Advisor bypasses security, signs 135 clients' forms—panel issues two-year ban and $25K penalty
A Canadian dealing representative electronically signed the names of 135 clients on 356 account forms, bypassing required security protocols and submitting the forms for processing—without the clients’ review or consent.
A CIRO hearing panel accepted a settlement agreement with Jeremy Liam Short, formerly of Investors Group Financial Services Inc., after finding that he had circumvented the Dealer Member’s two-factor authentication system on electronic signing platforms.
Instead of sending documents to clients for signature, Short sent them to his own email and used his phone number to complete the process, leaving no audit trail of client participation.
The forms involved included Know Your Client forms, Account Agreements, Letters of Direction, and other essential documentation.
In one case, Short electronically signed a client’s name to cancel a transfer of investments without speaking to the client, resulting in a delay and compensation to the affected client.
The panel found that Short also created false or misleading notes in the Dealer Member’s system on 13 occasions, indicating that clients had signed forms when they had not.
During the Dealer Member’s investigation, Short made false or misleading statements about the extent of his conduct.
The Dealer Member’s policies strictly prohibit Approved Persons from signing on behalf of clients, regardless of client request or intent.
The panel described Short’s actions as “extremely serious misconduct,” noting that such behaviour undermines public confidence in the industry and the integrity of compliance systems.
Short, who was 25 when the conduct began, cited pandemic restrictions and client difficulties with technology as circumstances, but acknowledged these did not justify his actions.
The panel imposed a $20,000 fine, $5,000 in costs, and a two-year prohibition from securities-related business with any CIRO Dealer Member.
No clients other than the one affected by the transfer reported losses or unauthorized transactions.
The panel concluded that the sanctions were reasonable and proportionate, sending a clear message about the importance of compliance and ethical standards in client documentation and communication.
