CASE ID – D-21-015

CHARTERED PROFESSIONAL ACCOUNTANTS OF ONTARIO

CHARTERED PROFESSIONAL ACCOUNTANTS OF ONTARIO ACT, 2017

DISCIPLINE COMMITTEE

IN THE MATTER OF: Allegations against Mark A. Hinchcliffe, CPA, CA, a member of the
Chartered Professional Accountants of Ontario, under Rules 202,
204.3 and 206.1 of the CPA Ontario Rules of Professional Conduct
and Code of Professional Conduct

BETWEEN:

Chartered Professional Accountants of Ontario

Professional Conduct Committee

-and-

Mark A. Hinchcliffe

APPEARANCES:

For the Professional Conduct Committee: Kelvin Kucey, Counsel

For Mr. Hinchcliffe: James Lane, Counsel

Heard: May 4, 2022

Decision and Order effective: May 4, 2022
Release of written reasons: June 8, 2022

REASONS FOR THE DECISION AND ORDER MADE MAY 4, 2022

I. OVERVIEW

[1] The Professional Conduct Committee of the Chartered Professional Accountants

of Ontario (“PCC”) has made Allegations that Mr. Hinchcliffe failed to carry out his
professional services with integrity, objectivity and due care in that as audit
engagement partner he failed to take responsibility for the performance of the audit
of a public company contrary to Rule 202 of the CPA Ontario Rules of Professional
Conduct (Rules) and Code of Professional Conduct (Code); that Mr. Hinchcliffe
failed to identify, evaluate and safeguard against threats to auditor independence
 while engaged to perform assurance services contrary to Rule 204.3 of the Rules
and the Code; and that Mr. Hinchcliffe failed to perform his professional services
in accordance with generally accepted standards of the profession while acting as
the engagement partner in five audits of financial statements, a restatement, and
a review engagement, in contravention of Rule 206.1 of the Rules.
[2] Mr. Hinchcliffe became a Chartered Accountant in 1972. He has been a partner at
HS & Partners LLP (HS&P), a registered accounting firm, since 2000. From 2014
through 2020, HS&P was a two-partner firm, with the other partner being Louis
Sapi CPA, CA. At all material times Mr. Sapi was the CEO and managing partner
of HS&P.
[3] This hearing was held to determine whether the Allegations were established and
whether the conduct of Mr. Hinchcliffe amounted to professional misconduct.
[4] Mr. Hinchcliffe admitted the Allegations made by the PCC.

II. THE COMPLAINT AND THE ALLEGATIONS

[5] Standards Enforcement staff opened a complaint against Mr. Sapi in January
2021, and shortly thereafter appointed investigators to investigate allegations of
misconduct against Mr. Sapi. The investigation focused on Mr. Sapi’s role as
managing partner of HS&P and the firm’s audits of investment vehicles created by
the firm’s client PEFC, including SSM which, along with related entities, was the
subject of an investigation by the Ontario Securities Commission (OSC) in 2016
and which was placed in receivership in 2017.
[6] The investigation into Mr. Sapi determined that the engagement partner for SSM
was Mr. Hinchcliffe, leading to the opening of a complaint and investigation into
Mr. Hinchcliffe in April 2021.
[7] The onus was on the PCC to show on a balance of probabilities that Mr.
Hinchcliffe’s conduct breached Rule 202 of the Rules and the Code, Rule 204.3 of
the Rules and the Code, and Rule 206.1 of the Rules, and constituted professional
misconduct.

III. PRELIMINARY ISSUES

[8] Both parties agreed there were no preliminary issues.

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IV. ISSUES

[9] The Panel identified the following issues arising from the Allegations:
A. Did the evidence establish, on a balance of probabilities, the facts on
which the Allegations by the PCC were based?
B. If the facts alleged by the PCC were established on the evidence on a
balance of probabilities, did the Allegations constitute professional
misconduct?

V. DECISION

[10] The Panel found that the evidence established, on a balance of probabilities, the
facts set out in the Allegations of professional misconduct.
[11] The Panel was satisfied that the Allegations constituted a breach of Rule 202 of
the Rules and the Code, Rule 204.3 of the Rules and the Code, and Rule 206.1
of the Rules, and, having breached these Rules, Mr. Hinchcliffe committed
professional misconduct.

VI. REASONS FOR THE DECISION ON MISCONDUCT

Findings Regarding the Conduct of Mr. Hinchcliffe

[12] Evidence in support of the Allegations was placed before the Panel through an
Agreed Statement of Facts (ASF), dated April 29, 2022 (Exhibit 1) and a Document
Brief to the Agreed Statement of Facts (Exhibit 2). The Standards Brief was made
Exhibit 3.

