Pace Securities | Page 4 | General financial discussion | Discussion forum

Please consider registering
guest

sp_LogInOut Log In sp_Registration Register

Register | Lost password?
Advanced Search

— Forum Scope —




— Match —





— Forum Options —





Minimum search word length is 3 characters - maximum search word length is 84 characters

sp_Feed Topic RSS sp_TopicIcon
Pace Securities
May 20, 2020
7:02 pm
Yaftica
Interwebs
Member
Members
Forum Posts: 67
Member Since:
May 15, 2020
sp_UserOfflineSmall Offline

Well thats a loaded question but I would presume (according to the Q&A area posted by Pace here:) https://www.pacecu.ca/SharedContent/documents/2020/PSCQ&A.pdf

With some 300 odd 'members' directly affected in different ways (I don't claim to understand every different way they could have distributed these shares I only know how they invested my TFSA transfer into them) I would surmise that people will be looking for their portfolio to be restored at what they were sold to us at ($5) minus previous dividends - someone mentioned this above that Pace Credit Union may elect to step in and protect their brand in this manner but I'm certain lawyers speak louder than board members and as a member - I too would probably balk at them reaching into my Chequing account to take $30 out to support this process even if it is the right thing to do, or maybe it doesn't work that way but you get the idea.

People will not be satisfied until such time as their $ is returned. This smells of deception and I'm not saying that because of my experience. But at this point in time, I would likely take an olive branch as well as a settlement offer rather than litigate for a decade too. I think most would. I don't know if this is the answer you were looking for ... Cheers.

May 20, 2020
7:36 pm
Doug
British Columbia, Canada
Member
Members
Forum Posts: 4273
Member Since:
December 12, 2009
sp_UserOfflineSmall Offline

Yaftica said
Well thats a loaded question but I would presume (according to the Q&A area posted by Pace here:) https://www.pacecu.ca/SharedContent/documents/2020/PSCQ&A.pdf

With some 300 odd 'members' directly affected in different ways (I don't claim to understand every different way they could have distributed these shares I only know how they invested my TFSA transfer into them) I would surmise that people will be looking for their portfolio to be restored at what they were sold to us at ($5) minus previous dividends - someone mentioned this above that Pace Credit Union may elect to step in and protect their brand in this manner but I'm certain lawyers speak louder than board members and as a member - I too would probably balk at them reaching into my Chequing account to take $30 out to support this process even if it is the right thing to do, or maybe it doesn't work that way but you get the idea.

People will not be satisfied until such time as their $ is returned. This smells of deception and I'm not saying that because of my experience. But at this point in time, I would likely take an olive branch as well as a settlement offer rather than litigate for a decade too. I think most would. I don't know if this is the answer you were looking for ... Cheers.  

Yeah, Bud has a bad habit of being overly concise, to the point that, more often than not, people do not know what he is trying to ask. He means well, but I agree that it was a bit of a loaded question or, at the very least, a case of putting the proverbial cart before the horse. 😉

I think that's the same Q&A document I shared earlier, but not sure if it's been added to or updated. It does at least provide some useful detail at Pace Savings & Credit Union at supporting members.

From Pace Savings' 2019 audited financial statements, they had ~$168 million in non-regulatory reserve deposits held at by the credit union, as well as a 30% equity stake in Continental Currency Exchange Ltd. arising from the former Pace Savings' executives arranging to have Pace Savings acquire CCE without obtaining the required FSRA regulatory approval—a stake which has since, ostensibly by court action, been increased to 100%. They also have a 30% equity stake in several residential home developments—Geranium Homes (Ballantrae, Ninth Line, and Scucog), Aurora Highland Gate, Bloomington Woods, and Claremont. Not sure if that acquired that through a commercial mortgage gone bad, one or more foreclosures, or some other questionable business decision, but the point is, they have a number of significant cash, equity, and real estate assets that could be sold at the prevailing market value to generate cash to at least help to make up the shortfall (i.e., amount owed to Laurentian Bank Securities for the margin loan) and part of the fall in the value of the liquidated securities. Even if Pace Securities customers get back $4 out of their $5 par value for each share, including any dividends that already been paid, such that, after taking into account the dividends which had been paid, each member only lost $1 per share, that would not be a terrible outcome. It doesn't seem like it would cost Pace more than $1-3 million to do this, but again, lack of financial transparency here is not helpful. 🙁

Cheers,
Doug

May 20, 2020
8:11 pm
Briguy
Member
Members
Forum Posts: 726
Member Since:
March 17, 2018
sp_UserOfflineSmall Offline

I haven't been following this thread closely, but I can feel the pain of our two members. I imagine they thought they were buying those market-linked gic's like the big 5 banks sell, or shares of Pace Credit Union itself.

