing Broker will represent to the Applicant, in an industry-standard give-up agreement, that it will perform its obligations in accordance with applicable laws, governmental, regulatory, self-regulatory, exchange and clearing house rules and the customs and usages of the exchange or clearing house on which the relevant Permitted Client’s orders will be executed and/or cleared. The Applicant will not enter into a give-up agreement with any carrying broker or clearing broker located in (i) the U.S. unless such broker is registered with the CFTC and/or the SEC, as applicable, or (ii) the U.K. unless such broker is authorised by the PRA or the FCA, as required.
21. As is customary for all trades in Exchange-Traded Futures, a clearing corporation appointed by the exchange or clearing division of the exchange is substituted as a universal counterparty on all trades in Exchange-Traded Futures and Permitted Client orders that are submitted to the exchange in the name of the Clearing Broker or the Applicant or, on exchanges where the Applicant is not a member, in the name of another carrying broker. The Permitted Client of the Applicant is responsible to the Clearing Broker for payment of daily mark-to-market variation margin and/or proper margin to carry open positions and the Clearing Broker is in turn responsible to the clearing corporation/division for payment.
22. Permitted Clients will pay commissions for trades to the Applicant for its role as execution-only broker and Permitted Clients shall be responsible to pay any commissions to their Clearing Broker directly, if applicable.
23. The trading restrictions in the CFA apply unless, among other things, an Exchange-Traded Future is traded on a recognized or registered commodity futures exchange and the form of the contract is approved by the Director. To date, no Non-Canadian Exchanges have been recognized or registered under the CFA.
24. If the Applicant were registered under the CFA as a “futures commission merchant”, it could rely upon certain exemptions from the trading restrictions in the CFA to effect trades in Exchange-Traded Futures to be entered into on certain Non-Canadian Exchanges.
November 7, 2019 (2019), 42 OSCB 8670
Decisions, Orders and Rulings
25. Section 3.1 of Rule 91-502 provides that no person shall trade as agent in, or give advice in respect of, a recognized option, as defined in section 1.1 of Rule 91-502, unless he or she has successfully completed the Canadian Options Course (which has been replaced by the Derivatives Fundamentals Course and the Options Licensing Course).
26. All Representatives of the Applicant who trade futures and options in the U.K. need to have attained and maintain a level of skills, knowledge and expertise to discharge their responsibilities in accordance with the FCA’s Training and Competency Handbook.
27. Representatives who trade futures and options will have passed examinations in U.K. Financial Regulation and Securities and/or Derivatives administered by the Chartered Institute for Securities & Investment (CISI) under its Capital Markets Programme.
28. Under the U.K. Senior Managers & Certification Regime, these Representatives who trade futures and options will be classified by the Applicant as certified individuals. Although these Representatives will not be subject to direct approval by the FCA, the Applicant must take reasonable care to ensure that a Representative does not perform a certification function without having first been certified as fit and proper to do so. This certification must be renewed on an annual basis.
AND UPON the Commission and Director being satisfied that it would not be prejudicial to the public interest to grant the exemptions requested;
IT IS RULED, pursuant to section 38 of the CFA, that the Applicant is not subject to the dealer registration requirements set out in the CFA or the trading restrictions in the CFA in connection with trades in Exchange-Traded Futures on Non-Canadian Exchanges where the Applicant is acting as principal or agent in such trades to, from or on behalf of Permitted Clients provided that:
(a) each client effecting trades of Exchange-Traded Futures is a Permitted Client;
(b) any Clearing Broker has represented and covenanted to the Applicant, and the Applicant has taken reasonable steps to verify, that the broker is or will be appropriately registered or exempt from registration under the CFA;
(c) the Applicant only executes trades in Exchange-Traded Futures for Permitted Clients on Non-Canadian Exchanges;
(d) at the time trading activity is engaged, the Applicant:
(i) has its head office or principal place of business in the U.K.;
(ii) is authorised and regulated by the FCA;
(iii) is approved by the NFA as an exempt foreign firm; and
(iv) engages in the business of an authorized firm in Exchange-Traded Futures in the U.K.;
(e) the Applicant has provided to the Permitted Client the following disclosure in writing:
(i) a statement that the Applicant is not registered in Ontario to trade in Exchange-Traded Futures as principal or agent;
(ii) a statement that the Applicant’s head office or principal place of business is located in London in the U.K.;
(iii) a statement that all or substantially all of the Applicant’s assets may be situated outside of Canada;
(iv) a statement that there may be difficulty enforcing legal rights against the Applicant because of the above; and
(v) the name and address of the Applicant’s agent for service of process in Ontario;
(f) the Applicant has submitted to the Commission a completed Submission to Jurisdiction and Appointment of Agent for Service in the form attached as Appendix “A” hereto;
November 7, 2019 (2019), 42 OSCB 8671
Decisions, Orders and Rulings
(g) the Applicant notifies the Commission of any regulatory action initiated after the date of this ruling in respect of the Applicant, or any predecessors or specified affiliates of the Applicant, by completing and filing with the Commission Appendix “B” hereto within ten days of the commencement of such action; provided that the Applicant may also satisfy this condition by filing with the Commission within ten days of the date of this Decision a notice making reference to and incorporating by reference the disclosure made relating to the Applicant pursuant to U.S. federal securities laws, and any updates to such disclosure that may be made from time to time, and by providing a copy, in a manner reasonably acceptable to the Director, of any Form BD “Regulatory Action Disclosure Reporting Page” relating to the Applicant;
(h) if the Applicant does not rely on the IDE, by December 31st of each year, the Applicant pays a participation fee based on its specified Ontario revenues for its previous financial year in compliance with the requirements of Part 3 and section 6.4 of OSC Rule 13-502 Fees, as if the Applicant relied on the IDE;
(i) by December 1st of each year, the Applicant notifies the Commission of its continued reliance on the exemption from the dealer registration requirement granted pursuant to this Decision by filing Form 13-502F4 Capital Markets Participation Fee Calculation; and
(j) this Decision will terminate on the earliest of:
(i) the expiry of any transition period as may be provided by law, after the effective date of the repeal of the CFA;
(ii) six months, or such other transition period as may be provided by law, after the coming into force of any amendment to Ontario commodity futures law (as defined in the CFA) or Ontario securities law (as defined in the OSA) that affects the dealer registration requirements in the CFA or the trading restrictions in the CFA; and
(iii) five years after the date of this Decision.
AND IT IS FURTHER RULED, pursuant to section 38 of the CFA, that a Permitted Client is not subject to the dealer registration requirements in the CFA or the trading restrictions in the CFA in connection with trades in Exchange-Traded Futures on Non- Canadian Exchanges where the Applicant acts in connection with trades in Exchange-Traded Futures on behalf of the Permitted Clients pursuant to the above ruling.
October 11, 2019
“Heather Zordel” Commissioner Ontario Securities Commission
“Lawrence P. Haber” Commissioner Ontario Securities Commission
IT IS THE DECISION of the Director, pursuant to section 6.1 of Rule 91-502, that section 3.1 of Rule 91-502 does not apply to the Applicant and its Representatives in respect of trades in Exchange-Traded Futures, provided that:
(a) the Applicant and its Representatives maintain their respective authorizations and approvals with the FCA and the NFA which permit them to trade commodity futures options in the U.K. and remain subject to regulation by the FCA; and
(b) this Decision will terminate on the earliest of:
(i) the expiry of any transition period as may be provided by law, after the effective date of the repeal of the CFA;
(ii) six months, or such other transition period as may be provided by law, after the coming into force of any amendment to Ontario commodity futures law (as defined in the CFA) or Ontario securities law (as defined in the OSA) that affects the dealer registration requirements in the CFA or the trading restrictions in the CFA; and
(iii) five years after the date of this Decision.
“Elizabeth King” Director Ontario Securities Commission
November 7, 2019 (2019), 42 OSCB 8672
Chapter 3
Reasons: Decisions, Orders and Rulings
3.1 OSC Decisions
3.1.1 3iQ Corp. and The Bitcoin Fund – s. 8
Citation: 3iQ Corp (Re), 2019 ONSEC 37 Date: October 29, 2019 File No. 2019-7
IN THE MATTER OF 3iQ CORP. and THE BITCOIN FUND
REASONS AND DECISION (Section 8 of the Securities Act, RSO 1990, c S.5)
Hearing: June 3, 6, 7 and July 24, 2019 Decision: October 29, 2019 Panel: Lawrence P. Haber Commissioner and Chair of the Panel Appearances: Christopher Naudie For 3iQ Corp. and The Bitcoin Fund Lori Stein Evan Thomas Louis Tsilivis Michelle Vaillancourt For Staff of the Ontario Securities Commission Alvin Qian
TABLE OF CONTENTS
I. OVERVIEW II. BACKGROUND A. The Application B. Bitcoin III. PRELIMINARY ISSUES IV. ISSUES V. IS BITCOIN AN ILLIQUID ASSET SUCH THAT THE FUND WILL NOT BE COMPLIANT WITH THE NI 81-102 RESTRICTIONS ON ILLIQUID ASSETS? A. Law on Liquidity B. Analysis C. Conclusion on Liquidity VI. IS ISSUING A RECEIPT FOR THE FUND’S PROSPECTUS NOT IN THE PUBLIC INTEREST? A. Law on the Public Interest Test B. Valuation and Market Manipulation C. Safeguarding of the Fund’s Assets D. Auditability of the Fund’s Financial Statements E. Application of the Public Interest Test VII. CONCLUSION AND TERMS AND CONDITIONS A. Conclusion B. Terms and Conditions C. Order
November 7, 2019 (2019), 42 OSCB 8673
Reasons: Decisions, Orders and Rulings
REASONS AND DECISION
I. OVERVIEW
[1] This is an application for a hearing and review under section 8 of the Securities Act.1 The Applicants – The Bitcoin Fund and 3iQ Corp. – seek to set aside the decision of the Director of the Ontario Securities Commission’s (the Commission) Investment Funds & Structured Products branch denying a receipt for The Bitcoin Fund’s prospectus.
[2] This application engages foundational concepts of securities legislation: the prospectus requirement, the public interest jurisdiction of the Commission, and the purposes and principles of the Act. Specifically, this application is about the prospectus clearance and review process under the Act and the scope and limits of the Director’s authority under the Act to refuse to issue a prospectus receipt.
[3] This application is not about the merits of the units to be offered by The Bitcoin Fund. It is not the role of securities regulators to approve or disapprove of the merits of securities being offered to the public. In fact, there is clear language to this effect on the face of the fund’s prospectus and on the face page of every prospectus filed in Ontario and in Canada:
No securities regulatory authority has expressed an opinion about these securities and it is an offence to claim otherwise.
[4] It is also outside the scope of the authority of securities regulators to immunize investors against risk or against loss. And, it is not the job of securities regulators to ban speculation or risk-taking.
[5] This application is not about the merits of bitcoin as an investment. As with other classes of assets or undertakings or businesses underlying an issuer, the investment potential of these underlying assets, undertakings and businesses are outside the scope of securities regulation.
[6] Bitcoin is a novel asset in an emerging and evolving market. It is a risky asset. Markets for novel asset classes and securities evolve over time. Emerging markets for securities and asset classes look and feel very different from mature markets. As markets evolve and mature, they change, either through the efforts of the market participants or through government intervention or regulation, or both.
[7] Some novel asset classes and securities products fail. They become tulip bulbs or dot.com’s. Others succeed and become gold or the next great technology. Securities regulators are not mandated to try to pick winners and losers.
[8] The public interest jurisdiction under the Act is broad, but it is not infinite.
[9] Securities regulators are required to ensure broad public interest considerations are addressed and to balance the (sometimes) competing purposes and principles of the Act. Consumer protection policy considerations, which do not otherwise engage the public interest test under the Act, are outside the scope of jurisdiction of securities regulation and must be left to federal, provincial and territorial governments to address (or not address), as they see fit.
[10] The Director denied a receipt for The Bitcoin Fund’s prospectus because of concerns about bitcoin, namely: concerns about bitcoin’s liquidity and the integrity of the bitcoin markets, and concerns about The Bitcoin Fund’s ability to value and safeguard its bitcoin and file audited financial statements.
[11] The concerns about bitcoin expressed by the Director, and by Staff in this proceeding, are warranted and should be taken seriously. But, for the reasons described herein, those concerns do not warrant denying a receipt for The Bitcoin Fund’s prospectus. An Order will be issued setting aside the Director’s decision and directing the Director to issue a receipt for a final prospectus of The Bitcoin Fund, provided the Director is satisfied that there are no grounds under s. 61 of the Act for the Director to refuse to issue a receipt for any such prospectus, other than the grounds set out in the Director’s decision or these reasons.
II. BACKGROUND
A. The Application
[12] In the normal course, if an investment fund wants to distribute its securities to the public in Ontario, it begins by filing a preliminary prospectus with the Commission’s Investment Funds & Structured Products branch (IFSP). Staff of the IFSP reviews, provides comments and may ask for changes to the preliminary prospectus. If the investment fund’s
1 Securities Act, RSO 1990, c S.5 (the Act), s 8.
November 7, 2019 (2019), 42 OSCB 8674
Reasons: Decisions, Orders and Rulings
preliminary prospectus meets the satisfaction of the IFSP, a final prospectus is submitted. If the IFSP Director (the Director) issues a receipt for a final prospectus, the prospectus can then be used to offer securities to the public. The investment fund becomes a reporting issuer in Ontario coincident with the issuance of the receipt for the final prospectus, and it is then subject to ongoing continuous disclosure and other public issuer obligations.
[13] There are two applicants in this proceeding: The Bitcoin Fund (the Fund) and 3iQ Corp. (3iQ) (collectively, the Applicants). The Fund will be a public, non-redeemable investment fund that will invest substantially all of its assets in bitcoin. It will be established as a trust under the laws of Ontario. 3iQ will be the Fund’s investment fund manager and portfolio manager. 3iQ also manages a private investment fund that invests in crypto-assets.
[14] Beginning in late 2016, 3iQ had a series of meetings and exchanged correspondence with IFSP Staff to discuss the Fund and its proposed preliminary prospectus. IFSP Staff ultimately advised that they would not be prepared to recommend that the Director issue a receipt for the Fund’s prospectus. 3iQ then publicly filed the Fund’s preliminary non-offering prospectus. IFSP formally recommended against the Director issuing a receipt for that prospectus. 3iQ responded by requesting that the Director issue written reasons regarding the refusal to issue a receipt for the Fund’s prospectus. 3iQ also waived its opportunity to be heard by the Director, on the basis that 3iQ would seek a hearing and review of the Director’s decision. After receiving the Director’s written decision, 3iQ and the Fund filed this application for a hearing and review.
[15] In this hearing and review application, the Applicants seek an order:
a. setting aside the Director’s decision dated February 15, 2019, denying a receipt for the Fund’s prospectus; and
b. directing the Director to issue a receipt for the Fund’s final non-offering prospectus.
[16] The application was heard over four days, including two days of oral evidence. Most evidence was entered via affidavits. The Applicants relied on the affidavits and testimony of Shaun Cumby, who is an officer, director and shareholder of 3iQ. He has been 3iQ’s Chief Investment Officer since 2018 and is responsible for its investment strategies. He was cross-examined on his affidavits by Staff at the hearing.
[17] Staff relied on the affidavits and testimony of Neeti Varma and Cosmin Cazan, both of whom were cross-examined by the Applicants. Ms. Varma is a Senior Accountant with IFSP and also a current Acting Manager within IFSP. Mr. Cazan is a Senior Investigator, Analytics and Market Specialist in the Market Abuse Team of the Commission’s Enforcement Branch. He is on secondment from the Commission’s Market Regulation Branch.
B. Bitcoin
[18] The Director denied a receipt for the Fund’s prospectus because of concerns about Bitcoin.2 Given that, I will first provide a brief general description of Bitcoin, its protocols and markets before turning to the specific issues for determination in this Application.
[19] Bitcoin is a digital crypto-asset that is not issued by any government, bank or central organization. It is based on the decentralized, open source protocol of the peer-to-peer Bitcoin computer network, which creates the decentralized public transaction ledger known as the “blockchain”. All bitcoin transactions are recorded on the blockchain.
[20] The blockchain is a record of every bitcoin transaction and every bitcoin address associated with a quantity of bitcoin. The Bitcoin network, and its software applications, can interpret the blockchain to determine the bitcoin balance of any public bitcoin address listed in the blockchain. A bitcoin private key controls the transfer or “spending” of bitcoin from its associated public bitcoin address.
[21] People who use Bitcoin must establish a bitcoin wallet. A wallet provides the user with a public key that is used to derive an address for others to send them bitcoin, as well as a private key, which is used to unlock balances of the user’s bitcoin to send to others. A bitcoin wallet may be software or a hardware device. In either case, the user is in control of the private keys that control the bitcoin. Alternatively, consumers may use a hosted bitcoin wallet where a provider protects the private keys, and the consumer accesses their accounts through a web browser or mobile application.
[22] Bitcoin private keys are stored in two different forms: “hot wallet” storage, whereby the private keys are stored on devices connected to the Internet, and “cold wallet” storage, where private keys are stored offline. Cold wallet storage is regarded as more secure because Internet-connected devices can be hacked, resulting in the theft of private keys
2 As is common practice, these Reasons will refer to Bitcoin with a capital “B” when referring to the protocol or network, and bitcoin with a lowercase “b” when referring to the digital asset.
November 7, 2019 (2019), 42 OSCB 8675
Reasons: Decisions, Orders and Rulings
and the bitcoin that those private keys control.
[23] There are two ways to hold bitcoin: 1) directly purchase and hold bitcoin, or 2) invest in securities of companies or other entities that hold bitcoin. If purchasing bitcoin directly, investors generally use either Bitcoin teller machines or crypto-asset trading platforms (often referred to as crypto-currency exchanges). Crypto-asset trading platforms operate websites that facilitate the purchase and sale of bitcoin and other crypto-assets.
[24] Though some investment products can provide investors with exposure to bitcoin, most of these products are only available on a private placement basis. One example is the Grayscale Bitcoin Trust (GBTC), which is available in the exempt market for purchase by “accredited investors”, as defined under applicable U.S. securities laws, and may be held in registered savings accounts. GBTC is also available to Canadians in the exempt market through a small number of financial institutions.
[25] Canadian investors can also indirectly obtain bitcoin and other crypto-assets by investing in reporting issuers that have crypto-assets as their primary asset and have obtained stock exchange listings by completing reverse take-overs on the Toronto Stock Exchange Venture Exchange (TSXV) or the Canadian Securities Exchange (CSE) (RTO Crypto Issuers). There are approximately ten RTO Crypto Issuers listed for trading on the TSXV. RTO Crypto Issuers are not investment funds and are not required to meet the securities law requirements for public investment funds.
III. PRELIMINARY ISSUES
[26] I will briefly address a few preliminary issues that were raised in this proceeding: 1) the burden and standard of proof, 2) the treatment of hearsay evidence, 3) the treatment of opinion evidence, and 4) a motion to file an authority that was issued after the close of the oral hearing.
[27] Staff concedes that it bears the burden of proof to show that a receipt should not be issued for the Fund’s prospectus. Staff bears this onus under the civil standard of proof that is applied in all hearing and review applications: proof on a balance of probabilities.3
[28] The evidence adduced by both parties includes significant amounts of hearsay evidence. Hearsay evidence is admissible in Commission proceedings,4 though the panel must determine the weight to be accorded to such evidence. Care must be taken to avoid placing undue reliance on uncorroborated evidence that lacks sufficient indicia of reliability.5 I admitted all the tendered hearsay evidence, subject to my consideration of the weight to give it. I will address the issue of weight for specific hearsay evidence as it arises in my below analysis.
[29] The parties also adduced opinion evidence. Although opinion evidence is generally only admissible when provided by an expert witness, other opinion evidence may be admissible when founded on a lay witness’s personal knowledge, observation, or experience.6 The parties did not adduce any expert evidence. The parties did elicit some opinion evidence from their witnesses. The majority of the opinion evidence adduced was hearsay opinion evidence in the form of articles, research papers and other exhibits to the affidavits of the parties’ witnesses. The opinion evidence was admitted subject to a determination of weight. I will address the issue of weight for specific opinion evidence as it arises in my below analysis.
[30] After the close of the oral hearing, on October 18, 2019, Staff brought a motion seeking that the Panel consider a decision of the Division of Trading and Markets of the U.S. Securities and Exchange Commission (the SEC) dated October 9, 2019. That decision concerned an application by an exchange for a proposed rule change to allow the listing and trading of shares of the Bitwise Bitcoin ETF Trust. The Applicants opposed the motion. Staff seeks to file the decision as a relevant authority that was not issued at the time of the hearing. I accept it on that basis, and not as evidence of the findings of fact made by the Division of Trading and Markets of the SEC on the evidentiary record that was before it. As I will discuss below, I distinguish this decision and several similar SEC decisions from the current case.
IV. ISSUES
[31] A hearing and review of a Director’s decision is a fresh consideration of the matter. The Commission may confirm the Director’s decision or substitute its own decision, making such other decision as the Commission considers proper.7
3 FH v McDougall, 2008 SCC 53, [2009] 3 SCR 41 at para 40. 4 Statutory Powers Procedure Act, RSO 1990, c S.22, s 15(1). 5 Sunwide Finance Inc (Re), 2009 ONSEC 20, (2009) 32 OSCB 4671 at para 22, citing Starson v Sway, 2003 SCC 32, [2003] 1 SCR 722 at para 115. 6 Banks (Re), (2003) 26 OSCB 3377 at para 17, citing A. Bryant, J. Sopinka & S. Lederman, The Law of Evidence in Canada, 2d ed. (Toronto: Butterworths, 1999) at 605-607. 7 Act, s 8(3).
November 7, 2019 (2019), 42 OSCB 8676
Reasons: Decisions, Orders and Rulings
The Commission need not show deference to the Director’s decision.8
[32] Staff submits that I should confirm the Director’s decision to refuse a receipt for the Fund’s prospectus for the reasons given by the Director, which are:
a. Bitcoin is an illiquid asset, as defined in National Instrument 81-102 Investment Funds (NI 81-102).9 Therefore, by holding bitcoin, the Fund would not comply with the restriction against holding illiquid assets set out in section 2.4 of NI 81-102.
b. It appears that it is not in the public interest for a receipt to be issued for the Fund’s prospectus given concerns about:
the Fund’s ability to value its assets for investors given the significant market integrity concerns regarding the trading of bitcoin;
the security and safekeeping of the Fund’s bitcoin; and
the Fund’s ability to file audited financial statements, as required.
[33] The Applicants submit that I should order the Director to issue a receipt for the Fund’s prospectus.
[34] The Applicants submit that Staff has not shown that bitcoin is an illiquid asset as defined in NI 81-102. On the contrary, the Applicants submit that trading platforms and over-the-counter (OTC) desks for trading bitcoin promote reliable price discovery so that the Fund can value its bitcoin and provide sufficient liquidity for the Fund to dispose of bitcoin, as required to satisfy redemption requests.
[35] The Applicants submit that Staff has not demonstrated that issuing a receipt for the Fund’s prospectus would not be in the public interest. They submit that the concerns identified by Staff are speculative and not demonstrated by the evidence. The Applicants argue that Staff failed to prove their above concerns on a balance of probabilities.
[36] The Applicants submit that the Fund would comply with all aspects of NI 81-102 and should not be held to a different standard just because it will hold bitcoin. Refusing a receipt for the Fund’s prospectus, they say, would deter future innovators, like the Fund, which seek to bring professional management to new asset classes like bitcoin, while mitigating the associated risks.
[37] The two main issues that arise from the parties’ submissions are:
a. Is bitcoin an illiquid asset such that the Fund will not be compliant with the NI 81-102 restrictions on illiquid assets?
b. Is issuing a receipt for the Fund’s prospectus not in the public interest?
V. IS BITCOIN AN ILLIQUID ASSET SUCH THAT THE FUND WILL NOT BE COMPLIANT WITH THE NI 81-102 RESTRICTIONS ON ILLIQUID ASSETS?
A. Law on Liquidity
[38] A receipt for a prospectus shall be refused where the prospectus does not comply with the Act or regulations. Specifically, s. 61(2)(a) of the Act provides that the Director shall not issue a receipt for a prospectus if it appears to the Director that the prospectus does not comply in any substantial respect with any of the requirements of the Act or the regulations.
[39] NI 81-102 is one of the regulations with which investment fund prospectuses must comply.10 Under NI 81-102, there are restrictions on the amount of illiquid assets that a non-redeemable investment fund (such as the Fund) can hold or purchase. The rationale for these restrictions is that illiquid assets are generally more difficult to value, for the purposes of calculating an investment fund's net asset value, than liquid assets. As a result, where a non-redeemable investment fund has a large proportion of its assets invested in illiquid assets, it may raise concerns about the accuracy of the fund's net asset value and the amount of any fees calculated with reference to the net asset value.11
8 Triax Growth Fund Inc (Re), 2005 ONSEC 16, (2005) 28 OSCB 10139 at para 25. 9 (2000), 23 OSCB (Supp 59). 10 Subsection 1(1) of the Act defines “regulations” to include rules made under s 143 of the Act. NI 81-102 is a rule made under s 143 of the Act, and therefore a regulation for the purpose of s 61(2)(a). 11 NI 81-102CP, s 3.3.1.
November 7, 2019 (2019), 42 OSCB 8677
Reasons: Decisions, Orders and Rulings
[40] Accordingly, the Fund would be prohibited from purchasing more than 20% of its net asset value in illiquid assets and holding more than 25% of its net asset value in illiquid assets for a period of 90 days or more.12
[41] The definition of “illiquid asset” is set out in NI 81-102 to include:13
a portfolio asset that cannot be readily disposed of through market facilities on which public quotations in common use are widely available at an amount that at least approximates the amount at which the portfolio asset is valued in calculating the net asset value per security of the investment fund…
[42] If bitcoin meets this definition of illiquid assets for the purposes of NI 81-102, then the Fund would not comply with NI 81-102, and s. 61(1)(2)(a) of the Act provides that a receipt for the Fund’s prospectus shall be refused.
B. Analysis
[43] Staff submits that a receipt for the Fund’s prospectus should not be issued because bitcoin is an illiquid asset as defined in NI 81-102. Therefore, the Fund, which would hold bitcoin, would not comply with the restriction against holding illiquid assets in section 2.4 of NI 81-102.
[44] I do not agree with Staff’s submission and, for the following reasons, I find that Staff has not shown that bitcoin is an illiquid asset, as defined in NI 81-102.
[45] Staff submits that bitcoin is not currently traded on market facilities comparable to the Toronto Stock Exchange (TSX), where trading activities are subject to real-time monitoring. There is also no central source for trading data concerning bitcoin. Staff argues that the publicly available trading volume data for bitcoin may be inaccurate and the Fund may have difficulties acquiring or liquidating its assets. Staff also notes that the Fund’s prospectus itself acknowledges potential liquidity issues, stating that the Fund may not always be able to acquire or liquidate its assets at a desired price, because bitcoin are still maturing assets.
[46] Staff adduced evidence about inaccurate trading data (along with allegations of fake and manipulated trading discussed in greater detail in the public interest analysis below) through the affidavits and attached exhibits, and testimony of Mr. Cazan and Ms. Varma. Much of their evidence was about crypto-assets, generally, rather than specifically addressing liquidity issues for bitcoin. I give no weight to their evidence insofar as it relates to non-bitcoin crypto-asset trading, and non-registered exchange trading.
[47] I find that there is sufficient evidence of real volume and real trading in bitcoin on registered exchanges in large dollar size, both in absolute terms and compared to other markets for commodities and equities, which constitutes a liquid market.
[48] The regulation does not define the term “market facility” that is found in the definition of “illiquid asset”. Staff argues that “market facility” should be interpreted to imply some form of established and mature trading facility or network, in order to promote a robust valuation of an investment fund’s assets.
[49] I disagree and find that Staff’s interpretation of “market facility” is unduly narrow. I agree with the Applicants’ submission that “market facility” is a market that provides sufficient liquidity for disposition of a fund asset and that promotes price discovery for calculating an asset’s net asset value.
[50] I also find that there is sufficient evidence that such market facilities currently exist for bitcoin. The Applicants adduced evidence about trading volume, data from the various markets and published price and volume information. That evidence included evidence about bitcoin trading platforms (including evidence about average daily volume in USD), the bitcoin OTC market, the bitcoin futures market, and the size of the bitcoin market. The evidence shows that substantial volumes of bitcoin trade daily on market facilities, many of which are regulated. These market facilities provide a liquid market for promoting price discovery for valuing the Fund’s assets and for disposing of bitcoin to satisfy redemption requests.
[51] Trading platforms for trading bitcoin promote reliable price discovery so that the Fund can value its bitcoin and provide sufficient liquidity. The top ten online trading platforms for bitcoin, which account for virtually all of the economic bitcoin trading, traded over USD $550 million in bitcoin on a daily basis, as of April 2019. By early June 2019, daily trading volume for bitcoin on these ten platforms had increased to over USD $900 million. The bitcoin market has narrow spreads on and between trading platforms.
12 NI 81-102, s 2.4. 13 NI 81-102, s 1.1.
November 7, 2019 (2019), 42 OSCB 8678
Reasons: Decisions, Orders and Rulings
[52] In addition to the trading platforms, OTC trading desks facilitate larger bitcoin transactions. Since the precise volumes traded in the OTC market are unknown, I place little weight on this evidence. However, Mr. Cumby did state in his evidence that the trading volume may be as large as, if not larger than, the volume traded on trading platforms, and his evidence on this point was uncontroverted.
[53] Many of the bitcoin trading platforms and OTC desks are regulated by the New York State Department of Financial Services (New York State) under the so-called BitLicense, a comprehensive scheme for regulating virtual currency businesses. Regardless of the OTC trading volume, trading volumes for bitcoin exceed trading volumes for some liquid Canadian equities and funds.
C. Conclusion on Liquidity
[54] For the above reasons, I conclude that, in so far as Staff has not demonstrated that bitcoin is an illiquid asset, the Fund will be compliant with the NI 81-102 restrictions on illiquid assets.
[55] Staff has not identified any other requirements of the Act or the regulations with which the Fund does not comply. Therefore, s. 61(2)(a) of the Act does not apply to the Fund’s prospectus and does not preclude the Director’s issuance of a receipt for the Fund’s prospectus.
[56] In this proceeding, there is no issue engaging s. 61(2) of the Act (i.e., the ‘blue sky’ laws) other than the issue regarding liquidity, which is addressed above. The public interest becomes the only remaining issue, which I turn to next.
VI. IS ISSUING A RECEIPT FOR THE FUND’S PROSPECTUS NOT IN THE PUBLIC INTEREST?
A. Law on the Public Interest Test
[57] Subsection 61(1) of the Act provides that the Director “shall issue a receipt for a prospectus filed … unless it appears to the Director that it is not in the public interest to do so.”
[58] The Commission has a broad discretion under the Act to determine what is or is not in the public interest. However, its discretion must be exercised with some caution and restraint,14 and is not unlimited. The Commission must exercise its jurisdiction in a manner consistent with the purposes and fundamental principles set out in the Act, and must not focus on one purpose at the expense of the others.15
[59] The Commission does not need to find a breach of Ontario securities law in order to exercise its public interest jurisdiction and refuse a receipt for the Fund’s prospectus.16 It is sufficient that issuing a receipt to the Fund would be inconsistent with Ontario securities law or the animating principles underlying that law, or an abuse of shareholders or the capital markets.17
[60] The Applicants and Staff made submissions on the scope of the Commission’s public interest jurisdiction under s. 61(1), including referring me to several decisions of the Commission or a Director of the Commission in which s. 61(1) was considered.18 Having regard to those submissions, I am not persuaded that the Commission’s public interest jurisdiction under s. 61(1) is broader or narrower than articulated above.
[61] In particular, the inclusion of the phrase “it appears” in s. 61(1) does not mean that the standard of proof under s. 61(1) is lower than a balance of probabilities. In this regard, I agree with and adopt the Commission’s reasons in Dhillon.19 Accordingly, the inclusion of the phrase “it appears” does not mean that the Commission’s public interest jurisdiction under s. 61(1) is necessarily broader than under the sections of the Act that do not contain this phrase.
[62] Staff submits that issuing a receipt for the Fund’s prospectus is not in the public interest because the operational risks inherent in the Fund cannot be adequately managed at this time. The operational risks identified by Staff are concerns about:
14 See e.g., Magna International Inc (Re), 2010 ONSEC 13, (2010) 34 OSCB 1290 (Magna) at para 186. 15 Committee for the Equal Treatment of Asbestos Minority Shareholders v Ontario (Securities Commission), 2001 SCC 37, [2001] 2 SCR 132 at paras 39-41. 16 Biovail Corporation (Re), 2010 ONSEC 21, (2010) 33 OSCB 8914 at paras 373-89; Canadian Tire Corp (Re), (1987) 10 OSCB 857 at para 130, aff’d Canadian Tire Corp v CTC Dealer Holdings Ltd (1987), 59 OR (2d) 79 (Div Ct). 17 Magna at para 186. 18 ONE Financial Corp (Re), (2012) 35 OSCB 3083; Biocapital Biotechnology & Healthcare Fund (Re), (2001) 24 OSCB 2659; Inland National Capital Ltd (Re), (1996) 19 OSCB 2053; Tricor Holdings Co Inc (Re), (1988) 11 OSCB 4059. 19 Dhillon (Re), 2018 ONSEC 14, (2018) 41 OSCB 3053 at paras 14-24.
November 7, 2019 (2019), 42 OSCB 8679
Reasons: Decisions, Orders and Rulings
a. the Fund’s ability to value its assets for investors given the significant market integrity concerns regarding the trading of bitcoin;
b. the security and safekeeping of the Fund’s bitcoin; and
c. the Fund’s ability to file audited financial statements, as required.
[63] I will first consider each of the operational risks that Staff has identified. I will then consider whether Staff has established that issuing a receipt for the Fund’s prospectus is not in the public interest.
B. Valuation and Market Manipulation
[64] Under National Instrument 81-106 Investment Fund Continuous Disclosure (NI 81-106),20 the Fund will be required to calculate its net asset value using the fair value of its assets and liabilities. “Fair value” means either: 1) the market value based on reported prices and quotations in an active market or, if such market value is unreliable or unavailable, 2) a value that is fair and reasonable in all of the circumstances.21
[65] The Applicants propose to value the Fund’s bitcoin by reference to an index maintained by MV Index Solutions GmbH (MVIS). The index is called the MVIS CryptoCompare Institutional Bitcoin Index (MVIBTC). MVIS is regulated as an index administrator by the German Federal Financial Supervisory Authority. The MVIBTC is calculated by CryptoCoin Comparison Ltd., based on transaction data from multiple exchanges and markets (MVIBTC Platforms), which have entered into information sharing agreements with CryptoCoin. The MVIS pricing benchmarks comply with the European Union benchmark regulations and the International Organisation of Securities Commissions regulations.
[66] Staff submits that the Fund will not be able to arrive at a net asset value that satisfies the requirements of NI 81-106. Staff argues that there are issues with the proposed valuation methodology and a number of concerns with several of the MVIBTC Platforms. Staff points to allegations of price distortion caused by market manipulation, such as wash trading, spoofing, pump-and-dump schemes, abusive trading and fake trading patterns. Some MVIBTC Platforms lack formal market surveillance tools and some allow for employees to trade on their own platforms, raising conflict of interest issues.
[67] Staff argues further that the MVIBTC is not based on the required “active market” because the reported bitcoin prices do not reflect “actual and regularly occurring market transactions on an arm’s length basis”.22 Rather, Staff argues that the majority of the reported bitcoin trading is fake, occurring on trading platforms with limited monitoring and regulatory oversight, if any. Staff says that no “active market” or even a “fair and reasonable” value for bitcoin currently exists because of arbitrage, whereby bitcoin pricing on “bad platforms” invariably affects the bitcoin pricing on “good platforms”.
[68] Although the risk of price manipulation associated with crypto-asset markets is real and Staff’s concerns in this regard are genuine, for the reasons that follow, I find that Staff has not established that the Fund will be unable to arrive at a net asset value that satisfies the requirements of NI 81-106.
[69] I place considerable weight on the Fund’s investment parameters and restrictions that are set out in the Fund’s prospectus and confirmed by Mr. Cumby’s evidence:
a. the Fund will invest in bitcoin, not in all crypto-assets,
b. the Fund will be static and will pursue a buy and hold strategy and not an active trading strategy, and
c. the Fund will only buy and sell bitcoin on regulated exchanges.
[70] The Fund will invest in bitcoin only. While there is evidence of market manipulation and the associated risks, there is also sufficient evidence of a real market in bitcoin, with real trading. Though that real trading may be somewhat impacted by fake trading and though other crypto-asset trading and unregistered market trading may have some knock-on effect, Staff has not proven that true price discovery in the bitcoin market is prevented by insufficient ‘true trading’ or price manipulation, at least on the regulated exchanges.
[71] While the Applicants acknowledge the existence of wash trading and fake volume on certain bitcoin trading platforms, there is less evidence of wash trading or fake volume in the bitcoin-to-USD markets on the top ten platforms.
20 (2005), 28 OSCB 4911. 21 NI 81-106, s 14.2. 22 Companion Policy to National Instrument 81-106 - Investment Fund Continuous Disclosure, (2005) 28 OSCB 4949 and (Supp-1) 1, as amended, s 9.4.
November 7, 2019 (2019), 42 OSCB 8680
Reasons: Decisions, Orders and Rulings
[72] Staff did not demonstrate that the purpose of such trading was to manipulate the price of bitcoin or that wash trading or fake volume has had a significant effect on bitcoin prices. On the evidence before me, the purpose of wash trading and fake volume is to attract crypto-asset traders and issuers of new crypto-assets by creating the illusion that a platform has liquidity.23 The evidence of other types of market manipulation identified by Staff also did not establish systemic and sustained manipulation of the price of bitcoin.
[73] I also place weight on the evidence of the steps the Applicants have taken to mitigate the existing risks of manipulation. While the risks of price manipulation in the bitcoin spot market still exist, 3iQ has mitigated the potential impact on the Fund’s valuation through several steps: its selection of MVIBTC as the index, the use of a professional investment manager experienced in bitcoin markets, and the Fund’s use of the non-redeemable investment fund structure.
[74] The Fund intends to use the MVIBTC to calculate the net asset value of the Fund’s bitcoin. MVIBTC is composed of bitcoin market prices drawn from 22 trading platforms and is provided by MVIS, a regulated index administrator. The methodology for MVIBTC reduces the ability of manipulation on any one platform to distort MVIBTC and therefore the valuation of the Fund’s bitcoin. I give credit to the Applicants for evolving the valuation methodology that it proposes to use for the Fund. Staff characterized their past changes as “a moving target” and asked me to draw a negative inference. I view the Applicants’ evolving methodology as evidence of the Applicants’ willingness to adapt, and I would hope that the Fund would continue to evolve its methodology in this regard over time, if circumstances warrant it.
[75] Mr. Cumby is a professional investment manager experienced in bitcoin markets. I rely on his evidence that he is confident he can price the bitcoin for the purposes of the Fund. The MVIBTC’s calculations are based on publicly available transaction data. 3iQ will therefore be able to confirm the accuracy of the MVIBTC, including through references to other alternative bitcoin pricing sources. However, in the event the MVIBTC price is not available or is believed to be unreliable, 3iQ has discretion as the portfolio manager to apply a bitcoin value that it considers to be fair and reasonable in all the relevant circumstances. 3iQ, as manager of the Fund, will have the ability to use other pricing sources to value the Fund’s bitcoin if, in the exercise of its professional judgment, it determines that MVIBTC is not fairly valuing the Fund’s bitcoin. This discretion is available to all registered investment fund managers, pursuant to NI 81-106.24
[76] I also note that other bitcoin holdings have been successfully valued. For instance, 3iQ has operated a private crypto-asset fund for over a year and has not encountered an issue valuing those crypto-assets. In addition, GBTC, which has units available to retail investors in the exempt market, holds over $1 billion USD worth of bitcoin and there was no evidence of any issues valuing its bitcoin.
