Hearing panel accepted a settlement agreement after the former rep admitted altering Know Your Client data and refusing a CIRO interview
A Canadian Investment Regulatory Organization hearing panel accepted a settlement agreement on July 14.
The settlement permanently prohibits Tiffany Lee Felker, a former dealing representative with BMO Investments Inc. in Edmonton, Alberta, from conducting securities-related business while employed by or associated with a CIRO Dealer Member.
The panel released its reasons for decision on September 4 and imposed a $10,000 fine and $2,500 in costs.
Felker admitted in the settlement agreement, dated July 13, that she processed transactions and updated Know Your Client information in March 2023 without a client's knowledge or authorization, contrary to Mutual Fund Dealer Rules 2.1.1, 2.2.1 and 2.2.6.
She also admitted failing to cooperate with CIRO Enforcement Staff between November 2023 and December 2025, contrary to Rule 6.2.1.
The client, identified as AL, met Felker on March 14, 2023 about banking business unrelated to her TFSA and RRSP accounts, the agreed facts state.
The two did not discuss the client's investments, and the meeting was their first and only interaction.
Felker reviewed the client's accounts afterward and formed the view that the client would benefit from a more aggressive portfolio.
On March 16 and 20, 2023, without speaking to the client, she electronically signed the client's signature on four account forms, processed unauthorized transactions, changed the KYC information, and cancelled and replaced the bi-weekly pre-authorized contributions in both accounts.
She recorded notes in the client's electronic file that falsely stated the client had instructed the changes.
The KYC record moved from a conservative balanced investment objective, low risk tolerance and fair investment knowledge to equity growth, medium-to-high risk tolerance and knowledge described as "somewhat knowledgeable", shifting the investor profile from conservative to aggressive.
Holdings in the BMO SelectTrust Conservative Portfolio were transferred to the BMO SelectTrust Equity Growth Portfolio in the RRSP and the BMO Dividend Fund in the TFSA.
Between March 27 and 29, 2023, the client discovered and reported the activity, then closed her TFSA and transferred her remaining holdings back to a conservative portfolio.
BMO Investments reported to Staff that the client's mutual fund holdings appreciated by $8.30, and terminated Felker's registration on or around May 18, 2023.
Felker did not communicate with Staff, provide requested information, or attend an interview scheduled for August 2024.
She relied on the advice of a lawyer authorized to practise law in Alberta concerning her obligation to participate in the investigation, and provided corroborating evidence to Staff after CIRO issued its Notice of Hearing on October 23, 2025.
Good faith reliance on legal advice is not a defence to a failure to comply with a statutory obligation but is relevant to sanction as a mitigating factor, Staff submitted, citing Re Deeb 2013 IIROC 8 and Re Legare 2011 MFDA 17.
The panel described the contraventions as serious given the role of an Approved Person in protecting investors and market integrity.
The misconduct was an isolated event, according to the reasons, and while the fine portion of the sanctions is low, Felker provided evidence of limited means, and the prohibition carries serious financial implications of its own.
Felker had not previously been the subject of MFDA or CIRO disciplinary proceedings.
