Did the Respondents fail to disclose commissions received in connection with their trades of securities?
• Did the Respondents make prohibited representations to investors during the course of an offering? • Did the Respondents use high-pressure sales tactics when selling securities to members of the public? PARTIES’ SUBMISSIONS A. Staff [36] Counsel for Staff submits that: • at all relevant times, the Respondents were trading in securities without being registered to do so, contrary to section 25 of the Act and to the public interest. Neither the accredited investor exemption under Rule 45-501, nor any other exemption from registration is available to the Respondents. They acted as market intermediaries and thus were required to be properly registered; • the Respondents distributed securities to investors without a prospectus or preliminary prospectus being filed and receipts obtained, contrary to section 53 of the Act; and • the Respondents acted as principal or agent in connection with a trade in securities without disclosing the commission charged in respect of the trade contrary to s
