The Ontario Securities Commission (OSC) has announced that Polina (Poly) Edry and Subramaniam Sulur were each sentenced in the Ontario Court of Justice at Old City Hall by Justice Malcolm McLeod.
Edry was sentenced to two years of probation, including 300 hours of community service, and a fine of $36,000. In addition to the fine, the court imposed a 25% ($9,000) victim fine surcharge as required by the Provincial Offences Act. The surcharge is credited to a special provincial government fund to assist victims of crime.
Sulur was sentenced to two years of probation, including 150 hours of community service, and a fine of $3,000. In addition to the fine, the court imposed a 25% ($750) victim fine surcharge.
The terms of probation also prohibit Edry and Sulur from engaging in any securities-related business until the completion of their community service hours to the satisfaction of their Probation Officers, and only in accordance with any terms and conditions imposed by the OSC.
Following an investigation by the OSC’s Joint Serious Offences Team (JSOT), Edry and Sulur each pleaded guilty to one count of participating in an improper referral arrangement with another person or company contrary to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations and contrary to s. 122(1) of the Securities Act (Ontario).
Edry was formerly a Branch Manager for Knowledge First Financial Inc. and Sulur was formerly an Assistant Branch Manager for C.S.T. Consultants Inc. Both were registered dealers.
Edry acknowledged in court that between January 1, 2012 and May 1, 2014, she purchased names from Shaida Bandali (a former employee of the Rouge Valley Health System), who she knew worked in a medical facility. The names were those of new parents of children that came from that medical facility. Edry also admitted that she was wilfully blind to the fact that not all of the patients had agreed to have their personal information shared. Edry admitted to paying Bandali $10,513.25 or approximately $2.50-2.75 per name. She purchased the names from Bandali to use as sources of potential Registered Education Savings Plans (RESP) investment sales leads.