Some links for taking it public:
https://cbchelp.cbc.ca/hc/en-ca/articles/217732587-Submit-a-news-tip-or-story-for-CBC-to-investigate

https://toronto.citynews.ca/contact-us-news-tips/

By the way, I started typing this in capitals, and I thought to myself, whatever happened to Chuck ?

May 20, 2020
8:24 pm
Bud
Member
Banned
Forum Posts: 1375
Member Since:
February 20, 2018
sp_UserOfflineSmall Offline

If it's just a few million then make it right.

Ive seen one of their assets Geranium Friday Harbour very nice development in Innisfil. It's the real deal.

Elaine try contacting this woman

https://en.m.wikipedia.org/wiki/Diane_Urquhart

May 20, 2020
11:51 pm
Loonie
Member
Members
Forum Posts: 9384
Member Since:
October 21, 2013
sp_UserOfflineSmall Offline

Financial abuse of lower income investors has now become a sufficiently significant concern that Osgoode Law School offers them a professor-directed student-run Investor Protection Clinic to help figure out how to proceed and in some cases to argue for the client, prepare letters etc. I don't know if either of the people affected here would qualify for hands-on help but there is no harm in asking. Although the Clinic is in Toronto, they have clients from AB and BC as well, according to their Annual Report.
https://www.osgoode.yorku.ca/community-clinics/investor-protection-clinic/

Again according to their Annual Report, the issues they have been asked to deal with include:
· Suitability of investments
· Inadequate disclosure about products
or fees
· Instructions not followed by financial
advisors
· Misrepresentations by financial
advisors
· Delays in buying or selling securities or
transferring funds
· Fraud

I think it's not surprising that suitability and disclosure appear to be the top complaints.

Hang on to your hats, folks, and especially to your TFSAs. That seems to be the most popular target for "advisors" these days.

If you read enough Annual Reports in the banking sector, it becomes obvious that their sights are all set on "wealth management" as the most promising aspect of their business in regards to individuals. That means you, if you have any money at all. Pretty well all of them mention this when talking about their future growth prospects. If too many clients are happy with their GICs and savings accouts, they can expect pressure to convert to riskier alternatives. But a great many don't realize they are part of this strategy. They just think the FI will not lead them astry. Hah!

I imagine we can expect even more of this in the future.

As long as I have my marbles I will be immune to this pressure, but it's easy to see how people will be vulnerable to it.
At Meridian, the most bank-like CU that I deal with, my rep, a very nice fellow, tells me almost every time I see him that he'd "like to see (my) money working harder" for me. This is the opening phrase that people need to be aware of. At this point I just cut him off with "I'm not interested", as I know it leads to riskier investments. If you aren't used to doing so, it cn be difficult to say no to these people as they offer you things they ultimately can't guarantee.
The last time he told me this was in January, when he proudly told me his percentage return on his investments last year - about 20%. I then gave HIM some free advice and told him to sell
because markets were at a peak. He said he was in it for the long haul and that didn't matter. If so, then why brag about short term gains? I haven't heard from him since the markets nose-dived.

I belong to several other CUs, not including PACE, and none of the others have ever tried to sell me "products". I would never join one where Frank Klees or Ernie Eves or any of his buddies had any role whatsoever. And I sure wouldn't put my elderly mother in a long term care home run by Mike Harris either (Chartwell).

For more background info, see previous thread, especially post #18 and following:
https://www.highinterestsavings.ca/forum/general-financial-discussion/dico-placed-pace-credit-union-under-admininstration-due-to-governance-issues/

May 21, 2020
4:13 am
Elaine
Member
Members
Forum Posts: 104
Member Since:
May 19, 2020
sp_UserOfflineSmall Offline

Briguy said
I haven't been following this thread closely, but I can feel the pain of our two members. I imagine they thought they were buying those market-linked gic's like the big 5 banks sell, or shares of Pace Credit Union itself.