[77] The fact of the Fund’s static portfolio is also a key means of mitigation. The Fund has ample time to plan for annual redemption and monthly reporting of pricing. This will help to mitigate the impact of any price manipulation at the margins of the markets. The analysis might have been somewhat different for an exchange-traded fund (ETF), which is distinguished by its nature. An ETF would require continuous purchases and sales to balance and rebalance the portfolio frequently and daily. An ETF is, by nature and design, a dynamic trading vehicle. In contrast, the Fund only has to report pricing monthly and provide for potential redemption yearly, so the impact of any manipulation in the market is mitigated for the Fund. Therefore, as a non-redeemable investment fund that does not create or redeem units on a daily basis, the Fund is less susceptible to price manipulation than an ETF or other type of investment vehicle that must create or redeem units daily.
[78] In reaching a determination, I distinguish the Bitcoin decisions issued by the SEC to date.25 These decisions concerned applications by exchanges for proposed rule changes to allow the listing and trading of shares of bitcoin-based ETFs. All but one of the seven submitted SEC decisions were issued by the Division of Trading and Markets of the SEC under delegated authority, and not issued by the SEC Commissioners themselves. The SEC decisions applied a different legal test to different evidence, with a different burden of proof, which burden was not placed on agency staff. In the most recent SEC decision filed by Staff on October 18, 2019, the Division of Trading and Markets of the SEC summarizes its considerations as follows:26
Although the Commission is disapproving this proposed rule change, the Commission emphasizes that its disapproval does not rest on an evaluation of whether bitcoin, or blockchain technology
23 T. Rodgers, 95% Of Volume Could Be Wash Trading As Bitcoin Price Surges (4 April 2019); Y. Khatri, Executives at Korean Crypto Exchange UPbit Indicted for Fraud (21 December 2018); O. Williams-Grut, Crypto exchanges are charging up to $1 million per ICO to list tokens: ‘It’s pure capitalism’ (12 March 2018), Exhibits 28, 29 and 30 to C. Cazan’s Affidavit sworn May 16, 2019. 24 NI 81-106, s 14.2(1.2)(b). 25 Winkelvoss Bitcoin Trust (Division of Trading and Markets, March 10, 2017), SolidX Bitcoin Trust (Division of Trading and Markets, March 28, 2017), Winkelvoss Bitcoin Trust (SEC Panel, July 26, 2018), ProShares Trust II (Division of Trading and Markets, August 22, 2018), Direxion Shares ETF Trust II (Division of Trading and Markets, August 22, 2018), GraniteShares ETP Trust (Division of Trading and Markets, August 22, 2018),and Bitwise Bitcoin ETF Trust (Division of Trading and Markets, October 9, 2019) (collectively, the SEC decisions). 26 Bitwise Bitcoin ETF Trust (Division of Trading and Markets, October 9, 2019), p 3.
November 7, 2019 (2019), 42 OSCB 8681
Reasons: Decisions, Orders and Rulings
more generally, has utility or value as an innovation or an investment. Rather, the Commission is disapproving this proposed rule change because, as discussed below, NYSE Arca has not met its burden under the Exchange Act and the Commission’s Rules of Practice to demonstrate that its proposal is consistent with the requirements of Exchange Act Section 6(b)(5), and, in particular, the requirement that the rules of a national securities exchange be “designed to prevent fraudulent and manipulative acts and practices. (footnotes omitted)
[79] The SEC decisions related to different products, with different structures. There are key material differences between ETFs and the Fund, including the amount of exposure to bitcoin and the frequency at which bitcoin is required to be purchased, sold and valued. Accordingly, I give little if any weight to the SEC’s consideration of proposed rule changes to allow the listing and trading of shares of bitcoin-based ETFs.
[80] Although this doesn’t impact my conclusion about price manipulation and valuation, it is worth noting that bitcoin is a commodity, not an equity or other security. As such, the bitcoin market should be examined like other commodity markets and not held to the standards applicable to securities markets. The risk of market manipulation exists in all commodity markets. Many of Staff’s stated concerns could apply equally to other commodities, such as precious metals or foreign currencies. Staff did not persuade me that bitcoin is more susceptible to manipulation than other commodity products.
C. Safeguarding of the Fund’s Assets
[81] To safeguard its assets, the Fund will use a regulated Canadian trust company as its custodian and a New York State trust company as a sub-custodian. The custodian, Cidel Trust Company (Cidel), is regulated by the federal Office of the Superintendent of Financial Institutions. It has experience as a custodian and with managing relationships with sub-custodians. The sub-custodian, Gemini Trust Company, LLC (Gemini), is regulated by New York State and is a qualified custodian under NI 81-102.
[82] Staff raises two concerns with the safeguarding of the Fund’s assets: 1) risk of loss, and 2) lack of insurance.
[83] Regarding the risk of bitcoin losses, Staff points to the risks of unauthorized access to the private keys that are used to send bitcoin. Once a private key is taken or lost, it is difficult or impossible to recover a crypto-asset. Staff also submits that it is commonplace for crypto-asset trading platforms to have substantial losses due to hackings, insider thefts, phishing scams and other security breaches. Though Staff acknowledges that Gemini has security controls in place, they argue that the specific implementation of the security controls is important. Gemini does not yet have a System and Organization Controls for Service Organizations (SOC 2) type 2 report, which would provide assurance and comfort that Gemini's security controls are working effectively. Staff says that, in the absence of a SOC 2 type 2 report, there is no available information on the effectiveness of Gemini’s internal controls.
[84] On the issue of the lack of insurance, Staff submits that neither the Fund nor Cidel will maintain insurance against the loss of bitcoin because such insurance is not available in Canada on economically reasonable terms. Gemini will have insurance for the Fund’s bitcoin when it is held in hot wallets, which will only be for brief periods when it is sold to satisfy redemption requests. Otherwise, the Fund’s bitcoin will be held offline, in “cold storage”, which is less vulnerable to hacking, and will be uninsured.27 Though Gemini will maintain commercial crime insurance for the digital assets in its hot wallets, Gemini will have no insurance for the bitcoin held in cold storage. Therefore, since the Applicants will hold the vast majority of its bitcoin in cold storage, there will be no government or private insurance in place for most of the Fund’s bitcoin assets.
[85] Like any valuable commodity, I accept that bitcoin can be stolen or lost. The Applicants also concede that point. But Staff did not establish that Cidel or Gemini, specifically, do not follow sufficient practices for safeguarding bitcoin. Rather, Staff relies on evidence of examples of losses incurred by crypto-asset trading platforms, all but one of which were unregulated and most of which involved hacks of hot wallets. I am not persuaded that there was sufficient evidence that professional, regulated crypto-asset custodians, like Gemini, have suffered losses of customer assets.
[86] I recognize the operational risks presented by the Applicants’ proposed safeguarding arrangements. However, in evaluating Staff’s concerns in the circumstances of this Application, I also weigh the risks of the Applicants’ proposed arrangements against the safekeeping risks that face investors who hold bitcoin directly, whether on crypto-asset trading platforms or otherwise. Staff has not shown that the bitcoin held by the Fund will be inadequately safeguarded despite the Fund’s use of qualified custodians and other protective measures.
27 A “cold storage” wallet is created and stored on a computer with no access to a network, i.e., an “air-gapped” computer with no ability to access the Internet.
November 7, 2019 (2019), 42 OSCB 8682
Reasons: Decisions, Orders and Rulings
[87] The general safeguarding of assets is an “operational risk” that is highlighted in the Fund’s prospectus. Staff’s concerns on this issue were sufficiently addressed by the Applicants for the purposes of this Application. In particular, I note that:
a. Cidel is a regulated Canadian trust company;
b. Cidel is an experienced custodian;
c. Gemini is regulated by New York State and is subject to a regulatory regime specific to crypto-assets. Every two years, New York State conducts an examination to determine the safety of the conduct of Gemini’s business;
d. Gemini has a legal obligation under New York law to establish and maintain an effective cybersecurity program and a written business continuity and disaster recovery plan;
e. Gemini is a qualified custodian under NI 81-102;
f. Gemini has over $100 million in assets (which could be used to satisfy any settlement or judgment in favor of the Fund, even without insurance); and
g. Gemini will have insurance for the Fund’s bitcoin to the extent it is held in hot wallets, for the brief periods when the bitcoin is sold to satisfy redemption requests. Otherwise, the Fund’s bitcoin will be held offline in cold storage. This approach to insurance appears to be the standard industry practice.
[88] Gemini obtained a SOC 2 type 1 report from a reputable accounting firm and expects to obtain a SOC 2 type 2 report by the end of 2019. I accept the Applicants’ submission that the absence of a SOC 2 type 2 report does not necessarily mean that Gemini’s controls are inadequate. Rather, Gemini has not yet satisfied an auditor applying a particular assurance that Gemini’s controls are effective. On the other hand, there is some evidence that Gemini has effective internal controls, including Gemini’s operation for over three years without a loss from its hot or cold wallets.
D. Auditability of the Fund’s Financial Statements
[89] Investment funds that are reporting issuers are required to file financial statements that have been audited and contain an auditor’s report.28 When an investment fund relies on a service organization,29 the controls at the service organization are relevant to the investment fund’s audit. Service organizations may rely on subservice organizations, such as Cidel relies on Gemini as the sub-custodian for the Fund. Pursuant to Canadian Auditing Standards, an investment fund’s auditor must obtain information about the operating effectiveness of controls at an investment fund’s subservice organization.
[90] The Fund’s proposed auditor is Raymond Chabot Grant Thornton LLP (Raymond Chabot), which is a participating firm under National Instrument 52-108 – Auditor Oversight. Raymond Chabot is a qualified and reputable auditor, with experience in the auditing of companies holding crypto-assets.
[91] When auditing the Fund to meet the objectives of the Canadian Auditing Standards, Raymond Chabot will need to obtain audit evidence about the operating effectiveness of Gemini’s controls. To do so, Raymond Chabot could: 1) obtain a SOC 2 type 2 report from Gemini’s auditor, or 2) perform appropriate testing of Gemini’s controls (either directly or by using another auditor to perform such testing). As already noted, Gemini does not currently have a SOC 2 type 2 report, but anticipates having one by the end of 2019.
[92] Staff submits that it is not in the public interest to issue a receipt for the Fund’s prospectus because of concerns over the Fund’s ability to file audited annual financial statements in the future.
[93] Staff points to the current lack of Gemini’s SOC 2 type 2 report and the fact that Gemini may deny Raymond Chabot access to test the operating effectiveness of Gemini’s controls. Gemini’s agreement with 3iQ does not oblige Gemini to provide access to their systems, books or records. Though Gemini provided a letter to the Commission in support of the Application, Gemini’s letter did not address the issue of access for Raymond Chabot if a SOC 2 type 2 report is not available.
[94] More generally, Staff also notes significant deficiencies in previous audits of other reporting issuers holding crypto-assets. There is no comparable audit of a public investment fund holding crypto-assets because no such investment fund currently exists. But Staff notes that the Canadian Public Accountability Board (CPAB), which is
28 NI 81-106, s 2.1. 29 The Canadian Auditing Standard 402, s 8(e) defines a “service organization” as a third-party organization that provides services to user entities where those services are part of the entity's information systems relevant to financial reporting.
November 7, 2019 (2019), 42 OSCB 8683
Reasons: Decisions, Orders and Rulings
Canada’s audit regulator, issued an inspection report of audits of three other crypto-miners and/or reporting issuers holding crypto-assets. That report found significant deficiencies in all three reviewed files.
[95] I note that the CPAB report confirmed that the identified deficiencies were in the course of being remediated. The CPAB report did not identify the nature of the deficiencies found for the audits of other issuers, including whether the deficiencies pertained to crypto-asset mining activities (which the Fund would not do) or crypto-assets other than bitcoin (which the Fund would not hold). The CPAB report does not provide a reasonable basis for me to conclude that Raymond Chabot will be unable to audit the Fund.
[96] Overall, I find that Staff has not shown that the Fund will be unable to obtain the required audit opinion. While I accept Staff’s concerns about the availability of the SOC 2 type 2 report, I rely on the Applicants’ evidence that a qualified and reputable auditor says it can conduct the audit, even without the report, and still comply with generally accepted auditing standards (GAAS).
[97] In coming to that determination, I consider the consequences of all three potential outcomes for the Fund’s efforts to obtain audited financial statements, which are:
a. Gemini’s auditor provides Raymond Chabot with a SOC 2 type 2 report,
b. in the absence of a report, Raymond Chabot performs appropriate testing of Gemini’s controls (either directly or by using another auditor to perform such testing), or
c. the Fund is ultimately unable to obtain the required audit opinion.
[98] First, it remains possible that Gemini’s auditor could provide Raymond Chabot with a SOC 2 type 2 report. There is evidence that work on Gemini’s SOC 2 type 2 report is underway and a timely SOC 2 type 2 report remains possible. Staff’s witness conceded on cross-examination that it remains possible for the report to be complete by the end of 2019.
[99] However, even if Gemini does not obtain a timely and satisfactory SOC 2 type 2 report, Raymond Chabot could still express the required unmodified audit opinion on the Fund’s financial statements. SOC 2 type 2 reports are not required for audits of public investment funds. There is no dispute that it is possible for an auditor to give an unmodified audit opinion on a reporting issuer, despite the absence of a SOC 2 type 2 report for its sub-custodian. If no report is available, there are other acceptable methods for Raymond Chabot to evaluate Gemini’s controls and render a clean audit report. Raymond Chabot would be required to obtain access to, or information from, Gemini and Staff has not shown that Gemini would refuse to provide it.
[100] The Applicants’ evidence is that Raymond Chabot is prepared to conduct the audit. As a qualified auditor for public issuers, Raymond Chabot must conduct the audit in compliance with GAAS. In its letter dated March 14, 2019, Raymond Chabot indicates an understanding that NI 81-106 requires an external auditor to express an unmodified opinion on the annual financial statements and states that, for an unmodified opinion to be expressed, the auditor needs to obtain sufficient appropriate audit evidence, including as it relates to the Fund's digital assets. According to Raymond Chabot, such audit evidence may include evidence related to the existence, accuracy, valuation, allocation, and ownership of the Fund's digital assets. Such audit evidence may also include the evidence obtained from third parties, including from SOC reports, if deemed necessary.30 It is notable that Raymond Chabot is the auditor of 3iQ’s private fund and gave an unmodified opinion regarding the private fund’s 2018 financial statements. In addition, other reporting issuers holding crypto-assets have obtained unmodified audit opinions on their financial statements.
[101] Finally, there is the possibility that the Fund will ultimately fail to deliver the required audit report. That operational risk is highlighted in the Fund’s prospectus. If those circumstances arise in the future, Staff will have access to the normal course measures to address that deficiency, including a potential request for a cease trade order. For a Panel to intervene at this time, based only on the speculation that the Fund might not be able to obtain the required audit report, in pre-emptive circumstances of this sort, would be extraordinary. I reject Staff’s submission that, ex ante, I should essentially decide now that the Fund is inauditable on the evidence before me.
E. Application of the Public Interest Test
[102] Having considered each of the operational risks identified by Staff, I now consider whether Staff has established that issuing a receipt for the Fund’s prospectus is not in the public interest. As discussed above, the Commission’s public interest jurisdiction is grounded in the purposes and fundamental principles set out in the Act. The purposes of the Act are as follows, and those that are relevant to my analysis are bolded:
30 Letter from L. Roy, Raymond Chabot, to 3iQ Corp (14 March 2019), Exhibit Z to S. Cumby’s Affidavit sworn April 12, 2019.
November 7, 2019 (2019), 42 OSCB 8684
Reasons: Decisions, Orders and Rulings
(a) provide protection to investors from unfair, improper or fraudulent practices;
(b) foster fair and efficient capital markets and confidence in capital markets; and
(c) contribute to the stability of the financial system and the reduction of systemic risk.31
[103] I agree with the Applicants and Staff that the third purpose is not applicable in this proceeding.
[104] The fundamental principles set out in the Act are listed below, and those that I find most relevant to my analysis are bolded:32
1. Balancing the importance to be given to each of the purposes of this Act may be required in specific cases.
2. The primary means for achieving the purposes of this Act are,
i. requirements for timely, accurate and efficient disclosure of information,
ii. restrictions on fraudulent and unfair market practices and procedures, and
iii. requirements for the maintenance of high standards of fitness and business conduct to ensure honest and responsible conduct by market participants.
3. Effective and responsive securities regulation requires timely, open and efficient administration and enforcement of this Act by the Commission.
4. The Commission should, subject to an appropriate system of supervision, use the enforcement capability and regulatory expertise of recognized self-regulatory organizations.
5. The integration of capital markets is supported and promoted by the sound and responsible harmonization and co-ordination of securities regulation regimes.
6. Business and regulatory costs and other restrictions on the business and investment activities of market participants should be proportionate to the significance of the regulatory objectives sought to be realized.
7. Innovation in Ontario’s capital markets should be facilitated.
[105] With respect to the first fundamental principle above, I have balanced the importance given to both purposes that are relevant to my analysis, and I do not attach greater weight to either.
[106] Staff submits that investor protection in the context of s. 61(1) includes a consideration of the assets that the Fund proposes to hold. Staff emphasizes the need to protect investors from the operational risks Staff has identified, which result from the Fund proposing to hold bitcoin.
[107] Staff submits that the market for bitcoin is in its infancy and is too new to have been fully addressed by Ontario securities law. Staff refers to the consultation paper jointly published earlier this year by the Canadian Securities Administrators (CSA) and the Investment Industry Regulatory Organization of Canada (IIROC),33 as evidence of the early stage of regulation of bitcoin and other crypto-assets, and of the market integrity and investor protection concerns regulators have with crypto-assets. Staff makes a similar submission about the status of regulation of crypto-assets in the United States. In particular, Staff relies on the SEC decisions in which the SEC rejected proposed rule amendments to list and trade shares of ETFs that would primarily invest in bitcoin or bitcoin futures. Given that the bitcoin market and regulation of that market is in its infancy, Staff submits that the Fund’s compliance with NI 81-102’s requirements is not enough to exhaust the policy concerns that led to NI 81-102 in the first place or the policy concerns underlying s. 61(1) of the Act.
31 Act, s 1(1). 32 Act, s 2.1. 33 Joint Canadian Securities Administrators/Investment Industry Regulatory Organization of Canada Consultation Paper 21-402, Proposed Framework for Crypto-Asset Trading Platforms (14 March 2019).
November 7, 2019 (2019), 42 OSCB 8685
Reasons: Decisions, Orders and Rulings
[108] Each of the operational risks identified by Staff arises from the assets that the Fund proposes to hold – bitcoin – and not from the structure or management of the Fund.
[109] I do not agree with Staff’s submission that investor protection under s. 61(1) necessarily extends to a consideration of the assets a fund proposes to hold or the markets in which those assets trade. If that analysis were applied to deny a receipt to the Fund, as Staff submits it should, it would amount to a ban on any funds holding bitcoin, regardless of their structure or management. Further, the length of Staff’s proposed ban would be uncertain. Staff is effectively proposing a ban on funds holding bitcoin that would remain in place until Staff deems the market for bitcoin to have matured enough that Staff’s concerns about the operational risks have diminished. Staff has not provided any authority for imposing such an indeterminate ban.
[110] Given that investors have other means of acquiring bitcoin, I question whether the ban proposed by Staff would protect investors from “unfair, improper or fraudulent practices”,34 as provided for under the Act’s purposes. Instead of ensuring that investors could not invest in bitcoin, denial of the receipt would only ensure that investors could not invest in bitcoin through a public fund.
[111] Denying investors the opportunity to invest in bitcoin through a public fund would not promote fair and efficient capital markets and confidence in capital markets. Instead, it would suggest that investors should acquire bitcoin through unregulated vehicles, and capital market participants should be encouraged to create those vehicles.
[112] Imposing a ban of uncertain length on investment funds that propose to hold particular assets would not be timely, open or efficient, and would not provide certainty for capital market participants.
[113] In the Panel’s view, investor protection under s. 61(1) of the Act is most often concerned with the issuer and matters that are within the issuer’s control or power, like the structure of the fund and the operations of the issuer by the issuer’s management and employees. For example, the Commission has refused a receipt where the issuer did not have a true business,35 and where the issuer could not prove that an unacceptable person with prior securities related criminal convictions for fraud was not in charge of the fund.36 Subsection 61(1) is less concerned with extraneous or external forces beyond the Fund’s control or power, like the issues Staff has identified with the assets the Fund intends to hold and the markets in which those assets are traded.
[114] There are no allegations in this matter that the Applicants would engage in unfair, improper or fraudulent practices in their operations and management of the Fund and, in fact, the evidence is to the contrary; the Applicants intend to operate and manage the Fund in a prudent and professional manner. Furthermore, insofar as the operational risks identified by Staff relate to potential unfair, improper or fraudulent practices in the bitcoin markets, these practices are not within the Applicants’ control or power. Rather, the evidence is that the Applicants are well aware of these operational risks and intend to take reasonable steps to mitigate them.
[115] The issue before me is not whether and how bitcoin or crypto-assets in general should be regulated. That issue is the subject of the joint consultation paper published by the CSA and IIROC and may also be a broader issue for governments of competent jurisdiction to consider within the scope of their legislative authority.
[116] The issuance of a receipt for the final prospectus of the Fund would promote efficient capital markets by creating an alternative to GBTC (which is available to Canadian retail investors in the secondary exempt market, but trades at a significant premium to its net asset value) and to RTO Crypto Issuers. The issuance of a receipt would also promote efficient capital markets by giving retail investors a means of diversifying their investment portfolios through access to an additional uncorrelated asset class.
[117] A refusal to issue a receipt would be contrary to the principle that business and regulatory costs and other restrictions on the business and investment activities of market participants should be proportionate to the significance of the regulatory objectives sought to be realized.
[118] The issue before me is whether a receipt should be issued for the Fund. The issue is fund-specific. In that regard, the SEC decisions referred to by Staff are distinguishable. The SEC was applying a different legal test to a different type of fund. It was considering whether to amend the rules to permit the listing of bitcoin ETFs. The SEC was also dealing with matters where the burden of proof was on the exchanges proposing rule changes, not on the agency staff.
[119] An ETF needs to create and redeem units on a frequent and ongoing basis. In contrast, the Fund need only redeem units at specific times. The Fund is a static buy and hold fund. It does not propose to be an active trader and does not need to trade actively to meet redemption requests. An ETF is, by nature and design, a dynamic trading vehicle and
34 Act, s 1(1)(a). 35 Inland National Capital Ltd (Re), (1996) 19 OSCB 2053. 36 Tricor Holdings Co Inc (Re), (1988) 11 OSCB 4059.
November 7, 2019 (2019), 42 OSCB 8686
Reasons: Decisions, Orders and Rulings
materially different than a static buy and hold fund. If the Fund were an ETF, that might have impacted my analysis of the risks identified by Staff, in particular, with regard to price manipulation risk.
[120] In addition to structuring the Fund so that it does not need to trade actively, the Applicants have sought to mitigate the risks posed by bitcoin and the bitcoin markets, by putting in place professional management, advisers and third-party service providers. 3iQ is also a registrant and as such, it must satisfy the proficiency, integrity and ongoing compliance requirements applicable to all registrants, which adds an additional measure of protection for investors.
[121] The notion of professionalizing investing in risky assets to mitigate risks should be encouraged, not discouraged. Ontario capital market participants should be encouraged to engage with the Commission, and not incentivized to avoid doing so.
[122] Pooling of investor funds under a professional management structure to address and mitigate risks in an underlying asset market is innovative and should be encouraged, especially when it provides an alternative to investors acquiring bitcoin through unregulated vehicles.
[123] Much has been said in the hearing of this matter about doors and gates; the front door and back door into Ontario’s capital markets, and the gates that control access of retail investors to investment products in the public securities markets. While the parties’ submissions in this regard did not impact my decision that Staff did not show, on a balance of probabilities, that issuing a receipt for the final prospectus would be contrary to the public interest, it is nevertheless worth addressing these issues relating to doors and gates, to provide some context.
[124] I disagree with Staff’s submission that approving the Fund’s final prospectus will open the floodgates to other public offerings of crypto-asset issuers.
[125] While I note the role of securities regulators as a front door gatekeeper of the capital markets through its function of approving prospectuses, it certainly isn’t the only front door gatekeeper. Investment dealers and their salespersons are also gatekeepers for retail investors through their know your client, suitability and other obligations and duties to their retail clients. In addition, investment dealers must approve products for their shelves before their salespersons are permitted to sell the products, and it is yet to be seen whether and to what extent such approval will be forthcoming regarding these types of investment products. This investment dealer/salesperson gatekeeper role should not be disregarded or discounted.
[126] In addition, and as noted above, the Applicants have come through the front door for prospectus review and approval, and this behaviour should be encouraged.
[127] While this doesn’t mean that every issuer coming in the front door for prospectus approval is entitled to approval (it does not), the front door prospectus approval process also needs to be viewed in the context of the back door to the Ontario capital markets that is still available.
[128] In Ontario and other Canadian jurisdictions, back door access to the public securities markets is available through one or more types of reverse take over corporate structures, whereby a private issuer with a business or assets combines with an existing public issuer (i.e., reporting issuer) whose business is dormant or defunct, effectively becoming a public issuer without ever coming in the front door for prospectus review and approval. This backdoor access has resulted in some of the largest and most prominent issuer failures in the Canadian capital markets (e.g., Sino-Forest Corporation and YBM Magnex International Inc., to name a few), with catastrophic financial consequences for investors in these issuers.
[129] It is outside the scope of this proceeding to address whether and to what extent the back door should be regulated or closed. Nevertheless, the fact of its existence, and the fact that, according to the evidence in this case, there are now approximately ten reporting issuers operating in Ontario that are RTO Crypto Issuers, which have accessed Ontario’s capital markets in this back door fashion, is a factor that the Panel considers in addressing both the investor protection test in the purposes of the Act and the broader public interest test, as outlined above.
[130] Finally, and as noted above, while the public interest jurisdiction under the Act is broad, it is not unlimited. In the context of the purposes of the Act, investor protection means protection from “unfair, improper and fraudulent practices” and not risk. If there are consumer protection issues or investor protection issues or concerns in relation to the issues raised in the preceding sections that are beyond the scope of the jurisdiction of the Commission under the Act, it is incumbent upon governments of competent jurisdiction to address those concerns, within the scope of their powers.
[131] Having considered all of the operational risks identified by Staff, viewed through the lens of the public interest test in s. 61(1) of the Act, and as informed by the purposes and principles in ss. 1.1 and 2.1 of the Act, I find that the issuance of a receipt for the final prospectus of the Fund is not contrary to the public interest.
November 7, 2019 (2019), 42 OSCB 8687
Reasons: Decisions, Orders and Rulings
VII. CONCLUSION AND TERMS AND CONDITIONS
A. Conclusion
[132] Staff has not demonstrated that:
a. bitcoin is an illiquid asset such that the Fund will not be compliant with the restrictions on illiquid assets in NI 81-102, or
b. it is not in the public interest to issue a receipt for the Fund’s prospectus, because of Staff’s concerns regarding the integrity of the bitcoin markets, and the Fund’s ability to value and safeguard the bitcoin it holds and file audited financial statements.
[133] Accordingly, I will order that the Director’s decision be set aside and the Director issue a receipt for the Fund’s prospectus.
B. Terms and Conditions
[134] Before closing arguments, I invited both Staff and the Applicants to provide submissions on the terms and conditions that may apply to an order that the Director issue a receipt for the Fund’s prospectus, should I decide to make that order.
[135] Staff submits that, in the event the Director is ordered to issue a receipt, the order: 1) should recognize that there are remaining steps for completion before a final offering prospectus can be receipted, and 2) should be subject to several specific terms.
[136] Regarding outstanding steps, Staff submits that if the Applicants wish to proceed with an offering of the Fund, they must file a final prospectus that contains the information required by Form 41-101F2 – Information Required in an Investment Fund. The final prospectus would include additional information regarding the offering, such as pricing information and details regarding underwriters. Also, if the Fund anticipates offering units in Canadian jurisdictions outside of Ontario, Staff submits that the Applicants will likely still need to consult with other CSA jurisdictions and file a prospectus in those jurisdictions.
[137] In response, the Applicants delivered a draft preliminary prospectus for the Fund (the July 2019 Preliminary Prospectus) to the Panel and Staff in advance of the oral closing arguments in this Application. They also delivered a blackline tracking the changes to the non-offering prospectus that was filed in March 2019 to inform the record for this proceeding. 3iQ also confirmed that it does intend to offer units of the Fund to Canadian retail investors in all provinces and territories of Canada. The filing of a preliminary prospectus of the Fund across Canada would require at least one IIROC dealer to certify the prospectus as agent of the Fund and would customarily include a syndicate of several IIROC dealers as agents. 3iQ expects that, if an Order is granted directing the Director to issue a receipt, the preliminary prospectus of the Fund that will ultimately be filed will be substantially in the form of the July 2019 Preliminary Prospectus, subject to input from the agents’ syndicate.
[138] Staff’s proposed conditions for the Order address several issues:
a. insurance requirements for the Fund’s bitcoin held in both hot wallets and cold wallets;
b. restrictions on the entities from whom the Fund may purchase bitcoin and to whom the Fund may sell bitcoin;
c. modified requirements for the quantity and quality of the pricing information that the Fund would use to value to its bitcoin; and
d. disclosure of the matters referred to above in any prospectus for which the Applicants seek a receipt.
[139] The Applicants submit that the Order should not prescribe any terms and conditions on the Fund, since all terms and conditions that must be satisfied prior to the issuance of a receipt are already prescribed in NI 81-102 and other applicable securities regulation.
[140] In the alternative, the Applicants propose a revised version of Staff’s conditions. The Applicants accept the proposed conditions about insurance for bitcoin held in hot wallets and about disclosure of the matters referred to in the conditions. But the Applicants maintain that cold wallet insurance is not a necessary condition because Gemini is a qualified custodian under NI 81-102 and Gemini’s cold storage has not suffered any previous losses. The Applicants also submit that there should be an expansion of Staff’s proposed restrictions on the entities from whom the Fund may
November 7, 2019 (2019), 42 OSCB 8688
Reasons: Decisions, Orders and Rulings
purchase bitcoin: in addition to entities subject to the BitLicense regulations administered by New York State, or other comparable regulatory requirements, the permitted sources should be expanded to include entities registered or licensed as dealers in securities or commodity futures contracts in Group of Seven (G7) countries. The Applicants submit that such an expanded list of counterparties would facilitate the best execution for the Fund.
[141] Finally, the Applicants submit that they are prepared to consider Staff’s views regarding the composition and methodology for a modified valuation index. Although the Applicants maintain that MVIBTC is an appropriate index, they are amenable to using a different index. But the Applicants argue that Staff’s proposed condition is not practical if it requires valuation to use pricing information from at least five entities that hold BitLicenses. The Applicants point to restrictions on information-sharing maintained by certain bitcoin sources and the limited number of BitLicensed trading platforms. Instead, 3iQ proposes a condition to value its bitcoin using pricing information primarily from at least three entities that hold a BitLicense, and verified with reference to the price of Chicago Mercantile Exchange bitcoin futures and the market price for bitcoin quoted on Bloomberg under ticker XBTUSD BGN.
[142] I find that the Applicants have taken reasonable steps to mitigate the risks associated with the Fund and the bitcoin markets through the structure of the Fund and the use of professional and qualified third-party service providers. The Applicants submit that the Order should not prescribe any terms and conditions on the Fund as described in paragraph [139] but, in the alternative, proposed modifications to Staff’s proposed terms and conditions if the Panel were to decide to impose terms and conditions.
[143] Specifically, the Applicants submit that they are prepared if necessary to accept the condition requested by Staff about insurance for bitcoin held in hot wallets. The Panel’s view is that it is not necessary to impose this condition on the Applicants. While such hot wallet insurance may be currently available and available on a reasonable cost basis, there is no assurance that such insurance will always be available to the Applicants or, if available, that it will be so on a reasonable cost basis. The Panel does not wish to impose a condition that may either be unable to be met in the future or that may only be met on a basis that is very expensive to the Fund. If 3iQ determines in its professional discretion that obtaining such insurance is prudent for the Fund then it should do so, but will not be required to do so by this Panel.
[144] The Applicants addressed Staff’s proposed restrictions on the entities from whom the Fund may purchase bitcoin and also Staff’s views regarding proposed restrictions on the composition and methodology for the Fund’s valuation index. The Panel does not wish to impose conditions that may unduly restrict or constrain 3iQ’s ability to exercise its professional judgement regarding these two matters. In both of these cases, as the bitcoin market evolves, it may in fact be prudent for 3iQ to adapt and evolve its practices and methodology. As such, the Panel does not accept Staff’s submissions that any constraints should be imposed in this regard by way of terms of conditions in the Order.
C. Order
[145] For the above reasons, I will order that:
a. the Director’s decision is set aside; and
b. the Director shall issue a receipt for a final prospectus of The Bitcoin Fund, provided the Director is satisfied that there are no grounds under subsection 61 of the Act for the Director to refuse to issue a receipt for any such prospectus, other than the grounds set out in the Director’s decision dated February 15, 2019 or in these reasons.
Dated at Toronto this 29th day of October, 2019.
“Lawrence P. Haber”
November 7, 2019 (2019), 42 OSCB 8689
Reasons: Decisions, Orders and Rulings
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November 7, 2019 (2019), 42 OSCB 8690
Chapter 4
Cease Trading Orders
4.1.1 Temporary, Permanent & Rescinding Issuer Cease Trading Orders
Company Name Date of Temporary Date of Hearing Date of Date of Order Permanent Order Lapse/Revoke
THERE IS NOTHING TO REPORT THIS WEEK.
Failure to File Cease Trade Orders
Company Name Date of Order Date of Revocation
Advantex Marketing International Inc. 01 November 2019
Besra Gold Inc. 01 November 2019
Chemesis International Inc. 01 November 2019
CellCube Energy Storage Systems Inc. 01 November 2019
CordovaCann Corp. 01 November 2019
EGF Theramed Health Corp. 01 November 2019
Eviana Health Corporation 01 November 2019
Lifestyle Global Brands Limited 01 November 2019 Melior Resources Inc. 01 November 2019
Peeks Social Ltd. 09 September 2019 01 November 2019
Star Navigation Systems Group Ltd. 01 November 2019
4.2.1 Temporary, Permanent & Rescinding Management Cease Trading Orders
Company Name Date of Order Date of Lapse
THERE IS NOTHING TO REPORT THIS WEEK.
4.2.2 Outstanding Management & Insider Cease Trading Orders
Date of Date of Order or Date of Date of Issuer Company Name Date of Hearing Temporary Order Permanent Order Lapse/ Expire Temporary Order Performance Sports 19 October 2016 31 October 2016 31 October 2016 Group Ltd.
Company Name Date of Order Date of Lapse CannTrust Holdings Inc. 15 August 2019
November 7, 2019 (2019), 42 OSCB 8691
Cease Trading Orders
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November 7, 2019 (2019), 42 OSCB 8692
Chapter 7
Insider Reporting
The following is a weekly summary of insider transactions by insiders of Ontario reporting issuers in SEDI® (the System for Electronic Disclosure by Insiders).1 The weekly summary contains insider transactions reported during the 7-day period ending Sunday at 11:59 p.m. (i.e. the Sunday prior to the Bulletin Issue date).2
Guide to Codes Relationship of Insider to Issuer (Rel=n)
1 Issuer 2 Subsidiary of Issuer 3 10% Security Holder of Issuer 4 Director of Issuer 5 Senior Officer of Issuer 6 Director or Senior Officer of 10% Security Holder 7 Director or Senior Officer of Insider or Subsidiary of Issuer (other than in 4,5,6) 8 Deemed Insider – 6 Months before becoming Insider
Nature of Transaction (T/O)
00 Opening Balance-Initial SEDI Report 10 Acquisition or disposition in the public market 11 Acquisition or disposition carried out privately 15 Acquisition or disposition under a prospectus 16 Acquisition or disposition under a prospectus exemption 22 Acquisition or disposition pursuant to a take-over bid, merger or acquisition 30 Acquisition or disposition under a purchase/ ownership plan 35 Stock dividend 36 Conversion or exchange 37 Stock split or consolidation 38 Redemption, retraction, cancellation, repurchase 40 Short sale 45 Compensation for property 46 Compensation for services 47 Acquisition or disposition by gift 48 Acquisition by inheritance or disposition by bequest 50 Grant of options 51 Exercise of options 52 Expiration of options 53 Grant of warrants 54 Exercise of warrants 55 Expiration of warrants 56 Grant of rights 57 Exercise of rights 59 Exercise for cash 70 Acquisition or disposition (writing) of third party derivative 71 Exercise of third party derivative 72 Other settlement of third party 73 Expiration of third party derivative 90 Change in nature of ownership 97 Other 99 Correction of Information
Note: The asterisk in the “Date/Month End Holding” column indicates the insider disagreed with the system calculated balance when the transaction was reported.
