The Investment Industry Regulatory Organization of Canada (IIROC) has fined Guylaine Raby, a registered representative from Montreal, $20,000 for failing to inform her employer of outside activities and for making off-book transactions.

From 2003 to 2011, Raby acted as an advisor for five clients with an account held with Crédit Agricole Suisse Bahamas (CASB), formerly National Bank International (NBI), according to the settlement agreement document. During that time frame, all transactions in these accounts were made off-book and without the knowledge of Raby’s then-employer Lévis, Que.-based Desjardins Securities Inc.

According to IIROC, the account was original held with Laurentian Bank and Trust Co. Ltd. a subsidiary of Laurentian Group in the Bahamas. Through subsequent sales starting in 1995, the account was eventually moved to Mouvement Desjardins and then to Banque BNP Paribas. The account was finally assigned to NBI.

Up until the assignment to NBI, Desjardins was aware of the account and properly monitored all trades. However, in 2003, Raby began forwarding trade instructions to NBI without the knowledge of Desjardins. According to IIROC, Raby was unaware that Desjardins did not know of the trades and that they were classified as outside business activities. Raby received $14,000 in commissions from the account from 2003 to 2011.

In addition to the fine, IIROC ordered Raby to disgorge the $14,000 made in commissions and to pay $5,000 in costs. Raby is currently an employee of Richardson GMP Ltd.