We are adopting the Staff Policy Statement on Early Resolution Offers that was originally published for comment on April 25, 2019 (Notice 19-0076), with minor revisions that clarify the purpose, application and scope of the policy.
The Staff Policy Statement on Early Resolution Offers is intended to promote the timely resolution of cases, increase the application of the Staff Policy Statement on Credit for Cooperation, and encourage Dealer Members (Dealers) to implement timely compensation and remedial measures.
Dealers and Approved Persons who choose to resolve a case by Early Resolution Offer will be granted a reduction of 30% on the sanctions IIROC Enforcement Staff (Staff) would otherwise seek in a settlement agreement and a quicker resolution of the proposed enforcement proceeding.
The Staff Policy Statement on Early Resolution Offers sets out the criteria Staff will consider in determining whether to make an Early Resolution Offer and the contents of such an offer.
The Staff Policy Statement is attached as Appendix A and can be found on the IIROC website here.
We summarized the public comments we received on the Early Resolution Offers proposal along with our responses in Appendix B.
Appendix A – Staff Policy Statement – Early Resolution Offers
Appendix B – Response to Public Comments on Notice 19-0076