Some links for taking it public:
https://cbchelp.cbc.ca/hc/en-ca/articles/217732587-Submit-a-news-tip-or-story-for-CBC-to-investigate

https://toronto.citynews.ca/contact-us-news-tips/

By the way, I started typing this in capitals, and I thought to myself, whatever happened to Chuck ?  

YES-this exactly what I thought.I had done stuff through my RRSP with the bank of Nova Scotia.When they were doing it.Now is a RIFF.But I always knew my capital money would be there and I would get an interest rate that may not be the "best" they had to offer but I was sure that I did not lose principal.Thanks for the links.A story on the news always attracts more attention and warns people off.Even if it not Pace Credit Union that is the problem -it is the issue of owning at least part of it and not being straight forward with customers.
I know this kind of crap would not have happened at All Trans.They knew I was a pensioner with a disabled son. And they still had at least one staff from All Trans working there last time I actually went in.And again-it was first time going to renew a GIC.And to a further post ,I agree,litigation goes on for years,as I found out with my son.I am open for someone from PACE to make this right.There have been some ideas floating around.
I am astounded at the amount of empathy and knowledge that there is on this site.Thank you all very much.When this happened I decided to be very open about it with every one.I am sure there are others out there in a dark hole .At least with the support of people like Chuck and everyone else(sorry ,early in morning) I can see I glimmer of humanity -and to people who may go into a deep depression over this-it can actually be a life saver.Heartfelt thanks for pinpointing exactly what I thought I was doing.

May 21, 2020
5:18 am
Elaine
Member
Members
Forum Posts: 104
Member Since:
May 19, 2020
sp_UserOfflineSmall Offline

I suppose the last thing I want to say is that when I bought what I thought were GIC's -with the preferred rate and the bonus-the guy started saying -Oh-I hope I can get it in-the offer closes soon.I will work on it in the evening until done.I believe it was a Friday.At that point-I felt a bit of a turning of the tummy-and then I thought it is a Credit Union-they would not play games like that.I have always made it clear in all my investments that the principal must be protected.
To get what I had been getting at Scotia Bank on my RRSP (not at that time as I had already turned to a RRIF)I did not find that unusual.I do not know why there was a 2% bonus.And still don't. Maybe if Ernie Eves is following the thread he can explain.

May 21, 2020
5:48 am
Yaftica
Interwebs
Member
Members
Forum Posts: 67
Member Since:
May 15, 2020
sp_UserOfflineSmall Offline

Elaine, you’re certain that your GIC is comprised of these Pace Preferred shares? Have you logged into Pace Securities web portal (still open) to see exactly where your losses have occurred?

I’m just not clear in reading everything you’ve posted that this is the product you’re caught up in as well. These ‘shares’ sold to me were explained as stock in the bank (Pace Credit Union). The broker ‘forgot’ to be explicit and advise of the private nature, not publicly traded and risk category I was looking at.

I know I signed a bunch of papers alright which I’m sure now if I can find them will likely implicate myself but in examining my portfolio data on that web site (profile especially) it lists me with a net worth over 250k and with an annual income over 80k. Neither of which is true, I don’t own anything, I rent, I work full time, and that was all the savings I had. There may have been internal protocol breached to sell me these shares but as I stated before it’s going to litigation now and pointless to argue at this point.

I was led astray and the broker targeted my TFSA portfolio as an attractive way to secure more funds for PFL in this manner, I’m seeing that now. Anyway, just double check exactly that this same scenario is yours too, you should have received something about the purchase of the shares in the mail as I did I would think.

May 21, 2020
6:07 am
Bill
Member
Members
Forum Posts: 4012
Member Since:
September 11, 2013
sp_UserOfflineSmall Offline

Some comments on this site over the years promoting credit unions over the bad "Big 5" banks, ethical nature of credit unions, etc. Guess not always the case.

This is an illustration of why I give zero advice to any adult I know, including family members, about saving/investing. I don't want to be even a tiny bit in the picture later if things don't work out, even in not-so-drastic ways - e.g. "I made 3% on this GIC you told me about and my buddy at work made 15% on the market last year?!" And if people ask what I do with mine, I usually skirt the issue or if I do tell them I'll accompany it with all the reasons I'm probably doing it all wrong.

