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The Investment Industry Association of Canada (IIAC) is calling for a proposed regulatory program for minor contraventions to issue lower fines or use a tiered approach.

In April, the Investment Industry Regulatory Organization of Canada (IIROC) released proposals for a minor contravention program and early resolution offers. The program would allow reps who admit to minor contraventions to pay a $5,000 fine and remain anonymous, while the early resolutions would offer dealers and reps a 30% discount on proposed sanctions if they agree to settle certain types of cases quickly.

In its submission, IIAC suggested lower fines or a tiered approach, “where the fine amount matches the seriousness of the contraventions along with an explanation for the charge.” IIROC was initially considering fining reps $2,500 under the program before increasing the proposed fine to $5,000.

IIAC also asked for clarity on how much time reps would have to accept an offer under the program, in addition to more information on eligibility parameters.

On the early resolution offers, IIAC suggested the offers “would be most beneficial if they were discussed early in the enforcement stage to reduce the burden on firms.”

The association requested more information on the timelines for the offers, and clarity on what happens when a respondent declines and proceeds to an enforcement hearing, among other matters.

Investor advocates have expressed concern that offenders wouldn’t be publicly identified under the process.

Read full submissions from IIAC and others.