1 SEDI® is a registered trademark owned by CDS INC. 2 ©CDS INC.
November 7, 2019 (2019), 42 OSCB 8693
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed 1933 Industries Inc Common Shares Sutton, Brayden Robert 4, 5 2019-10-28 10 0.265 5,545,224 14,400 1933 Industries Inc Common Shares Sutton, Brayden Robert 4, 5 2019-10-28 10 0.265 5,569,676 24,452 4Front Ventures Corp. Subordinate Voting Gontmakher, Leonid 3, 4, 5 2019-09-20 36 5,612,897 1,075,440 Shares (Class A Subordinate Voting Shares) 4Front Ventures Corp. Subordinate Voting Gontmakher, Leonid 3, 4, 5 2019-09-20 36 306,637 -13,443 Shares (Class B Subordinate Proportionate Voting Shares) A&W Revenue Royalties Trust Units Mindell, David Allen 4 2019-10-31 10 37.48 42,727 180 Income Fund A&W Revenue Royalties Trust Units Mindell, David Allen 4 2019-10-31 10 37.48 2,050 8 Income Fund AbraPlata Resource Corp. Common Shares Zaballa, Hernan Miguel 4 2019-10-31 16 0.06 3,065,280 1,250,000 AbraPlata Resource Corp. Warrants Zaballa, Hernan Miguel 4 2017-04-24 00 AbraPlata Resource Corp. Warrants Zaballa, Hernan Miguel 4 2019-10-31 16 1,250,000 1,250,000 Advantage Oil & Gas Ltd. Rights Deferred Share Angevine, Jill Terilee 4 2019-10-31 56 69,096 2,741 Units Advantage Oil & Gas Ltd. Rights Deferred Share Balog, Stephen 4 2019-10-31 56 78,214 2,741 Units Advantage Oil & Gas Ltd. Rights Deferred Share Fagerheim, Grant Bradley 4 2019-10-31 56 67,417 1,371 Units Advantage Oil & Gas Ltd. Rights Deferred Share Haggis, Paul 4 2019-10-31 56 86,877 3,015 Units Advantage Oil & Gas Ltd. Rights Deferred Share McIntosh, Ronald A 4 2019-10-31 56 119,633 4,167 Units Advantex Marketing Common Shares Abramson, Randall 3 2017-12-22 00 International Inc. Advantex Marketing Common Shares Abramson, Randall 3 2019-10-28 16 10,824,400 10,824,400 International Inc. Advantex Marketing Debentures Abramson, Randall 3 2017-12-22 00 International Inc. Advantex Marketing Debentures Abramson, Randall 3 2019-10-28 16 $100,000 $100,000 International Inc. Adventus Mining Options Dueñas, Alvaro 5 2019-10-08 00 Corporation Adventus Mining Options Dueñas, Alvaro 5 2019-10-23 50 0.97 800,000 800,000 Corporation Adventus Mining Rights RSU Dueñas, Alvaro 5 2019-10-08 00 Corporation Adventus Mining Rights RSU Dueñas, Alvaro 5 2019-10-23 56 200,000 200,000 Corporation Aether Catalyst Solutions, Common Shares Woodward, Paul John 3, 4, 6, 5 2019-10-30 10 0.4 2,971,700 -500 Inc. Courtney AGF Management Limited Common Shares Class B AGF Management Limited, 1 2019-10-28 38 5.7356 8,900 8,900 La Societe de Gestion AGF Limitee AGF Management Limited Common Shares Class B AGF Management Limited, 1 2019-10-28 38 5.7356 0 -8,900 La Societe de Gestion AGF Limitee AGF Management Limited Common Shares Class B AGF Management Limited, 1 2019-10-31 38 5.77 2,800 2,800 La Societe de Gestion AGF Limitee AGF Management Limited Common Shares Class B AGF Management Limited, 1 2019-10-31 38 5.77 0 -2,800 La Societe de Gestion AGF Limitee Agnico Eagle Mines Limited Common Shares Allan, Don 5 2019-10-28 10 75.93 26,706 -1,731 Agnico Eagle Mines Limited Common Shares Blackburn, Alain 5 2019-10-31 51 36.37 3,692 2,000 Agnico Eagle Mines Limited Common Shares Blackburn, Alain 5 2019-10-31 10 80.03 1,692 -2,000 Agnico Eagle Mines Limited Options Blackburn, Alain 5 2019-10-31 51 36.37 98,000 -2,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-11-01 99 87,000 -120,000 Agnico Eagle Mines Limited Restricted Share Units Gosselin, Guy 5 2019-11-01 99 33,000 25,160 Agnico Eagle Mines Limited Common Shares Laing, R. Gregory 5 2019-10-31 51 28.92 40,638 2,500 Agnico Eagle Mines Limited Common Shares Laing, R. Gregory 5 2019-10-31 10 80.628 38,138 -2,500
November 7, 2019 (2019), 42 OSCB 8694
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Agnico Eagle Mines Limited Options Laing, R. Gregory 5 2019-10-31 51 28.92 153,500 -2,500 Air Canada Class B Voting Shares Air Canada 1 2019-10-28 38 46.332 25,000 25,000 Air Canada Class B Voting Shares Air Canada 1 2019-10-28 38 0 -25,000 Air Canada Class B Voting Shares Air Canada 1 2019-10-29 38 47.522 25,000 25,000 Air Canada Class B Voting Shares Air Canada 1 2019-10-29 38 0 -25,000 Air Canada Class B Voting Shares Air Canada 1 2019-10-30 38 47.112 25,000 25,000 Air Canada Class B Voting Shares Air Canada 1 2019-10-30 38 0 -25,000 Air Canada Class B Voting Shares Air Canada 1 2019-10-31 38 46.495 35,000 35,000 Air Canada Class B Voting Shares Air Canada 1 2019-10-31 38 0 -35,000 Air Canada Class A Variable Voting Kazzaz, Amos 5 2019-10-31 51 5.35 16,220 11,697 Shares Air Canada Class A Variable Voting Kazzaz, Amos 5 2019-10-31 10 46.31 4,523 -11,697 Shares Air Canada Class A Variable Voting Kazzaz, Amos 5 2019-10-31 51 2.49 12,023 7,500 Shares Air Canada Class A Variable Voting Kazzaz, Amos 5 2019-10-31 10 46.322 4,523 -7,500 Shares Air Canada Class A Variable Voting Kazzaz, Amos 5 2019-10-31 51 5.35 16,220 11,697 Shares Air Canada Class A Variable Voting Kazzaz, Amos 5 2019-10-31 10 46.31 4,523 -11,697 Shares Air Canada Options (Long-Term Kazzaz, Amos 5 2019-10-31 51 5.35 107,681 -11,697 Incentive Plan) Air Canada Options (Long-Term Kazzaz, Amos 5 2019-10-31 51 2.49 100,181 -7,500 Incentive Plan) Air Canada Options (Long-Term Kazzaz, Amos 5 2019-10-31 51 5.35 88,484 -11,697 Incentive Plan) Air Canada Class B Voting Shares Rousseau, Michael Stewart 5 2019-10-31 51 5.39 130,151 45,151 Air Canada Class B Voting Shares Rousseau, Michael Stewart 5 2019-10-31 10 46.75 85,000 -45,151 Air Canada Class B Voting Shares Rousseau, Michael Stewart 5 2019-10-31 51 5.39 98,400 13,400 Air Canada Class B Voting Shares Rousseau, Michael Stewart 5 2019-10-31 10 46.6 85,000 -13,400 Air Canada Class B Voting Shares Rousseau, Michael Stewart 5 2019-10-31 51 5.39 116,751 31,751 Air Canada Class B Voting Shares Rousseau, Michael Stewart 5 2019-10-31 10 46.75 85,000 -31,751 Air Canada Options (Long-Term Rousseau, Michael Stewart 5 2019-10-31 51 5.39 604,444 -45,151 Incentive Plan) Air Canada Options (Long-Term Rousseau, Michael Stewart 5 2019-10-31 51 5.39 591,044 -13,400 Incentive Plan) Air Canada Options (Long-Term Rousseau, Michael Stewart 5 2019-10-31 51 5.39 559,293 -31,751 Incentive Plan) Akumin Inc. Common Shares Fitzgerald, Christopher 5 2019-10-31 30 164 5 Gifford Akumin Inc. Common Shares Kassa, Laura Mae 5 2019-10-31 30 512 17 Akumin Inc. Common Shares Luckey, Michael 5 2019-10-31 30 426 17 Akumin Inc. Common Shares Meredith, Michael 5 2019-10-31 30 385 15 Akumin Inc. Common Shares Moore, Karen 7 2019-10-31 30 213 13 Akumin Inc. Common Shares Quesenberry, Marcus 5 2019-10-31 30 431 15 Akumin Inc. Common Shares Richardson, Jason 5 2019-10-31 30 506 17 Alamos Gold Inc. Rights Deferred Share Prichard, John Robert 4 2019-10-31 30 19,874 517 Units Stobo Altiplano Metals Inc. Common Shares Yaseniuk, Jeremy 4 2019-11-01 10 0.11 1,768,950 5,000 Altius Minerals Corporation Common Shares Gaumond, André 4 2019-10-31 10 10.5 4,000 2,000 American Hotel Income Units O'Neill, John Christopher 5 2019-10-29 30 6.8327 424,569 3,765 Properties REIT LP Americas Gold and Silver Rights Deferred Share Alfers, Stephen Douglas 4 2019-05-15 00 Corporation Units Americas Gold and Silver Rights Deferred Share Alfers, Stephen Douglas 4 2019-10-31 56 1,018 1,018 Corporation Units Americas Gold and Silver Rights Deferred Share Alfers, Stephen Douglas 4 2019-10-31 56 1,865 847 Corporation Units Americas Gold and Silver Rights Deferred Share Davidson, Alexander John 4 2019-10-31 56 85,075 1,822 Corporation Units Americas Gold and Silver Rights Deferred Share Davidson, Alexander John 4 2019-10-31 56 86,558 1,483 Corporation Units
November 7, 2019 (2019), 42 OSCB 8695
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Americas Gold and Silver Rights Deferred Share Edwards, Alan R. 4 2019-10-31 56 1,249 Corporation Units Americas Gold and Silver Rights Deferred Share Edwards, Alan R. 4 2019-10-31 56 1,249 Corporation Units Americas Gold and Silver Rights Deferred Share Edwards, Alan R. 4 2019-10-31 56 1,017 Corporation Units Americas Gold and Silver Rights Deferred Share Edwards, Alan R. 4 2019-10-31 56 1,017 Corporation Units Americas Gold and Silver Rights Deferred Share Edwards, Alan R. 4 2019-10-31 56 48,975 1,249 Corporation Units Americas Gold and Silver Rights Deferred Share Edwards, Alan R. 4 2019-10-31 56 49,992 1,017 Corporation Units Americas Gold and Silver Rights Deferred Share Kipp, Bradley Robert 4 2019-10-31 56 73,106 1,353 Corporation Units Americas Gold and Silver Rights Deferred Share Kipp, Bradley Robert 4 2019-10-31 56 74,207 1,101 Corporation Units Americas Gold and Silver Rights Deferred Share Pridham, Gordon E. 4 2019-10-31 56 44,314 1,301 Corporation Units Americas Gold and Silver Rights Deferred Share Pridham, Gordon E. 4 2019-10-31 56 45,373 1,059 Corporation Units Americas Gold and Silver Rights Deferred Share RIVERA RABA, MANUEL 4 2019-10-31 56 8,184 1,122 Corporation Units ALBERTO Americas Gold and Silver Rights Deferred Share RIVERA RABA, MANUEL 4 2019-10-31 56 9,158 974 Corporation Units ALBERTO Americas Gold and Silver Rights Deferred Share Waisberg, Lorie 4 2019-10-31 56 48,300 1,405 Corporation Units Americas Gold and Silver Rights Deferred Share Waisberg, Lorie 4 2019-10-31 56 49,444 1,144 Corporation Units Anaconda Mining Inc. Common Shares Bullock, Kevin 4, 5 2019-10-31 10 0.2 640,000 25,000 ANC Capital Ventures Inc. Common Shares Karabelas, Leonidas 3, 4 2019-10-25 00 700,000 ANC Capital Ventures Inc. Options Karabelas, Leonidas 3, 4 2019-10-25 00 185,000 Antibe Therapeutics Inc. Common Shares Flower, Roderick John 4 2019-10-24 10 0.445 212,492 -120,000 Aphria Inc. (formerly, Black Common Shares Dym, Shawn 4 2017-10-25 00 Sparrow Capital Corp.) Aphria Inc. (formerly, Black Common Shares Dym, Shawn 4 2019-10-28 10 7.03 6,000 6,000 Sparrow Capital Corp.) Aphria Inc. (formerly, Black Common Shares Dym, Shawn 4 2019-10-29 10 6.61 10,000 4,000 Sparrow Capital Corp.) Aphria Inc. (formerly, Black Common Shares MERTON, Carl 5 2019-10-17 51 3.9 97,797 19,767 Sparrow Capital Corp.) Aphria Inc. (formerly, Black Options MERTON, Carl 5 2019-10-17 51 410,000 -50,000 Sparrow Capital Corp.) Aptose Biosciences Inc. Common Shares Rice, William Glenn 4, 5 2019-10-24 10 1.92 163,014 10,000 Aritzia Inc. Subordinate Voting Bensadoun, Aldo 4 2019-10-23 10 105,000 -10,000 Shares Aritzia Inc. Options Neal, Jennifer Michelle 4, 5 2019-10-29 51 1,282,671 -9,284 Wong Aritzia Inc. Subordinate Voting Neal, Jennifer Michelle 4, 5 2019-10-29 51 24,316 9,284 Shares Wong Aritzia Inc. Subordinate Voting Neal, Jennifer Michelle 4, 5 2019-10-29 10 19.009 15,032 -9,284 Shares Wong Artemis Gold Inc. Options Beedie, Ryan K 4 2019-07-19 00 Artemis Gold Inc. Options Beedie, Ryan K 4 2019-10-24 50 100,000 100,000 Aurania Resources Ltd. Options Kagan, Jonathan 4 2019-06-20 00 Aurania Resources Ltd. Options Kagan, Jonathan 4 2019-10-24 50 2.7 200,000 200,000 Aurelius Minerals Inc. Common Shares Ashcroft, Mark Nicholas 4, 5 2019-10-30 16 0.05 3,300,000 1,000,000 (formerly Galena James International Resources Ltd.) Aurelius Minerals Inc. Warrants Ashcroft, Mark Nicholas 4, 5 2019-10-30 16 0.05 3,050,000 1,000,000 (formerly Galena James International Resources Ltd.) Aurelius Minerals Inc. Common Shares Coombs, Germaine 5 2019-10-30 11 0.05 900,000 400,000 (formerly Galena Marleen International Resources Ltd.)
November 7, 2019 (2019), 42 OSCB 8696
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Aurelius Minerals Inc. Warrants Coombs, Germaine 5 2019-10-30 11 900,000 400,000 (formerly Galena Marleen International Resources Ltd.) Aurelius Minerals Inc. Common Shares MacGillivray, Lorna 5 2019-01-23 00 (formerly Galena International Resources Ltd.) Aurelius Minerals Inc. Common Shares MacGillivray, Lorna 5 2019-10-30 11 0.05 400,000 400,000 (formerly Galena International Resources Ltd.) Aurelius Minerals Inc. Warrants MacGillivray, Lorna 5 2019-01-23 00 (formerly Galena International Resources Ltd.) Aurelius Minerals Inc. Warrants MacGillivray, Lorna 5 2019-10-30 11 400,000 400,000 (formerly Galena International Resources Ltd.) Aurelius Minerals Inc. Common Shares Niemi, Jeremy Karl 5 2019-10-30 15 0.05 500,000 200,000 (formerly Galena International Resources Ltd.) Aurelius Minerals Inc. Warrants Niemi, Jeremy Karl 5 2019-10-30 15 0.06 350,000 200,000 (formerly Galena International Resources Ltd.) Ayr Strategies Inc. (formerly, Subordinate Voting Ayr Strategies Inc. 1 2019-10-31 38 0 -7,400 Cannabis Strategies Shares Acquisition Corp.) Azarga Uranium Corp. Options Church, Curtis 6 2019-10-27 52 1.2 376,025 -228,125 Azarga Uranium Corp. Options O'Kane, Matthew James 6 2019-10-27 52 1.2 545,000 -28,336 Gerard Azarga Uranium Corp. Options Steele, Blake Albert 5 2019-10-27 52 1.2 1,975,000 -136,875 Bank of Nova Scotia, The Rights Director Deferred Aufreiter, Nora Anne 4 2019-10-29 56 75.55 12,206 860 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Aufreiter, Nora Anne 4 2019-10-29 30 75.55 12,341 135 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Babatz, Guillermo 4 2019-10-29 56 75.55 11,978 480 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Babatz, Guillermo 4 2019-10-29 30 75.55 12,116 138 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Bonham, Scott Barclay 4 2019-10-29 56 75.55 12,453 778 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Bonham, Scott Barclay 4 2019-10-29 30 75.55 12,591 138 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Dallara, Charles Harry 4 2019-10-29 56 75.55 12,213 480 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Dallara, Charles Harry 4 2019-10-29 30 75.55 12,353 140 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Macklem, Richard Tiffany 4 2019-10-29 56 75.55 16,004 910 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Macklem, Richard Tiffany 4 2019-10-29 30 75.55 16,184 180 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Penner, Michael D. 5 2019-10-29 56 75.55 7,559 778 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Penner, Michael D. 5 2019-10-29 30 75.55 7,640 81 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Power, Una Marie 4 2019-10-29 56 75.55 13,033 943 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Power, Una Marie 4 2019-10-29 30 75.55 13,176 143 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Regent, Aaron William 4 2019-10-29 56 75.55 27,085 1,489 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Regent, Aaron William 4 2019-10-29 30 75.55 27,390 305 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Samarasekera, Indira 4 2019-10-29 56 75.55 39,285 480 Stock Units (DDSU) Vasanti
November 7, 2019 (2019), 42 OSCB 8697
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Bank of Nova Scotia, The Rights Director Deferred Samarasekera, Indira 4 2019-10-29 30 75.55 39,748 463 Stock Units (DDSU) Vasanti Bank of Nova Scotia, The Rights Director Deferred Segal, Susan Louise 4 2019-10-29 56 75.55 29,956 778 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Segal, Susan Louise 4 2019-10-29 30 75.55 30,303 347 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Thomson, Scott 4 2019-10-29 56 75.55 12,025 943 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Thomson, Scott 4 2019-10-29 30 75.55 12,158 133 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Warmbold, Benita Marie 4 2019-10-29 56 75.55 3,117 745 Stock Units (DDSU) Bank of Nova Scotia, The Rights Director Deferred Warmbold, Benita Marie 4 2019-10-29 30 75.55 3,145 28 Stock Units (DDSU) BevCanna Enterprises Inc. Options Andrews, Emma 5 2019-10-24 50 100,000 100,000 BevCanna Enterprises Inc. Options Lyon, Camilo 4 2019-10-24 50 300,000 150,000 BIGG Digital Assets Inc. Common Shares Anstey, Shone Tyler 4 2019-10-25 10 0.045 9,137,755 10,000 BIGG Digital Assets Inc. Common Shares BIGG Digital Assets Inc 1 2019-10-25 10 0.0485 1,447,000 150,000 BIGG Digital Assets Inc. Common Shares BIGG Digital Assets Inc 1 2019-10-30 10 0.0464 1,797,000 350,000 BIGG Digital Assets Inc. Common Shares BIGG Digital Assets Inc 1 2019-10-31 10 0.05 1,897,000 100,000 BIGG Digital Assets Inc. Common Shares BIGG Digital Assets Inc 1 2019-11-01 10 0.05 1,997,000 100,000 BIGG Digital Assets Inc. Common Shares Binns, Mark Andrew 4 2019-10-25 10 0.045 394,000 94,000 BIGG Digital Assets Inc. Common Shares Binns, Mark Andrew 4 2019-10-25 10 0.04 400,000 6,000 BIGG Digital Assets Inc. Common Shares Binns, Mark Andrew 4 2019-10-31 10 0.05 410,000 10,000 Biocure Technology Inc. Common Shares Lichtenwald, Konstantin 4, 5 2019-10-30 11 0.43 11,100 -11,100 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-10 10 0.54 5,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-10 10 0.54 5,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-11 10 0.55 8,511,137 -1,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-11 10 0.54 8,516,137 5,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-11 10 0.56 8,513,137 -3,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-11 10 0.57 8,509,637 -3,500 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-11 10 0.58 8,487,137 -22,500 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-11 10 0.6 8,442,637 -44,500 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-11 10 0.61 8,432,637 -10,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-11 10 0.62 8,429,137 -3,500 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-11 10 0.625 8,428,137 -1,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-11 10 0.64 8,426,137 -2,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-15 10 0.53 8,427,137 1,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-15 10 0.54 8,428,137 1,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-15 10 0.54 8,425,137 -3,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-15 10 0.55 8,426,137 1,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-15 10 0.56 8,425,137 -1,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-15 10 0.6 8,424,137 -1,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-16 10 0.51 8,423,637 -500 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-16 10 0.52 8,409,137 -14,500 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-16 10 0.53 8,404,137 -5,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-17 10 0.51 8,400,137 -4,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-17 10 0.52 8,390,137 -10,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-17 10 0.53 8,380,137 -10,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-17 10 0.54 8,375,137 -5,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-17 10 0.55 8,370,137 -5,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-18 10 0.51 8,366,137 -4,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-18 10 0.52 8,342,137 -24,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-18 10 0.53 8,340,137 -2,000 Bitfarms Ltd. Common Shares Quimper, Pierre-Luc 3 2019-10-21 10 0.51 8,333,637 -6,500 BitRush Corp. Common Shares Arend, Karsten Achim 4, 5 2016-04-05 00 Richard BitRush Corp. Common Shares Arend, Karsten Achim 4, 5 2019-10-25 97 0.05 4,700,000 4,700,000 Richard BitRush Corp. Common Shares HSRC Investment Pte Ltd 6 2019-10-25 97 32,600,000 13,456,910 BitRush Corp. Common Shares HSRC Investment Pte Ltd 6 2019-10-25 97 34,600,000 2,000,000
November 7, 2019 (2019), 42 OSCB 8698
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed BitRush Corp. Common Shares Wollner, Sven 6 2016-03-11 00 BitRush Corp. Common Shares Wollner, Sven 6 2016-03-11 00 Blackline Safety Corp. Common Shares Slater, Cody 4 2019-10-28 51 1.8 1,382,732 50,000 Blackline Safety Corp. Options Slater, Cody 4 2019-10-28 51 1.8 165,000 -50,000 Blue Star Gold Corp. Options Metcalfe, Robert 4 2019-10-17 50 0.06 1,500,000 Blue Star Gold Corp. Options Metcalfe, Robert 4 2019-10-18 50 0.06 1,800,000 1,500,000 Blue Star Gold Corp. Options Yurichuk, Kenneth R. 4 2019-10-18 50 0.06 1,800,000 1,500,000 Blueberries Medical Corp. Common Shares Bajurny, Matthew 4 2018-11-06 00 Blueberries Medical Corp. Common Shares Bajurny, Matthew 4 2019-10-31 16 0.25 40,000 40,000 Blueberries Medical Corp. Warrants Bajurny, Matthew 4 2018-11-06 00 Blueberries Medical Corp. Warrants Bajurny, Matthew 4 2019-10-31 16 40,000 40,000 Blueberries Medical Corp. Warrants VILLALBA, PATRICIO 4 2019-02-0500 Blueberries Medical Corp. Warrants VILLALBA, PATRICIO 4 2019-10-31 46 33,903 33,903 Bonterra Energy Corp. Common Shares Fink, George Frederick 3, 4, 5 2019-10-23 10 3.445 3,870,499 5,000 Boreal Metals Corp. Common Shares EMX Royalty Corporation 3 2019-10-01 10 0.05 8,146,735 213,000 Boreal Metals Corp. Common Shares EMX Royalty Corporation 3 2019-10-03 10 0.05 8,286,735 140,000 Boreal Metals Corp. Common Shares EMX Royalty Corporation 3 2019-10-04 10 0.05 8,525,735 239,000 Boreal Metals Corp. Common Shares EMX Royalty Corporation 3 2019-10-08 10 0.05 8,563,735 38,000 Boreal Metals Corp. Common Shares EMX Royalty Corporation 3 2019-10-11 10 0.05 8,613,735 50,000 Boreal Metals Corp. Common Shares EMX Royalty Corporation 3 2019-10-15 10 0.05 8,684,735 71,000 Boreal Metals Corp. Common Shares EMX Royalty Corporation 3 2019-10-21 10 0.05 8,734,735 50,000 Boreal Metals Corp. Common Shares EMX Royalty Corporation 3 2019-10-30 10 0.05 9,525,735 791,000 BQE Water Inc. Common Shares hubbard, richard 3 2019-10-28 10 8.1 218,359 800 BQE Water Inc. Common Shares hubbard, richard 3 2019-10-29 10 8.1 218,659 300 BQE Water Inc. Common Shares hubbard, richard 3 2019-10-30 10 8.1 218,859 200 BQE Water Inc. Common Shares hubbard, richard 3 2019-10-31 10 8.1 219,059 200 Braveheart Resources Inc. Common Shares Berzins, Ian Martin 4, 5 2019-10-28 10 0.135 2,391,500 -10,500 Braveheart Resources Inc. Common Shares Berzins, Ian Martin 4, 5 2019-10-28 10 0.15 2,394,000 2,500 Braveheart Resources Inc. Common Shares Berzins, Ian Martin 4, 5 2019-10-30 10 0.15 2,409,000 15,000 Braveheart Resources Inc. Common Shares Berzins, Ian Martin 4, 5 2019-10-31 10 0.14 2,383,000 -26,000 Braveheart Resources Inc. Common Shares Berzins, Ian Martin 4, 5 2019-10-31 10 0.15 2,398,000 15,000 Braveheart Resources Inc. Common Shares Berzins, Ian Martin 4, 5 2019-11-01 10 0.135 2,366,500 -31,500 Braveheart Resources Inc. Common Shares Berzins, Ian Martin 4, 5 2019-11-01 10 0.136 2,370,500 4,000 Braveheart Resources Inc. Common Shares Berzins, Ian Martin 4, 5 2019-11-01 10 0.14 2,381,000 10,500 Braveheart Resources Inc. Common Shares Berzins, Ian Martin 4, 5 2019-11-01 10 0.145 2,387,000 6,000 Braveheart Resources Inc. Common Shares Matlock, Aaron 4, 5 2019-10-28 10 0.145 6,620,501 8,000 Braveheart Resources Inc. Common Shares Matlock, Aaron 4, 5 2019-10-30 10 0.14 6,610,501 -10,000 Braveheart Resources Inc. Common Shares Matlock, Aaron 4, 5 2019-10-30 10 0.15 6,615,501 5,000 Braveheart Resources Inc. Common Shares Matlock, Aaron 4, 5 2019-10-31 10 0.15 6,630,501 15,000 Brixton Metals Corporation Common Shares Thompson, Gary Robert 6 2019-10-31 10 0.235 2,315,584 20,000 Brompton Oil Split Corp. Class A Shares Kikuchi, Craig 4, 5 2019-10-28 10 1.35 0 -5,800 Buhler Industries Inc. Common Shares Fillion Kopp, Joelle Rae 3 2019-10-24 10 3.6 3,862,486 300 Buhler Industries Inc. Common Shares Fillion Kopp, Joelle Rae 3 2019-10-29 10 3.6 3,863,486 1,000 Bunker Hill Mining Corp. Options Aird, Hugh Housser 4 2019-07-19 00 (formerly, Liberty Silver Corp.) Bunker Hill Mining Corp. Options Aird, Hugh Housser 4 2019-10-24 50 265,000 265,000 (formerly, Liberty Silver Corp.) Bunker Hill Mining Corp. Options Hall, Hugh Dickson 4 2018-01-05 00 (formerly, Liberty Silver Corp.) Bunker Hill Mining Corp. Options Hall, Hugh Dickson 4 2019-10-24 50 265,000 265,000 (formerly, Liberty Silver Corp.) Bunker Hill Mining Corp. Options Liu, Jian Xiong 4 2018-11-09 00 (formerly, Liberty Silver Corp.) Bunker Hill Mining Corp. Options Liu, Jian Xiong 4 2019-10-24 50 240,000 240,000 (formerly, Liberty Silver Corp.)
November 7, 2019 (2019), 42 OSCB 8699
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Bunker Hill Mining Corp. Options Parsons, Steven Wayne 4 2019-01-22 00 (formerly, Liberty Silver Corp.) Bunker Hill Mining Corp. Options Parsons, Steven Wayne 4 2019-10-24 50 415,000 415,000 (formerly, Liberty Silver Corp.) Bunker Hill Mining Corp. Options Ryan, John Patrick 4 2019-10-24 50 1,790,000 390,000 (formerly, Liberty Silver Corp.) Cabral Gold Inc. Common Shares Carter, Alan 4, 6, 5 2019-10-31 10 0.105 8,733,332 499,000 Canada Jetlines Ltd. Common Shares Robinson, Deborah Wallis 4 2019-10-31 10 0.05 0 -110,000 Common & Variable Voting Shares CanadaBis Capital Inc. Warrants Michaud, Alex Joseph 4 2019-04-26 00 CanadaBis Capital Inc. Warrants Michaud, Alex Joseph 4 2019-04-26 00 62,500 CanadaBis Capital Inc. Warrants Ryan, Shawn Michael 5 2019-04-26 00 CanadaBis Capital Inc. Warrants Ryan, Shawn Michael 5 2019-04-26 00 56,500 Canadian Metals Inc. Common Shares Panneton, Gerald 4 2019-10-25 10 0.25 65,000 3,000 Canadian Pacific Railway Common Shares Marquis, Tony 5 2019-10-25 30 -145 -300 Limited Canadian Pacific Railway Common Shares Redeker, Michael 5 2019-10-29 51 6,891 6,100 Limited Canadian Pacific Railway Common Shares Redeker, Michael 5 2019-10-29 10 295.42 791 -6,100 Limited Canadian Pacific Railway Options Redeker, Michael 5 2019-10-29 51 30,753 -6,100 Limited Canadian Western Bank Rights Restricted Share Christensen, Lars Kurt 5 2019-10-31 56 8,861 3,082 Units Canadian Western Bank Rights Restricted Share Christensen, Lars Kurt 5 2019-10-31 59 5,606 -3,255 Units CANEX Metals Inc. Common Shares Ebert, Shane William 4 2019-10-29 11 0.05 856,788 300,000 (formerly Northern Abitibi Mining Corp.) Cannabis One Holdings Inc. Options Shapiro, Jordan 4 2016-09-23 52 46,000 -61,000 (formerly, Metropolitan Energy Corp.) Cannabis One Holdings Inc. Options Shapiro, Jordan 4 2016-11-01 52 0 -46,000 (formerly, Metropolitan Energy Corp.) Cannabis One Holdings Inc. Subordinate Voting Shapiro, Jordan 4 2018-03-29 37 10,416 -93,751 (formerly, Metropolitan Shares Class "A" Energy Corp.) subordinate voting shares Cannabis One Holdings Inc. Subordinate Voting Shapiro, Jordan 4 2018-03-29 16 0.075 1,010,416 1,000,000 (formerly, Metropolitan Shares Class "A" Energy Corp.) subordinate voting shares Cannabis One Holdings Inc. Subordinate Voting Shapiro, Jordan 4 2018-03-29 37 2,550 -22,950 (formerly, Metropolitan Shares Class "A" Energy Corp.) subordinate voting shares Cannabis One Holdings Inc. Subordinate Voting Shapiro, Jordan 4 2018-06-08 16 0.35 131,050 128,500 (formerly, Metropolitan Shares Class "A" Energy Corp.) subordinate voting shares Cannabis One Holdings Inc. Warrants Shapiro, Jordan 4 2013-05-22 00 (formerly, Metropolitan Energy Corp.) Cannabis One Holdings Inc. Warrants Shapiro, Jordan 4 2018-03-29 16 1,000,000 1,000,000 (formerly, Metropolitan Energy Corp.) Cannabis One Holdings Inc. Warrants Shapiro, Jordan 4 2016-10-27 55 0 -370,000 (formerly, Metropolitan Energy Corp.) Cannabis One Holdings Inc. Warrants Shapiro, Jordan 4 2018-06-08 16 128,500 128,500 (formerly, Metropolitan Energy Corp.) Cannabix Technologies Inc Common Shares Loree, Bryan 4, 5 2019-10-22 51 0.125 3,610,000 630,000 Cannabix Technologies Inc Options Loree, Bryan 4, 5 2019-10-22 51 0.125 920,000 -630,000 Cardinal Energy Ltd. Common Shares Brussa, John Albert 4 2019-10-31 10 1.95 1,290,844 20,000 Cardinal Resources Limited Common Shares Shipway, Sarah 5 2019-10-29 46 0.378 333,668 79,468 Cenovus Energy Inc. Common Shares Chhina, Harbir Singh 5 2019-01-31 90 206,708 187,708
November 7, 2019 (2019), 42 OSCB 8700
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Cenovus Energy Inc. Common Shares Chhina, Harbir Singh 5 2009-11-02 00 Cenovus Energy Inc. Common Shares Chhina, Harbir Singh 5 2019-01-31 90 177,708 177,708 Cenovus Energy Inc. Common Shares Chhina, Harbir Singh 5 2009-11-02 00 Cenovus Energy Inc. Common Shares Chhina, Harbir Singh 5 2019-01-31 90 69,992 69,992 Cenovus Energy Inc. Common Shares Chhina, Harbir Singh 5 2019-01-31 90 73,942 -435,408 CGI Inc. Deferred Stock Unit Bouchard, Alain 4 2019-10-24 56 101.73 18,782 516 (DSUs) / Unités d'actions différées UAD CGI Inc. Deferred Stock Unit Brochu, Sophie 4 2019-10-24 56 101.73 861 516 (DSUs) / Unités d'actions différées UAD CGI Inc. Deferred Stock Unit Doré, Paule 4 2019-10-24 56 101.73 12,267 258 (DSUs) / Unités d'actions différées UAD CGI Inc. Deferred Stock Unit Evans, Richard B. 4 2019-10-24 56 101.73 32,243 678 (DSUs) / Unités d'actions différées UAD CGI Inc. Deferred Stock Unit Hearn, Timothy James 4 2019-10-24 56 101.73 7,187 308 (DSUs) / Unités d'actions différées UAD CGI Inc. Deferred Stock Unit Labbé, Gilles 4 2019-10-24 56 101.73 27,525 565 (DSUs) / Unités d'actions différées UAD CGI Inc. Deferred Stock Unit Pedersen, Mike 4 2019-10-24 56 101.73 6,166 516 (DSUs) / Unités d'actions différées UAD CGI Inc. Deferred Stock Unit Roach, Michael 4 2019-10-24 56 101.73 4,076 258 (DSUs) / Unités d'actions différées UAD CGI Inc. Deferred Stock Unit Waller, Kathy Nadine 4 2019-10-24 56 101.73 2,320 679 (DSUs) / Unités d'actions différées UAD Chemesis International Inc. Options Rosenberg, Joshua James 4 2019-09-17 00 CIBT Education Group Inc. Common Shares CIBT Education Group Inc 1 2019-10-25 10 0.67 2,624,500 1,000 CIBT Education Group Inc. Common Shares CIBT Education Group Inc 1 2019-10-28 10 0.67 2,632,000 7,500 CIBT Education Group Inc. Common Shares CIBT Education Group Inc 1 2019-10-29 10 0.6707 2,639,500 7,500 CIBT Education Group Inc. Common Shares CIBT Education Group Inc 1 2019-10-30 10 0.68 2,647,000 7,500 CIBT Education Group Inc. Common Shares CIBT Education Group Inc 1 2019-10-31 10 0.65 2,654,500 7,500 CIBT Education Group Inc. Common Shares Weir, Shane 4 2019-10-30 10 0.68 1,130,000 -3,500 CIBT Education Group Inc. Common Shares Weir, Shane 4 2019-10-30 10 0.68 1,129,000 -1,000 Citation Growth Corp. Common Shares Misle, Howard Nathan 5 2019-08-06 00 Citation Growth Corp. Common Shares Misle, Howard Nathan 5 2019-10-30 16 0.3 1,961,250 1,961,250 Citation Growth Corp. Warrants Misle, Howard Nathan 5 2019-08-06 00 Citation Growth Corp. Warrants Misle, Howard Nathan 5 2019-10-30 16 0.6 980,625 980,625 Cloud Nine Education Group Options Larson, Dalton Leroy 4 2019-10-25 50 0.12 125,000 45,000 Ltd. Cloud Nine Education Group Common Shares Lee, Peter 4 2019-10-29 11 38,667 -233,333 Ltd. Cloud Nine Education Group Options Lee, Peter 4 2019-10-25 50 0.12 105,000 45,000 Ltd. Cloud Nine Education Group Options Sandher, Kulwant 4 2019-10-25 50 0.12 110,000 75,000 Ltd. Co-operators General Preferred Shares Class A Daniel, Kevin 7 2019-11-01 30 100 1,809 1 Insurance Company Series B Co-operators General Preferred Shares Class A Hanna, Paul 7 2019-11-01 30 100 1,006 1 Insurance Company Series B CO2 Solutions Inc. Options Lavoie, Jérémie 5 2019-10-27 52 436,250 -181,250 COLLIERS Options McLernon, C.R. 2 2019-10-31 50 66.02 20,000 20,000 INTERNATIONAL GROUP INC. Colonial Coal International Common Shares Emri, David 3 2019-10-25 10 0.23 8,126,000 10,000 Corp. Colonial Coal International Common Shares Emri, David 3 2019-10-28 10 0.23 8,136,000 10,000 Corp. Cominar Real Estate Parts incessibles Commisso, Osvaldo 5 2019-10-29 57 13.4 1,182 -507 Investment Trust
November 7, 2019 (2019), 42 OSCB 8701
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Cominar Real Estate Parts incessibles Commisso, Osvaldo 5 2019-10-29 35 12.22 1,204 22 Investment Trust Cominar Real Estate Trust Units Commisso, Osvaldo 5 2019-10-29 57 13.4 22,418 507 Investment Trust Computer Modelling Group Common Shares Miller, Mark Robert 4 2019-10-23 00 Ltd. Constellation Software Inc. Common Shares Leonard, Mark Henri 4, 5 2019-10-28 30 1302.5 2,600 -100 COPPER REEF MINING Common Shares Kendall, David Wayne 5 2019-10-28 10 0.035 3,750,000 200,000 CORPORATION Copperbank Resources Common Shares Kovacevic, John Gianni 4, 5 2019-10-29 10 0.045 18,316,815 100,000 Corp. Copperbank Resources Common Shares Ricci, Antonio 4, 5 2019-11-01 10 0.05 1,740,000 40,000 Corp. CordovaCann Corp. Options Nienhuis, Nathan William 4, 5 2017-11-22 00 (formerly LiveReel Media Corporation) CordovaCann Corp. Options Nienhuis, Nathan William 4, 5 2018-01-16 11 150,000 150,000 (formerly LiveReel Media Corporation) CordovaCann Corp. Options Nienhuis, Nathan William 4, 5 2018-03-09 11 300,000 150,000 (formerly LiveReel Media Corporation) CordovaCann Corp. Warrants Nienhuis, Nathan William 4, 5 2017-11-01 11 3,000,000 3,000,000 (formerly LiveReel Media Corporation) CordovaCann Corp. Warrants Nienhuis, Nathan William 4, 5 2017-11-22 00 (formerly LiveReel Media Corporation) CordovaCann Corp. Warrants Nienhuis, Nathan William 4, 5 2018-03-09 11 4,500,000 1,500,000 (formerly LiveReel Media Corporation) Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-01 38 5.5807 1,703,200 216,800 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-02 38 5.3833 1,927,900 224,700 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-03 38 5.2993 2,156,200 228,300 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-04 38 5.3503 2,382,300 226,100 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-04 38 949,100 -1,433,200 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-07 38 5.3695 1,174,400 225,300 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-08 38 5.1824 1,407,800 233,400 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-09 38 5.07 1,646,400 238,600 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-10 38 4.9802 1,889,300 242,900 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-11 38 5.0996 2,126,500 237,200 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-11 38 974,800 -1,151,700 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-15 38 5.1781 1,208,400 233,600 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-16 38 5.1726 1,442,300 233,900 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-17 38 5.0902 1,680,000 237,700 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-18 38 5.0142 1,921,300 241,300 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-18 38 973,700 -947,600 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-21 38 5.1026 1,210,800 237,100 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-22 38 5.2481 1,441,300 230,500 Corp.