May 21, 2020
2:07 pm
Norman1
Member
Members
Forum Posts: 7138
Member Since:
April 6, 2013
sp_UserOfflineSmall Offline

Doug said

The fact that we have at least one confirmed report, from Elaine, of a Pace Savings representative, ostensibly an unlicensed teller or receptionist at the credit union branch, mentioning potential returns (strictly prohibited by IIROC and MFDA regulations governing the activities of non-licensed assistants and other staff) is highly problematic. Together with that, the integrated Pace Securities and Pace Savings account statements, and the fact that there was likely widespread confusion on where investors stood in their buying Pace Financial Ltd preference shares as opposed to Pace Savings & Credit Union Ltd preference shares is also highly problematic, and, I think, may show some potential legal liability on the part of the credit union, no?

I'm aware of no such restrictions. Anyone can pass on the info that one of the licensed staff has provided and approved. The branch staff can even hang up a poster in the window with info that the mutual fund or investment dealer staff has approved.

It is not clear to me how confusion arose. The transaction confirmation that Yaftica uploaded clearly shows PACE Financial non-voting preferred shares were involved, with CIPF member PACE Securities Corp. acting as the agent. There's no mention of PACE Savings & Credit Union.

… So, essentially, if an Alberta investor read through the offering memorandum (or at least received it), but only grossed $50,000 per year in income from employment and a further $5,000 per year in income from deposits and investments, they could still purchase up to $10,000 per year as a non-eligible investor and also provided they completed the applicable questionnaires and risk profile acknowledgements?

That's correct. Income and assets don't matter in Alberta when purchasing up to $10,000 of a private placement without a prospectus. I think that is to allow for something called crowdfunding. I prefer the other name that critics have given for what that $10,000 limit allows: crowdfleecing.

May 21, 2020
2:18 pm
Norman1
Member
Members
Forum Posts: 7138
Member Since:
April 6, 2013
sp_UserOfflineSmall Offline

Elaine said

This is the only letter I have EVER received from Pace Financial Limited.
I hope some of you know what it means

It means that you invested essentially in a hedge fund that transacted in junk bonds and options.

For every $5 invested into PACE Financial, around $10 was borrowed to buy up to $15 of junk bonds and options. That could multiply gains by up to 3X. Unfortunately, it works the other way as well. Losses would be multiplied by 3X.

May 21, 2020
3:02 pm
Doug
British Columbia, Canada
Member
Members
Forum Posts: 4273
Member Since:
December 12, 2009
sp_UserOfflineSmall Offline

Norman1 said
I'm aware of no such restrictions. Anyone can pass on the info that one of the licensed staff has provided and approved. The branch staff can even hang up a poster in the window with info that the mutual fund or investment dealer staff has approved.

Yes, that's true. I can't find where it itemizes the permitted activities of non-registered branch staff of the investment mutual fund dealer or related bank or credit union, so perhaps that was an internal bank- or credit union-specific communication that synthesizes the applicable MFDA/IIROC, as applicable, Rules and National Instruments. Nevertheless, what I do know, and National Instuments 81-102 and 81-103 elucidate this, is that non-registered staff are prohibited from discussing the contents of any official mutual fund document (i.e., Fund Facts, prospectus, etc.). So, mentioning potential returns would be specifically excluded from that. All that credit union staff member would've been permitted to do is to have told Elaine or Yaftica essentially that the credit union has "other investment products, sold by registered and approved branch staff" with higher risk/return characteristics than traditional GICs and other deposit products. Specifically suggesting the potential return of approximately 6%, as Elaine highlighted above, would be prohibited.

Relating to IIROC specifically, have a look at Rule 2400, item #9, https://www.iiroc.ca/Rulebook/MemberRules/Rule02400_en.pdf.

That's correct. Income and assets don't matter in Alberta when purchasing up to $10,000 of a private placement without a prospectus. I think that is to allow for something called crowdfunding. I prefer the other name that critics have given for what that $10,000 limit allows: crowdfleecing.  

Thanks, Norman. Yeah, I'm generally in favour of crowdfunding, though, honestly, I wouldn't mind seeing the maximum be a percentage of one's annual income, or $10,000, whichever is less. Say if it were limited to (a) the lesser of 10% of one's annual income or (b) $10,000, then one earning $50,000 could only contribute up to $5,000 to any single investment whereas one earning $150,000 but not meeting the "accredited investor" standard would be limited to $10,000.

While not the same, I do generally think we are better by having a new class of investment dealer, that of exempt market dealers. I'm curious to know, though, from a legal perspective, what added protections a prospectus offers versus an offering memorandum. Does it just have to do with the right to cancel a purchase within a prescribed period of time in the case of the former? In terms of legal recourse through the courts, if one was misled, I would think the legal recourse applies whether they received an offering memorandum or a prospectus.