[13] The parties also agreed to stipulate the fact that at all material times Mr. Hinchcliffe
held a Public Accounting Licence.

[14] The parties tendered no further evidence.

HS&P’s Engagement with PEFC and SSM

[15] The company PEFC was a registered mortgage broker that arranged and
administered second mortgages on single-family properties. PEFC’s May 31,
2014 year-end financials were upgraded to an audit, as the Financial Services
Commission of Ontario required a statutory audit of its trust funds with an
accompanying audit report.

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[16] Starting in September 2014, PEFC’s principals began establishing various related,
subsidiary corporations and investment funds including SSM. SSM was made up
of three companies: SSM LP, SSM GP, and SSM Trust (collectively “SSM”). The
principals of SSM used it as a pooled investor fund, administered by PEFC, to lend
money to borrowers on the security of second mortgages. PEFC administered
SSM and promoted its investments through a network of referral agents.

[17] HS&P prepared the corporate tax returns for SSM for fiscal years 2014 and 2015.
Starting in October 2015, HS&P undertook the assurance work of SSM. The
assurance engagement was for the years ended December 31, 2014, and 2015
for the audit of the financial statements of SSM LP and SSM GP; the audit of the
restatements of the 2014 and 2015 SSM LP financial statements; and the audit of
the consolidated financial statements of the SSM Group, consisting of SSM GP,
SSM LP, and SSM Trust for the year ended December 31, 2015 (collectively the
“SSM Audits”).

[18] With Mr. Hinchcliffe as the engagement partner, HS&P issued unqualified audit
opinions on the financial statements of all SSM entities for the SSM Audits.

Resignation of HS&P and investigation by the OSC

[19] HS&P formally resigned as SSM’s auditor in April 2017, in the face of an OSC
investigation into PEFC and its related entities, including SSM. The next month
the OSC obtained a receivership order over PEFC and its related companies, to
protect investors who were told their money would be invested in second
residential mortgages. The OSC subsequently alleged that, contrary to PEFC’s
representations to investors, approximately $50 million of their funds were invested
in higher risk land and development projects, and that the principals of PEFC
engaged in hidden self-dealing by paying millions of fees to themselves and taking
a 50% direct ownership in such projects, as well as using investor funds for their
own purposes.

[20] In March 2019 the Receiver filed a Statement of Claim against PEFC, its related
companies and principals, seeking $50 million in damages for negligence, breach
of fiduciary duty, and breach of trust.

[21] In March 2020 the OSC filed amended allegations against PEFC, SSM and other
related entities, seeking significant remedies against the defendants based on
fraud, misleading investors, unregistered trading, and the illegal distribution of
securities. In April 2022 the OSC released its decision and reasons, concluding

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 that, among other things, the principals of PEFC and SSM engaged in fraud
against their investors.

Other HS&P Engagements

[22] CPA Ontario investigated two additional engagements from 2020 for which Mr.
Hinchcliffe was the engagement partner: the audit of Company “T” for the year
ended March 31, 2020, and the review engagement of Company “E” for the year
ended February 29, 2020.

[23] The SSM Audits and these two engagements are collectively referred to as the
“Engagements”.

Engagement Failures

[24] The Allegations contain 68 particulars of professional misconduct, relating to Mr.

Hinchcliffe’s role as engagement partner in the Engagements. The ASF identifies
the deficiencies related to each of the particulars, and cross references the
relevant requirements as included in the Canadian Accounting Standards for
Private Enterprises, Canadian Auditing Standard (CAS) and Canadian Standard
for Review Engagements (CSRE) 2400 in effect at the time of the audits and
reviews.

[25] In doing so the ASF organizes the 68 particulars into nine categories of
misconduct. It includes detailed evidence in support of the Allegations that Mr.
Hinchcliffe (a) failed to take responsibility for the performance of audit; (b) failed to
safeguard against threats to auditor independence; (c) completed engagement
work after the date of the engagement report; (d) failed to communicate
deficiencies with management; (e) failed to conduct a validation of SSM’s
compliance with OSC regulatory requirements; (f) failed to identify the high risk of
material misstatement for SSM; (g) failed to obtain sufficient appropriate audit
evidence to support balance sheet items of SSM; (h) failed to ensure the inclusion
of all necessary audit elements for Company “T”; and (i) failed to avoid shortfalls
in the review procedure for Company “E”.