November 7, 2019 (2019), 42 OSCB 8702
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-23 38 5.2947 1,669,800 228,500 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-24 38 5.3145 1,897,400 227,600 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-25 38 5.3048 2,125,400 228,000 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-25 38 950,300 -1,175,100 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-28 38 5.2917 1,181,400 231,100 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-29 38 5.2782 1,413,100 231,700 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-30 38 5.2267 1,646,900 233,800 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-31 38 4.8172 1,901,400 254,500 Corp. Crescent Point Energy Corp. Common Shares Crescent Point Energy 1 2019-10-31 38 983,000 -918,400 Corp. Crown Capital Partners Inc. Common Shares Crown Capital Partners Inc. 1 2019-10-31 10 7.3299 2,555 2,555 Crystal Peak Minerals Inc. Common Shares Voting Basse, Daniel William 4 2019-10-29 10 0.125 1,834,882 14,500 Currency Exchange Options August, Joseph Andrade 4 2019-10-23 50 28,859 8,952 International, Corp. Currency Exchange Options Bezhitashvili, Khatuna 5 2019-10-23 50 19,277 11,393 International, Corp. Currency Exchange Options Bhavsar, Chirag 4 2019-10-23 50 28,859 8,952 International, Corp. Jashvantlal Currency Exchange Options Bracy, Wade Alan 5 2019-10-23 50 56,094 21,240 International, Corp. Currency Exchange Options Brossard, Johanne 4 2019-10-23 50 14,711 8,952 International, Corp. Currency Exchange Options FISCHBACH, JAY 5 2019-10-23 50 15,643 8,955 International, Corp. STEVEN Currency Exchange Options Fitzpatrick, Stephen 5 2019-10-23 50 54,877 26,925 International, Corp. Michael Currency Exchange Options Kohli, Chitwant 7 2019-10-23 50 13,595 8,952 International, Corp. Currency Exchange Options Lahar, Shivani 5 2019-10-23 50 14,687 8,968 International, Corp. Currency Exchange Options McDougall, Jennifer Islay 7 2019-10-23 50 32,153 19,154 International, Corp. Currency Exchange Options Mickleborough, Mark 4 2019-10-23 50 8,952 International, Corp. Douglas Currency Exchange Options Mickleborough, Mark 4 2019-10-23 50 8,952 International, Corp. Douglas Currency Exchange Options Mickleborough, Mark 4 2019-10-23 50 24,835 8,952 International, Corp. Douglas Currency Exchange Options Ohm, Paul Christian 5 2019-10-23 50 12,207 International, Corp. Currency Exchange Options Ohm, Paul Christian 5 2019-10-23 50 24,328 12,207 International, Corp. Currency Exchange Options Pinna, Randolph W. 3, 4, 5 2019-10-23 50 169,542 63,477 International, Corp. Currency Exchange Options Sardo, Vincent James 4 2019-10-23 50 24,835 8,952 International, Corp. Currency Exchange Options Schillo, Matthew Alan 5 2019-10-23 50 53,612 18,229 International, Corp. Currency Exchange Options Yeo, Daryl Edward 4 2019-10-23 50 8,952 8,952 International, Corp. Currency Exchange Options Yeo, Daryl Edward 4 2019-10-23 50 14,789 5,837 International, Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-10-28 10 0.095 64,500 17,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-10-29 10 0.095 78,000 13,500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-10-29 10 0.1 88,000 10,000 Corp.
November 7, 2019 (2019), 42 OSCB 8703
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-10-29 10 0.1 93,000 5,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-10-29 10 0.1 98,000 5,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-10-29 10 0.095 101,000 3,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-10-29 10 0.11 151,000 50,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-10-30 10 0.095 156,000 5,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-11-01 10 0.095 157,000 1,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-11-01 10 0.095 172,000 15,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-11-01 10 0.095 177,000 5,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2019-11-01 10 0.095 192,000 15,000 Corp. Cymat Technologies Ltd. Common Shares Deyannis, Angie 5 2019-10-25 51 84,333 50,217 Cymat Technologies Ltd. Options Deyannis, Angie 5 2019-10-25 51 0.185 593,333 -50,217 Cymat Technologies Ltd. Common Shares Gill, Jon David 4 2019-10-28 51 77,200 50,000 Cymat Technologies Ltd. Options Gill, Jon David 4 2019-10-28 51 0.185 250,000 -50,000 CYNTAR VENTURES INC. Options Carlson, Gerald George 4 2019-10-28 52 0.1 0 -150,000 CYNTAR VENTURES INC. Options Chew, Harry 4, 5 2019-10-28 97 0 -400,000 CYNTAR VENTURES INC. Options Chew, Sonny 4, 5 2019-10-28 97 0 -250,000 Datable Technology Common Shares Oishi, Kim 4 2019-10-24 10 0.0339 6,072,000 50,000 Corporation (formerly 3TL Technologies Corp.) DECISIVE DIVIDEND Rights Restricted Share Campbell, Michael Bruce 4 2013-07-02 00 CORPORATION Unit DECISIVE DIVIDEND Rights Restricted Share Campbell, Michael Bruce 4 2019-10-24 56 5,000 5,000 CORPORATION Unit DECISIVE DIVIDEND Rights Restricted Share Conway, Michael 4 2013-07-02 00 CORPORATION Units DECISIVE DIVIDEND Rights Restricted Share Conway, Michael 4 2019-10-24 56 5,000 5,000 CORPORATION Units DECISIVE DIVIDEND Rights Restricted Share Matheos, Warren Frederick 4 2013-07-02 00 CORPORATION Units DECISIVE DIVIDEND Rights Restricted Share Matheos, Warren Frederick 4 2019-10-24 56 5,000 5,000 CORPORATION Units DECISIVE DIVIDEND Common Shares Paterson, James Andrew 4, 5 2019-10-24 56 15,000 CORPORATION DECISIVE DIVIDEND Common Shares Paterson, James Andrew 4, 5 2019-10-24 56 15,000 CORPORATION DECISIVE DIVIDEND Rights restricted share Paterson, James Andrew 4, 5 2013-07-02 00 CORPORATION unit DECISIVE DIVIDEND Rights restricted share Paterson, James Andrew 4, 5 2019-10-24 56 15,000 15,000 CORPORATION unit Delphi Energy Corp. Common Shares Luminus Delphi Holdings II 3 2019-10-21 00 43,194,030 Ltd. Delphi Energy Corp. Subscription Rights Luminus Delphi Holdings II 3 2019-10-21 00 16,778,306 Equity Subscription Ltd. Receipts DHX Media Ltd. Rights (Common Voting) Ames, Aaron 5 2018-04-18 00 DHX Media Ltd. Rights (Common Voting) Ames, Aaron 5 2019-10-23 56 1.67 25,000 25,000 DHX Media Ltd. Rights (Common Voting) Colville, David Cameron 4 2014-05-16 00 DHX Media Ltd. Rights (Common Voting) Colville, David Cameron 4 2014-05-16 00 DHX Media Ltd. Rights (Common Voting) Colville, David Cameron 4 2019-10-23 56 1.67 12,500 12,500 DHX Media Ltd. Rights (Common Voting) Drisdell, Deborah Ann 4 2015-12-16 00 DHX Media Ltd. Rights (Common Voting) Drisdell, Deborah Ann 4 2019-10-23 56 1.67 33,400 33,400 DHX Media Ltd. Rights (Variable Voting) Ellenbogen, Eric 4 2018-12-18 00 DHX Media Ltd. Rights (Variable Voting) Ellenbogen, Eric 4 2019-10-23 56 1.67 50,000 50,000 DHX Media Ltd. Rights (Common Voting) Gosine, Mark Gregory 5 2006-12-15 00 DHX Media Ltd. Rights (Common Voting) Gosine, Mark Gregory 5 2019-10-23 56 1.67 70,149 70,149 DHX Media Ltd. Rights (Common Voting) Hibben, Alan Roy 4 2018-03-23 00
November 7, 2019 (2019), 42 OSCB 8704
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed DHX Media Ltd. Rights (Common Voting) Hibben, Alan Roy 4 2019-10-23 56 1.67 35,000 35,000 DHX Media Ltd. Rights (Common Voting) Lamb, Douglas Edward 5 2018-02-26 00 John DHX Media Ltd. Rights (Common Voting) Lamb, Douglas Edward 5 2019-10-23 56 1.67 20,000 20,000 John DHX Media Ltd. Rights (Common Voting) Loi, Anne H. 5 2018-04-18 00 DHX Media Ltd. Rights (Common Voting) Loi, Anne H. 5 2019-10-23 56 1.67 218,525 218,525 DHX Media Ltd. Rights (Common Voting) Machum, Donald Geoffrey 4 2014-05-16 00 DHX Media Ltd. Rights (Common Voting) Machum, Donald Geoffrey 4 2019-10-23 56 1.67 135,065 135,065 DHX Media Ltd. Rights (Common Voting) Regan, David A. 5 2006-05-1500 DHX Media Ltd. Rights (Common Voting) Regan, David A. 5 2019-10-23 56 1.67 93,191 93,191 DHX Media Ltd. Rights (Common Voting) Regan, David A. 5 2006-05-1500 DHX Media Ltd. Rights (Common Voting) Regan, David A. 5 2019-10-23 56 1.67 7,000 7,000 DHX Media Ltd. Rights (Common Voting) Scherba, Joshua Charles 5 2018-04-18 00 DHX Media Ltd. Rights (Common Voting) Scherba, Joshua Charles 5 2019-10-23 56 1.67 91,544 91,544 DHX Media Ltd. Rights (Common Voting) Tedesco, Joseph 5 2014-07-3100 DHX Media Ltd. Rights (Common Voting) Tedesco, Joseph 5 2019-10-23 56 1.67 6,152 6,152 Diamond Estates Wines & Common Shares Lassonde Industries Inc. 3 2019-10-30 11 0.19 38,478,947 1,578,947 Spirits Inc. Diamond Estates Wines & Common Shares Oakwest Corporation 3 2019-10-30 11 0.19 28,732,182 1,315,800 Spirits Inc. Limited Diamond Estates Wines & Common Shares Oakwest Corporation 3 2019-10-30 51 0.12 30,732,182 2,000,000 Spirits Inc. Limited Diamond Estates Wines & Options Oakwest Corporation 3 2013-09-24 00 Spirits Inc. Limited Diamond Estates Wines & Options Oakwest Corporation 3 2014-11-10 50 0.12 2,000,000 2,000,000 Spirits Inc. Limited Diamond Estates Wines & Options Oakwest Corporation 3 2019-10-30 51 0.12 0 -2,000,000 Spirits Inc. Limited Digital Consumer Dividend Trust Units Brasseur, Jeremy 6 2019-10-28 10 9.2727 31,000 5,500 Fund Digital Consumer Dividend Trust Units Brasseur, Jeremy 6 2019-10-29 10 9.3782 33,200 2,200 Fund Digital Consumer Dividend Trust Units Brasseur, Jeremy 6 2019-10-30 10 9.35 35,700 2,500 Fund Digital Consumer Dividend Trust Units Digital Consumer Dividend 1 2019-10-25 38 9.35 221,800 8,300 Fund Fund Digital Consumer Dividend Trust Units Digital Consumer Dividend 1 2019-10-28 38 9.2894 226,700 4,900 Fund Fund Digital Consumer Dividend Trust Units Digital Consumer Dividend 1 2019-10-29 38 9.1982 230,500 3,800 Fund Fund Digital Consumer Dividend Trust Units Digital Consumer Dividend 1 2019-10-30 38 9.21 232,400 1,900 Fund Fund Digital Consumer Dividend Trust Units Digital Consumer Dividend 1 2019-10-31 38 9.5005 234,300 1,900 Fund Fund Dollarama Inc. Common Shares Assaly, John 7 2019-10-28 10 45.08 7,526 -32,000 E Split Corp. Preferred Shares Brasseur, Jeremy 6 2019-10-29 10 10.208 5,900 2,500 Earth Alive Clean Common Shares Blais, Jean Paul 5 2019-10-28 15 0.1 500,000 300,000 Technologies Inc. Earth Alive Clean Warrants Expiring Blais, Jean Paul 5 2017-12-19 00 3,200,000 Technologies Inc. October 11, 2022 Earth Alive Clean Common Shares Groupe Lune Rouge Inc. 3 2019-10-28 15 0.1 33,840,347 Technologies Inc. Earth Alive Clean Common Shares Groupe Lune Rouge Inc. 3 2019-10-28 15 0.1 37,978,572 15,000,000 Technologies Inc. Earth Alive Clean Common Shares Groupe Lune Rouge Inc. 3 2019-10-28 36 0.1 56,818,919 18,840,347 Technologies Inc. Earth Alive Clean Convertible Debentures Groupe Lune Rouge Inc. 3 2019-10-28 15 -$1,500,000 Technologies Inc. 15% Maturité 11 octobre 2019 Earth Alive Clean Convertible Debentures Groupe Lune Rouge Inc. 3 2019-10-28 36 $0 -$1,500,000 Technologies Inc. 15% Maturité 11 octobre 2019 Earth Alive Clean Warrants Groupe Lune Rouge Inc. 3 2019-10-28 15 0.25 16,750,000 15,000,000 Technologies Inc.
November 7, 2019 (2019), 42 OSCB 8705
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Earth Alive Clean Common Shares Laliberté, Guy 3 2019-10-28 15 0.1 33,840,347 Technologies Inc. Earth Alive Clean Common Shares Laliberté, Guy 3 2019-10-28 15 0.1 37,978,572 15,000,000 Technologies Inc. Earth Alive Clean Common Shares Laliberté, Guy 3 2019-10-28 36 0.1 56,818,919 18,840,347 Technologies Inc. Earth Alive Clean Convertible Debentures Laliberté, Guy 3 2019-10-28 15 -$1,500,000 Technologies Inc. 15% Maturité 11 octobre 2019 Earth Alive Clean Convertible Debentures Laliberté, Guy 3 2019-10-28 36 $0 -$1,500,000 Technologies Inc. 15% Maturité 11 octobre 2019 Earth Alive Clean Warrants Laliberté, Guy 3 2019-10-28 15 0.25 16,750,000 15,000,000 Technologies Inc. Earth Alive Clean Common Shares Patterson, WAYNE Todd 4 2019-10-28 15 0.1 220,000 200,000 Technologies Inc. Earth Alive Clean Warrants Patterson, WAYNE Todd 4 2019-06-27 00 200,000 Technologies Inc. EarthRenew Inc. (Formerly Options Atin, Aaron 5 2019-10-25 50 0.06 300,000 200,000 known as Valencia Ventures Inc.) EarthRenew Inc. (Formerly Options Best, Christopher William 4 2019-10-25 50 0.06 300,000 100,000 known as Valencia Ventures Inc.) EarthRenew Inc. (Formerly Options Driver, Keith 5 2019-10-25 50 0.06 600,000 400,000 known as Valencia Ventures Inc.) EarthRenew Inc. (Formerly Options Ptolemy, Ryan Jeffery 5 2019-10-25 50 0.06 700,000 300,000 known as Valencia Ventures Inc.) EarthRenew Inc. (Formerly Options Stretch, Catherine 4 2019-10-25 50 0.06 1,190,000 400,000 known as Valencia Ventures Inc.) East Coast Investment Units Arrow Capital Management 7 2019-11-01 10 9.3 986,200 -2,900 Grade Income Fund Inc. Eastmain Resources Inc. Common Shares Curtis, Laurence Wilson 4 2019-10-24 16 0.12 790,000 100,000 Eastmain Resources Inc. Warrants Curtis, Laurence Wilson 4 2019-10-24 16 0.16 100,000 50,000 Eastmain Resources Inc. Common Shares Lemasson, Claude 4, 5 2019-10-24 16 0.12 3,809,460 416,667 Eastmain Resources Inc. Warrants Lemasson, Claude 4, 5 2015-11-10 00 Eastmain Resources Inc. Warrants Lemasson, Claude 4, 5 2019-10-24 16 0.16 208,333 208,333 Eastmain Resources Inc. Common Shares Lendon, Heather Maura 4 2019-10-24 16 0.12 366,667 166,667 Eastmain Resources Inc. Warrants Lendon, Heather Maura 4 2019-10-24 16 0.16 158,333 83,333 Eastmain Resources Inc. Common Shares Schultz, Blair 4 2019-10-24 16 0.12 647,500 Eastmain Resources Inc. Common Shares Schultz, Blair 4 2019-10-24 16 0.12 400,000 200,000 Eastmain Resources Inc. Warrants Schultz, Blair 4 2016-04-28 00 Eastmain Resources Inc. Warrants Schultz, Blair 4 2019-10-24 16 0.16 100,000 100,000 Emerald Bay Energy Inc. Common Shares Rice, Michael 5 2019-10-28 10 0.01 11,728,178 3,032,678 Encana Corporation Common Shares Mayson, Howard John 4 2019-11-01 10 3.9843 55,488 5,000 Encana Corporation Common Shares Mayson, Howard John 4 2019-11-01 10 3.9382 60,488 5,000 Encana Corporation Common Shares Nimocks, Suzanne Paquin 4 2019-11-01 10 3.93 41,684 6,000 Encana Corporation Common Shares Ricks, Thomas Gregory 4 2019-11-01 10 3.9599 258,657 62,500 Encana Corporation Common Shares Suttles, Douglas James 4, 5 2019-11-01 10 3.92 241,677 12,500 Endurance Gold Corporation Common Shares Boyd, Robert T. 4, 5 2019-10-30 10 0.035 1,580,000 6,000 Endurance Gold Corporation Common Shares Boyd, Robert T. 4, 5 2019-10-31 10 0.035 1,585,000 5,000 Endurance Gold Corporation Common Shares Boyd, Robert T. 4, 5 2019-11-01 10 0.035 1,590,000 5,000 Epsilon Energy Ltd. Common Shares Epsilon Energy Ltd. 1 2019-10-25 38 3.4633 396,537 150 Epsilon Energy Ltd. Common Shares Epsilon Energy Ltd. 1 2019-10-29 38 3.2794 401,337 4,800 EQ Inc. Common Shares Lobo, Vernon 4, 6 2019-10-29 47 2,305,673 -7,000 Equitable Group Inc. Common Shares Beutel, Eric Marshall 4, 6 2019-08-12 10 94.524 2,500 Equitable Group Inc. Common Shares Beutel, Eric Marshall 4, 6 2019-08-12 10 94.524 2,500 Erdene Resource Common Shares Byrne, John Philip 4 2019-10-25 11 0.2 5,975,929 250,000 Development Corporation Erdene Resource Warrants October 2019 Byrne, John Philip 4 2004-08-26 00 Development Corporation
November 7, 2019 (2019), 42 OSCB 8706
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Erdene Resource Warrants October 2019 Byrne, John Philip 4 2019-10-25 53 0.2 125,000 125,000 Development Corporation ESSA Pharma Inc. Common Shares BERGER, FRANKLIN 4 2019-10-31 10 4.6079 486,688 7,000 MILAN ESSA Pharma Inc. Options BERGER, FRANKLIN 4 2019-10-30 50 4.67 67,000 25,000 MILAN ESSA Pharma Inc. Options Brettman, Ari 1 2019-10-30 50 4.67 50,000 25,000 ESSA Pharma Inc. Options Glickman, Richard 4 2019-10-30 50 4.67 77,000 25,000 ESSA Pharma Inc. Options Martin, John Alexander 4 2019-10-30 50 4.67 50,000 25,000 ESSA Pharma Inc. Options Requadt, Scott 4 2019-10-30 50 4.67 67,000 25,000 ESSA Pharma Inc. Options Sollis, Gary Ralph 4 2019-10-30 50 4.67 67,000 25,000 ESSA Pharma Inc. Options Thorell, Ann Marella 4 2019-10-30 50 4.67 50,000 25,000 ESSA Pharma Inc. Common Shares Wood, David Sidney 5 2019-10-31 10 450 14,185 100 ESSA Pharma Inc. Common Shares Wood, David Sidney 5 2019-11-01 10 4.5 16,485 2,300 ESSA Pharma Inc. Options Zweifach, Sanford 4 2019-10-30 50 4.67 50,000 25,000 Eurolife Brands Inc. Common Shares Moniz, Shawn 3, 4, 5 2019-10-28 10 0.095 38,834,739 100,000 European Focused Dividend Trust Units European Focused 1 2019-10-25 38 8.01 1,032,400 600 Fund Dividend Fund European Focused Dividend Trust Units European Focused 1 2019-10-29 38 7.9971 1,033,100 700 Fund Dividend Fund European Focused Dividend Trust Units European Focused 1 2019-10-30 38 7.9082 1,036,500 3,400 Fund Dividend Fund European Focused Dividend Trust Units European Focused 1 2019-10-31 38 7.8671 1,040,000 3,500 Fund Dividend Fund Falcon Gold Corp. Common Shares Farley, James Donald 4 2019-10-31 10 0.035 2,199,400 100,000 Firan Technology Group Common Shares Crichton, James 5 2019-09-09 00 Corporation Firan Technology Group Common Shares Crichton, James 5 2019-10-23 10 3.55 135 135 Corporation Firan Technology Group Common Shares Crichton, James 5 2019-10-24 10 3.57 1,335 1,200 Corporation Firan Technology Group Common Shares Crichton, James 5 2019-10-25 10 3.59 5,900 4,565 Corporation FIRSTSERVICE Common Shares Patterson, D. Scott 4, 5 2019-10-28 51 23.96 1,005,262 60,000 CORPORATION FIRSTSERVICE Options Patterson, D. Scott 4, 5 2019-10-28 51 23.96 500,000 -60,000 CORPORATION FIRSTSERVICE Common Shares Rakusin, Jeremy Alan 5 2019-10-28 51 23.96 123,600 13,000 CORPORATION FIRSTSERVICE Options Rakusin, Jeremy Alan 5 2019-10-28 51 23.96 257,000 -13,000 CORPORATION Fort St. James Nickel Corp. Common Shares Brown, Barry Everett 4 2019-10-28 16 0.1 1,425,000 750,000 Fort St. James Nickel Corp. Warrants Brown, Barry Everett 4 2019-10-28 16 0.12 1,425,000 750,000 Fort St. James Nickel Corp. Common Shares Mitton, Gerald Alexander 3 2019-11-01 16 0.1 4,215,500 1,000,000 Fort St. James Nickel Corp. Warrants Mitton, Gerald Alexander 3 2019-11-01 16 0.12 1,400,000 1,000,000 FPX Nickel Corp. (formerly Common Shares Turenne, Martin Emery 5 2019-10-25 10 0.125 3,050,019 49,500 First Point Minerals Corp.) Joseph FPX Nickel Corp. (formerly Common Shares Turenne, Martin Emery 5 2019-10-28 10 0.125 3,070,019 20,000 First Point Minerals Corp.) Joseph FRONTIER LITHIUM INC. Common Shares Didone, John Ralph 4 2019-10-29 10 0.21 200,000 10,000 FRONTIER LITHIUM INC. Common Shares Didone, John Ralph 4 2019-10-30 10 0.22 205,000 5,000 Future Farm Technologies Options Gildea, William 4, 1, 5 2019-10-24 50 0.065 2,127,500 1,065,000 Inc. G2 Goldfields Inc. Common Shares Noone, Daniel Joseph 4 2019-10-28 54 0.2 4,517,500 200,000 G2 Goldfields Inc. Warrants Noone, Daniel Joseph 4 2019-07-19 54 2,067,500 -500,000 G2 Goldfields Inc. Warrants Noone, Daniel Joseph 4 2019-10-28 54 1,867,500 -200,000 G2 Goldfields Inc. Warrants Noone, Daniel Joseph 4 2019-07-19 54 -500,000 Galway Metals Inc. Common Shares Hinchcliffe, Robert 3, 4, 5 2019-10-25 10 0.29 12,786,619 17,000 Galway Metals Inc. Common Shares Hinchcliffe, Robert 3, 4, 5 2019-10-28 10 0.28 12,829,619 43,000 Galway Metals Inc. Common Shares Hinchcliffe, Robert 3, 4, 5 2019-10-28 10 0.29 12,833,619 4,000 Galway Metals Inc. Common Shares Hinchcliffe, Robert 3, 4, 5 2019-10-28 10 0.3 12,858,619 25,000 Galway Metals Inc. Common Shares Hinchcliffe, Robert 3, 4, 5 2019-10-29 10 0.3 12,888,619 30,000 Galway Metals Inc. Common Shares Hinchcliffe, Robert 3, 4, 5 2019-10-29 10 0.295 12,949,119 60,500
November 7, 2019 (2019), 42 OSCB 8707
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Galway Metals Inc. Common Shares Hinchcliffe, Robert 3, 4, 5 2019-10-30 10 0.31 13,029,119 80,000 Galway Metals Inc. Common Shares Hinchcliffe, Robert 3, 4, 5 2019-10-31 10 0.31 13,069,119 40,000 Genesis Acquisition Corp. Options Danard, Karen 3, 4 2019-04-12 00 Genesis Acquisition Corp. Options Danard, Karen 3, 4 2019-10-30 50 60,833 60,833 Genesis Acquisition Corp. Options Hodgson, Eugene 4 2019-04-12 00 60,833 Genesis Acquisition Corp. Options McDougall, Jason Wayne 3, 4 2019-04-12 00 Genesis Acquisition Corp. Options McDougall, Jason Wayne 3, 4 2019-10-30 50 60,833 60,833 Genesis Acquisition Corp. Options Miller, Joseph 3, 4 2019-04-12 00 Genesis Acquisition Corp. Options Miller, Joseph 3, 4 2019-10-30 50 60,833 60,833 Genesis Acquisition Corp. Options Wilson, Charles Blair 4, 5 2019-04-11 00 Genesis Acquisition Corp. Options Wilson, Charles Blair 4, 5 2019-10-30 50 0.2 60,835 60,835 Genesis Acquisition Corp. Options Wilson, Kelly Janine 5 2019-04-12 00 Genesis Acquisition Corp. Options Wilson, Kelly Janine 5 2019-10-30 50 0.2 60,833 60,833 GENIUS METALS INC. Common Shares Goulet, Guy 5 2019-10-30 10 0.185 1,377,686 2,000 Geomega Resources Inc. Options Cayer, Alain 5 2019-10-23 50 0.155 150,000 Geomega Resources Inc. Options Cayer, Alain 5 2019-10-23 50 0.155 600,000 150,000 Geomega Resources Inc. Options Mugerman, Kiril 4, 5 2019-10-23 50 0.155 1,455,000 200,000 Getchell Gold Corp. Common Shares Wagener, William 4, 5 2019-10-29 10 0.14 250,055 10,000 GFG Resources Inc. Common Shares Johnson, Rick 5 2019-10-24 16 0.22 424,000 115,000 GFG Resources Inc. Common Shares Skanderbeg, Brian Neville 5 2019-10-24 16 0.22 4,282,437 363,637 GIGA Metals Corporation Common Shares Young, Leslie 5 2019-10-30 10 0.45 27,240 -25,000 Global Atomic Corporation Common Shares Roman, Stephen G. 4, 5 2019-10-25 10 0.45 4,846,584 38,000 Global Atomic Corporation Common Shares Roman, Stephen G. 4, 5 2019-10-25 10 0.46 4,863,584 17,000 Global Innovation Dividend Trust Units Global Innovation Dividend 1 2019-10-30 38 10.06 942,100 300 Fund Fund Global Innovation Dividend Trust Units Global Innovation Dividend 1 2019-10-31 38 9.9842 948,300 6,200 Fund Fund Global Real Estate & E- Trust Units Global Real Estate & E- 1 2019-10-28 38 10.785 403,400 1,100 Commerce Dividend Fund Commerce Dividend Fund Global Real Estate & E- Trust Units Global Real Estate & E- 1 2019-10-29 38 10.734 406,500 3,100 Commerce Dividend Fund Commerce Dividend Fund Global Real Estate & E- Trust Units Global Real Estate & E- 1 2019-10-30 38 10.788 410,100 3,600 Commerce Dividend Fund Commerce Dividend Fund Global Real Estate & E- Trust Units Global Real Estate & E- 1 2019-10-31 38 10.772 413,600 3,500 Commerce Dividend Fund Commerce Dividend Fund GlobeX Data Ltd. Common Shares Davis, Scott 5 2019-10-28 10 0.16 243,000 1,000 GlobeX Data Ltd. Common Shares Davis, Scott 5 2019-10-29 10 0.15 245,000 2,000 GlobeX Data Ltd. Common Shares Ghiai Chamlou, Alain 4, 5 2019-10-28 10 0.15 28,980,501 20,000 Mehdi GlobeX Data Ltd. Common Shares Ghiai Chamlou, Alain 4, 5 2019-10-29 15 0.15 28,985,501 5,000 Mehdi goeasy Ltd. (formerly, Deferred Share Unit Plan Appel, David Harry 4 2019-10-31 56 59.94 63,806 56 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Plan Basian, Karen 4 2019-10-31 56 59.94 22,143 56 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Plan Doniz, Susan 4 2019-10-31 56 59.94 4,434 56 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Plan Johnson, Donald Kenneth 3, 4 2019-10-31 56 59.94 72,677 56 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Plan Morrison, Sean 4 2019-10-31 56 59.94 9,174 56 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Plan Thomson, David J. 4 2019-10-31 56 59.94 27,119 56 easyhome Ltd.) Gran Colombia Gold Corp. 2024 Gold-Linked Notes De La Campa, Miguel 4, 5 2019-10-31 38 1 $730,351 -$51,789 Angel Gran Colombia Gold Corp. 2024 Gold-Linked Notes Iacono, Serafino 4, 5 2019-10-31 38 1 $6,528,567 -$462,935 Gran Colombia Gold Corp. 2024 Gold-Linked Notes Iacono, Serafino 4, 5 2019-11-01 10 1.049 $6,628,567 $100,000 Gran Colombia Gold Corp. 2024 Gold-Linked Notes Perez, Jaime 4 2019-10-31 38 1 $109,447 -$7,761 Granite Oil Corp. Common Shares Andrus, Kevin 4 2019-10-29 57 24,085 20,397 Granite Oil Corp. Performance Awards Andrus, Kevin 4 2019-10-29 57 0 -17,101 Granite Oil Corp. Common Shares Carrigy, Brendan Richard 4, 5 2019-10-29 57 1,102,619 20,397 Granite Oil Corp. Common Shares Carrigy, Brendan Richard 4, 5 2019-10-29 10 0.49 1,112,619 10,000
November 7, 2019 (2019), 42 OSCB 8708
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Granite Oil Corp. Common Shares Carrigy, Brendan Richard 4, 5 2019-10-29 10 0.47 1,122,619 10,000 Granite Oil Corp. Common Shares Carrigy, Brendan Richard 4, 5 2019-10-30 10 0.46 1,124,619 2,000 Granite Oil Corp. Common Shares Carrigy, Brendan Richard 4, 5 2019-10-31 10 0.46 1,127,619 3,000 Granite Oil Corp. Performance Awards Carrigy, Brendan Richard 4, 5 2019-10-29 57 0 -17,101 Granite Oil Corp. Common Shares Cheyne, Martin James 4, 5 2019-10-29 57 438,468 20,397 Granite Oil Corp. Performance Awards Cheyne, Martin James 4, 5 2019-10-29 57 0 -17,101 Granite Oil Corp. Common Shares Griffiths, Devon 5 2019-10-29 57 123,085 66,490 Christopher Granite Oil Corp. Performance Awards Griffiths, Devon 5 2019-10-29 57 0 -57,000 Christopher Granite Oil Corp. Common Shares Kabanuk, Michael Lyle 4, 5 2019-10-25 10 0.5 1,160,976 10,000 Granite Oil Corp. Common Shares Kabanuk, Michael Lyle 4, 5 2019-10-28 10 0.5 1,165,976 5,000 Granite Oil Corp. Common Shares Kabanuk, Michael Lyle 4, 5 2019-10-29 10 0.485 1,168,476 2,500 Granite Oil Corp. Common Shares Kabanuk, Michael Lyle 4, 5 2019-10-31 10 0.47 1,170,476 2,000 Granite Oil Corp. Common Shares Kabanuk, Michael Lyle 4, 5 2019-11-01 10 0.475 1,171,476 1,000 Granite Oil Corp. Common Shares Kabanuk, Michael Lyle 4, 5 2019-11-01 10 0.48 1,173,476 2,000 Granite Oil Corp. Performance Awards Kabanuk, Michael Lyle 4, 5 2019-10-29 59 0 -130,000 Granite Oil Corp. Common Shares Kenney, Daniel Ellis 5 2019-10-29 57 76,763 20,397 Granite Oil Corp. Performance Awards Kenney, Daniel Ellis 5 2019-10-29 57 0 -17,101 Granite Oil Corp. Common Shares Porter, Bradley Blair 4 2019-10-29 57 572,268 20,397 Granite Oil Corp. Performance Awards Porter, Bradley Blair 4 2019-10-29 57 0 -17,101 Great Bear Resources Ltd. Common Shares McEwen, Robert R. 3 2019-10-24 10 7.11 3,113,346 -31,400 Great Bear Resources Ltd. Common Shares McEwen, Robert R. 3 2019-10-25 10 7.01 3,044,746 -68,600 Great Bear Resources Ltd. Common Shares McEwen, Robert R. 3 2019-10-30 10 7.16 2,930,046 -114,700 Great Bear Resources Ltd. Common Shares McEwen, Robert R. 3 2019-10-31 10 7.02 2,752,246 -177,800 Great Bear Resources Ltd. Common Shares McEwen, Robert R. 3 2019-11-01 10 7.02 2,685,346 -66,900 Great Bear Resources Ltd. Common Shares Ramshaw, Douglas William 4 2019-10-25 51 0.23 257,241 20,000 Great Bear Resources Ltd. Common Shares Ramshaw, Douglas William 4 2019-10-25 10 7.01 247,241 -10,000 Great Bear Resources Ltd. Common Shares Ramshaw, Douglas William 4 2019-10-28 10 6.8 242,241 -5,000 Great Bear Resources Ltd. Common Shares Ramshaw, Douglas William 4 2019-10-30 10 6.993 237,241 -5,000 Great Bear Resources Ltd. Options Ramshaw, Douglas William 4 2019-10-25 51 0.23 311,500 -20,000 Guerrero Ventures Inc. Common Shares Medalist Capital Ltd. 3 2019-10-18 00 5,853,220 Hamilton Thorne Ltd. Common Shares Wolf, David 4, 5 2019-11-01 10 1.05 1,386,236 -250,000 Hammond Power Solutions Common Shares Class A MACADAM, DON 4 2019-10-28 10 8 12,600 -10,000 Inc. Hammond Power Solutions Common Shares Class A MACADAM, DON 4 2019-10-30 51 6.62 17,600 5,000 Inc. Hammond Power Solutions Options Plan July 22 MACADAM, DON 4 2019-10-30 51 6.62 15,000 -5,000 Inc. 2005 Harrys Manufacturing Inc. Common Shares Dhesi, Harinder Singh 3, 4 2019-10-15 38 5,166,700 -3,000,000 (formerly, Westridge Resources Inc.) Harrys Manufacturing Inc. Common Shares kohanik, kevin 3, 4, 5 2019-06-06 11 0.05 8,366,699 200,000 (formerly, Westridge Resources Inc.) Harrys Manufacturing Inc. Common Shares kohanik, kevin 3, 4, 5 2019-10-15 38 6,366,699 -2,000,000 (formerly, Westridge Resources Inc.) HEXO Corp. Options Burwash, Stephen, Harry, 5 2019-10-29 50 3.3 402,899 77,899 Donald HEXO Corp. Options Burwash, Stephen, Harry, 5 2019-10-29 50 542,104 139,205 Donald HEXO Corp. Options Courtney, Donald, Joseph 5 2019-10-29 50 3.3 402,899 77,899 HEXO Corp. Options Courtney, Donald, Joseph 5 2019-10-29 50 542,104 139,205 HEXO Corp. Options Hamel, Veronique 5 2019-10-29 50 3.3 375,428 50,428 HEXO Corp. Options Hamel, Veronique 5 2019-10-29 50 465,542 90,114 HEXO Corp. Options Jones, Dominique Claude 5 2019-10-29 50 3.3 382,041 57,041 HEXO Corp. Options Jones, Dominique Claude 5 2019-10-29 50 483,973 101,932 HEXO Corp. Options St-Louis, Sebastien G. 5 2019-10-29 50 3.3 5,869,142 508,726 HEXO Corp. Options St-Louis, Sebastien G. 5 2019-10-29 50 6,725,203 856,061 HEXO Corp. Options Vaillancourt, Roch 5 2019-10-29 50 3.3 557,041 57,041 HEXO Corp. Options Vaillancourt, Roch 5 2019-10-29 50 658,973 101,932
November 7, 2019 (2019), 42 OSCB 8709
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Hudson's Bay Company Common Shares Catalyst Capital Group Inc. 3 2019-08-21 00 29,431,738 Hudson's Bay Company Common Shares Catalyst Capital Group Inc. 3 2019-10-31 10 32,326,878 2,895,140 Hudson's Bay Company Common Shares Record, Edward 5 2019-10-29 57 10 44,494 19,249 Hudson's Bay Company Common Shares Record, Edward 5 2019-10-29 57 10 37,954 -6,540 Hudson's Bay Company Restricted Share Units Record, Edward 5 2019-10-29 57 10 229,212 -19,249 IBC Advanced Alloys Corp. Common Shares Smith, Mark 4 2019-10-29 51 0.4 3,562,659 50,000 IBC Advanced Alloys Corp. Common Shares Smith, Mark 4 2019-10-29 54 0.5 3,732,067 169,408 IBC Advanced Alloys Corp. Options Smith, Mark 4 2019-10-29 51 0.4 50,000 -50,000 IBC Advanced Alloys Corp. Warrants Smith, Mark 4 2019-07-12 55 0.45 -44,666 IBC Advanced Alloys Corp. Warrants Smith, Mark 4 2019-07-12 55 0.45 -44,666 IBC Advanced Alloys Corp. Warrants Smith, Mark 4 2019-10-29 54 0.5 1,497,258 -169,408 Igen Networks Corp. Common Shares Chan, Neil 4 2019-10-28 10 0.04 1,848,111 5,000 Igen Networks Corp. Common Shares Chan, Neil 4 2019-10-29 10 0.03 1,868,111 20,000 Igen Networks Corp. Common Shares Chan, Neil 4 2019-10-31 10 0.033 1,943,111 75,000 Igen Networks Corp. Common Shares Chan, Neil 4 2019-10-31 10 0.038 1,948,111 5,000 IGM Financial Inc. Executive Performance Asman, Todd 7 2019-10-31 30 37.17 8,421 125 Share Units IGM Financial Inc. Restricted Share Units Asman, Todd 7 2019-10-31 30 37.17 2,198 33 IGM Financial Inc. Executive Performance Bast, Esther 7 2019-10-31 30 37.17 2,908 43 Share Units IGM Financial Inc. Restricted Share Units Bast, Esther 7 2019-10-31 30 37.17 2,341 34 IGM Financial Inc. Senior Executive Share Bast, Esther 7 2019-10-31 30 37.17 14,405 215 Units IGM Financial Inc. Executive Performance Carney, Jeffrey 4, 5 2019-10-31 30 37.17 98,063 1,462 Share Units IGM Financial Inc. Senior Executive Share Carney, Jeffrey 4, 5 2019-10-31 30 37.17 10,241 152 Units IGM Financial Inc. Executive Performance Dibden, Michael William 7 2019-10-31 30 37.17 15,683 234 Share Units IGM Financial Inc. Restricted Share Units Dibden, Michael William 7 2019-10-31 30 37.17 6,273 94 IGM Financial Inc. Executive Performance Elavia, Tony 7 2019-10-31 30 37.17 22,249 332 Share Units IGM Financial Inc. Restricted Share Units Elavia, Tony 7 2019-10-31 30 37.17 16,661 249 IGM Financial Inc. Senior Executive Share Elavia, Tony 7 2019-10-31 30 37.17 4,495 67 Units IGM Financial Inc. Executive Performance Goldberg, Rhonda 5 2019-10-31 30 37.17 6,090 91 Share Units IGM Financial Inc. Restricted Share Units Goldberg, Rhonda 5 2019-10-31 30 37.17 2,333 35 IGM Financial Inc. Executive Performance Gould, J. Luke 5 2019-10-31 30 37.17 10,368 155 Share Units IGM Financial Inc. Restricted Share Units Gould, J. Luke 5 2019-10-31 30 37.17 3,517 52 IGM Financial Inc. Executive Performance Kinzel, Mark Richard 7 2019-10-31 30 37.17 12,064 180 Share Units IGM Financial Inc. Restricted Share Units Kinzel, Mark Richard 7 2019-10-31 30 37.17 3,154 47 IGM Financial Inc. Executive Performance Lawrence, Ian 7 2019-10-31 30 37.17 3,184 48 Share Units IGM Financial Inc. Restricted Share Units Lawrence, Ian 7 2019-10-31 30 37.17 1,912 28 IGM Financial Inc. Executive Performance McInerney, Barry 7 2019-10-31 30 37.17 81,417 1,213 Share Units IGM Financial Inc. Executive Performance Milne, Douglas 7 2019-10-31 30 37.17 5,315 80 Share Units IGM Financial Inc. Restricted Share Units Milne, Douglas 7 2019-10-31 30 37.17 2,126 32 IGM Financial Inc. Executive Performance Sen, Subhas 7 2019-10-31 30 37.17 5,125 77 Share Units IGM Financial Inc. Restricted Share Units Sen, Subhas 7 2019-10-31 30 37.17 2,063 31 IGM Financial Inc. Executive Performance Shewchuk, Blaine 7 2019-10-31 30 37.17 5,943 88 Share Units IGM Financial Inc. Restricted Share Units Shewchuk, Blaine 7 2019-10-31 30 37.17 2,138 31 IGM Financial Inc. Senior Executive Share Tretiak, Gregory Dennis 4, 6 2019-10-31 30 37.17 8,891 133 Units
November 7, 2019 (2019), 42 OSCB 8710
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Imagination Park Common Shares Inwentash, Sheldon 4, 6 2019-10-24 10 0.05 2,611,000 21,000 Technologies Inc. (formerly Imagination Park Entertainment Inc.) Imagination Park Common Shares Inwentash, Sheldon 4, 6 2019-10-25 10 0.05 2,626,000 15,000 Technologies Inc. (formerly Imagination Park Entertainment Inc.) IMAX Corporation Common Shares IMAX Corporation 1 2019-10-31 30 71,567 -97 Imperial Oil Limited Common Shares Exxon Mobil Corporation 3 2019-10-25 38 33.26 522,097,305 -108,550 Imperial Oil Limited Common Shares Exxon Mobil Corporation 3 2019-10-28 38 33.16 521,988,754 -108,551 Imperial Oil Limited Common Shares Exxon Mobil Corporation 3 2019-10-29 38 33.15 521,880,204 -108,550 Imperial Oil Limited Common Shares Exxon Mobil Corporation 3 2019-10-30 38 32.76 521,771,654 -108,550 Imperial Oil Limited Common Shares Exxon Mobil Corporation 3 2019-10-31 38 32.8 521,663,103 -108,551 Indiva Limited Common Shares Sutherland, Hugh Hamish 4 2017-12-13 00 Indiva Limited Common Shares Sutherland, Hugh Hamish 4 2019-09-17 10 0.3 100,000 100,000 InMed Pharmaceuticals Inc. Common Shares Mancini, Alexandra Diane 5 2019-10-28 10 0.26 158,000 10,000 Janet InMed Pharmaceuticals Inc. Common Shares Mancini, Alexandra Diane 5 2019-10-31 10 0.2468 166,500 8,500 Janet InMed Pharmaceuticals Inc. Common Shares Mancini, Alexandra Diane 5 2019-11-01 10 0.2456 200,000 33,500 Janet INV Metals Inc. Common Shares Dundee Precious Metals 3 2019-10-28 00 Inc. INV Metals Inc. Common Shares Dundee Precious Metals 3 2019-10-28 00 26,538,462 Inc. INV Metals Inc. Common Shares IAMGOLD Corporation 3 2019-10-28 16 0.4 48,482,871 13,889,880 Inventus Mining Corp. Common Shares Spears, Stephan Michael 6 2019-10-24 10 0.075 862,501 5,000 Seydegart Itasca Capital Ltd. Common Shares Fundamental Global 3 2019-10-28 10 0.35 3,839,502 1,974,113 Investors, LLC Itasca Capital Ltd. Common Shares Kingsway Financial 3 2019-10-30 11 0.35 3,011,447 -1,974,113 Services Josemaria Resources Inc. Common Shares Lorito Holdings S.à.r.l. 3 2019-11-01 11 24,580,000 80,000 Journey Energy Inc. Common Shares Boklaschuk, Brett 1 2019-10-24 57 2.15 137,534 50,830 Journey Energy Inc. Rights Performance Boklaschuk, Brett 1 2019-10-24 57 66,500 -22,500 Share Unit Journey Energy Inc. Rights Restricted Share Boklaschuk, Brett 1 2019-10-24 57 54,000 -52,750 Unit Journey Energy Inc. Common Shares Crone, Howard James 4 2019-10-24 57 2.15 62,146 15,637 Journey Energy Inc. Rights Restricted Share Crone, Howard James 4 2019-10-24 57 30,000 -22,500 Unit Journey Energy Inc. Common Shares Gilewicz, Gerald 5 2019-10-24 57 2.15 271,292 62,877 Journey Energy Inc. Common Shares Gilewicz, Gerald 5 2019-10-25 10 2 266,292 -5,000 Journey Energy Inc. Rights Performance Gilewicz, Gerald 5 2019-10-24 57 80,500 -27,500 Share Unit Journey Energy Inc. Rights Restricted Share Gilewicz, Gerald 5 2019-10-24 57 66,333 -65,917 Unit Journey Energy Inc. Common Shares Laustsen, Dana Bruce 4 2019-10-24 57 2.15 51,900 15,637 Journey Energy Inc. Rights Restricted Share Laustsen, Dana Bruce 4 2019-10-24 57 30,000 -22,500 Unit Journey Energy Inc. Common Shares Moore, Terry John 5 2019-10-24 57 2.15 261,881 50,830 Journey Energy Inc. Rights Performance Moore, Terry John 5 2019-10-24 57 66,500 -22,500 Share Unit Journey Energy Inc. Rights Restricted Share Moore, Terry John 5 2019-10-24 57 54,000 -52,750 Unit Journey Energy Inc. Common Shares Polini, Anthony Victor 5 2019-10-24 57 2.15 55,630 Journey Energy Inc. Common Shares Polini, Anthony Victor 5 2019-10-24 57 2.15 131,409 45,630 Journey Energy Inc. Common Shares Polini, Anthony Victor 5 2019-10-24 57 2.15 85,238 10,000 Journey Energy Inc. Rights Performance Polini, Anthony Victor 5 2019-10-24 57 66,500 -22,500 Share Unit Journey Energy Inc. Rights Restricted Share Polini, Anthony Victor 5 2019-10-24 57 54,000 -52,750 Unit Journey Energy Inc. Common Shares Shay, Ryan 4 2019-10-24 57 2.15 15,637 15,637