Cheers,
Doug

May 21, 2020
3:20 pm
AltaRed
BC Interior
Member
Members
Forum Posts: 3111
Member Since:
October 27, 2013
sp_UserOfflineSmall Offline

Norman1 said

Elaine said

This is the only letter I have EVER received from Pace Financial Limited.
I hope some of you know what it means

It means that you invested essentially in a hedge fund that transacted in junk bonds and options.

For every $5 invested into PACE Financial, around $10 was borrowed to buy up to $15 of junk bonds and options. That could multiply gains by up to 3X. Unfortunately, it works the other way as well. Losses would be multiplied by 3X.  

A very good characterization. The equity bull market of some 10 years made junk bonds look invincible with negligible risk of loss. A lot of products, such as this one and even mainstream ETFs, were developed to capture investor appetite for yield. Unfortunately, leveraged junk bonds are an especially speculative investment and Laurentien was savvy enough to call in the leverage quickly as the house of cards started to quiver.

May 22, 2020
8:43 am
Bud
Member
Banned
Forum Posts: 1375
Member Since:
February 20, 2018
sp_UserOfflineSmall Offline

I dealt with Pace in the last month no issues at branch level good service. Only positive things to say over the years I've done well with them on the Gic front.

May 22, 2020
9:05 am
Doug
British Columbia, Canada
Member
Members
Forum Posts: 4273
Member Since:
December 12, 2009
sp_UserOfflineSmall Offline

Bud said
I dealt with Pace in the last month no issues at branch level good service. Only positive things to say over the years I've done well with them on the Gic front.  

That's nice, Bud. sf-cool

Cheers,
Doug

May 22, 2020
9:23 am
Elaine
Member
Members
Forum Posts: 104
Member Since:
May 19, 2020
sp_UserOfflineSmall Offline

That is nice ,too
I just feel very strongly that there is a conflict of interest(no pun intended) when the dividends would show up on your regular PACE CREDIT UNION statement.And I confirmed that today with PACE.Something like P.S.DIV.So at least I have that answer from them right away which saved me a lot of searching.
It's Friday-got other things to do-glad my dividends were paid out so I only lost about 84000(my guess until I go through all my online statements) and I did find 20 bucks on the road yesterday.
Because of the perceived(I am not a lawyer) conflict of interest I am not sure what the fate of PACE CREDIT UNION will be.
I have not had a problem with PACE itself and the manager even offered me a coffee while I was picketing in front of it the other day.

May 22, 2020
10:12 am
Norman1
Member
Members
Forum Posts: 7138
Member Since:
April 6, 2013
sp_UserOfflineSmall Offline

Elaine said

I just feel very strongly that there is a conflict of interest(no pun intended) when the dividends would show up on your regular PACE CREDIT UNION statement.And I confirmed that today with PACE.Something like P.S.DIV.So at least I have that answer from them right away which saved me a lot of searching.

That looks like a direct deposit of dividend money from PACE Securities to that account. If that is the case, then that is not significant.

Any company in Canada with the account number, transit number, and PACE Credit Union's institution number can do direct deposits to the account through a clearing system run by Payments Canada.

If you had worked at "Alice's Shoes", you could find your pay directly deposited to that account as "ALICE'S SHOES.PAY". It won't mean that PACE Credit Union vouches for Alice's Shoes and PACE Credit Union would owe you missing pay should Alice's Shoe go bankrupt before sending out your last pay.

Keep in mind that there are different members in the PACE family of companies. PACE Credit Union, PACE Securities, and PACE Financial. Each member has their own character. Like a human family, the parents could be fine. But, some of the children end up to be something else!

I'm pretty sure some of the PACE Credit Union staff are appalled at what happened to you and Yaftica after they referred you to PACE Securities. The staff probably thought you'd be pitched some conservative mutual funds and maybe shares of some large blue-chip companies, like Loblaws, BCE, or an "evil competitor" Royal Bank. No-one likely suspected you'd be steered into a hedge fund.

May 22, 2020
2:26 pm
Yaftica
Interwebs
Member
Members
Forum Posts: 67
Member Since:
May 15, 2020
sp_UserOfflineSmall Offline

I received a call from Pace this week. The rep was calling to ensure that I received their head office info and such. They seemed to have no other idea as to why head office asked them to call 300 or so people. I clued the person specifically to the loss I’ve experienced here and with my limited knowledge gained so far, how it transpired.

