CIRO Sanctions Pollitt & Co. Inc.

Type: Enforcement Notice> Decision


Joanna Nicholson
Manager, Public Affairs

Toronto (Ontario), November 3, 2023 – On October 24, 2023, a hearing panel of the Investment Dealer Division of the Canadian Investment Regulatory Organization (CIRO) accepted a settlement agreement, with sanctions, between Enforcement Staff and Pollitt & Co. Inc. (Pollitt & Co).

Pollitt & Co admitted to the following violations:

  1. between January and December 2020, Pollitt & Co failed to have and maintain risk adjusted capital greater than zero at all times and failed to immediately notify CIRO when its risk adjusted capital was less than zero, contrary to Dealer Member Rule 17.1;
  2. between January and December 2020, Pollitt & Co failed to establish and maintain adequate internal controls, contrary to the internal control policy statements in Dealer Member Rule 2600 and Dealer Member Rule 17.2A;
  3. between January and December 2020, Pollitt & Co failed to keep and maintain a proper system of books and records, contrary to Dealer Member Rule 17.2 and Dealer Member Rule 200.2;
  4. between September 2018 and November 2022, Pollitt & Co failed to report information about all transactions in debt securities, contrary to Dealer Member Rule 2800C and Investment Dealer Rule 7200 (in effect January 1, 2022); and
  5. between May 2021 and January 2022, while designated in Early Warning Level 2, Pollitt & Co made payments to an affiliate, without obtaining written consent from CIRO, contrary to Dealer Member Rule 30.3 and Section 4135 of the Investment Dealer Rules (in effect January 1, 2022).

Pursuant to the settlement agreement, Pollitt & Co agreed to a fine of $175,000.

Pollitt & Co also agreed to pay costs in the amount of $15,000.

The Settlement Agreement is available at:

Pollitt & Co – Settlement Agreement

The hearing panel’s decision will be made available at

Pollitt & Co is a CIRO-registered Dealer Member. It is subject to Terms and Conditions imposed on its membership on February 3, 2023.

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All information about disciplinary proceedings relating to current and former member firms and individual registrants is available in the Enforcement section of the IIROC website for investment dealer disciplinary proceedings and the MFDA website for mutual fund dealer disciplinary proceedings.

Background information regarding the qualifications and disciplinary history, if any, of advisors currently employed by CIRO-regulated firms (Investment Dealer Division) is available free of charge through the AdvisorReport service. Information on how to make investment dealer, advisor or marketplace-related complaints is available by calling 1-877-442-4322.

CIRO investigates possible misconduct by its member firms and individual registrants. It can bring disciplinary proceedings which may result in sanctions including fines, suspensions, permanent bars, expulsion from membership, or termination of rights and privileges for individuals and firms.

Canadian Investment Regulatory Organization (CIRO) is the national self-regulatory organization that oversees all investment dealers, mutual fund dealers and trading activity on Canada’s debt and equity marketplaces. CIRO is committed to the protection of investors, providing efficient and consistent regulation, and building Canadians’ trust in financial regulation and the people managing their investments. For more information, visit


Other Notices associated with this Enforcement Proceeding:

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