November 7, 2019 (2019), 42 OSCB 8711
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Journey Energy Inc. Rights Restricted Share Shay, Ryan 4 2019-10-24 57 30,000 -22,500 Unit Journey Energy Inc. Common Shares Verge, Alexander G. 4, 5 2019-10-24 57 2.15 2,193,190 147,917 Journey Energy Inc. Rights Performance Verge, Alexander G. 4, 5 2019-10-24 57 100,000 -32,500 Share Unit Journey Energy Inc. Rights Restricted Share Verge, Alexander G. 4, 5 2019-10-24 57 83,333 -82,917 Unit Karmin Exploration Inc. Common Shares Ciccarelli, Larry 4, 6, 5 2019-10-30 22 0.7705 0 -14,338,156 Karmin Exploration Inc. Common Shares Iannozzi, John 6, 5 2019-10-30 22 0.7705 0 -5,837,493 Karmin Exploration Inc. Common Shares Karr Securities Inc. 3 2019-10-30 22 0.7705 0 -8,278,170 Keyera Corp. Common Shares Marikar, Eileen 5 2019-06-13 10 32.15 6,519 30 Keyera Corp. Common Shares Marikar, Eileen 5 2019-06-13 10 32.16 6,619 100 Keyera Corp. Common Shares Marikar, Eileen 5 2019-06-13 10 32.17 7,019 400 Keyera Corp. Common Shares Marikar, Eileen 5 2019-06-13 10 32.18 7,359 340 Keyera Corp. Common Shares Marikar, Eileen 5 2019-09-10 10 33.4 8,276 144 Leucrotta Exploration Inc. Common Shares Disbrow, Robert 3 2019-10-25 10 0.46 11,353,000 124,500 Leucrotta Exploration Inc. Common Shares Disbrow, Robert 3 2019-10-25 10 0.46 9,492,900 63,500 LexaGene Holdings Inc. Common Shares Furtado, Manohar Rajeev 4 2019-10-29 15 0.49 211,520 31,490 (formerly, Wolfeye Resource Corp.) LexaGene Holdings Inc. Warrants Furtado, Manohar Rajeev 4 2017-08-24 00 62,981 (formerly, Wolfeye Resource Corp.) LexaGene Holdings Inc. Common Shares Mitchell, Jeffrey 5 2019-10-29 15 0.52 85,885 75,577 (formerly, Wolfeye Resource Corp.) LexaGene Holdings Inc. Warrants Mitchell, Jeffrey 5 2019-10-29 15 0.75 85,885 75,577 (formerly, Wolfeye Resource Corp.) LexaGene Holdings Inc. Common Shares Regan, John 3, 8, 4, 6, 2019-10-29 15 0.52 5,636,089 62,981 (formerly, Wolfeye Resource 7, 1, 5, 2 Corp.) LexaGene Holdings Inc. Warrants Regan, John 3, 8, 4, 6, 2019-10-29 15 0.75 83,597 62,981 (formerly, Wolfeye Resource 7, 1, 5, 2 Corp.) Liberty Leaf Holdings Ltd. Common Shares Rascan, William 4, 5 2019-10-24 10 0.04 3,183,000 26,000 Lodge Resources Inc. Common Shares Mathiesen, Steve 3, 4, 5 2019-05-24 00 2,000,000 Lodge Resources Inc. Options Mathiesen, Steve 3, 4, 5 2019-05-24 00 200,000 Lodge Resources Inc. Common Shares Place, James Howard 4 2019-05-24 00 40,000 Lodge Resources Inc. Options Place, James Howard 4 2019-05-24 00 100,000 Logistec Corporation Common Shares Class A LOGISTEC 1 2019-10-08 38 38 500 500 CORPORATION Logistec Corporation Common Shares Class A LOGISTEC 1 2019-10-11 38 0 -500 CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-10-07 38 37.25 200 200 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-10-08 38 37.67 300 100 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-10-11 38 0 -300 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-10-30 38 38.05 500 500 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-11-01 38 0 -500 Shares Class B CORPORATION Loncor Resources Inc. Common Shares KONDRAT, ARNOLD T. 3, 4, 5 2019-10-28 90 25,155,616 2,125,666 Loncor Resources Inc. Common Shares KONDRAT, ARNOLD T. 3, 4, 5 2019-10-28 90 0 -2,125,666 Lumina Gold Corp. Options RIVADENEIRA, 5 2019-10-11 50 962,298 125,000 MARCELO Luxxfolio Holdings Inc. Common Shares Byron, Michael 4 2019-10-31 16 0.05 350,000 150,000 Magnetic North Acquisition Common Shares Pinetree Capital Ltd. 3 2017-02-24 37 400,000 -11,600,000 Corp (Formerly Black Bull Resources Inc.) Manulife Financial Common Shares Manulife Financial 1 2019-10-01 38 24.015 450,000 150,000 Corporation Corporation
November 7, 2019 (2019), 42 OSCB 8712
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Manulife Financial Common Shares Manulife Financial 1 2019-10-02 38 23.184 600,000 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-03 38 22.967 812,100 212,100 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-04 38 23.34 962,100 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-07 38 23.485 1,112,100 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-08 38 23.095 1,295,400 183,300 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-09 38 23.241 1,445,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-10 38 23.542 1,595,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-11 38 24.029 1,745,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-15 38 24.349 1,895,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-16 38 24.333 2,045,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-17 38 24.202 2,195,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-18 38 24.299 2,345,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-21 38 24.573 2,495,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-22 38 24.635 2,645,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-23 38 24.627 2,795,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-24 38 24.371 2,945,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-25 38 24.402 3,095,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-28 38 24.781 3,245,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-29 38 24.787 3,395,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-30 38 24.652 3,545,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-31 38 24.442 3,695,400 150,000 Corporation Corporation Manulife Financial Common Shares Manulife Financial 1 2019-10-31 38 300,000 -3,395,400 Corporation Corporation Maple Leaf Foods Inc. Common Shares Hathaway, Suzanne 5 2019-11-01 10 22.73 2,500 1,500 Maple Leaf Foods Inc. Rights PSU - Sawatzky, Jonathan David 5 2019-08-26 00 3,165 Performance Share Units settled with market shares Maple Leaf Foods Inc. Rights Restricted Share Sawatzky, Jonathan David 5 2019-08-26 00 3,165 Units settled with market shares Matachewan Consolidated Options common shares Dumond, Edward 4, 5 2019-10-21 52 0 -175,000 Mines, Limited Matachewan Consolidated Options common German, Richard 4 2019-10-21 52 0 -150,000 Mines, Limited Matachewan Consolidated Options common McCloskey, Richard 4, 5 2019-10-21 52 0 -250,000 Mines, Limited Duncan Matachewan Consolidated Options common Zurowski, Michael T. 4 2019-10-21 52 0 -150,000 Mines, Limited Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2017-06-23 10 0.045 500,000 500,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2017-06-23 10 0.45 0 -500,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2017-11-22 51 0.11 1,000,000 1,000,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2017-11-22 10 0.16 900,000 -100,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2017-11-22 10 0.16 800,000 -100,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2017-11-23 10 0.18 700,000 -100,000
November 7, 2019 (2019), 42 OSCB 8713
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2017-11-23 10 0.18 600,000 -100,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2017-11-23 10 0.17 500,000 -100,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2017-11-23 10 0.17 400,000 -100,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2017-11-24 10 0.16 300,000 -100,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2017-11-24 10 0.16 0 -300,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-08 51 0.51 300,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-08 51 0.51 300,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-08 51 0.42 300,000 300,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-08 10 0.58 228,000 -72,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-09 51 0.42 300,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-09 51 0.42 300,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-10 10 0.58 200,000 -28,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-10 10 0.62 100,000 -100,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-10 10 0.61 0 -100,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-10 51 0.42 200,000 200,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-10 10 0.68 100,000 -100,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-11 10 0.75 0 -100,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-19 51 0.42 300,000 300,000 Matica Enterprises Inc. Common Shares Deol, Gurcharn 4, 5 2018-01-23 10 0.57 0 -300,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-06-23 11 500,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-06-23 11 500,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-06-23 11 -500,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-06-23 11 -500,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-22 10 1,000,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-22 51 1,000,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-22 51 1,000,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-22 10 0.1675 -1,000,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-22 10 0.16 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-22 10 0.16 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-22 10 0.16 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-22 10 0.16 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-23 10 0.18 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-23 10 0.18 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-23 10 0.18 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-23 10 0.18 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-23 10 0.17 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-23 10 0.17 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-23 10 0.17 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-23 10 0.17 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-24 10 0.16 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-24 10 0.16 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-24 10 0.16 -300,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2017-11-24 10 0.16 -300,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-08 51 300,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-08 51 300,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-08 51 -300,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-08 10 0.58 -72,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-08 10 0.58 -72,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-10 10 0.58 -28,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-10 10 0.58 -28,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-10 10 0.62 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-10 10 0.62 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-10 10 0.61 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-10 10 0.61 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-11 51 0.64 200,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-11 51 0.42 200,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-11 51 0.42 200,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-11 51 0.64 -200,000
November 7, 2019 (2019), 42 OSCB 8714
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-11 10 0.68 200,000 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-11 10 0.75 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-11 10 0.75 -100,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-23 51 300,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-23 51 300,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-23 51 -300,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-23 10 -300,000 Matica Enterprises Inc. Options Deol, Gurcharn 4, 5 2018-01-23 10 -300,000 Mawson Resources Limited Common Shares DeMare, Nick 4, 5 2019-10-30 16 0.16 313,500 102,500 Mawson Resources Limited Common Shares DeMare, Nick 4, 5 2019-10-30 16 0.16 235,250 110,000 Mawson Resources Limited Warrants DeMare, Nick 4, 5 2010-08-28 00 Mawson Resources Limited Warrants DeMare, Nick 4, 5 2019-10-30 16 0.24 51,250 51,250 Mawson Resources Limited Warrants DeMare, Nick 4, 5 2010-08-28 00 Mawson Resources Limited Warrants DeMare, Nick 4, 5 2019-10-30 16 0.24 55,000 55,000 Mawson Resources Limited Common Shares Henstridge, David Alan 4 2019-10-30 16 0.16 1,084,125 62,500 Mawson Resources Limited Warrants Henstridge, David Alan 4 2019-10-30 16 31,250 31,250 Mawson Resources Limited Common Shares Hudson, Michael Robert 4 2019-10-30 16 0.16 462,500 387,500 Mawson Resources Limited Warrants Hudson, Michael Robert 4 2019-10-30 16 231,250 193,750 Mawson Resources Limited Common Shares Saxon, Mark Stephen 5 2019-10-30 16 0.16 1,749,119 62,500 Mawson Resources Limited Warrants Saxon, Mark Stephen 5 2019-10-30 16 68,750 31,250 Maxtech Ventures Inc. Options Hodgson, Eugene 4 2019-01-01 38 0 -500,000 Maxtech Ventures Inc. Options Wilson, Peter Grant 4, 5 2019-01-01 38 0 -400,000 Maxtech Ventures Inc. Options Wilson, Peter Grant 4, 5 2019-01-01 38 0 -225,000 Maxtech Ventures Inc. Options Wilson, Peter Grant 4, 5 2019-01-01 38 0 -650,000 Mazarin Inc. Common Shares Huppé, Serge 4 2019-10-29 10 0.055 112,000 1,000 MBN Corporation Common Shares Equity MBN Corporation 1 2019-10-25 38 6.5918 2,200 2,200 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2019-10-25 38 0 -2,200 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2019-10-28 38 6.5581 4,200 4,200 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2019-10-28 38 0 -4,200 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2019-10-29 38 6.61 300 300 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2019-10-29 38 0 -300 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2019-10-30 38 6.61 7,300 7,300 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2019-10-30 38 0 -7,300 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2019-10-31 38 6.6102 5,900 5,900 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2019-10-31 38 0 -5,900 Shares Media Central Corporation Options Kalish, Brian 4, 5 2019-10-23 00 Inc. (formerly IntellaEquity Inc.) Media Central Corporation Options Kalish, Brian 4, 5 2019-10-28 50 0.08 15,000,000 15,000,000 Inc. (formerly IntellaEquity Inc.) Media Central Corporation Options Latowsky, Larry 4 2019-10-23 00 Inc. (formerly IntellaEquity Inc.) Media Central Corporation Options Latowsky, Larry 4 2019-10-28 50 0.08 750,000 750,000 Inc. (formerly IntellaEquity Inc.) Media Central Corporation Options Steinfeld, Gil 4 2019-10-23 00 Inc. (formerly IntellaEquity Inc.) Media Central Corporation Options Steinfeld, Gil 4 2019-10-28 50 0.08 750,000 750,000 Inc. (formerly IntellaEquity Inc.)
November 7, 2019 (2019), 42 OSCB 8715
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Media Central Corporation Options Wilson, Neill Scott Charles 4 2019-10-23 00 Inc. (formerly IntellaEquity Inc.) Media Central Corporation Options Wilson, Neill Scott Charles 4 2019-10-28 50 0.08 750,000 750,000 Inc. (formerly IntellaEquity Inc.) Medicure Inc. Common Shares Friesen, Albert David 4, 5 2019-10-21 11 106,952 106,952 MedXtractor Corp Common Shares Vinck, Dwayne Albert 5 2019-11-01 10 0.065 142,500 30,000 MEG Energy Corp. Notes 6.500% Senior MEG Energy Corp. 1 2019-10-23 38 $1,145,000 $1,145,000 Secured Second Lien Notes due 2025 MEG Energy Corp. Notes 6.500% Senior MEG Energy Corp. 1 2019-10-24 38 $15,000,000 $13,855,000 Secured Second Lien Notes due 2025 MEG Energy Corp. Notes 6.500% Senior MEG Energy Corp. 1 2019-10-25 38 $13,855,000 -$1,145,000 Secured Second Lien Notes due 2025 MEG Energy Corp. Notes 6.500% Senior MEG Energy Corp. 1 2019-10-28 38 $0 -$13,855,000 Secured Second Lien Notes due 2025 MegumaGold Corp. Common Shares Nguyen, Peter Michael 5 2018-06-20 00 MegumaGold Corp. Common Shares Nguyen, Peter Michael 5 2019-11-01 10 0.1975 70,000 70,000 MegumaGold Corp. Common Shares van der Linde, Theo 5 2019-10-29 10 0.145 135,949 40,000 MegumaGold Corp. Common Shares van der Linde, Theo 5 2019-10-29 10 0.135 138,949 3,000 MegumaGold Corp. Common Shares van der Linde, Theo 5 2019-10-31 10 0.155 193,949 55,000 MegumaGold Corp. Common Shares van der Linde, Theo 5 2019-10-31 10 0.185 343,949 150,000 MegumaGold Corp. Common Shares van der Linde, Theo 5 2019-10-31 10 0.19 393,949 50,000 MegumaGold Corp. Common Shares van der Linde, Theo 5 2019-10-31 10 0.175 418,949 25,000 MegumaGold Corp. Common Shares van der Linde, Theo 5 2019-11-01 10 0.185 543,949 125,000 Melcor Developments Ltd. Common Shares Melcor Developments Ltd. 1 2019-10-29 38 12.415 15,900 1,000 Melcor Developments Ltd. Common Shares Melcor Developments Ltd. 1 2019-10-30 38 12.45 16,200 300 Melcor Developments Ltd. Common Shares Melcor Developments Ltd. 1 2019-10-31 38 12.341 300 -15,900 Melcor Developments Ltd. Common Shares Melcor Developments Ltd. 1 2019-11-01 38 12.5 1,300 1,000 Metalo Manufacturing Inc. Common Shares Hennigar, David John 4, 5 2019-11-01 45 0.2773 2,691,968 90,171 (formerly Muskrat Minerals Incorporated) Methanex Corporation Common Shares M&G Investment 3 2019-10-28 90 38.96 1,806,963 5,126 Management Limited Methanex Corporation Common Shares M&G Investment 3 2019-10-25 10 36.947 4,361,775 913 Management Limited Methanex Corporation Common Shares M&G Investment 3 2019-10-28 90 38.96 4,356,649 -5,126 Management Limited Methanex Corporation Common Shares M&G Investment 3 2019-10-30 10 38.219 4,357,824 1,175 Management Limited MGX Minerals Inc. Common Shares Reimann, Michael Andrew 5 2019-10-28 10 0.13 224,500 -50,000 MGX Minerals Inc. Common Shares Reimann, Michael Andrew 5 2019-10-29 10 0.1387 174,500 -50,000 MGX Minerals Inc. Common Shares Reimann, Michael Andrew 5 2019-10-31 10 0.125 124,500 -50,000 Millennial Lithium Corp. Common Shares Abasov, Farhad 5 2019-10-28 10 1.19 280,266 3,000 Millrock Resources Inc. Common Shares Beischer, Gregory Allan 5 2019-10-28 10 0.136 863,706 5,000 Mineral Mountain Resources Options Clark, James Garnet 4 2019-10-07 50 0.175 456,000 100,000 Ltd. (Garry) MINT Income Fund Trust Units MINT Income Fund 1 2019-10-30 38 5.981 71,562,351 2,000 MINT Income Fund Trust Units MINT Income Fund 1 2019-10-31 38 5.9197 71,565,251 2,900 MJardin Group, Inc. Options Witcher, Pat 5 2019-09-19 50 272,000 150,000 (formerly, Sumtra Diversified Inc.) MLI Marble Lending Inc. Common Shares Scharfe, Jason Wesley 4 2019-10-30 10 0.205 796,500 3,000 MLI Marble Lending Inc. Common Shares Scharfe, Jason Wesley 4 2019-10-30 10 0.205 946,500 150,000 Monarch Gold Corporation Options Baril, Michel 4 2019-10-28 50 0.25 1,275,000 250,000 Monarch Gold Corporation Options Bouchard, Michel 4 2019-10-28 50 0.25 1,300,000 350,000 Monarch Gold Corporation Options Bourassa, guy georges 4, 6 2019-10-28 50 0.25 1,600,000 250,000 Monarch Gold Corporation Options Desjardins, Lucie 5 2019-10-28 50 0.25 170,000 35,000 Monarch Gold Corporation Common Shares Gaborit, Laurence 4 2019-10-28 00 400 Monarch Gold Corporation Common Shares Gaborit, Laurence 4 2019-10-29 10 0.21 24,400 24,000
November 7, 2019 (2019), 42 OSCB 8716
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Monarch Gold Corporation Options Gaborit, Laurence 4 2019-10-28 00 250,000 Monarch Gold Corporation Options Lacoste, Jean-Marc 4, 5 2019-10-28 50 0.25 2,650,000 450,000 Monarch Gold Corporation Options Lavergne, Marc-André 5 2019-10-28 50 0.25 700,000 200,000 Monarch Gold Corporation Options Lévesque, Alain 5 2019-10-28 50 0.25 850,000 200,000 Monarch Gold Corporation Options Pichette, Christian 4 2019-10-28 50 0.25 825,000 250,000 Monarch Gold Corporation Options Séguin, Mathieu 5 2019-10-28 50 0.25 450,000 200,000 Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-24 10 0.16 10,972,167 24,500 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-24 10 0.17 10,987,167 15,000 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-24 10 0.17 10,997,167 10,000 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-29 10 0.149 11,022,167 25,000 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-29 10 0.16 11,036,167 14,000 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-29 10 0.16 11,047,167 11,000 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-30 10 0.15 11,088,167 41,000 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-30 10 0.14 11,103,667 15,500 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-30 10 0.16 11,104,167 500 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-30 10 0.155 11,107,667 3,500 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-30 10 0.159 11,110,167 2,500 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-30 10 0.16 11,120,167 10,000 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-30 10 0.165 11,133,667 13,500 Inc. Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2019-10-30 10 0.165 11,142,667 9,000 Inc. MONETA PORCUPINE Common Shares Vejvoda, Josef 4 2019-10-24 10 0.1 23,751,091 10,000 MINES INC. MONETA PORCUPINE Common Shares Vejvoda, Josef 4 2019-10-25 10 0.1 23,857,091 106,000 MINES INC. MONETA PORCUPINE Common Shares Vejvoda, Josef 4 2019-10-28 10 0.105 23,917,091 60,000 MINES INC. MONETA PORCUPINE Common Shares Vejvoda, Josef 4 2019-10-29 10 0.103 24,027,091 110,000 MINES INC. MONETA PORCUPINE Common Shares Vejvoda, Josef 4 2019-10-30 10 0.103 24,107,091 80,000 MINES INC. MONETA PORCUPINE Common Shares Vejvoda, Josef 4 2019-10-31 10 0.107 24,318,091 211,000 MINES INC. MONETA PORCUPINE Common Shares Vejvoda, Josef 4 2019-11-01 10 0.108 24,468,091 150,000 MINES INC. MPV Exploration Inc. Common Shares lavoie, marc andre 4 2019-10-24 10 0.08 585,000 25,000 MTY Food Group Inc. Options Beauchamp, Marie-Line 5 2018-03-01 00 MTY Food Group Inc. Options Beauchamp, Marie-Line 5 2019-10-21 50 40,000 40,000 MTY Food Group Inc. Common Shares Benzacar, Marc 5 2018-11-02 00 2,767 MTY Food Group Inc. Options Benzacar, Marc 5 2018-11-02 00 MTY Food Group Inc. Options Benzacar, Marc 5 2019-10-21 50 40,000 40,000 MTY Food Group Inc. Options Brading, Jason 5 2018-12-01 00 MTY Food Group Inc. Options Brading, Jason 5 2019-10-31 50 52.01 40,000 40,000 MTY Food Group Inc. Options Lefebvre, Eric 4, 5 2019-10-21 50 40,000 MTY Food Group Inc. Options Lefebvre, Eric 4, 5 2019-10-21 50 240,000 40,000 MTY Food Group Inc. Common Shares St-Onge, Renee 5 2019-10-04 30 61.74 1,726 28 MTY Food Group Inc. Options St-Onge, Renee 5 2018-11-05 00 MTY Food Group Inc. Options St-Onge, Renee 5 2019-10-28 50 40,000 40,000 Mullen Group Ltd. Common Shares McGinley, Christine Ellen 4 2019-11-01 10 8.29 10,509 388 Mullen Group Ltd. Common Shares McGinley, Christine Ellen 4 2019-11-01 10 8.29 10,805 296 Mullen Group Ltd. Common Shares McGinley, Christine Ellen 4 2019-11-01 10 8.31 11,178 373
November 7, 2019 (2019), 42 OSCB 8717
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Must Capital Inc. (formerly Common Shares Marrandino, Michele 4, 5 2019-10-29 10 0.06 40,000 20,000 Intrinsic4D Inc.) MustGrow Biologics Corp. Common Shares Bletsky, Colin Michael 3, 4 2019-10-28 10 0.29 819,864 8,500 MustGrow Biologics Corp. Common Shares Bletsky, Colin Michael 3, 4 2019-10-28 10 0.295 861,364 41,500 NanoXplore Inc. Common Shares Schoch, David Linden 6 2019-10-25 10 1.0073 2,000 2,000 NanoXplore Inc. Common Shares Schoch, David Linden 6 2019-10-25 10 1.01 4,000 2,000 NanoXplore Inc. Common Shares Schoch, David Linden 6 2019-10-28 10 1 7,000 3,000 National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.32 400,600 600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.33 402,200 1,600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.35 402,700 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.37 403,400 700 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.38 404,200 800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.39 404,800 600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.4 405,500 700 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.41 405,800 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.42 406,300 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.43 406,900 600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.45 407,600 700 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.46 408,200 600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.47 408,400 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.48 408,800 400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.49 409,000 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.5 409,200 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.51 409,500 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.52 410,200 700 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.53 410,600 400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.54 412,400 1,800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.55 412,500 100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.56 413,500 1,000 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.57 413,800 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.58 414,000 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.59 414,500 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.6 415,600 1,100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.61 416,900 1,300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.62 418,400 1,500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.63 419,500 1,100 Canada
November 7, 2019 (2019), 42 OSCB 8718
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.64 420,500 1,000 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.65 421,300 800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.66 422,100 800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.67 422,800 700 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.68 423,700 900 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.69 424,900 1,200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.7 426,700 1,800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.71 427,000 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.72 427,300 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.73 432,400 5,100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.74 433,000 600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.75 433,200 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.76 433,600 400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.77 433,900 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.78 435,500 1,600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.79 436,900 1,400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.8 438,500 1,600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.81 439,000 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.82 439,600 600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.83 440,600 1,000 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.84 441,400 800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.86 441,800 400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.87 442,300 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.88 442,500 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.89 442,700 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.9 443,300 600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.92 443,800 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.93 444,100 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.94 444,400 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.97 444,700 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.98 444,900 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 65.99 445,200 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.02 445,500 300 Canada
November 7, 2019 (2019), 42 OSCB 8719
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.03 445,900 400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.05 446,000 100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.06 446,300 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.07 446,600 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.08 447,200 600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.09 447,300 100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.1 447,400 100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.11 447,600 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.12 448,100 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.13 448,800 700 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.14 449,300 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.17 449,600 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-01 38 66.2 450,000 400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.5 450,200 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.51 450,400 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.52 450,900 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.54 451,300 400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.57 451,500 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.59 451,800 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.6 452,100 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.61 452,500 400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.62 452,700 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.63 453,500 800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.64 454,700 1,200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.65 455,700 1,000 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.66 456,400 700 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.67 457,200 800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.68 457,400 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.69 458,500 1,100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.7 459,300 800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.71 459,600 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.72 460,100 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.73 460,400 300 Canada
November 7, 2019 (2019), 42 OSCB 8720
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.74 460,800 400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.76 461,500 700 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.77 461,700 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.79 461,900 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.81 462,400 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.82 464,000 1,600 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.83 465,200 1,200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.84 466,700 1,500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.85 467,900 1,200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.86 469,100 1,200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.87 470,000 900 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.875 470,100 100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.88 472,400 2,300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.89 478,100 5,700 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.895 478,200 100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.9 481,000 2,800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.905 481,100 100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.91 482,500 1,400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.92 485,400 2,900 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.93 487,500 2,100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.94 490,300 2,800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.95 493,100 2,800 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.96 494,000 900 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.97 494,300 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.975 494,400 100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.98 495,100 700 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 64.99 496,000 900 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 65 496,100 100 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 65.01 496,500 400 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 65.02 497,400 900 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 65.03 497,900 500 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 65.04 498,600 700 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 65.05 499,000 400 Canada
November 7, 2019 (2019), 42 OSCB 8721
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 65.06 499,300 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 65.07 499,500 200 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 65.08 499,800 300 Canada National Bank of Canada Common Shares Banque Nationale du 1 2019-10-02 38 65.09 500,000 200 Canada Neptune Wellness Solutions Restricted Share Units Cammarata, Michael 4 2019-10-23 59 4.43 -82,717 Inc. (formerly Neptune Taylor Technologies & Bioressources Inc.) Neptune Wellness Solutions Restricted Share Units Cammarata, Michael 4 2019-10-23 97 2,566,666 -82,717 Inc. (formerly Neptune Taylor Technologies & Bioressources Inc.) Nerds On Site Inc. Subordinate Voting Smit, Jacques Antonius 4 2019-11-01 10 0.07 223,000 23,000 Shares Nerds On Site Inc. Subordinate Voting Smit, Jacques Antonius 4 2019-11-01 10 0.075 300,000 77,000 Shares NervGen Pharma Corp. Common Shares Pilz, Robert 5 2019-10-31 10 1.54 356,900 -15,000 NervGen Pharma Corp. Common Shares Pilz, Robert 5 2019-11-01 10 1.6 341,900 -15,000 Nevada Sunrise Gold Options Roy, Charles Edward 4 2019-10-30 52 0.5 370,000 -200,000 Corporation Nevada Sunrise Gold Warrants Sweatman, Michael 4 2019-10-25 55 0.3 195,000 -40,000 Corporation New Pacific Metals Corp. Common Shares Beaty, Ross J. 6 2019-10-25 15 4 24,724,068 724,068 New Pacific Metals Corp. Common Shares Busby, Steven 6 2019-10-25 15 4 24,724,068 724,068 New Pacific Metals Corp. Common Shares Carroll, Michael Louis 3 2019-10-25 15 4 24,724,068 724,068 New Pacific Metals Corp. Common Shares de Gelder, Neil 3 2019-10-25 15 4 24,724,068 724,068 New Pacific Metals Corp. Common Shares Doyle, Alun Robert 6 2019-10-25 15 4 24,724,068 724,068 New Pacific Metals Corp. Common Shares Jeannes, Charles A. 6 2019-10-25 15 4 24,724,068 724,068 New Pacific Metals Corp. Common Shares McArthur, C. Kevin 6 2019-10-25 15 4 24,724,068 724,068 New Pacific Metals Corp. Common Shares Pan American Silver Corp. 3 2019-10-25 15 4 24,724,068 724,068 New Pacific Metals Corp. Common Shares Segsworth, Walter Thomas 6 2019-10-25 15 4 24,724,068 724,068 New Pacific Metals Corp. Common Shares Silvercorp Metals Inc. 3 2019-10-25 15 4 31,789,306 1,247,606 New Pacific Metals Corp. Common Shares Steinmann, Michael 6 2019-10-25 15 4 24,724,068 724,068 New Pacific Metals Corp. Common Shares Winckler, Gillian 3 2019-10-25 15 4 24,724,068 724,068 New Tech Minerals Corp. Common Shares george, jonathan 4, 5 2019-10-25 10 0.015 346,000 16,000 New Tech Minerals Corp. Common Shares george, jonathan 4, 5 2019-10-30 10 0.015 356,000 10,000 New Wave Esports Corp. Common Shares Fisher, Trumbull Grant 4, 5 2019-10-24 00 150,000 (formerly, Trueclaim Exploration Inc.) New Wave Esports Corp. Common Shares Fisher, Trumbull Grant 4, 5 2019-10-28 57 0.15 650,000 500,000 (formerly, Trueclaim Exploration Inc.) New Wave Esports Corp. Options Fisher, Trumbull Grant 4, 5 2019-10-24 00 2,000,000 (formerly, Trueclaim Exploration Inc.) New Wave Esports Corp. Rights Restricted Share Fisher, Trumbull Grant 4, 5 2019-10-24 00 2,000,000 (formerly, Trueclaim Units Exploration Inc.) New Wave Esports Corp. Rights Restricted Share Fisher, Trumbull Grant 4, 5 2019-10-28 57 1,500,000 -500,000 (formerly, Trueclaim Units Exploration Inc.) New Wave Esports Corp. Warrants Fisher, Trumbull Grant 4, 5 2019-10-24 00 1,150,000 (formerly, Trueclaim Exploration Inc.) New Wave Esports Corp. Common Shares Lee, Tiffany Amanda 4, 5 2019-10-24 00 250,000 (formerly, Trueclaim Exploration Inc.) New Wave Esports Corp. Common Shares Mitre, Daniel 5 2019-10-24 00 2,000,000 (formerly, Trueclaim Exploration Inc.) New Wave Esports Corp. Common Shares Mitre, Daniel 5 2019-10-28 57 0.15 2,250,000 250,000 (formerly, Trueclaim Exploration Inc.)