A) Responsibility for audit and review performance

[26] Mr. Hinchcliffe provided an unqualified Independent Auditor’s Report in respect of

each of the audit Engagements. As the engagement partner, Mr. Hinchcliffe was
responsible for the audit engagement and its performance and for the auditor’s

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 report issued on behalf of the firm. CAS 220 requires the engagement partner to
take responsibility for the direction, supervision, and performance of the audit
engagement in compliance with professional standards and applicable legal and
regulatory requirements.

[27] During the investigation Mr. Hinchcliffe could not produce any emails, notes from
telephone conversations, calendar entries, memoranda, notes, or any
documentary evidence to support that he was actively engaged in the
Engagements.

[28] For the SSM Audits, the extent of Mr. Hinchcliffe’s involvement was his
participation in the planning meeting, a few discussions with members of HS&P, a
high-level review of the working paper file, and a review of the financial statements.
He did not participate in audit decisions throughout the engagement, but relied on,
and deferred to, other HS&P accountants (including Mr. Sapi) on all significant
issues.

[29] The principals of PEFC and SSM wrongly identified Mr. Sapi, not Mr. Hinchcliffe,
as the engagement partner. They communicated only with Mr. Sapi during the
duration of the SSM Audits and restatement engagement.

[30] Mr. Hinchcliffe was not involved in the decision and discussions regarding HS&P’s
resignation in the Spring of 2017. It was Mr. Sapi who wrote the auditor
resignation, on behalf of HS&P, on which Mr. Hinchcliffe was not even copied.

[31] Mr. Sapi, rather than Mr. Hinchcliffe, was heavily involved in the SSM
engagements and took on responsibilities properly reserved to Mr. Hinchcliffe as
the engagement partner. Mr. Sapi circumvented Mr. Hinchcliffe’s purported
leadership of the SSM audit engagements, by routinely engaging with SSM’s
leadership without Mr. Hinchcliffe’s participation.

[32] With respect to the Company “T” and Company “E” engagements, the role
performed by Mr. Hinchcliffe was similarly limited and did not satisfy the
requirements of an engagement partner as set out in CAS 220 and CSRE 2400.

[33] In summary, Mr. Hinchcliffe as the engagement partner was inappropriately

disconnected from the Engagements, instead relying on the work of other HS&P
accountants, especially Mr. Sapi. Mr. Hinchcliffe abrogated the role of
engagement partner and failed to take responsibility for the quality and
performance of the Engagements.

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 B) Auditor Independence

[34] The Rules and Code require HS&P to be independent of SSM while acting as
auditors of their financial statements. Rule 204 identifies that a financial interest in
the assurance client may create a self-interest threat, and prohibits a member who
is a partner in a firm from holding a direct or indirect financial interest in an audit
client.

[35] Mr. Sapi invested $100,000 in SSM in August 2015, two months before HS&P was
retained to provide audit services to SSM. At the commencement of the audit
engagement, Mr. Sapi completed the HS&P independence disclosure document,
representing that he did not hold a financial interest in SSM. During the course of
the audit engagement, Mr. Sapi was aware and permitted a staff member of HS&P
to solicit investors for SSM in consideration for referral fee payments.

[36] Mr. Sapi did not advise Mr. Hinchcliffe or any other member of the HS&P audit
team of his investments in SSM. The HS&P 2015 audit working papers for SSM
LP include the SSM trial balance, which lists Mr. Sapi as a $100,000 investor. The
HS&P audit team signed off on this document without comment. In November
2015 HS&P issued its audit reports for SSM GP and SSM LP with unqualified
opinions.

[37] In February 2016, Mr. Sapi invested a further $100,000 in SSM. In March 2016
HS&P issued its audit reports for SSM GP and SSM LP with unqualified opinions.

[38] Mr. Sapi made further investments in SSM in May and August 2016, raising his
investments to $280,000. He was paid $13,500 by SSM in compensation for his
referrals and investments.

[39] Mr. Sapi compromised the independence of HS&P’s audits of the financial
statements of SSM for the years ended December 31, 2014 and 2015 and the
subsequent audit of the restatement of the financial statements for the year ended
December 31, 2015, dated September 6, 2016.

[40] Mr. Sapi failed to disclose the fact of his investments and referral relationship with
SSM to Mr. Hinchcliffe from October 8, 2015 through April 20, 2017.

[41] In 2016, Mr. Sapi advised Mr. Hinchcliffe that an HS&P staff member was earning
referral fees for referring investors to SSM. This triggered a review which resulted
in an Independence Memorandum in which HS&P identified this situation as a
potential threat to objectivity, and identified safeguards to reduce the threat,

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 including that HS&P would step down from providing assurance services to SSM
going forward.

[42] The Independence Memorandum was not included in HS&P’s SSM audit
engagement files. