In a decision released Thursday, an Ontario Securities Commission panel found that Maple Leaf Investment Fund Corp., Joe Henry Chau, Tulsiani Investments Inc., and Sunil Tulsiani breached the Ontario Securities Act and acted contrary to the public interest in connection with the sale of Maple Leaf bonds to members of the public, which raised over $4 million from over 80 investors.

In its decision, the OSC panel found that Maple Leaf and Chau breached the Securities Act by trading Maple Leaf bonds without registration, distributing these securities without a prospectus, and making prohibited representations contrary to securities law and the public interest.

The OSC panel found that Maple Leaf and Chau misled potential investors by providing false and incomplete information and that they diverted funds, knowingly placing investors’ funds at risk.

The OSC panel also found that Sunil Tulsiani and Tulsiani Investments breached securities law by advising with respect to the Maple Leaf 400 series bonds without being registered to do so, including by, directly and/or indirectly, promoting the Maple Leaf 400 series bonds as “risk free” to members of an investment club that Sunil Tulsiani and Tulsiani Investments operated.

“The OSC panel concluded that the conduct of the respondents was egregious and dishonest, and that they preyed on vulnerable investors, many of whom did not understand the purported investments,” the OSC said in a release.

A sanctions hearing in this matter is pending.