They didn’t know about the hearing on Thursday only that the Securities arm was now defunct and that E&Y were assisting their clients. The person admitted to me that he was not made aware of the specifics which have affected people here as far as losses go. I found that hard to believe but he certainly sounded shocked that I lost my entire TFSA savings in the span of being involved with PSC over 6 months.

Doesn’t matter now but I relayed the reason the CU seems to exist, why I initially joined and what they market in their branding of supporting membership which is what I hope they want to preserve here in possibly making this right some day. I know, a long shot. I have to wonder however if they would feel compelled somewhat with this major news hitting the public sector union memberships which comprise a great deal of clientele and people start to distrust that branding, begin to pull their cash accounts in fear the rest of the corporation is going in the same direction.

This was a deliberate business decision by Pace CU to scuttle the ship and avoid bankruptcy, it should be broadcast in that manner to the rest of the membership not in the vanilla way they have done it so far.

I’m eager to see my letter next week from E&Y that went out today.

https://www.iiroc.ca/Documents/2020/2bdb988a-f56d-4228-a606-536e94d52735_en.pdf

May 23, 2020
11:13 am
Norman1
Member
Members
Forum Posts: 7138
Member Since:
April 6, 2013
sp_UserOfflineSmall Offline

Yaftica said
I received a call from Pace this week. The rep was calling to ensure that I received their head office info and such. They seemed to have no other idea as to why head office asked them to call 300 or so people. I clued the person specifically to the loss I’ve experienced here and with my limited knowledge gained so far, how it transpired.

They didn’t know about the hearing on Thursday only that the Securities arm was now defunct and that E&Y were assisting their clients. The person admitted to me that he was not made aware of the specifics which have affected people here as far as losses go. I found that hard to believe but he certainly sounded shocked that I lost my entire TFSA savings in the span of being involved with PSC over 6 months.

The caller probably works for PACE Credit Union, not PACE Securities. So, he was likely not privy to what happened to credit union members who got referred to PACE Securities.

… I have to wonder however if they would feel compelled somewhat with this major news hitting the public sector union memberships which comprise a great deal of clientele and people start to distrust that branding, begin to pull their cash accounts in fear the rest of the corporation is going in the same direction.

Probably not. At worst, PACE CU would have a loss on the money they had sank into PACE Securities. I don't think PACE CU would have put any money into PACE Financial.

This was a deliberate business decision by Pace CU to scuttle the ship and avoid bankruptcy, it should be broadcast in that manner to the rest of the membership not in the vanilla way they have done it so far.

It wasn't their own bankruptcy that PACE CU was trying to avoid. It was that of PACE Securities. If it was closed and wound up before it runs out of money, then there might be enough money left to pay off all the creditors and some left for the shareholders. That's likely why it was a windup filing and not a bankruptcy filing.

PACE CU did shop PACE Securities around. But, no buyer was found.

May 23, 2020
11:29 am
Norman1
Member
Members
Forum Posts: 7138
Member Since:
April 6, 2013
sp_UserOfflineSmall Offline

Doug said

…Nevertheless, what I do know, and National Instuments 81-102 and 81-103 elucidate this, is that non-registered staff are prohibited from discussing the contents of any official mutual fund document (i.e., Fund Facts, prospectus, etc.). So, mentioning potential returns would be specifically excluded from that. … Specifically suggesting the potential return of approximately 6%, as Elaine highlighted above, would be prohibited.

Relating to IIROC specifically, have a look at Rule 2400, item #9, https://www.iiroc.ca/Rulebook/MemberRules/Rule02400_en.pdf.

There is no prohibition on communicating specific potential returns in item #9. 9(a)(iv) just prohibits non-registered staff from recommending buying and selling activity in the accounts:

9 (a) Non-registered personnel employed by the Dealer Member or representatives of the financial services entity may not conduct certain activities. These individuals may not:

(iv) provide recommendations or any advice on any activity in or for the account of the Dealer Member, …

National Instrument 81-102 deals with the contents of sales communications. I didn't see any restrictions on who may do the communicating.

National Instrument 81-103 deals with requirements of registrants. Non registrants are not subject to any of those requirements, just as those who are not registered as an investment counsellor are not subject to the fiduciary obligations of an investment counsellor.

Please write your comments in the forum.