November 7, 2019 (2019), 42 OSCB 8722
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed New Wave Esports Corp. Options Mitre, Daniel 5 2019-10-24 00 1,000,000 (formerly, Trueclaim Exploration Inc.) New Wave Esports Corp. Rights Restricted Share Mitre, Daniel 5 2019-10-24 00 1,000,000 (formerly, Trueclaim Units Exploration Inc.) New Wave Esports Corp. Rights Restricted Share Mitre, Daniel 5 2019-10-28 57 750,000 -250,000 (formerly, Trueclaim Units Exploration Inc.) New Wave Esports Corp. Common Shares Stevens, Jeff 4 2019-10-24 00 500,000 (formerly, Trueclaim Exploration Inc.) Nextleaf Solutions Ltd. Common Shares Boodram, Sherry 4 2019-10-1600 Nextleaf Solutions Ltd. Options Boodram, Sherry 4 2019-10-16 00 150,000 NextSource Materials Inc. Common Shares Johnson, Marc 5 2019-10-25 16 0.045 633,334 333,334 NextSource Materials Inc. Warrants Johnson, Marc 5 2019-10-25 16 274,167 166,667 NextSource Materials Inc. Common Shares Larson, Dalton Leroy 4 2014-11-06 00 NioBay Metals Inc. (formerly Common Shares Bonneau, Jacques 4 2019-10-29 10 0.46 757,562 20,000 MDN INC.) NioBay Metals Inc. (formerly Common Shares Bonneau, Jacques 4 2019-10-29 10 0.41 767,562 10,000 MDN INC.) NioBay Metals Inc. (formerly Common Shares David, Jean-Sébastien 4 2019-10-31 10 0.47 486,632 2,000 MDN INC.) NioBay Metals Inc. (formerly Common Shares Dufresne, Claude 4, 5 2019-10-28 10 0.47 541,200 13,000 MDN INC.) NioBay Metals Inc. (formerly Common Shares Dufresne, Claude 4, 5 2019-10-29 10 0.405 551,200 10,000 MDN INC.) Northern Dynasty Minerals Options BALAKRISHNAN, 4 2019-09-27 50 721,000 120,000 Ltd. Desmond Northern Dynasty Minerals Common Shares Collier, Thomas Cleveland 7 2019-10-29 36 74,294 25,792 Ltd. Northern Dynasty Minerals Restricted Share Units Collier, Thomas Cleveland 7 2019-10-29 36 0 -35,877 Ltd. Northway Resources Corp. Common Shares Flood, Zachary Edward 4, 6, 5 2019-10-30 10 0.08 1,181,000 181,000 Norvista Capital Corporation Common Shares Norvista Capital 1 2019-10-22 38 0.085 484,000 25,000 Corporation Norvista Capital Corporation Common Shares Norvista Capital 1 2019-10-23 38 0.095 494,000 10,000 Corporation Norvista Capital Corporation Common Shares Norvista Capital 1 2019-10-23 38 0.09 504,000 10,000 Corporation NOVAGOLD RESOURCES Common Shares Dowdall, Sharon Elizabeth 4 2019-10-31 51 3.18 96,400 96,400 INC. NOVAGOLD RESOURCES Common Shares Dowdall, Sharon Elizabeth 4 2019-10-31 38 9.48 64,063 -32,337 INC. NOVAGOLD RESOURCES Common Shares Dowdall, Sharon Elizabeth 4 2019-10-31 10 9.46 0 -64,063 INC. NOVAGOLD RESOURCES Options Dowdall, Sharon Elizabeth 4 2019-10-31 51 3.18 391,300 -96,400 INC. Novoheart Holdings Inc. Common Shares Ngan Ng, Yu Ying 4 2019-10-11 54 12,865,893 Novoheart Holdings Inc. Common Shares Ngan Ng, Yu Ying 4 2019-10-11 54 19,313,178 12,865,892 Novoheart Holdings Inc. Warrants Ngan Ng, Yu Ying 4 2019-10-11 54 0.3635 0 -10,292,714 Novoheart Holdings Inc. Common Shares Ngan, Chi Wing 4 2019-10-11 54 12,865,892 Novoheart Holdings Inc. Common Shares Ngan, Chi Wing 4 2019-10-11 54 19,313,179 12,865,893 Novoheart Holdings Inc. Warrants Ngan, Chi Wing 4 2019-10-11 54 0.3635 0 -10,292,714 Nuran Wireless Inc. Common Shares BÉDARD, Martin 3 2015-06-02 00 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares BÉDARD, Martin 3 2015-06-02 00 (formerly 1014372 B.C. Ltd.) OceanaGold Corporation Rights Deferred Share Reid, Ian MacNevin 4 2018-04-26 56 3.42 37,632 37,632 Units OceanaGold Corporation Rights Deferred Share Reid, Ian MacNevin 4 2018-06-01 56 3.42 128,700 Units Oceanus Resources Common Shares Gordon, Richard Basil 4, 5 2019-10-29 10 0.08 2,139,456 5,000 Corporation Oceanus Resources Common Shares Gordon, Richard Basil 4, 5 2019-10-30 10 0.08 2,141,956 2,500 Corporation
November 7, 2019 (2019), 42 OSCB 8723
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Olivut Resources Ltd. Options Keough, Leni Edna 4, 5 2019-10-29 50 0.05 2,202,500 300,000 Florence Olivut Resources Ltd. Options Reith, Craig Owen 4 2019-10-29 50 0.05 742,500 200,000 Olivut Resources Ltd. Options Shaw, Ian 5 2019-10-29 50 0.05 410,000 200,000 ONEX CORPORATION Rights Deferred Share Casey, Daniel C. 4 2019-10-31 56 76.71 96,605 126 Units (cash settled) ONEX CORPORATION Rights Deferred Share Copeland, David Wayne 5 2019-10-31 56 77.43 1,180 2 Units (cash settled) ONEX CORPORATION Rights Deferred Share Daly, Andrea Elizabeth 5 2019-10-31 56 77.43 13,202 17 Units (cash settled) ONEX CORPORATION Rights Deferred Share Etherington, William 4 2019-10-31 56 76.71 70,187 91 Units (cash settled) ONEX CORPORATION Rights Deferred Share Goldhar, Mitchell 4 2019-10-31 56 76.71 12,367 16 Units (cash settled) ONEX CORPORATION Rights Deferred Share Gouin, Serge 4 2019-10-31 56 76.71 99,205 129 Units (cash settled) ONEX CORPORATION Rights Deferred Share Govan, Christopher Allan 5 2019-10-31 56 77.43 116,606 150 Units (cash settled) ONEX CORPORATION Rights Deferred Share Heersink, Ewout R. 4, 5 2019-10-31 56 77.43 314,962 406 Units (cash settled) ONEX CORPORATION Rights Deferred Share Huffington, Arianna 4 2019-10-31 56 76.71 22,632 30 Units (cash settled) ONEX CORPORATION Rights Deferred Share McCoy, John Bonnet 4 2019-10-31 56 76.71 90,746 118 Units (cash settled) ONEX CORPORATION Rights Deferred Share Mersky, Seth Mitchell 5 2019-10-31 56 77.43 103,039 133 Units (cash settled) ONEX CORPORATION Rights Deferred Share Munk, Anthony 7 2019-10-31 56 77.43 23,984 31 Units (cash settled) ONEX CORPORATION Rights Deferred Share Popatia, Tawfiq 5 2019-10-31 56 77.43 18,967 25 Units (cash settled) ONEX CORPORATION Rights Deferred Share Prichard, John Robert 4 2019-10-31 56 76.71 93,397 122 Units (cash settled) Stobo ONEX CORPORATION Rights Deferred Share Reisman, Heather M. 4 2019-10-31 56 76.71 84,180 110 Units (cash settled) ONEX CORPORATION Rights Deferred Share Thorsteinson, Arni Clayton 4 2019-10-31 56 76.71 122,056 159 Units (cash settled) ONEX CORPORATION Rights Deferred Share Wilkinson, Beth Ann 4 2019-10-31 56 76.71 7,995 10 Units (cash settled) ONEX CORPORATION Rights Deferred Share Wright, Nigel Stewart 7 2019-10-31 56 77.43 55,056 71 Units (cash settled) Open Text Corporation Common Shares OTEX Parker, Douglas Michael 5 2019-10-21 00 Common Open Text Corporation Deferred Share Units Parker, Douglas Michael 5 2019-10-21 00 Open Text Corporation Options All OTEX Option Parker, Douglas Michael 5 2019-10-21 00 Plans Open Text Corporation Performance Share Units Parker, Douglas Michael 5 2019-10-21 00 Open Text Corporation Restricted Share Units Parker, Douglas Michael 5 2019-10-21 00 Organto Foods Inc. Common Shares Gianulis, Peter Lawrence 6 2019-10-29 10 0.06 4,344,500 150,000 Oroco Resource Corp. Common Shares Dalziel, Craig James 4, 5 2019-10-25 00 1,050,000 Oroco Resource Corp. Common Shares Dalziel, Craig James 4, 5 2019-10-25 00 6,118,000 Oroco Resource Corp. Common Shares Dalziel, Craig James 4, 5 2019-10-25 00 442,000 Oroco Resource Corp. Common Shares Dalziel, Craig James 4, 5 2019-10-25 00 831,000 Oroco Resource Corp. Warrants Dalziel, Craig James 4, 5 2019-10-25 00 412,500 Oroco Resource Corp. Options Graham, Ian 5 2019-11-01 50 0.3 600,000 300,000 Pacific Empire Minerals Common Shares Ritchie, Rory 4, 5 2019-10-28 10 0.03 1,059,500 30,000 Corp. Palamina Corp. Common Shares Thomson, Andrew 4 2019-10-28 10 0.2 631,200 8,300 Palamina Corp. Common Shares Thomson, Andrew 4 2019-10-28 10 0.19 634,200 3,000 Palamina Corp. Common Shares Thomson, Andrew 4 2019-10-28 10 0.21 636,700 2,500 Parkland Fuel Corporation Common Shares Haugh, Douglas Scott 5 2019-11-01 30 44.06 17,433 3,034 Pathfinder Income Fund Trust Units Pathfinder Convertible 1 2019-10-31 38 7.9863 11,149,198 2,400 Debenture Fund PharmaCielo Ltd. (formerly, Common Shares Bache, Douglas 4 2018-01-15 00 AAJ Capital 1 Corp.)
November 7, 2019 (2019), 42 OSCB 8724
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed PharmaCielo Ltd. (formerly, Common Shares Bache, Douglas 4 2019-06-18 57 10,000 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Common Shares Bache, Douglas 4 2019-10-09 57 10,000 10,000 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Bache, Douglas 4 2018-01-15 00 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Bache, Douglas 4 2018-12-18 56 20,000 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Bache, Douglas 4 2019-04-17 56 20,000 20,000 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Bache, Douglas 4 2019-06-18 57 10,000 -10,000 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Common Shares Botero Diaz, Andres Felipe 7 2019-07-22 00 300,000 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Common Shares Botero Diaz, Andres Felipe 7 2019-09-01 00 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Botero Diaz, Andres Felipe 7 2019-07-22 00 300,000 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Botero Diaz, Andres Felipe 7 2019-09-01 00 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Botero Diaz, Andres Felipe 7 2019-09-01 00 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Laitinen, R. Scott 5 2019-01-15 00 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Laitinen, R. Scott 5 2019-05-23 56 250,000 250,000 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Laitinen, R. Scott 5 2019-05-24 56 250,000 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Common Shares Uribe, Carlos Manuel 4, 7 2019-06-01 57 37500 387,500 37,500 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Uribe, Carlos Manuel 4, 7 2019-01-15 00 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Uribe, Carlos Manuel 4, 7 2019-01-15 00 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Uribe, Carlos Manuel 4, 7 2019-04-17 56 75,000 75,000 AAJ Capital 1 Corp.) PharmaCielo Ltd. (formerly, Restricted Share Units Uribe, Carlos Manuel 4, 7 2019-06-01 57 37,500 -37,500 AAJ Capital 1 Corp.) Photon Control Inc. Common Shares McDonnell, David Neil 4 2019-11-01 57 174,648 11,837 Photon Control Inc. Common Shares McDonnell, David Neil 4 2019-11-01 57 199,409 24,761 Photon Control Inc. Rights RSU McDonnell, David Neil 4 2019-11-01 57 31,163 -11,837 Photon Control Inc. Rights RSU McDonnell, David Neil 4 2019-11-01 57 6,402 -24,761 Photon Control Inc. Rights RSU McDonnell, David Neil 4 2019-11-01 38 0 -6,402 Physinorth Acquisition Options Al-Shawwa, Hassan 3, 4 2017-12-19 00 Corporation Inc. Physinorth Acquisition Options Al-Shawwa, Hassan 3, 4 2018-12-21 50 45,983 45,983 Corporation Inc. Physinorth Acquisition Common Shares Chouinard, Eric 3, 4 2017-12-19 00 Corporation Inc. Physinorth Acquisition Common Shares Chouinard, Eric 3, 4 2018-12-21 15 0.15 33,330 33,330 Corporation Inc. Physinorth Acquisition Common Shares Chouinard, Eric 3, 4 2018-12-21 15 0.15 699,997 33,330 Corporation Inc. Physinorth Acquisition Options Chouinard, Eric 3, 4 2017-12-19 00 Corporation Inc. Physinorth Acquisition Options Chouinard, Eric 3, 4 2018-10-21 50 45,983 Corporation Inc. Physinorth Acquisition Options Chouinard, Eric 3, 4 2018-12-21 50 45,983 45,983 Corporation Inc. Physinorth Acquisition Common Shares Cianci, Joseph 3, 4, 5 2018-12-21 15 0.15 299,997 33,330 Corporation Inc. Physinorth Acquisition Options Cianci, Joseph 3, 4, 5 2017-12-19 00 Corporation Inc. Physinorth Acquisition Options Cianci, Joseph 3, 4, 5 2018-12-21 50 122,622 122,622 Corporation Inc.
November 7, 2019 (2019), 42 OSCB 8725
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Physinorth Acquisition Common Shares Pronovost, Jean-Robert 3, 4, 5 2017-12-19 00 Corporation Inc. Physinorth Acquisition Common Shares Pronovost, Jean-Robert 3, 4, 5 2018-12-21 15 0.15 50,000 50,000 Corporation Inc. Physinorth Acquisition Common Shares Pronovost, Jean-Robert 3, 4, 5 2018-12-21 15 0.15 316,667 50,000 Corporation Inc. Physinorth Acquisition Options Pronovost, Jean-Robert 3, 4, 5 2017-12-19 00 Corporation Inc. Physinorth Acquisition Options Pronovost, Jean-Robert 3, 4, 5 2018-12-21 50 122,622 122,622 Corporation Inc. Physinorth Acquisition Options Seguin, Gilles 3, 5 2017-12-19 00 Corporation Inc. Physinorth Acquisition Options Seguin, Gilles 3, 5 2018-12-21 50 122,622 122,622 Corporation Inc. Pieridae Energy Limited Common Shares Boulanger, Charles 4 2019-10-17 11 0.86 233,453 87,209 (formerly Petrolia Inc.) Pieridae Energy Limited Subscription Receipts Boulanger, Charles 4 2012-12-11 00 (formerly Petrolia Inc.) Pieridae Energy Limited Subscription Receipts Boulanger, Charles 4 2019-10-10 11 0.86 87,209 87,209 (formerly Petrolia Inc.) Pieridae Energy Limited Subscription Receipts Boulanger, Charles 4 2019-10-17 36 0 -87,209 (formerly Petrolia Inc.) Pieridae Energy Limited Options de Freitas, Timothy 4 2019-10-25 50 0.92 156,809 12,000 (formerly Petrolia Inc.) Pieridae Energy Limited Common Shares Gamba, Charle 4 2019-10-24 10 0.86 198,374 116,258 (formerly Petrolia Inc.) Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-08 10 0.13 100,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-08 10 0.13 100,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-22 11 0.13 5,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-22 11 0.13 5,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-08 10 0.13 20,755,587 100,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-22 10 0.13 3,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-22 10 0.13 20,783,087 3,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-22 11 0.13 20,778,087 -5,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-29 97 20,703,087 -75,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-25 10 0.125 20,942,691 250,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-29 10 0.125 21,042,691 100,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-08 10 0.13 100,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-22 10 0.13 3,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-10-22 11 0.13 -5,000 Pine Trail Real Estate Trust Units Shapack, Andrew Irwin 4, 5 2019-10-24 10 0.165 63,000 3,000 Investment Trust (formerly, Pine Trail Capital Trust) Plateau Energy Metals Inc. Common Shares Ferry, Alan Louis Henry 4 2019-10-29 90 0.21 435,000 435,000 Plateau Energy Metals Inc. Common Shares Ferry, Alan Louis Henry 4 2019-10-29 90 0.21 0 -435,000 Plus Products Inc. Common Shares Braff, Jill 4 2019-11-01 00 Plus Products Inc. Common Shares Braff, Jill 4 2019-11-01 00 Polymet Mining Corp. Common Shares Freyberg, Peter Carl 4 2019-07-31 00 Polymet Mining Corp. DSU's Freyberg, Peter Carl 4 2019-07-31 00 Polymet Mining Corp. Options Freyberg, Peter Carl 4 2019-07-31 00 PrairieSky Royalty Ltd. Common Shares Estey, James 4 2019-10-30 10 13.01 856,791 10,000 PrairieSky Royalty Ltd. Common Shares Estey, James 4 2019-11-01 10 13.06 860,265 3,474 PrairieSky Royalty Ltd. Common Shares Estey, James 4 2019-11-01 10 13.06 120,412 6,526 PrairieSky Royalty Ltd. Common Shares KAZEIL, PAMELA PEARL 5 2019-10-30 10 13 57,846 2,500 PrairieSky Royalty Ltd. Common Shares Phillips, Andrew 5 2019-10-30 10 13.24 556,515 10,000 PrairieSky Royalty Ltd. Common Shares PROCTOR, CAMERON 5 2019-10-30 10 12.977 62,296 1,500 MACLEAN PrairieSky Royalty Ltd. Common Shares PROCTOR, CAMERON 5 2019-10-30 10 12.99 35,405 2,000 MACLEAN PrairieSky Royalty Ltd. Common Shares PROCTOR, CAMERON 5 2019-10-30 10 12.982 3,019 1,000 MACLEAN Precision Drilling Common Shares Neveu, Kevin A. 4, 5 2019-10-25 10 1.43 1,071,761 200 Corporation
November 7, 2019 (2019), 42 OSCB 8726
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Precision Drilling Common Shares Neveu, Kevin A. 4, 5 2019-10-25 10 1.43 1,081,561 9,800 Corporation Primary Energy Metals Inc. Common Shares Clelland, Chadwick Adam 4 2019-10-28 00 666,700 Primary Energy Metals Inc. Warrants Clelland, Chadwick Adam 4 2019-10-28 00 333,350 Primary Energy Metals Inc. Common Shares Shacker, Joel 4, 5 2019-10-30 11 0.075 266,666 133,333 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2019-10-25 10 0.2 5,646,465 5,000 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2019-10-25 10 0.15 5,651,465 5,000 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2019-10-25 10 0.15 5,656,465 5,000 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2019-10-30 10 0.14 5,661,465 5,000 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2019-10-30 10 0.14 5,671,465 10,000 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2019-10-28 10 0.145 2,131,500 10,000 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2019-10-29 10 0.135 2,146,500 15,000 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2019-10-29 10 0.145 2,156,500 10,000 QMX Gold Corporation Common Shares Humphrey, Bradley Dean 4, 5 2019-10-30 10 0.05 2,049,000 300,000 (formerly Alexis Minerals Corporation) Radial Research Corp. Common Shares Lamb, Nelson Garry 5 2019-10-25 00 Radial Research Corp. Options Lamb, Nelson Garry 5 2019-10-25 00 100,000 RAMM Pharma Corp. Common Shares AUGEREAU, DANIEL 4 2019-10-28 00 6,800,000 RAMM Pharma Corp. Common Shares Bajurny, Matthew 4 2019-10-18 00 RAMM Pharma Corp. Common Shares Bajurny, Matthew 4 2019-10-28 11 75,000 75,000 RAMM Pharma Corp. Common Shares BLANKLEIDER, 3, 4 2019-10-28 00 20,000,000 ARMANDO GABRIEL RAMM Pharma Corp. Common Shares Burnett, Jackie Peter 3, 4, 5 2019-10-28 00 17,700,000 RAMM Pharma Corp. Options Burnett, Jackie Peter 3, 4, 5 2019-10-28 00 3,000,000 RAMM Pharma Corp. OTC Calls (including Burnett, Jackie Peter 3, 4, 5 2019-10-28 00 15,000,000 Private Options to Purchase) RAMM Pharma Corp. Options DELMONTE, GUILLERMO 5 2019-10-28 00 1,000,000 RAMM Pharma Corp. Options PIÑEIRO, MATIAS 5 2019-10-28 00 100,000 Rapid Dose Therapeutics Common Shares Upsdell, Mark 4 2018-12-07 00 142,857 Corp. (formerly ACME RESOURCES CORP.) RavenQuest BioMed Inc. Common Shares Ahrens-Townsend, Mark 4 2019-10-30 00 165,000 William RavenQuest BioMed Inc. Options Ahrens-Townsend, Mark 4 2019-10-30 00 William RavenQuest BioMed Inc. Warrants Ahrens-Townsend, Mark 4 2019-10-30 00 William Razor Energy Corp. Common Shares Bailey, Douglas George 4, 5 2019-10-31 10 0.94 1,284,415 2,000 Razor Energy Corp. Common Shares Bailey, Douglas George 4, 5 2019-10-31 10 0.95 1,284,915 500 Razor Energy Corp. Common Shares Bailey, Douglas George 4, 5 2019-10-31 10 0.94 1,291,415 6,500 Razor Energy Corp. Common Shares Bailey, Douglas George 4, 5 2019-10-31 10 0.93 1,292,415 1,000 Razor Energy Corp. Common Shares Bailey, Douglas George 4, 5 2019-11-01 10 0.87 1,294,415 2,000 Razor Energy Corp. Common Shares Bailey, Douglas George 4, 5 2019-11-01 10 0.86 1,294,915 500 Razor Energy Corp. Common Shares Bailey, Douglas George 4, 5 2019-11-01 10 0.85 1,296,915 2,000 Razor Energy Corp. Common Shares Bailey, Douglas George 4, 5 2019-11-01 10 0.9 1,297,415 500 Razor Energy Corp. Common Shares Bailey, Douglas George 4, 5 2019-11-01 30 0.9 1,304,868 7,453 Razor Energy Corp. Common Shares Bergevin, Marc Jay 5 2019-11-01 30 0.9 38,847 6,481 Razor Energy Corp. Common Shares Braun, Kevin Edward 5 2019-11-01 30 0.9 180,829 6,481 Razor Energy Corp. Common Shares Braun, Kevin Edward 5 2019-10-31 30 0.86 36,119 517 Razor Energy Corp. Common Shares Braun, Kevin Edward 5 2019-10-31 30 0.86 9,217 96 Razor Energy Corp. Common Shares Mueller, Lisa Ann 5 2019-10-31 30 0.86 105,078 1,248 Razor Energy Corp. Common Shares Mueller, Lisa Ann 5 2019-11-01 30 0.9 111,559 6,481 Razor Energy Corp. Common Shares Mueller, Lisa Ann 5 2019-10-31 30 0.86 48,538 163 Razor Energy Corp. Common Shares Mueller, Lisa Ann 5 2019-10-31 30 0.86 24,672 315 Razor Energy Corp. Common Shares Muller, Frank Peter 4, 5 2019-10-31 30 0.86 1,018,769 2,091 Razor Energy Corp. Common Shares Muller, Frank Peter 4, 5 2019-11-01 30 0.9 1,025,898 7,129 Razor Energy Corp. Common Shares Sundstrom, Devin Kent 5 2019-11-01 30 0.9 226,691 2,592 Razor Energy Corp. Common Shares Sych, Stephen George 5 2019-11-01 30 0.9 189,760 3,240 Real Matters Inc. Common Shares Real Matters Inc. 1 2019-10-09 38 10.5 169 169
November 7, 2019 (2019), 42 OSCB 8727
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Real Matters Inc. Common Shares Real Matters Inc. 1 2019-10-09 38 10.5 0 -169 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-11-01 10 0.185 4,745,800 5,000 Relay Medical Corp. Common Shares Invidx Corp 3 2019-10-28 10 16,597,552 -14,000 (formerly, ChroMedX Corp). RepliCel Life Sciences Inc. Common Shares Hall, David M. 4, 5 2019-10-29 16 0.28 302,216 50,892 RepliCel Life Sciences Inc. Common Shares Lewis, Peter Winston 4 2019-10-30 11 0.28 75,610 34,821 RepliCel Life Sciences Inc. Common Shares Lowry, Peter 4 2019-10-29 16 0.28 657,716 34,821 Reservoir Capital Corp. Common Shares Gueneau, Vincent Thomas 3, 4 2018-09-21 00 Paul Reservoir Capital Corp. Common Shares Gueneau, Vincent Thomas 3, 4 2019-10-29 22 10,000,000 10,000,000 Paul Reservoir Capital Corp. Common Shares Gueneau, Vincent Thomas 3, 4 2018-09-21 00 88,800,000 Paul Reservoir Capital Corp. Common Shares Gueneau, Vincent Thomas 3, 4 2019-10-29 22 37,000,000 1,000,000 Paul Reservoir Capital Corp. Warrants Gueneau, Vincent Thomas 3, 4 2018-11-14 55 0.05 1,200,000 -2,800,000 Paul Reservoir Capital Corp. Warrants Gueneau, Vincent Thomas 3, 4 2018-12-07 55 0.05 0 -1,200,000 Paul Restaurant Brands Common Shares Macedo, Alexandre 5 2019-10-30 10 64.31 23,030 -63,035 International Inc. Restaurant Brands Common Shares Macedo, Alexandre 5 2019-10-30 10 64.55 0 -103,799 International Inc. Revival Gold Inc. Common Shares Agro, Hugh 3, 4, 5 2019-10-29 10 0.5 3,395,100 25,000 Richelieu Hardware Ltd. Unités d'actions différées Chicoyne, Denyse 4 2019-10-31 35 26.78 62,691 148 Richelieu Hardware Ltd. Unités d'actions différées Courteau, Robert 4, 5 2019-10-31 35 26.78 64,244 151 Richelieu Hardware Ltd. Unités d'actions différées Gauvin, Mathieu 4 2019-10-31 56 26.78 169 Richelieu Hardware Ltd. Unités d'actions différées Gauvin, Mathieu 4 2019-10-31 35 26.78 71,517 169 Richelieu Hardware Ltd. Unités d'actions différées Pomerleau, Pierre 4 2019-10-31 35 26.78 8,796 21 Richelieu Hardware Ltd. Unités d'actions différées Poulin, Marc 4 2019-10-31 35 26.78 18,945 45 Richelieu Hardware Ltd. Unités d'actions différées Proteau, Jocelyn 4 2019-10-30 35 26.78 34,630 82 Richelieu Hardware Ltd. Common Shares Quincaillerie Richelieu Ltée 1 2019-10-25 38 26.94 200,000 200,000 Richelieu Hardware Ltd. Common Shares Quincaillerie Richelieu Ltée 1 2019-10-25 38 26.94 0 -200,000 Richelieu Hardware Ltd. Unités d'actions différées Vachon, Sylvie 4 2019-10-31 56 26.78 21 Richelieu Hardware Ltd. Unités d'actions différées Vachon, Sylvie 4 2019-10-31 35 26.78 8,948 21 Ridgewood Canadian Units Ridgewood Capital Asset 3 2019-10-25 10 16.8 9,523,857 322 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2019-10-25 10 16.8 9,523,527 -330 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2019-10-28 10 16.8 9,524,529 1,002 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2019-10-28 10 16.8 9,523,502 -1,027 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2019-10-29 10 16.8 9,523,561 59 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2019-10-29 10 16.8 9,523,501 -60 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2019-10-30 10 16.798 9,524,853 1,352 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2019-10-30 10 16.8 9,523,778 -1,075 Investment Grade Bond Management Fund Ridgewood Canadian Units Simpson, John H. 5 2019-10-25 10 16.8 36,713 -330 Investment Grade Bond Fund Rise Gold Corp. Common Shares Lepard, Lawrence 4 2019-08-22 00 7,320,000 Rise Gold Corp. Options Lepard, Lawrence 4 2019-08-22 00 Rise Gold Corp. Options Lepard, Lawrence 4 2019-08-22 00
November 7, 2019 (2019), 42 OSCB 8728
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Riverside Resources Inc. Common Shares Staude, John-Mark 5 2019-10-28 10 0.145 1,868,460 1,000 Gardner Riverside Resources Inc. Common Shares Staude, John-Mark 5 2019-10-31 10 0.14 1,883,460 15,000 Gardner Riverside Resources Inc. Common Shares Staude, John-Mark 5 2019-10-31 10 0.15 1,888,460 5,000 Gardner Rogers Communications Non-Voting Shares Class Brooks, Bonnie 4 2019-10-24 46 6,487 184 Inc. B Rogers Communications Non-Voting Shares Class Brooks, Bonnie 4 2019-10-29 10 61.88 7,687 1,200 Inc. B Rogers Communications Non-Voting Shares Class Brooks, Bonnie 4 2019-10-29 10 61.91 7,987 300 Inc. B Rogers Communications Non-Voting Shares Class Clappison, John 4 2019-10-24 46 4,680 96 Inc. B Rogers Communications Non-Voting Shares Class Rogers, Edward 4, 6, 7, 5 2019-10-24 46 10,685 1,037 Inc. B Rogers Communications Non-Voting Shares Class Rogers, Loretta A. 4, 6 2019-10-24 46 55,617 319 Inc. B Rogers Communications Non-Voting Shares Class Rogers, Martha 4, 6 2019-10-24 46 6,547 319 Inc. B Rogers Communications Non-Voting Shares Class Rogers, Melinda M. 4, 6, 7 2019-10-24 46 5,978 518 Inc. B Route1 Inc. Common Shares Doolan, Michael Frederick 4 2019-10-31 10 4,122,393 8,093 Route1 Inc. Common Shares Fraser, David 4 2019-10-31 10 0.37 1,988,407 8,768 Route1 Inc. Common Shares Harris, Michael Deane 4 2019-10-31 10 0.37 4,940,605 13,489 Route1 Inc. Common Shares Marino, John 4 2019-10-31 10 0.375 8,000 Route1 Inc. Common Shares Marino, John 4 2019-10-31 10 0.375 8,000 Route1 Inc. Common Shares Marino, John 4 2019-10-31 10 0.375 725,901 8,000 Route1 Inc. Common Shares Reeder, Edward 4 2019-10-31 10 0.375 14,444 Route1 Inc. Common Shares Reeder, Edward 4 2019-10-31 10 0.375 227,203 14,444 Route1 Inc. Common Shares West, Barry Charles 4 2019-08-28 00 Route1 Inc. Common Shares West, Barry Charles 4 2019-10-31 10 0.375 3,333 Route1 Inc. Common Shares West, Barry Charles 4 2019-10-31 10 0.375 3,333 3,333 Royal Nickel Corporation Options Sloan, Graeme John 7 2019-10-28 00 500,000 dba as RNC Minerals Royal Nickel Corporation Rights Restricted Share Sloan, Graeme John 7 2019-10-28 00 100,000 dba as RNC Minerals Units Rubicon Organics Inc. Common Shares Savics, Eric 3 2019-10-25 10 1.7 66,400 20,000 Rugby Mining Limited Common Shares Adams, Alejandro 5 2019-10-30 11 0.1 146,133 50,000 Rugby Mining Limited Warrants Adams, Alejandro 5 2019-10-30 11 0.17 105,833 50,000 Sandspring Resources Ltd. Options Barnes, Phillip Gregory 4, 5 2019-10-29 50 2,300,000 500,000 Sandspring Resources Ltd. Options Beharry, Suresh Edward 4 2019-10-29 50 1,700,000 350,000 Sandspring Resources Ltd. Options Keep, Gordon 4 2019-10-29 50 1,690,000 650,000 Sandspring Resources Ltd. Options Keep, Gordon 4 2019-10-29 50 1,875,000 350,000 Sandspring Resources Ltd. Options Laing, David Charles 4 2019-10-29 50 1,700,000 350,000 Sandspring Resources Ltd. Options Munson, Richard Allen 4, 6, 5 2019-10-29 50 2,800,000 900,000 Sandspring Resources Ltd. Options Paes-Braga, Brian 3 2019-08-27 00 Alexander Sandspring Resources Ltd. Options Paes-Braga, Brian 3 2019-10-29 50 400,000 400,000 Alexander Sandspring Resources Ltd. Options Paredes Arenas, Lombardo 4, 6 2019-10-29 50 1,050,000 350,000 Sandspring Resources Ltd. Options Restrepo, Federico 4 2019-10-29 50 1,050,000 350,000 Savaria Corporation Common Shares BOURASSA, JEAN-MARIE 4, 6, 5 2002-03-07 00 Savaria Corporation Common Shares BOURASSA, JEAN-MARIE 4, 6, 5 2002-03-07 00 241,000 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2003-01-24 00 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2003-01-24 00 727,000 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2013-12-24 47 -125,000 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2013-12-24 47 157,900 -125,000 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2014-12-02 47 -125,000 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2014-12-02 47 32,900 -125,000 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2014-12-04 47 -125,000 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2003-01-24 00
November 7, 2019 (2019), 42 OSCB 8729
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2003-01-24 00 67,500 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2003-01-24 00 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2013-12-24 47 125,000 125,000 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2014-12-03 47 250,000 125,000 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2003-01-24 00 Savaria Corporation Common Shares Bourassa, Marcel 4, 6, 5 2003-01-24 00 7,699,300 ScoZinc Mining Ltd. Common Shares Billings, Mark Anthony 4 2019-10-25 00 ScoZinc Mining Ltd. Options Billings, Mark Anthony 4 2019-10-25 00 Secure Energy Services Inc. Units PSUs Callihoo, Michael Wayne 5 2019-07-30 00 22,411 Secure Energy Services Inc. Units RSUs Callihoo, Michael Wayne 5 2019-07-30 00 42,661 Sernova Corp. Common Shares Weber, Bruce Allen 4 2019-10-31 57 534,944 284,944 Sernova Corp. Rights Deferred Share Weber, Bruce Allen 4 2019-10-31 57 0 -284,944 Units Sharc International Systems Options Pannu, Hanspaul 5 2019-10-11 38 0.4 0 -120,000 Inc. (formerly, International Wastewater Systems Inc.) Shopify Inc. Multiple Voting Shares Finkelstein, Harley Michael 5 2019-10-31 51 0.152 2,459 2,459 Class B Multiple Voting Shares Shopify Inc. Multiple Voting Shares Finkelstein, Harley Michael 5 2019-10-31 36 0 -2,459 Class B Multiple Voting Shares Shopify Inc. Options Finkelstein, Harley Michael 5 2019-10-31 51 0.152 21,640 -2,459 Shopify Inc. Subordinate Voting Finkelstein, Harley Michael 5 2019-10-31 36 2,638 2,459 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Finkelstein, Harley Michael 5 2019-10-31 30 316.31 179 -2,459 Shares Class A Subordinate Voting Shares Shopify Inc. Options Frasca, Joseph Andrew 5 2019-10-29 51 62.15 38,449 -3,000 Shopify Inc. Subordinate Voting Frasca, Joseph Andrew 5 2019-10-29 51 62.15 4,905 3,000 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Frasca, Joseph Andrew 5 2019-10-29 30 304.11 1,905 -3,000 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Lutke, Tobias Albin 4, 5 2019-10-28 30 322.3 36,000 -4,000 Shares Class A Subordinate Voting Shares Shopify Inc. Options Shapero, Amy Elizabeth 5 2019-10-28 51 137.72 60,735 -149 Shopify Inc. Subordinate Voting Shapero, Amy Elizabeth 5 2019-10-28 51 137.72 5,699 149 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Shapero, Amy Elizabeth 5 2019-10-28 30 321.93 5,550 -149 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Shapero, Amy Elizabeth 5 2019-10-28 30 321.93 5,471 -79 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Weiser, Jeffrey Kane 5 2019-10-25 30 316.72 605 -161 Shares Class A Subordinate Voting Shares SilverCrest Metals Inc. Common Shares Campbell, Nicholas James 5 2019-09-10 54 1.45 381,500 47,500 SilverCrest Metals Inc. Warrants Campbell, Nicholas James 5 2019-09-10 54 0 -47,500 SilverCrest Metals Inc. Common Shares Ritchie, Christopher Kyle 5 2018-01-01 00 SilverCrest Metals Inc. Common Shares Ritchie, Christopher Kyle 5 2018-01-01 00 258,700 SilverCrest Metals Inc. Common Shares Yong, Anne 5 2019-10-31 54 1.45 49,334 12,000 SilverCrest Metals Inc. Warrants Yong, Anne 5 2019-10-31 54 0 -12,000
November 7, 2019 (2019), 42 OSCB 8730
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Sire Bioscience Inc. Common Shares Crudo, Domenic 5 2019-10-31 00 Sire Bioscience Inc. Options Crudo, Domenic 5 2019-10-31 00 Sire Bioscience Inc. Warrants Crudo, Domenic 5 2019-10-31 00 SITKA GOLD CORP. Common Shares Coe, Corwin 4, 5 2019-10-28 10 0.135 1,507,000 2,500 SITKA GOLD CORP. Common Shares COE, RYAN 4 2019-10-31 16 0.11 2,450,500 200,000 SITKA GOLD CORP. Warrants COE, RYAN 4 2019-10-31 16 0.16 1,302,000 100,000 Skyharbour Resources Ltd. Common Shares Trimble, Jordan 4 2019-10-28 10 0.195 789,250 10,000 Skyharbour Resources Ltd. Common Shares Trimble, Jordan 4 2019-10-30 10 0.19 794,250 5,000 Skyharbour Resources Ltd. Common Shares Trimble, Jordan 4 2019-10-31 10 0.1775 799,250 5,000 Skyharbour Resources Ltd. Common Shares Trimble, Jordan 4 2019-10-31 10 0.1775 804,250 5,000 Skyharbour Resources Ltd. Common Shares Trimble, Jordan 4 2019-11-01 10 0.1725 814,250 10,000 Skyharbour Resources Ltd. Common Shares Trimble, Jordan 4 2019-10-31 10 0.1775 5,000 Skyharbour Resources Ltd. Common Shares Trimble, Jordan 4 2019-10-31 10 0.1775 5,000 SmartCentres Real Estate Class B Series 1 Limited Goldhar, Mitchell 3 2019-10-30 11 32.59 6,110 6,110 Investment Trust (formerly, Partnership IV Units Smart Real Estate Investment Trust) SmartCentres Real Estate Class B Series 1 Limited Goldhar, Mitchell 3 2019-10-30 90 32.59 0 -6,110 Investment Trust (formerly, Partnership IV Units Smart Real Estate Investment Trust) SmartCentres Real Estate Class B Series 1 Limited Goldhar, Mitchell 3 2019-10-30 90 32.59 2,838,954 6,110 Investment Trust (formerly, Partnership IV Units Smart Real Estate Investment Trust) SmartCentres Real Estate Class C Series 1 Limited Goldhar, Mitchell 3 2019-10-30 11 28.7 387,859 -6,938 Investment Trust (formerly, Partnership IV Units Smart Real Estate Investment Trust) SmartCentres Real Estate Special Voting Units Goldhar, Mitchell 3 2019-10-30 11 6,110 6,110 Investment Trust (formerly, Smart Real Estate Investment Trust) SmartCentres Real Estate Special Voting Units Goldhar, Mitchell 3 2019-10-30 90 0 -6,110 Investment Trust (formerly, Smart Real Estate Investment Trust) SmartCentres Real Estate Special Voting Units Goldhar, Mitchell 3 2019-10-30 90 4,490,490 6,110 Investment Trust (formerly, Smart Real Estate Investment Trust) SmartCentres Real Estate Trust Units Goldhar, Mitchell 3 2019-10-28 11 32.25 1,193,378 -800,000 Investment Trust (formerly, Smart Real Estate Investment Trust) SmartCentres Real Estate Trust Units Goldhar, Mitchell 3 2019-10-28 11 32.25 12,367,369 800,000 Investment Trust (formerly, Smart Real Estate Investment Trust) Société d'exploration Common Shares Fedosiewich, Mark Brian 5 2019-10-25 10 0.11 5,678,500 3,000 minière Vior Inc. Société d'exploration Common Shares Fedosiewich, Mark Brian 5 2019-10-29 10 0.1 5,686,500 8,000 minière Vior Inc. Société d'exploration Common Shares Fedosiewich, Mark Brian 5 2019-10-29 10 0.11 5,689,500 3,000 minière Vior Inc. SoftLab9 Software Solutions Common Shares Pannu, Hanspaul 5 2019-03-05 37 89,067 -44,533 Inc. SoftLab9 Software Solutions Common Shares Pannu, Hanspaul 5 2019-08-26 37 6,851 -82,216 Inc. SoftLab9 Software Solutions Common Shares Pannu, Hanspaul 5 2019-09-02 16 0.09 562,406 555,555 Inc. SoftLab9 Software Solutions Options Pannu, Hanspaul 5 2019-10-31 38 0 -500,000 Inc. Sonoro Metals Corp. Common Shares Darch, John Michael 4 2019-10-29 10 0.15 611,500 10,000 Sonoro Metals Corp. Common Shares Darch, John Michael 4 2019-10-31 54 200000 200,000 Sonoro Metals Corp. Common Shares Darch, John Michael 4 2019-10-31 54 0.15 2,300,000 200,000 Sonoro Metals Corp. Common Shares Darch, John Michael 4 2019-10-31 54 0.15 2,600,000 300,000
November 7, 2019 (2019), 42 OSCB 8731
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Sonoro Metals Corp. Warrants Darch, John Michael 4 2019-10-31 54 0.15 300,000 -200,000 Sonoro Metals Corp. Warrants Darch, John Michael 4 2019-10-31 54 0.15 0 -300,000 Sonoro Metals Corp. Common Shares Kenwood, Stephen 4 2019-10-23 51 0.1 556,916 100,000 Sonoro Metals Corp. Options Kenwood, Stephen 4 2014-12-01 50 0.1 175,000 100,000 Sonoro Metals Corp. Options Kenwood, Stephen 4 2019-10-23 51 0.1 75,000 -100,000 Southern Arc Minerals Inc. Common Shares Morris, Klid 4 2019-10-31 16 0.35 516,020 155,050 Southern Arc Minerals Inc. Common Shares Proust, John Graham 4, 5 2005-06-21 00 Southern Arc Minerals Inc. Common Shares Proust, John Graham 4, 5 2019-10-31 16 0.35 1,150,000 1,150,000 Southern Arc Minerals Inc. Common Shares Subin, Neil S. 3 2019-10-31 11 0.35 118,069 20,369 Southern Arc Minerals Inc. Common Shares Subin, Neil S. 3 2019-10-31 11 0.35 19,940 3,440 Southern Arc Minerals Inc. Common Shares Subin, Neil S. 3 2019-10-31 11 0.35 643,156 110,956 Southern Arc Minerals Inc. Common Shares Subin, Neil S. 3 2019-10-31 11 0.35 644,968 111,268 Southern Arc Minerals Inc. Common Shares Subin, Neil S. 3 2019-10-31 11 0.35 1,500,817 258,917 Southstone Minerals Limted Common Shares Gallagher, Kevin Cormack 4 2019-10-29 37 145,658 -14,420,502 Southstone Minerals Limted Options Gallagher, Kevin Cormack 4 2019-10-29 36 135,000 -1,215,000 Southstone Minerals Limted Common Shares Khalaf, Samer 4 2019-10-29 37 588,000 -5,292,000 Southstone Minerals Limted Options Khalaf, Samer 4 2019-10-29 37 45,000 -405,000 Southstone Minerals Limted Common Shares Moroney, Donna 4, 5 2019-10-29 37 30,000 -270,000 Southstone Minerals Limted Options Moroney, Donna 4, 5 2019-10-29 37 100,000 -900,000 Southstone Minerals Limted Options Tucker, Terry Lee 4 2019-10-29 37 120,000 -1,080,000 Southstone Minerals Limted Warrants Tucker, Terry Lee 4 2019-10-29 37 170,000 -1,530,000 Southstone Minerals Limted Common Shares van der Loo, Simon 5 2019-10-29 37 50,000 -450,000 Southstone Minerals Limted Options van der Loo, Simon 5 2019-10-29 37 85,000 -765,000 Spark Power Group Inc. Rights CG Investments Inc. 3 2017-07-25 00 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Rights CG Investments Inc. 3 2019-10-08 56 3,421,667 3,421,667 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Rights CG Investments Inc. 3 2019-10-29 58 - Expiration of rights 3,421,667 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Rights CG Investments Inc. 3 2019-10-29 58 - Expiration of rights 3,421,667 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Rights CG Investments Inc. 3 2019-10-29 58 - Expiration 0 -3,421,667 (formerly Canaccord of rights Genuity Acquisition Corp.) Spark Power Group Inc. Rights CG Investments Inc. 3 2017-07-25 00 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Rights CG Investments Inc. 3 2019-10-08 56 1,015,420 1,015,420 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Rights CG Investments Inc. 3 2019-10-29 10 0.0005 957,420 -58,000 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Rights CG Investments Inc. 3 2019-10-29 58 - Expiration of rights -649,720 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Rights CG Investments Inc. 3 2019-10-29 58 - Expiration of rights -649,720 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Rights CG Investments Inc. 3 2019-10-29 58 - Expiration 0 -957,420 (formerly Canaccord of rights Genuity Acquisition Corp.) Spark Power Group Inc. Rights CG Investments Inc. 3 2017-07-25 00 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Common Shares Ranson, Sharon Margaret 4 2019-10-29 57 132,509 15,842 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Rights Rights Offering Ranson, Sharon Margaret 4 2018-08-31 00 (formerly Canaccord Genuity Acquisition Corp.)
November 7, 2019 (2019), 42 OSCB 8732
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Spark Power Group Inc. Rights Rights Offering Ranson, Sharon Margaret 4 2019-10-29 56 15,842 15,842 (formerly Canaccord Genuity Acquisition Corp.) Spark Power Group Inc. Rights Rights Offering Ranson, Sharon Margaret 4 2019-10-29 58 - Expiration 0 -15,842 (formerly Canaccord of rights Genuity Acquisition Corp.) Spark Power Group Inc. Common Shares Taylor, Larry Douglas 4 2019-10-29 57 0.96 333,859 45,144 (formerly Canaccord Genuity Acquisition Corp.) Sphinx Resources Ltd. Common Shares Biron, François 4 2019-10-25 10 0.03 245,000 45,000 Spot Coffee (Canada) Ltd. Common Shares AYOUB, ANTON MICHEL 4, 5 2019-10-30 10 0.095 2,239,458 1,500 Spot Coffee (Canada) Ltd. Common Shares AYOUB, ANTON MICHEL 4, 5 2019-10-31 10 0.095 2,240,958 1,500 Spot Coffee (Canada) Ltd. Common Shares Lorenzo, John Michael 4 2019-10-25 10 0.1 9,817,900 10,000 Spot Coffee (Canada) Ltd. Common Shares Lorenzo, John Michael 4 2019-10-28 10 0.1 9,827,900 10,000 Spot Coffee (Canada) Ltd. Common Shares Lorenzo, John Michael 4 2019-10-31 10 0.91 9,842,900 15,000 Spot Coffee (Canada) Ltd. Common Shares Lorenzo, John Michael 4 2019-10-31 10 0.9 9,858,900 16,000 SRG Mining Inc. Common Shares CORIS Capital SA 3 2019-10-24 54 0.5 12,583,333 1,125,000 SRG Mining Inc. Warrants CORIS Capital SA 3 2019-10-24 54 0.5 1,333,333 -1,125,000 St-Georges Eco-Mining Common Shares Dumas, Francois 4, 5 2019-11-01 10 0.08 7,122,641 50,000 Corp. St-Georges Eco-Mining Common Shares Dumas, Francois 4, 5 2019-11-01 10 0.08 7,222,641 100,000 Corp. St-Georges Eco-Mining Common Shares Dumas, Francois 4, 5 2019-11-01 10 0.065 7,271,641 49,000 Corp. St-Georges Eco-Mining Common Shares Dumas, Francois 4, 5 2019-11-01 10 0.075 7,322,641 51,000 Corp. Stella-Jones Inc. Common Shares Vachon, Eric 7 2016-09-07 10 43.92 -800 Stella-Jones Inc. Common Shares Vachon, Eric 7 2016-09-07 10 43.93 -200 Stella-Jones Inc. Common Shares Vachon, Eric 7 2016-09-07 10 43.96 -640 Stella-Jones Inc. Common Shares Vachon, Eric 7 2016-09-07 10 43.92 3,200 -800 Stella-Jones Inc. Common Shares Vachon, Eric 7 2016-09-07 10 43.93 3,000 -200 Stella-Jones Inc. Common Shares Vachon, Eric 7 2016-09-07 10 43.96 2,360 -640 Stella-Jones Inc. Common Shares Vachon, Eric 7 2016-08-08 90 411 -4,000 Stella-Jones Inc. Common Shares Vachon, Eric 7 2016-08-08 90 4,000 4,000 Steppe Gold Ltd. Convertible Debentures Tumur-Ochir, Bataa 4, 5 2018-05-03 00 Steppe Gold Ltd. Convertible Debentures Tumur-Ochir, Bataa 4, 5 2019-10-28 11 0.52 $2,500,000 $2,500,000 Storm Resources Ltd. Common Shares Conboy, Jamie Peter 5 2019-10-22 10 1.3735 550,048 -12,000 Stroud Resources Ltd. Common Shares Jobin-Bevans, Laurence 4, 5 2014-07-07 00 Scott Stroud Resources Ltd. Common Shares Jobin-Bevans, Laurence 4, 5 2014-07-07 00 Scott Stroud Resources Ltd. Common Shares Jobin-Bevans, Laurence 4, 5 2019-10-31 46 0.5 132,500 132,500 Scott Summit Industrial Income #NAME? Morassutti, Lawrence 4 2013-04-04 00 REIT Summit Industrial Income #NAME? Morassutti, Lawrence 4 2019-10-17 15 12.9 25,000 25,000 REIT Summit Industrial Income #NAME? Tadeson, Thomas James 4 2012-09-25 00 REIT Summit Industrial Income #NAME? Tadeson, Thomas James 4 2019-10-17 15 12.9 2,245 2,245 REIT Summit Industrial Income #NAME? Tadeson, Thomas James 4 2012-09-25 00 REIT Summit Industrial Income #NAME? Tadeson, Thomas James 4 2019-10-17 15 12.9 1,625 1,625 REIT Surge Energy Inc. Common Shares Monden, Rod J 5 2019-09-17 30 1.2499 389,540 716 Surge Energy Inc. Common Shares Monden, Rod J 5 2019-09-30 30 1.16 390,312 772 Synex International Inc. Common Shares Sgro, Danny 4 2019-02-07 00 Synex International Inc. Common Shares Sgro, Danny 4 2019-10-24 10 0.24 13,000 13,000 TAG Oil Ltd Common Shares TAG Oil Ltd. 1 2019-10-24 10 0.34 5,500 5,500 TAG Oil Ltd Common Shares TAG Oil Ltd. 1 2019-10-28 38 0 -5,500 Tamarack Valley Energy Common Shares Christensen, David Keith 5 2019-10-30 30 1.98 125,680 3,761 Ltd.
November 7, 2019 (2019), 42 OSCB 8733
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Tamarack Valley Energy Common Shares Cruikshank, Ken 5 2019-10-30 30 1.98 125,407 3,370 Ltd. Tamarack Valley Energy Common Shares Malek, Martin 5 2019-10-30 30 1.98 30,041 2,071 Ltd. Tamarack Valley Energy Common Shares Malek, Martin 5 2019-10-30 30 1.98 7,600 338 Ltd. Tamarack Valley Energy Common Shares Reimond, Scott William 5 2019-10-30 30 1.98 263,522 3,370 Ltd. Tamarack Valley Energy Common Shares Schmidt, Brian Leslie 5 2019-10-30 30 1.98 668,347 5,554 Ltd. Tamarack Valley Energy Common Shares Screen, Kevin 5 2019-10-30 30 1.98 358,706 3,875 Ltd. Tanzanian Gold Corporation Common Shares Harvey, William 4 2019-10-30 10 0.7649 175,424 -5,000 Target Capital Inc. Common Shares Mottahed, Shahin (Sonny) 4, 5 2019-10-28 10 0.02 5,708,000 11,000 Target Capital Inc. Common Shares Mottahed, Shahin (Sonny) 4, 5 2019-10-30 10 0.02 5,793,000 85,000 Target Capital Inc. Common Shares Mottahed, Shahin (Sonny) 4, 5 2019-10-31 10 0.02 6,063,000 270,000 Tartisan Nickel Corp. Common Shares Appleby, D. Mark 4, 5 2019-10-25 10 0.045 2,327,000 155,000 Tartisan Nickel Corp. Common Shares Appleby, D. Mark 4, 5 2019-10-25 10 0.05 2,337,000 10,000 Tartisan Nickel Corp. Common Shares Appleby, D. Mark 4, 5 2019-10-28 10 0.045 2,449,000 112,000 Tartisan Nickel Corp. Common Shares Appleby, D. Mark 4, 5 2019-10-28 10 0.05 2,637,000 188,000 Tartisan Nickel Corp. Common Shares Appleby, D. Mark 4, 5 2019-10-29 10 0.045 2,647,000 10,000 Tartisan Nickel Corp. Common Shares Appleby, D. Mark 4, 5 2019-10-29 10 0.05 2,827,000 180,000 Teck Resources Limited Class B Subordinate Andres, Dale Edwin 5 2019-10-30 10 21.58 64,200 4,200 Voting Shares Teck Resources Limited Class B Subordinate Andres, Dale Edwin 5 2019-10-30 10 21.57 65,000 800 Voting Shares Teck Resources Limited Class B Subordinate Andres, Dale Edwin 5 2019-10-31 10 20.92 70,000 5,000 Voting Shares Teck Resources Limited Class B Subordinate Teck Resources Limited 1 2019-10-29 38 16.884 45,284 45,284 Voting Shares Teck Resources Limited Class B Subordinate Teck Resources Limited 1 2019-10-29 38 22.112 86,284 41,000 Voting Shares Teck Resources Limited Class B Subordinate Teck Resources Limited 1 2019-10-30 38 16.346 233,084 146,800 Voting Shares Teck Resources Limited Class B Subordinate Teck Resources Limited 1 2019-10-30 38 21.496 379,884 146,800 Voting Shares Teck Resources Limited Class B Subordinate Teck Resources Limited 1 2019-10-31 38 15.761 576,684 196,800 Voting Shares Teck Resources Limited Class B Subordinate Teck Resources Limited 1 2019-10-31 38 20.708 673,484 96,800 Voting Shares Temple Hotels Inc. Common Shares Armoyan, Sime 3 2019-10-23 10 1.75 12,518,534 1,000 Temple Hotels Inc. Common Shares Armoyan, Sime 3 2019-10-23 10 1.75 12,519,434 900 Temple Hotels Inc. Common Shares Armoyan, Sime 3 2019-10-25 10 1.75 12,519,734 300 Temple Hotels Inc. Common Shares Armoyan, Sime 3 2019-10-25 10 1.76 12,529,734 10,000 Temple Hotels Inc. Common Shares Armoyan, Sime 3 2019-10-28 10 1.78 12,537,934 8,200 Temple Hotels Inc. Common Shares Armoyan, Sime 3 2019-10-28 10 1.77 12,559,934 22,000 Temple Hotels Inc. Common Shares Armoyan, Sime 3 2019-10-28 10 1.809 12,664,834 104,900 TerraVest Industries Inc. Common Shares Gering, Michael 1 2019-10-28 10 12.5 103,939 -4,200 (formerly TerraVest Capital Inc.) TerraVest Industries Inc. Common Shares Gering, Michael 1 2019-10-28 10 12.51 103,539 -400 (formerly TerraVest Capital Inc.) TFI International Inc. Common Shares TFI International Inc. 1 2019-10-01 38 40.17 90,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-02 38 39 105,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-03 38 30,419 -75,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-03 38 38.5 45,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-04 38 38.79 60,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-07 38 38.74 75,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-08 38 37.99 90,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-09 38 38.29 105,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-10 38 39.62 120,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-11 38 40.5 135,419 15,000
November 7, 2019 (2019), 42 OSCB 8734
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed TFI International Inc. Common Shares TFI International Inc. 1 2019-10-15 38 40.32 150,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-16 38 40.78 165,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-18 38 40.99 180,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-18 38 41.24 195,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-21 38 41.67 210,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-22 38 41.91 225,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-23 38 41.83 240,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-24 38 41.94 255,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-25 38 42.47 270,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-28 38 41.75 285,419 15,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-29 38 41.28 310,419 25,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-30 38 41.56 335,419 25,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-31 38 41.64 360,419 25,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-10-31 38 65,419 -295,000 The Yield Growth Corp. Options Karla Deeaan, Williams 5 2019-10-21 00 500,000 The Yield Growth Corp. Common Shares Pineo, Krystal 4 2019-10-30 10 0.295 3,197,500 -5,000 The Yield Growth Corp. Common Shares Pineo, Krystal 4 2019-10-30 10 0.295 3,193,000 -4,500 The Yield Growth Corp. Common Shares Pineo, Krystal 4 2019-10-30 10 0.295 3,189,500 -3,500 The Yield Growth Corp. Common Shares Pineo, Krystal 4 2019-10-30 10 0.295 3,184,500 -5,000 The Yield Growth Corp. Common Shares Pineo, Krystal 4 2019-10-30 10 0.285 3,169,500 -15,000 The Yield Growth Corp. Common Shares Pineo, Krystal 4 2019-10-30 10 0.29 3,167,500 -2,000 The Yield Growth Corp. Common Shares Pineo, Krystal 4 2019-10-31 10 0.28 3,147,500 -20,000 The Yield Growth Corp. Common Shares Pineo, Krystal 4 2019-11-01 10 0.285 3,135,500 -12,000 The Yield Growth Corp. Common Shares Pineo, Krystal 4 2019-11-01 10 0.29 3,120,500 -15,000 The Yield Growth Corp. Common Shares White, Penny Olga 3, 4, 5 2019-10-29 10 0.3125 669,500 -36,500 Tidewater Midstream and Common Shares McDonnell, Reed 5 2019-10-28 57 0.98 369,773 143,000 Infrastructure Ltd. Tidewater Midstream and Common Shares McDonnell, Reed 5 2019-10-28 57 0.98 458,207 88,434 Infrastructure Ltd. Tidewater Midstream and Common Shares McDonnell, Reed 5 2019-10-28 57 0.98 508,342 50,135 Infrastructure Ltd. Tidewater Midstream and Common Shares McDonnell, Reed 5 2019-10-28 57 0.99 3,090 Infrastructure Ltd. Tidewater Midstream and Common Shares McDonnell, Reed 5 2019-10-28 57 0.98 511,432 3,090 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units McDonnell, Reed 5 2019-10-28 57 0.98 749,821 -275,000 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units McDonnell, Reed 5 2019-10-28 57 0.98 579,750 -170,071 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units McDonnell, Reed 5 2019-10-28 57 0.98 483,332 -96,418 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units McDonnell, Reed 5 2019-10-28 57 0.98 477,388 -5,944 Infrastructure Ltd. Tidewater Midstream and Common Shares Mckenna, Tobias John 4, 5 2019-10-28 57 0.98 1,344,903 143,000 Infrastructure Ltd. Tidewater Midstream and Common Shares Mckenna, Tobias John 4, 5 2019-10-28 57 89621 89,621 Infrastructure Ltd. Tidewater Midstream and Common Shares Mckenna, Tobias John 4, 5 2019-10-28 57 0.98 1,434,524 89,621 Infrastructure Ltd. Tidewater Midstream and Common Shares Mckenna, Tobias John 4, 5 2019-10-28 57 52004 52,004 Infrastructure Ltd. Tidewater Midstream and Common Shares Mckenna, Tobias John 4, 5 2019-10-28 57 0.98 1,486,528 52,004 Infrastructure Ltd. Tidewater Midstream and Common Shares Mckenna, Tobias John 4, 5 2019-10-28 57 0.98 1,489,663 3,135 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units Mckenna, Tobias John 4, 5 2019-10-28 57 0.98 755,697 -275,000 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units Mckenna, Tobias John 4, 5 2019-10-28 57 0.98 583,343 -172,354 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units Mckenna, Tobias John 4, 5 2019-10-28 57 0.98 483,333 -100,010 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units Mckenna, Tobias John 4, 5 2019-10-28 57 0.98 477,302 -6,031 Infrastructure Ltd.
November 7, 2019 (2019), 42 OSCB 8735
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Tidewater Midstream and Common Shares Vorra, Joel Kyle 5 2019-10-29 57 0.98 451,603 143,000 Infrastructure Ltd. Tidewater Midstream and Common Shares Vorra, Joel Kyle 5 2019-10-29 57 0.98 541,224 89,621 Infrastructure Ltd. Tidewater Midstream and Common Shares Vorra, Joel Kyle 5 2019-10-29 57 0.98 593,215 51,991 Infrastructure Ltd. Tidewater Midstream and Common Shares Vorra, Joel Kyle 5 2019-10-29 57 0.98 596,350 3,135 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units Vorra, Joel Kyle 5 2019-10-29 57 0.98 755,674 -275,000 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units Vorra, Joel Kyle 5 2019-10-29 57 0.98 583,320 -172,354 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units Vorra, Joel Kyle 5 2019-10-29 57 0.98 483,333 -99,987 Infrastructure Ltd. Tidewater Midstream and Restricted Share Units Vorra, Joel Kyle 5 2019-10-29 57 0.98 477,302 -6,031 Infrastructure Ltd. Tocvan Ventures Corp. Options Ball, Gregory Edward 4, 5 2019-10-24 50 0.15 112,500 50,000 Tocvan Ventures Corp. Options Smethurst, Mark Trevelyan 4 2019-10-24 50 0.15 300,000 150,000 Tocvan Ventures Corp. Options Sutherland, Brodie Alan 4 2019-10-24 50 0.15 285,000 150,000 Tocvan Ventures Corp. Options Wood, Derek 4, 5 2019-10-24 50 0.15 285,000 150,000 Top Strike Resources Corp Common Shares Sharun, Jonathan Robert 5 2019-10-31 10 0.025 14,703,800 40,000 Torrent Capital Ltd. Common Shares Dawe, Wade K. 5 2019-10-28 10 0.35 3,006,000 12,000 Torrent Capital Ltd. Common Shares Dawe, Wade K. 5 2019-10-28 10 0.365 1,445,000 3,000 Torrent Capital Ltd. Common Shares Dawe, Wade K. 5 2019-10-28 10 0.36 1,455,000 10,000 Torrent Capital Ltd. Common Shares Dawe, Wade K. 5 2019-10-28 10 0.355 1,458,000 3,000 Total Energy Services Inc. Common Shares Total Energy Services Inc 1 2019-10-29 10 6.5247 28,100 18,100 Tourmaline Oil Corp. Common Shares Rose, Mike 5 2019-10-28 10 11.51 10,549,330 2,500 Tourmaline Oil Corp. Common Shares Tourmaline Oil Corp. 1 2019-10-28 38 11.559 520,000 50,000 Tourmaline Oil Corp. Common Shares Tourmaline Oil Corp. 1 2019-10-29 38 11.676 570,000 50,000 TransAlta Renewables Inc. DSU (Deferred Share Drinkwater, David William 4 2019-10-31 56 14.18 25,362 139 Units) TransAlta Renewables Inc. DSU (Deferred Share Hagerman, Allen R. 4 2019-10-31 56 14.18 152 Units) TransAlta Renewables Inc. DSU (Deferred Share Hagerman, Allen R. 4 2019-10-31 56 14.18 152 Units) TransAlta Renewables Inc. DSU (Deferred Share Hagerman, Allen R. 4 2019-10-31 56 14.18 27,769 153 Units) TransAlta Renewables Inc. DSU (Deferred Share McQuade, Kathryn Ann 4 2019-10-31 56 14.18 28,749 158 Units) Bova TransAlta Renewables Inc. DSU (Deferred Share TAYLOR, PAUL H. E. 4 2019-10-31 56 14.18 30,350 167 Units) TransCanada PipeLines Common Shares TC Energy Corporation 3 2019-10-31 11 66.38 902,108,711 3,719,141 Limited Transcanna Holdings Inc. Common Shares Johannson, Arni Thomas 4 2019-10-28 10 0.49 1,920,000 1,000 Transcanna Holdings Inc. Common Shares Johannson, Arni Thomas 4 2019-10-28 10 0.5 1,939,000 19,000 Transcanna Holdings Inc. Common Shares Johannson, Arni Thomas 4 2019-10-29 10 0.46 1,942,000 3,000 Transcanna Holdings Inc. Common Shares Johannson, Arni Thomas 4 2019-10-29 10 0.48 1,949,000 7,000 Transcanna Holdings Inc. Common Shares Johannson, Arni Thomas 4 2019-10-29 10 0.49 1,951,000 2,000 Transcontinental Inc. Participation Units Brues, Peter 4 2019-10-27 56 15.32 8,352 2,072 d'actions différées (UAD- administrateurs) / (DSU- directors) Transcontinental Inc. Participation Units Cote, Jacynthe 4 2019-10-27 56 15.32 20,223 2,024 d'actions différées (UAD- administrateurs) / (DSU- directors) Transcontinental Inc. Participation Units Leduc, Yves 4 2019-10-27 56 15.32 10,804 1,632 d'actions différées (UAD- administrateurs) / (DSU- directors) Transcontinental Inc. Participation Units Martini, Anna 4 2019-10-27 56 15.32 52,965 1,877 d'actions différées (UAD- administrateurs) / (DSU- directors)
November 7, 2019 (2019), 42 OSCB 8736
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Transcontinental Inc. Participation Units Plourde, Mario 4 2019-10-27 56 15.32 23,516 1,762 d'actions différées (UAD- administrateurs) / (DSU- directors) Transcontinental Inc. Participation Units Raymond, Jean 4 2019-10-27 56 15.32 13,978 1,665 d'actions différées (UAD- administrateurs) / (DSU- directors) Transcontinental Inc. Participation Units Thabet, Annie 4 2019-10-27 56 15.32 14,920 922 d'actions différées (UAD- administrateurs) / (DSU- directors) TREE OF KNOWLEDGE Common Shares Caridi, Michael 4 2019-10-30 10 0.05 12,663,429 165,000 INTERNATIONAL CORP. Trevali Mining Corporation Common Shares Trevali Mining Corporation 1 2019-10-28 38 1,490,000 -1,153,500 Trevali Mining Corporation Common Shares Trevali Mining Corporation 1 2019-10-28 38 0.2114 1,778,000 288,000 Trevali Mining Corporation Common Shares Trevali Mining Corporation 1 2019-10-29 38 0.2012 2,081,000 303,000 Trigon Metals Inc. Common Shares Silvercorp Metals Inc. 3 2019-10-25 10 0.18 7,165,500 -23,000 Trigon Metals Inc. Common Shares Silvercorp Metals Inc. 3 2019-10-29 10 0.18 7,137,500 -28,000 Trigon Metals Inc. Common Shares Silvercorp Metals Inc. 3 2019-10-30 10 0.18 7,134,500 -3,000 Trigon Metals Inc. Common Shares Silvercorp Metals Inc. 3 2019-10-31 10 0.18 7,134,000 -500 Trilogy Metals Inc. (formerly Common Shares Jacko, Robert Michael 5 2019-10-24 10 1.88 17,646 2,646 NovaCopper Inc.) Tudor Gold Corp. Common Shares Pownall, Sean Patrick 4 2019-10-02 51 0.4 5,055,321 987,500 Tudor Gold Corp. Common Shares Pownall, Sean Patrick 4 2019-10-23 10 0.6 5,005,321 -35,000 Tudor Gold Corp. Warrants Pownall, Sean Patrick 4 2018-12-19 00 1,506,250 Tudor Gold Corp. Warrants Pownall, Sean Patrick 4 2019-10-02 54 0.4 518,750 -987,500 TWC Enterprises Limited Common Shares TWC Enterprises Limited 1 2019-10-21 38 13.36 900 900 TWC Enterprises Limited Common Shares TWC Enterprises Limited 1 2019-10-21 38 0 -900 Ubique Minerals Limited Common Shares Harper, Gerald 4, 5 2019-10-29 54 0.1 2,916,379 100,000 Ubique Minerals Limited Warrants Harper, Gerald 4, 5 2019-10-29 54 0.1 475,000 -100,000 Ucore Rare Metals Inc. Rights Dostal, Jaroslav 4 2007-08-17 00 Ucore Rare Metals Inc. Rights Dostal, Jaroslav 4 2019-09-20 56 0.1 36,000 36,000 Ucore Rare Metals Inc. Rights Dostal, Jaroslav 4 2019-10-23 58 - Expiration 0 -36,000 of rights Ucore Rare Metals Inc. Common Shares Johnson, Randy T. 3 2019-10-25 57 0.1 51,124,067 10,000,000 Ucore Rare Metals Inc. Rights Johnson, Randy T. 3 2019-10-25 57 27,266,367 -10,000,000 Ucore Rare Metals Inc. Rights Johnson, Randy T. 3 2019-10-25 58 - Expiration 0 -27,266,367 of rights Ucore Rare Metals Inc. Common Shares Manuel, Peter Allan 5 2019-10-23 57 0.1 710,000 460,000 Ucore Rare Metals Inc. Rights $0.10 Rights Manuel, Peter Allan 5 2009-09-21 00 Expiring Oct 23, 2019 Ucore Rare Metals Inc. Rights $0.10 Rights Manuel, Peter Allan 5 2019-10-23 10 0.01 300 300 Expiring Oct 23, 2019 Ucore Rare Metals Inc. Rights $0.10 Rights Manuel, Peter Allan 5 2019-10-23 56 250,300 250,000 Expiring Oct 23, 2019 Ucore Rare Metals Inc. Rights $0.10 Rights Manuel, Peter Allan 5 2019-10-23 57 0 -250,300 Expiring Oct 23, 2019 Ucore Rare Metals Inc. Common Shares McKenzie, James Stephen 5 2019-10-23 57 0.1 7,164,900 1,380,000 Ucore Rare Metals Inc. Rights McKenzie, James Stephen 5 2006-11-0100 Ucore Rare Metals Inc. Rights McKenzie, James Stephen 5 2019-09-17 56 5,373,400 5,373,400 Ucore Rare Metals Inc. Rights McKenzie, James Stephen 5 2019-10-23 57 3,993,400 -1,380,000 Ucore Rare Metals Inc. Rights McKenzie, James Stephen 5 2019-10-23 58 - Expiration 0 -3,993,400 of rights Ucore Rare Metals Inc. Common Shares Meister, Steven Harold 4 2016-11-01 00 Ucore Rare Metals Inc. Common Shares Meister, Steven Harold 4 2016-11-01 10 22,000 22,000 Ucore Rare Metals Inc. Common Shares Meister, Steven Harold 4 2019-10-25 57 0.1 144,000 122,000 Ucore Rare Metals Inc. Common Shares Meister, Steven Harold 4 2019-10-29 10 0.1 166,000 22,000 Ucore Rare Metals Inc. Rights Meister, Steven Harold 4 2016-11-01 00 Ucore Rare Metals Inc. Rights Meister, Steven Harold 4 2019-09-20 56 0.1 22,000 22,000 Ucore Rare Metals Inc. Rights Meister, Steven Harold 4 2019-09-23 10 44,000 22,000 Ucore Rare Metals Inc. Rights Meister, Steven Harold 4 2019-10-10 10 144,000 100,000 Ucore Rare Metals Inc. Rights Meister, Steven Harold 4 2019-10-23 57 22,000 -122,000
November 7, 2019 (2019), 42 OSCB 8737
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed Ucore Rare Metals Inc. Rights Meister, Steven Harold 4 2019-10-23 58 - Expiration 0 -22,000 of rights Ucore Rare Metals Inc. Common Shares Orca Holdings, LLC 3 2019-10-25 57 0.1 51,124,067 10,000,000 Ucore Rare Metals Inc. Rights Orca Holdings, LLC 3 2019-10-25 57 27,266,367 -10,000,000 Ucore Rare Metals Inc. Rights Orca Holdings, LLC 3 2019-10-25 58 - Expiration 0 -27,266,367 of rights Uniserve Communications Common Shares Nelson, Gordon Thomas 4 2019-09-29 00 100,000 Corporation Uniserve Communications Common Shares Scholz, Michael Curt 4 2019-10-28 10 0.06 6,000 Corporation Uniserve Communications Common Shares Scholz, Michael Curt 4 2019-10-28 10 0.1 1,000,747 6,000 Corporation Uniserve Communications Common Shares Scholz, Michael Curt 4 2019-10-30 10 0.1 1,006,247 5,500 Corporation United Corporations Limited Common Shares E-L Financial Corporation 3 2019-10-25 10 94 6,369,859 200 Limited Valens Groworks Corp. Options Zakrevsky, Ernestina 5 2019-08-19 00 50,000 (formerly Genovation Capital Corp.) Vecima Networks Inc. Common Shares Wood, Hugh Charles 3 2019-10-29 10 9.4 1,789,600 -200,000 Vecima Networks Inc. Common Shares Wood, Hugh Charles 3 2019-10-31 10 9.4 1,589,600 -200,000 Velocity Data Inc. (formerly Common Shares Class A Bates, Robert Lee 4, 5 2014-07-18 00 GTO Resources Inc.) Velocity Data Inc. (formerly Common Shares Class A Bates, Robert Lee 4, 5 2019-09-01 90 4,210,414 4,210,414 GTO Resources Inc.) Ventripoint Diagnostics Ltd. Common Shares Dalla-Longa, Danny 4, 5 2019-09-03 11 0.15 16,500 (formerly Luca Capital Inc.) Ventripoint Diagnostics Ltd. Common Shares Dalla-Longa, Danny 4, 5 2019-09-03 11 0.15 110,000 (formerly Luca Capital Inc.) Ventripoint Diagnostics Ltd. Common Shares Dalla-Longa, Danny 4, 5 2019-10-03 11 0.15 448,467 110,000 (formerly Luca Capital Inc.) Ventura Cannabis and Options Kaplan, Lloyd 4 2019-10-28 00 Wellness Corp. (formerly BLVD Centers Corporation) Ventura Cannabis and Options Kaplan, Lloyd 4 2019-10-28 00 Wellness Corp. (formerly BLVD Centers Corporation) Ventura Cannabis and Options Kaplan, Lloyd 4 2019-10-28 00 250,000 Wellness Corp. (formerly BLVD Centers Corporation) VIQ Solutions Inc. Common Shares Taylor, Larry Douglas 4 2019-10-28 10 0.1 7,093,687 11,500 VIQ Solutions Inc. Common Shares Taylor, Larry Douglas 4 2019-10-28 10 0.095 7,094,687 1,000 VIQ Solutions Inc. Common Shares Taylor, Larry Douglas 4 2019-10-28 10 0.09 7,095,187 500 VIQ Solutions Inc. Common Shares Wells, Bradley W. 4 2019-09-25 00 VIQ Solutions Inc. Common Shares Wells, Bradley W. 4 2019-09-25 00 23,599,756 VIVO Cannabis Inc. Common Shares Laflamme, Daniel 3, 4, 5 2019-10-28 10 0.3 36,958,539 -20,000 VIVO Cannabis Inc. Common Shares Laflamme, Daniel 3, 4, 5 2019-10-29 10 0.295 36,938,539 -20,000 VIVO Cannabis Inc. Common Shares Laflamme, Daniel 3, 4, 5 2019-10-30 10 0.2858 36,918,539 -20,000 VIVO Cannabis Inc. Common Shares Laflamme, Daniel 3, 4, 5 2019-10-31 10 0.26 36,898,539 -20,000 VIVO Cannabis Inc. Common Shares Laflamme, Daniel 3, 4, 5 2019-11-01 10 0.265 36,878,539 -20,000 Volatus Capital Corp. Common Shares Crest Resources Inc. 3 2019-10-07 11 0.075 3,600,000 1,600,000 Voleo Trading Systems Inc. Common Shares Wilson, Glen Patrick 4 2019-10-25 10 0.065 3,043,683 5,000 VR Resources Ltd. Common Shares Thomson, Michael Gary 3, 4, 5 2019-10-29 10 0.2524 494,666 -176,000 VR Resources Ltd. Common Shares Thomson, Michael Gary 3, 4, 5 2019-10-29 10 0.253 487,166 -7,500 VR Resources Ltd. Common Shares Thomson, Michael Gary 3, 4, 5 2019-10-29 10 0.25 482,666 -4,500 VR Resources Ltd. Common Shares Thomson, Michael Gary 3, 4, 5 2019-10-29 10 0.251 438,666 -44,000 Wallbridge Mining Company Common Shares Day, Shawn 4 2019-10-25 10 0.485 487,000 21,000 Limited Western Resources Corp. Common Shares Venter, Frederick 4, 5 2019-10-29 10 0.28 228,000 1,000 Christiaan WestJet Airlines Ltd. Rights Deferred Share Beddoe, Clive 5 2019-09-27 56 327 Units WestJet Airlines Ltd. Rights Deferred Share Beddoe, Clive 5 2019-09-27 30 45 Units
November 7, 2019 (2019), 42 OSCB 8738
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed WestJet Airlines Ltd. Rights Deferred Share Beddoe, Clive 5 2019-09-30 56 10,022 327 Units WestJet Airlines Ltd. Rights Deferred Share Beddoe, Clive 5 2019-09-30 30 10,067 45 Units WestJet Airlines Ltd. Rights Deferred Share Brenneman, Ron A. 4 2019-09-27 56 469 Units WestJet Airlines Ltd. Rights Deferred Share Brenneman, Ron A. 4 2019-09-27 30 65 Units WestJet Airlines Ltd. Rights Deferred Share Brenneman, Ron A. 4 2019-09-30 56 14,581 469 Units WestJet Airlines Ltd. Rights Deferred Share Brenneman, Ron A. 4 2019-09-30 30 14,646 65 Units WestJet Airlines Ltd. Rights Deferred Share Burley, Christopher 4 2019-09-27 56 1,142 Units Michael WestJet Airlines Ltd. Rights Deferred Share Burley, Christopher 4 2019-09-27 30 109 Units Michael WestJet Airlines Ltd. Rights Deferred Share Burley, Christopher 4 2019-09-30 56 24,871 1,142 Units Michael WestJet Airlines Ltd. Rights Deferred Share Burley, Christopher 4 2019-09-30 30 24,980 109 Units Michael WestJet Airlines Ltd. Rights Deferred Share Godfrey, Brett Alan 4 2019-09-27 56 469 Units WestJet Airlines Ltd. Rights Deferred Share Godfrey, Brett Alan 4 2019-09-27 30 73 Units WestJet Airlines Ltd. Rights Deferred Share Godfrey, Brett Alan 4 2019-09-30 56 16,312 469 Units WestJet Airlines Ltd. Rights Deferred Share Godfrey, Brett Alan 4 2019-09-30 30 16,385 73 Units WestJet Airlines Ltd. Rights Deferred Share Jackson, Allan William 4 2019-09-27 56 1,183 Units WestJet Airlines Ltd. Rights Deferred Share Jackson, Allan William 4 2019-09-27 30 323 Units WestJet Airlines Ltd. Rights Deferred Share Jackson, Allan William 4 2019-09-30 56 71,730 1,183 Units WestJet Airlines Ltd. Rights Deferred Share Jackson, Allan William 4 2019-09-30 30 72,053 323 Units WestJet Airlines Ltd. Rights Deferred Share Jackson, Steven Barry 4 2019-09-27 56 1,036 Units WestJet Airlines Ltd. Rights Deferred Share Jackson, Steven Barry 4 2019-09-27 30 243 Units WestJet Airlines Ltd. Rights Deferred Share Jackson, Steven Barry 4 2019-09-30 56 54,249 1,036 Units WestJet Airlines Ltd. Rights Deferred Share Jackson, Steven Barry 4 2019-09-30 30 54,492 243 Units WestJet Airlines Ltd. Rights Deferred Share Johnston, Colleen 4 2019-09-27 56 469 Units WestJet Airlines Ltd. Rights Deferred Share Johnston, Colleen 4 2019-09-27 30 10 Units WestJet Airlines Ltd. Rights Deferred Share Johnston, Colleen 4 2019-09-30 56 2,513 469 Units WestJet Airlines Ltd. Rights Deferred Share Johnston, Colleen 4 2019-09-30 30 2,523 10 Units WestJet Airlines Ltd. Rights Deferred Share Rennie, Janice Gaye 4 2019-09-27 56 1,101 Units WestJet Airlines Ltd. Rights Deferred Share Rennie, Janice Gaye 4 2019-09-27 30 140 Units WestJet Airlines Ltd. Rights Deferred Share Rennie, Janice Gaye 4 2019-09-30 56 31,597 1,101 Units WestJet Airlines Ltd. Rights Deferred Share Rennie, Janice Gaye 4 2019-09-30 30 31,737 140 Units WestJet Airlines Ltd. Rights Deferred Share Sheriff, Karen 4 2019-09-27 56 1,101 Units WestJet Airlines Ltd. Rights Deferred Share Sheriff, Karen 4 2019-09-27 30 95 Units WestJet Airlines Ltd. Rights Deferred Share Sheriff, Karen 4 2019-09-30 56 21,860 1,101 Units
November 7, 2019 (2019), 42 OSCB 8739
Insider Reporting
Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month Acquired/ Date Price End Holdings Disposed WestJet Airlines Ltd. Rights Deferred Share Sheriff, Karen 4 2019-09-30 30 21,955 95 Units White Gold Corp. Common Shares D'Onofrio, David 4, 5 2019-10-27 54 0.27 1,183,333 550,000 White Gold Corp. Warrants non flow- D'Onofrio, David 4, 5 2019-10-27 54 0.27 0 -550,000 through White Gold Corp. Common Shares DiCapo, Pasquale 3 2019-10-27 54 0.27 11,400,000 5,650,000 White Gold Corp. Warrants non flow- DiCapo, Pasquale 3 2019-10-27 54 0.27 0 -5,650,000 through White Metal Resources Warrants Strashin, Elliot Phillip 3, 4, 5 2019-11-01 55 0.1 367,500 -1,000,000 Corp. Wikileaf Technologies Inc. Options Lalonde, Patrick 5 2019-10-25 38 980,780 -2,943,755 Willow Biosciences Inc. Common Shares Peters, Trevor Anthony 4, 5 2019-10-28 10 0.76 3,177,563 50,000 Willow Biosciences Inc. Common Shares Peters, Trevor Anthony 4, 5 2019-10-31 10 0.74 3,227,563 50,000 Wow Unlimited Media Inc. Common Shares Voting Hirsh, Michael 4 2019-10-25 10 0.6 129,000 29,000 (formerly, Rainmaker Entertainment Inc.) X-Terra Resources Inc. Common Shares Ferreira, Michael 4, 5 2019-11-01 10 0.14 551,000 10,000 XORTX Therapeutics Inc. Common Shares Williams, Allan William 4 2019-10-30 10 0.18 1,997,770 12,500 (formerly: APAC Resources Inc.) Xtra-Gold Resources Corp. Common Shares Xtra-Gold Resources Corp. 1 2019-08-28 38 0.39 500 500 Xtra-Gold Resources Corp. Common Shares Xtra-Gold Resources Corp. 1 2019-08-28 38 0 -500 Yellow Pages Digital & 10% Senior Secured Yellow Pages Digital & 1 2019-11-01 38 1010 $30,000,000 $30,000,000 Media Solutions Limited Notes due Oct 19, 2022 Media Solutions Limited / Pages Jaunes Solutions numériques et médias Limitée Yellow Pages Digital & 10% Senior Secured Yellow Pages Digital & 1 2019-11-01 38 1010 $0 -$30,000,000 Media Solutions Limited Notes due Oct 19, 2022 Media Solutions Limited / Pages Jaunes Solutions numériques et médias Limitée Zedcor Energy Inc. Common Shares Swanberg, Dean Sylvan 3, 4, 5 2019-10-23 10 0.07 1,272,018 491,000
November 7, 2019 (2019), 42 OSCB 8740
Chapter 11
IPOs, New Issues and Secondary Financings
INVESTMENT FUNDS Issuer Name: Issuer Name: Dividend Growth Split Corp. Life & Banc Split Corp. Principal Regulator - Ontario Principal Regulator - Ontario Type and Date: Type and Date: Preliminary Shelf Prospectus (NI 44-102) dated October Preliminary Shelf Prospectus (NI 44-102) dated October 31, 2019 31, 2019 NP 11-202 Preliminary Receipt dated November 4, 2019 NP 11-202 Preliminary Receipt dated November 1, 2019 Offering Price and Description: Offering Price and Description: Maximum: $300,000,000 - Preferred Shares and Class A $300,000,000.00 - Preferred Shares and Class A Shares Shares Price: Preferred Shares $10.31 and Class A Shares - $7.89 Price: Preferred Shares - $10.23 and Class A Shares - Underwriter(s) or Distributor(s): $4.93 N/A Underwriter(s) or Distributor(s): Promoter(s): N/A N/A Promoter(s): Project #2981052 N/A Project #2981059 ______Issuer Name: ______Vertex Bond Alpha Fund Issuer Name: Vertex Canadian Equity Alpha Fund Harvest Canadian Consolidated Energy Fund Vertex Liquid Alternative Fund Principal Regulator - Ontario Vertex Liquid Alternative Fund Plus Type and Date: Vertex U.S. Equity Alpha Fund Preliminary Long Form Prospectus dated October 29, 2019 Principal Regulator - British Columbia NP 11-202 Preliminary Receipt dated October 29, 2019 Type and Date: Offering Price and Description: Amendment #2 to Final Simplified Prospectus dated Maximum Offering: $• - • Units January 11, 2019 Minimum Offering: $20,000,004 - 1,666,667 Units Received on October 31, 2019 Price per Unit: $12.00 Offering Price and Description: Underwriter(s) or Distributor(s): - BMO Nesbitt Burns Inc. Underwriter(s) or Distributor(s): CIBC World Markets Inc. N/A RBC Dominion Securities Inc. Promoter(s): Scotia Capital Inc. Vertex One Asset Management Inc. National Bank Financial Inc. Project #2831383 TD Securities Inc. Canaccord Genuity Corp. ______GMP Securities L.P. Raymond James Ltd. Desjardins Securities Inc. Echelon Wealth Partners Inc. Industrial Alliance Securities Inc. Mackie Research Capital Corporation Manulife Securities Incorporated PI Financial Corp. Promoter(s): N/A Project #2979123
______
November 7, 2019 (2019), 42 OSCB 8741
IPOs, New Issues and Secondary Financings
Issuer Name: Issuer Name: TD Active Global Income ETF Counsel All Equity Portfolio TD Active Global Real Estate Equity ETF Counsel Balanced Portfolio TD Active U.S. High Yield Bond ETF Counsel Canadian Dividend TD Canadian Long Term Federal Bond ETF Counsel Canadian Growth TD Income Builder ETF Counsel Canadian Value TD Q Canadian Dividend ETF Counsel Conservative Portfolio TD Q Global Dividend ETF Counsel Fixed Income TD Q Global Multifactor ETF Counsel Global Dividend TD Q U.S. Small-Mid-Cap Equity ETF Counsel Global Real Estate TD U.S. Long Term Treasury Bond ETF Counsel Global Small Cap Principal Regulator – Ontario Counsel Global Trend Strategy Type and Date: Counsel Growth Portfolio Preliminary Long Form Prospectus dated Oct 31, 2019 Counsel High Income Portfolio NP 11-202 Final Receipt dated Nov 4, 2019 Counsel High Yield Fixed Income Offering Price and Description: Counsel International Growth Units Counsel International Value Underwriter(s) or Distributor(s): Counsel Money Market N/A Counsel Monthly Income Portfolio Promoter(s): Counsel Retirement Accumulation Portfolio N/A Counsel Retirement Foundation Portfolio Project #2968330 Counsel Retirement Income Portfolio Counsel Retirement Preservation Portfolio ______Counsel Short Term Bond Issuer Name: Counsel U.S. Growth DFA World Equity Portfolio Counsel U.S. Value Principal Regulator – British Columbia IPC Multi-Factor Canadian Equity Type and Date: IPC Multi-Factor International Equity Preliminary Simplified Prospectus dated Oct 24, 2019 IPC Multi-Factor U.S. Equity NP 11-202 Final Receipt dated Oct 29, 2019 Principal Regulator – Ontario Offering Price and Description: Type and Date: Class F Units, Class I Units and Class A Units Combined Preliminary and Pro Forma Simplified Underwriter(s) or Distributor(s): Prospectus dated Oct 29, 2019 N/A NP 11-202 Final Receipt dated Oct 31, 2019 Promoter(s): Offering Price and Description: N/A Series A securities, Series Private Wealth I securities, Project #2968387 Series T securities, Series O securities, Series FT securities, Series B securities, Series IB securities, Series ______IT securities, Series I securities, Series C securities and Series F securities Underwriter(s) or Distributor(s): N/A Promoter(s): N/A Project #2965013
______
November 7, 2019 (2019), 42 OSCB 8742
IPOs, New Issues and Secondary Financings
Issuer Name: Vertex Enhanced Income Fund Vertex Growth Fund Vertex Value Fund Principal Regulator – British Columbia Type and Date: Amendment #2 to Final Simplified Prospectus dated October 21, 2019 NP 11-202 Final Receipt dated Oct 31, 2019 Offering Price and Description: Class F Units and Class B Units Underwriter(s) or Distributor(s): N/A Promoter(s): N/A Project #2921460
______Issuer Name: TD Q U.S. Small-Mid-Cap Equity ETF Principal Regulator – Ontario Type and Date: Amendment #1 to Final Simplified Prospectus dated October 29, 2019 NP 11-202 Final Receipt dated Nov 1, 2019 Offering Price and Description: Class A units and Class O units Underwriter(s) or Distributor(s): N/A Promoter(s): N/A Project #2910703
______
November 7, 2019 (2019), 42 OSCB 8743
IPOs, New Issues and Secondary Financings
NON-INVESTMENT FUNDS
Issuer Name: Issuer Name: Ag Growth International Inc. Fire & Flower Holdings Corp. (formerly Cinaport Acquisition Principal Regulator - Manitoba Corp. II) Type and Date: Principal Regulator - Ontario Preliminary Short Form Prospectus (NI 44-101) dated Type and Date: Received on October 30, 2019 Final Shelf Prospectus (NI 44-102) dated November 1, Offering Price and Description: 2019 - NP 11-202 Receipt dated November 4, 2019 Underwriter(s) or Distributor(s): Offering Price and Description: - $200,000,000.00 - COMMON SHARES WARRANTS Promoter(s): UNITS SUBSCRIPTION RECEIPTS DEBT SECURITIES - Underwriter(s) or Distributor(s): Project #2979951 - Promoter(s): ______- Issuer Name: Project #2950423 Almaden Minerals Ltd. Principal Regulator - British Columbia ______Type and Date: Issuer Name: Amendment dated November 1, 2019 to Preliminary Shelf GFL Environmental Inc. Prospectus (NI 44-102) dated October 4, 2019 Principal Regulator - Ontario NP 11-202 Preliminary Receipt dated November 1, 2019 Type and Date: Offering Price and Description: Amendment dated November 1, 2019 to Preliminary Long US$100,000,000.00 Form Prospectus dated July 19, 2019 Common Shares NP 11-202 Preliminary Receipt dated November 1, 2019 Warrants Offering Price and Description: Subscription Receipts - Units Underwriter(s) or Distributor(s): Underwriter(s) or Distributor(s): J.P. Morgan Securities Canada Inc. - BMO Nesbitt Burns Inc. Promoter(s): Goldman Sachs Canada Inc. - RBC Dominion Securities Inc. Project #2973185 Scotia Capital Inc. Barclays Capital Canada Inc. ______Raymond James Ltd. Issuer Name: TD Securities Inc. BSR Real Estate Investment Trust Merrill Lynch Canada Inc. Principal Regulator - Ontario CIBC World Markets Inc. Type and Date: HSBC Securities (Canada) Inc. Preliminary Shelf Prospectus (NI 44-102) dated November Macquarie Capital Markets Canada Ltd. 1, 2019 National Bank Financial Inc. NP 11-202 Preliminary Receipt dated November 1, 2019 Promoter(s): Offering Price and Description: - Project #2941753 US$500,000,000 Units ______Debt Securities Warrants Subscription Receipts The price per Offered Unit is stated in U.S. dollars. Underwriter(s) or Distributor(s): - Promoter(s): - Project #2980993
______
November 7, 2019 (2019), 42 OSCB 8744
IPOs, New Issues and Secondary Financings
Issuer Name: Issuer Name: Golden Star Resources Ltd. Open Text Corporation Principal Regulator - Ontario Principal Regulator - Ontario Type and Date: Type and Date: Final Shelf Prospectus (NI 44-102) dated October 28, 2019 Preliminary Shelf Prospectus (NI 44-102) dated October NP 11-202 Receipt dated October 29, 2019 31, 2019 Offering Price and Description: NP 11-202 Preliminary Receipt dated November 1, 2019 U.S.$300,000,000 Common Shares Preferred Shares Offering Price and Description: Subscription Receipts Warrants Debt Securities U.S. $1,500,000,000.00 Underwriter(s) or Distributor(s): Common Shares - Preference Shares Promoter(s): Debt Securities - Depositary Shares Project #2970477 Warrants Purchase Contracts ______Units Issuer Name: Subscription Receipts H2O INNOVATION INC. Underwriter(s) or Distributor(s): Principal Regulator - Quebec - Type and Date: Promoter(s): Amendment dated October 29, 2019 to Preliminary Short - Form Prospectus (NI 44-101) dated October 28, 2019 Project #2980787 NP 11-202 Preliminary Receipt dated October 30, 2019 Offering Price and Description: ______$14,001,750.00 Issuer Name: 13,335,000 Subscription Receipts each representing the Titan Medical Inc. right to receive one Unit Principal Regulator - Ontario Underwriter(s) or Distributor(s): Type and Date: Desjardins Securities Inc. Final Short Form Prospectus (NI 44-101) dated October 31, Canaccord Genuity Corp. 2019 Acumen Capital Finance Partners Limited NP 11-202 Receipt dated November 1, 2019 Beacon Securities Limited Offering Price and Description: Industrial Alliance Securities Inc, Minimum: US $15,000,000 (33,333,333 Units) Haywood Securities Inc. Maximum: US $25,000,000 (55,555,556 Units) Promoter(s): Price: US $0.45 per Unit - Underwriter(s) or Distributor(s): Project #2978517 BLOOM BURTON SECURITIES INC. Promoter(s): ______- Issuer Name: Project #2969015 Kalon Acquisition Corp. Principal Regulator - British Columbia ______Type and Date: Issuer Name: Final CPC Prospectus (TSX-V) dated October 30, 2019 Trilogy Metals Inc. (formerly NovaCopper Inc.) NP 11-202 Receipt dated November 1, 2019 Principal Regulator - British Columbia Offering Price and Description: Type and Date: $400,000.00 - $550,000.00 Final Shelf Prospectus (NI 44-102) dated October 31, 2019 4,000,000 Common Shares up to a maximum of 5,500,000 NP 11-202 Receipt dated October 31, 2019 Common Shares Offering Price and Description: Price: $0.10 per Common Share US$100,000,000 - Common Shares, Warrants to Purchase Underwriter(s) or Distributor(s): Common Shares, Share Purchase Contracts, Subscription Haywood Securities Inc. Receipts, Units Promoter(s): Underwriter(s) or Distributor(s): - - Project #2967410 Promoter(s): - ______Project #2974492
______
November 7, 2019 (2019), 42 OSCB 8745
IPOs, New Issues and Secondary Financings
Issuer Name: Triple Flag Precious Metals Corp. Principal Regulator - Ontario Type and Date: Preliminary Long Form Prospectus dated November 4, 2019 NP 11-202 Preliminary Receipt dated November 4, 2019 Offering Price and Description: C$* - * Common Shares Price: C$* per Offered Share Underwriter(s) or Distributor(s): Merrill Lynch Canada Inc. Scotia Capital Inc. CIBC World Markets Inc. BMO Nesbitt Burns Inc. National Bank Financial Inc. RBC Dominion Securiites Inc. TD Securities Inc. Promoter(s): Triple Flag Mining Elliott and Management Co-Invest GP Ltd. Project #2981424
______
November 7, 2019 (2019), 42 OSCB 8746
Chapter 12
Registrations
12.1.1 Registrants
Type Company Category of Registration Effective Date
Excel Funds Management Voluntary Surrender Investment Fund Manager October 31, 2019 Inc.
Excel Investment Counsel Portfolio Manger and Voluntary Surrender October 31, 2019 Inc. Exempt Market Dealer
IEPP Investment Voluntary Surrender Portfolio Manager November 1, 2019 Management Inc.
November 7, 2019 (2019), 42 OSCB 8747
Registrations
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November 7, 2019 (2019), 42 OSCB 8748
Chapter 13
SROs, Marketplaces, Clearing Agencies and Trade Repositories
13.3 Clearing Agencies 13.3.2 Canadian Derivatives Clearing Corporation (CDCC) – Proposed Amendments to the Rules, 13.3.1 CDS Clearing and Depository Services Inc. – Risk Manual and Operations Manual with Material Amendments to CDS Rules Related to Respect to Liquidity Risk Management – Liquidity Risk Management – Notice of Notice of Request for Comment Request for Comment OSC STAFF NOTICE OF REQUEST FOR COMMENT OSC STAFF NOTICE OF REQUEST FOR COMMENT CANADIAN DERIVATIVES CLEARING CORPORATION CDS CLEARING AND DEPOSITORY SERVICES INC. (CDCC) (CDS®) PROPOSED AMENDMENTS TO MATERIAL AMENDMENTS TO THE RULES, RISK MANUAL AND OPERATIONS CDS RULES RELATED TO MANUAL WITH RESPECT TO LIQUIDITY RISK MANAGEMENT LIQUIDITY RISK MANAGEMENT
The Ontario Securities Commission is publishing for 30-day The Ontario Securities Commission is publishing for public public comment material amendments to the CDS Rules comment the amendments to CDCC’s Rules, Risk Manual relating to liquidity risk management. The purpose of the and Operations Manual with respect to liquidity risk proposed rules amendments is to enhance CDS’s liquidity management. The purpose of the proposed amendments is risk management by requiring Participants to provide to enhance CDCC’s observance of Principle 7 of the PFMIs money in Canadian dollars as the sole type of eligible by requiring Clearing Members to satisfy their contributions collateral permitted in satisfying certain collateral to CDCC’s Clearing Fund by using only one form of requirements such as the Default Fund and the acceptable eligible collateral: money in Canadian dollars. Supplemental Liquidity Fund. The comment period ends December 9, 2019. The comment period ends on December 9, 2019. A copy of the CDCC Notice is published on our website at A copy of the CDS Notice is published on our website at http://www.osc.gov.on.ca. http://www.osc.gov.on.ca.
November 7, 2019 (2019), 42 OSCB 8749
SROs, Marketplaces, Clearing Agencies and Trade Repositories
13.3.3 CDS Clearing and Depository Services Inc. – Material Amendments to CDS Rules Related to Tiered Participation Information Sharing – Notice of Request for Comment
OSC STAFF NOTICE OF REQUEST FOR COMMENT
CDS CLEARING AND DEPOSITORY SERVICES INC. (CDS®)
MATERIAL AMENDMENTS TO CDS RULES RELATED TO TIERED PARTICIPATION INFORMATION SHARING
The Ontario Securities Commission is publishing for a 30-day public comment period material amendments to the CDS Rules relating to tiered participation information sharing.
The purpose of the proposed rule amendments is to specify that, upon request from CDS Clearing, Participants will be required to provide information in order to ensure observance of CDS Clearing’s obligations under Principle 19 – Tiered Participation Arrangements of the CPMI-IOSCO Principles for Financial Market Infrastructures.
The comment period ends on December 6, 2019.
A copy of the CDS Notice is published on our website at http://www.osc.gov.on.ca.
November 7, 2019 (2019), 42 OSCB 8750
SROs, Marketplaces, Clearing Agencies and Trade Repositories
CDS Clearing and Depository Services Inc. (CDS®)
MATERIAL AMENDMENTS TO CDS PARTICIPANT RULES RELATED TO TIERED PARTICIPATION INFORMATION SHARING
NOTICE AND REQUEST FOR COMMENTS
A. DESCRIPTION OF THE PROPOSED RULE AMENDMENTS
The proposed rule amendments will specify that, upon request from CDS Clearing, Participants will be required to provide such information as CDS Clearing may reasonably request in order to ensure observance of CDS Clearing’s obligations under Principle 19 – Tiered Participation Arrangements of the CPMI-IOSCO Principles for Financial Market Infrastructures (PFMIs). While disclosure and information sharing obligations are enshrined in several sections of the CDS Participant Rules, CDS Clearing, and CDS Clearing’s principal regulators, are of the view that CDS Clearing’s general observance of, inter alia, the PFMIs, CDS’s regulatory oversight by the Bank of Canada, National Instrument 24-102 – Clearing Agency Requirements (NI 24-102), and of CDS’s provincial recognition framework, will benefit from further clarification in the Rules as to the scope of such obligations.
The proposed rule amendments, to CDS Participant Rule 5.1, consist of the addition of a requirement to share information for the purposes of monitoring Participants’ activities, and are provided in Appendix “A” to this Notice.
B. NATURE AND PURPOSE OF THE PROPOSED RULE AMENDMENTS
The legal basis for participation, and the operational relationship, which exists between CDS Clearing and its direct Participants is a fundamental aspect of Canada’s indirect securities holding regime. This regime also results in the establishment of indirect clearing arrangements, pursuant to which a clearing broker provides services to a third-party broker. The permissibility of the foregoing structure carries with it the obligation, on CDS Clearing and on CDS Clearing Participants, to ensure continued and fulsome observance of the PFMIs and the implementation of same under Canadian federal and provincial oversight.
Principle 19 of the PFMIs, originally published in April, 2012, requires CDS Clearing to identify, monitor and manage the material risks to CDS Clearing arising from the tiered participation arrangements of its direct Participants. In general, tiered participation arrangements occur when a firm (i.e., an indirect participant, which is defined as an entity that is not bound by the rules of a Financial Market Infrastructure (FMI), but whose transactions are cleared, settled, or recorded by or through the FMI) relies on the services provided by another firm (i.e., a direct Participant) to use CDS Clearing’s Securities Settlement Service (SSS), Central Counterparty (CCP) service and/or Cross-Border DTCC (X- Border) services.
The Bank of Canada incorporated the PFMIs, including Principle 19, into their risk management standards for systemically important financial market infrastructures (FMIs) in 2012, and such FMIs have been expected to observe all applicable principles since 31 December, 2016.
Principle 19 applies to CDS Clearing at the provincial level pursuant to Section 3.1 of NI 24-102. CDS Clearing’s recognition orders and decisions (2012), as subsequently varied and amended (Ontario Securities Commission Recognition Order, Section 9.1; Autorité des marches financiers Recognition Decision, Section 28.1) required that CDS Clearing observe the PFMIs as soon as possible, and continue to so require.
In CDSX, the principal Participant categories are Extenders of Credit, Settlement Agents, and Receivers of Credit. These Participants have direct access to CDSX and are contractually bound by CDS Clearing’s Participant Rules. Indirect participants access CDS Clearing’s SSS, CCP and X-Border FMI services via direct Participants. In other words, they are clients of CDS Clearing’s direct Participants.
CDS Clearing has not, to-date, formalized tiered participation arrangements pursuant to which CDS Clearing recognizes, acknowledges, or maintains a contractual relationship with, the clients of our direct Participants except for purposes of ensuring that beneficial security-holders are not deprived of the rights attached to such holdings. CDS Clearing does, however, retain the ability to both monitor Participant activities in CDSX and to require declarations from CDS Clearing Participants in respect of the securities which CDS Clearing holds on those participants’ behalf. In 2017, CDS Clearing presented a Tiered Participation Risk Management Framework and requested certain information and data for the purpose of compliance with PFMI Principle 19. CDS Clearing prepared (i) a risk management framework to ensure that CDS operates within its risk appetite statement; and (ii) a participant questionnaire for the purpose of collecting information from its direct Participants in order to monitor and assess their activities in CDS Clearing’s Services as such activities may relate to the magnitude and scope of their respective tiered participation arrangements.
November 7, 2019 (2019), 42 OSCB 8751
SROs, Marketplaces, Clearing Agencies and Trade Repositories
The 2017 questionnaire was voluntary, and was circulated to a limited sample of Participants whose operations were known, by CDS, to include acting as a correspondent/clearing participant for non-participants. The results of the request were collected, analyzed, and presented at the end of 2017. To be assured of timely, complete and detailed survey responses, however, CDS is proposing the present rule amendments to make provision of tiered participation details mandatory for Participants.
The proposed rule amendments are intended to enhance the comprehensiveness of Tiered Participation information gathering by CDS and to improve data related to indirect Participant activity profiles and related risk exposures.
C. IMPACT OF THE PROPOSED RULE AMENDMENTS
(a) CDS Clearing – The proposed rule amendments will align CDS Clearing with the PFMI requirements and with the legal and risk management practices of CDS Clearing’s global comparators.
(b) CDS Participants – The proposed rule amendments will codify Participants’ obligation to share information related to tiered participation arrangements with CDS Clearing. The proposed rule amendments take account of other legislative or regulatory requirements to which Participants may be subject and of the possibility that disclosure to CDS Clearing may, in certain circumstances, be limited by the foregoing.
(c) Other Market Participants – The proposed rule amendments will have no impact on other market participants. The proposed rule amendments take account of other legislative or regulatory requirements to which Participants may be subject and of the possibility that disclosure of information related to other market participants (i.e., Participant clients) to CDS Clearing may, in certain circumstances, be limited by the foregoing.
(d) Securities and Financial Markets in General – The proposed rule amendments will have no impact on securities and financial markets in general.
C.1 Competition
The proposed rule will apply to all CDS Clearing Participants. As concerns fair access, no CDS Clearing Participant will be disadvantaged or otherwise prejudiced by the introduction of these changes.
C.2 Risks and Compliance Costs
The proposed rule amendments are intended to enhance CDS Clearing’s information gathering abilities and risk management capacity and clarify Participant information provision obligations.
C.3 Comparison to International Standards – (a) Committee on Payment and Settlement Systems of the Bank for International Settlements, (b) Technical Committee of the International Organization of Securities Commissions, and (c) the Group of Thirty
The proposed rule amendments are intended more clearly and specifically to align CDS Clearing’s Participant Rules with the PFMIs.
D. DESCRIPTION OF THE RULE DRAFTING PROCESS
D.1 Development Context
CDS legal and risk management staff prepared documents describing the proposed rule amendments.
D.2 Rule Amendment Drafting Process
The proposed rule amendments were drafted by CDS Clearing legal staff in consultation with CDS Clearing risk management, and was subsequently submitted for consultation to the CDS Legal Drafting Group (“LDG”) on October 17, 2019. The LDG comments on the drafting of proposed amendments to the CDS Participant Rules and may suggest further revisions or additions. The LDG’s membership includes representatives from a cross-section of the CDS Participant community and meets on an ad hoc basis.
D.3 Issues Considered
As noted above, in drafting the proposed rule amendments, CDS Clearing’s primary consideration was to update its risk management practices with respect to PFMI 19 and to clarify CDS Clearing’s Participant Rules related thereto.
November 7, 2019 (2019), 42 OSCB 8752
SROs, Marketplaces, Clearing Agencies and Trade Repositories
D.4 Consultation
CDS Clearing received input from the following Participant Advisory Committee:
The CDS Legal Drafting Group reviewed the Rule Amendment (17 October, 2019)
CDS Clearing’s regulators attend Participant Advisory Committee meetings as observers.
The Rule Amendment was presented to the Risk Management and Audit Committee and the Board of Directors on October 31, 2019.
D.5 Alternatives Considered
CDS Clearing legal personnel, in consultation with CDS Clearing risk management, reviewed existing CDS Clearing Participant Rules and determined that, while the Participant Rules provide for the monitoring of Participants’ activities by CDS Clearing, and for the potential restriction or suspension of a Participant’s system functionality, the obligation to provide information in furtherance of CDS Clearing’s observance of regulatory oversight requirements was not explicitly or specifically stated.
CDS Clearing personnel considered whether it was appropriate to make specific reference to CDS Participant’s existing obligation to provide notice of material change to information (Rule 2.2.11), but determined that the most appropriate location for the proposed amendments was in the context of CDS Clearing’s existing rights to monitor Participants, and to take action consequent to such monitoring (Rule 5.1.3).
D.6 Implementation Plan
CDS is recognized as a clearing agency by the Ontario Securities Commission pursuant to section 21.2 of the Securities Act (Ontario), by the British Columbia Securities Commission pursuant to Section 24(d) of the Securities Act (British Columbia) and by the Autorité des marchés financiers pursuant to section 169 of the Securities Act (Québec). In addition CDS is deemed to be the clearing house for CDSX®, a clearing and settlement system designated by the Bank of Canada pursuant to section 4 of the Payment Clearing and Settlement Act.
This Rule Amendment is expected to become effective upon approval by the Recognizing Regulators following the prescribed public notice and comment period.
E. TECHNOLOGICAL SYSTEM CHANGES
The proposed Rule Amendment is not expected to have an impact on technological systems, or re-quire changes to such systems for CDS, CDS Participants, or other market participants.
F. COMPARISON TO OTHER CLEARING AGENCIES
CDS Clearing’s principal international comparator is the Depository Trust & Clearing Corporation (DTCC), and its two operating subsidiaries, the Depository Trust Company (DTC) and the National Securities Clearing Corporation (NSCC) in the United States. CDS Clearing reviewed the DTC & NSCC Rules, and determined that the rules of both DTC and NSCC contained specific reference to the provision of information related to clients of DTC and NSCC members. The PFMI disclosure frameworks for each for each of DTC and NSCC also refer to this authority in the context of DTC and NSCC’s management of risk related to tiered participation arrangement.
G. PUBLIC INTEREST ASSESSMENT
CDS Clearing has determined that the proposed rule amendments are not contrary to the public interest.
November 7, 2019 (2019), 42 OSCB 8753
SROs, Marketplaces, Clearing Agencies and Trade Repositories
H. COMMENTS
Comments on the proposed Rule Amendment should be in writing and submitted within 30 calendar days following the date of publication of this Request for Comments in the Ontario Securities Commission Bulletin to:
Legal Department Attn: Tony Hoffmann, Senior Legal Counsel CDS Clearing and Depository Services Inc. 100 Adelaide Street West, Suite 300 Toronto, Ontario M5H 1S3
e-mail: [email protected]
Copies should also be provided to the Autorité des marchés financiers, British Columbia Securities Commission and the Ontario Securities Commission by forwarding a copy to each of the following individuals:
Philippe Lebel Manager, Market Regulation Corporate Secretary and Market Regulation Branch Executive Director, Legal Affairs Ontario Securities Commission Suite 1903, Box 55, Autorité des marchés financiers 20 Queen Street West 800, square Victoria, 22e étage Toronto, Ontario, M5H 3S8 C.P. 246, tour de la Bourse Fax: 416-595-8940 Montréal (Québec) H4Z 1G3 e-mail: [email protected] Télécopieur: (514) 864-6381 Courrier électronique: [email protected] Doug MacKay Ms. Ami Iaria Manager, Market and SRO Oversight Senior Legal Counsel British Columbia Securities Commission British Columbia Securities Commission 701 West Georgia Street 701 West Georgia Street P.O. Box 10142, Pacific Centre C.P. 10142, Pacific Centre Vancouver, B.C. V7Y 1L2 Vancouver (Colombie-Britannique) V7Y 1L2 Fax: 604-899-6506 Télécopieur : 604 899-6506 Email: [email protected] Courriel : [email protected]
CDS will make available to the public, upon request, all comments received during the comment period.
I. PROPOSED CDS RULE AMENDMENT
Appendix “A” contains text of current CDS Participant Rules marked to reflect the proposed Rule Amendment as well as text of these rules reflecting the adoption of the proposed Rule Amendment.
November 7, 2019 (2019), 42 OSCB 8754
SROs, Marketplaces, Clearing Agencies and Trade Repositories
APPENDIX “A” PROPOSED CDS RULE AMENDMENT
Text of CDS Participant Rules marked to reflect Text of CDS Participant Rules reflecting the adoption of proposed amendment proposed amendment [marked text of rules – deletions are strikethrough text and in red font]
5.1.3 Monitoring of Participants 5.1.3 Monitoring of Participants
Monitoring of Participants In order to measure potential risks Monitoring of Participants In order to measure potential risks to CDS and the Services, CDS shall monitor the to CDS and the Services, CDS shall monitor the Transactions, Settlement obligations and activity in the Transactions, Settlement obligations and activity in the system of that Participant. Acting in good faith and in system of that Participant. Acting in good faith and in accordance with the Rules, CDS shall take steps to ensure accordance with the Rules, CDS shall take steps to ensure the due performance by the Participant of its obligations to the due performance by the Participant of its obligations to CDS, when CDS considers such action to be necessary to CDS, when CDS considers such action to be necessary to protect the interests of CDS and to be in the best interest of protect the interests of CDS and to be in the best interest of all other Participants. In taking such steps, CDS shall take all other Participants. In taking such steps, CDS shall take into consideration any relevant information, including the into consideration any relevant information, including the financial stability or regulatory status of the Participant, the financial stability or regulatory status of the Participant, the amount of its obligations to CDS, the market volatility, amount of its obligations to CDS, the market volatility, liquidity, concentration or market float of any issue of liquidity, concentration or market float of any issue of Securities held by or to be delivered by or to the Participant, Securities held by or to be delivered by or to the Participant, and any other factor that CDS considers relevant. The steps and any other factor that CDS considers relevant. The steps CDS may take include: CDS may take include:
(a) requiring the Participant to provide additional (a) requiring the Participant to provide additional Contributions to any Fund or Link Fund of which the Contributions to any Fund or Link Fund of which the Participant is a Member, pursuant to Rules 5.8.2 or Participant is a Member, pursuant to Rules 5.8.2 or 10.6.4; 10.6.4; (b) requiring the Participant to grant to CDS a security (b) requiring the Participant to grant to CDS a security interest in Specific Collateral, CCP Collateral, or Cross- interest in Specific Collateral, CCP Collateral, or Cross- Border Specific Collateral pursuant to Rules 5.2.3, Border Specific Collateral pursuant to Rules 5.2.3, 5.14.3, or 10.5.3; 5.14.3, or 10.5.3; (c) decreasing the Participant's System-Operating Cap (c) decreasing the Participant's System-Operating Cap pursuant to Rule 5.10.18; restricting the Participant's pursuant to Rule 5.10.18; restricting the Participant's right to use system functionality in any Function or right to use system functionality in any Function or Service pursuant to Rule 2.7.1; Service pursuant to Rule 2.7.1; (d) releasing giving information relating to the Participant's (d) releasing information relating to the Participant's CCP CCP Contributions Total in accordance with Rule 5.14.2; Contributions Total in accordance with Rule 5.14.2; or or (e) requiring the Participant to provide, upon request by (e) requiring the Participant to provide, upon request by CDS, information sufficient, in a form acceptable to CDS, CDS, information sufficient, in a form acceptable to CDS, to demonstrate the Participants satisfactory financial to demonstrate the Participants satisfactory financial condition and operational capability, including, but not condition and operational capability, including, but not limited to, information in respect of the Participant’s limited to, information in respect of the Participant’s operations and in respect of its risk management operations and in respect of its risk management practices with respect to CDS’s Services used by the practices with respect to CDS’s Services used by the Participant for another Person or Persons; provided, Participant for another Person or Persons; provided, however, that the provision of any such financial or however, that the provision of any such financial or operational information to CDS shall be subject to Rule operational information to CDS shall be subject to Rule 3.6 and to any applicable laws or rules and regulations of 3.6 and to any applicable laws or rules and regulations regulatory bodies having jurisdiction over the Participant of regulatory bodies having jurisdiction over the which relate to the confidentiality of records. Participant which relate to the confidentiality of records. (e)(f) taking any other feasible steps consistent with the (f) taking any other feasible steps consistent with the Rules. Rules.
November 7, 2019 (2019), 42 OSCB 8755 SROs, Marketplaces, Clearing Agencies and Trade Repositories
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November 7, 2019 (2019), 42 OSCB 8756
Index
3iQ Corp. EGF Theramed Health Corp. Notice from the Office of the Secretary ...... 8639 Cease Trading Order ...... 8691 Order – s. 8 ...... 8661 Reasons and Decision ...... 8673 Eviana Health Corporation Cease Trading Order ...... 8691 Advantex Marketing International Inc. Cease Trading Order ...... 8691 Evolve Funds Group Inc. Decision ...... 8641 Besra Gold Inc. Cease Trading Order ...... 8691 Excel Funds Management Inc. Voluntary Surrender ...... 8747 Bitcoin Fund (The) Notice from the Office of the Secretary ...... 8639 Excel Investment Counsel Inc. Order – s. 8 ...... 8661 Voluntary Surrender ...... 8747 Reasons and Decision ...... 8673 First Trust Short Duration High Yield Bond ETF (CAD- Brown, Gary Hedged) Notice from the Office of the Secretary ...... 8640 Decision ...... 8645
Caldwell Investment Management Ltd. FT Portfolios Canada Co. Decision ...... 8656 Decision ...... 8645
Canadian Derivatives Clearing Corporation Greystone Capital Management Inc. Clearing Agencies – Proposed Amendments to the Decision ...... 8653 Rules, Risk Manual and Operations Manual with Respect to Liquidity Risk Management – Notice of Greystone Managed Investments Inc. Request for Comment ...... 8749 Decision ...... 8653
CannTrust Holdings Inc. Holloway Lodging Corporation Cease Trading Order ...... 8691 Order ...... 8666
CDCC ICAP Securities Limited Clearing Agencies – Proposed Amendments to the Ruling & Exemption – s. 38 of the CFA and s. 6.1 Rules, Risk Manual and Operations Manual with of OSC Rule 91-502 Trades in Recognized Respect to Liquidity Risk Management – Notice of Options ...... 8667 Request for Comment ...... 8749 IEPP Investment Management Inc. CDS Clearing and Depository Services Inc. Voluntary Surrender ...... 8747 Clearing Agencies – Material Amendments to CDS Rules Related to Liquidity Risk Management – Jones, Bradley Notice of Request for Comment ...... 8749 Notice from the Office of the Secretary ...... 8640 Clearing Agencies – Material Amendments to CDS Rules Related to Tiered Participation Information Lifestyle Global Brands Limited Sharing – Notice of Request for Comment...... 8750 Cease Trading Order ...... 8691
CellCube Energy Storage Systems Inc. Melior Resources Inc. Cease Trading Order ...... 8691 Cease Trading Order ...... 8691
Chemesis International Inc. MOAG Copper Gold Resources Inc. Cease Trading Order ...... 8691 Notice from the Office of the Secretary ...... 8640
Clearpoint Global Dividend Fund Peeks Social Ltd. Decision ...... 8656 Cease Trading Order ...... 8691
CordovaCann Corp. Performance Sports Group Ltd. Cease Trading Order ...... 8691 Cease Trading Order ...... 8691
November 7, 2019 (2019), 42 OSCB 8757
Index
Portfolio 22 Multi-Family REIT LP Order ...... 8662
Silk Road Energy Inc. Partial Revocation Order ...... 8663
Star Navigation Systems Group Ltd. Cease Trading Order ...... 8691
TD Asset Management Inc. Decision ...... 8653
TD Investment Services Inc. Decision ...... 8649
Triple Flag Precious Metals Corp. Decision ...... 8651
November 7, 2019 (2019), 42 OSCB 8758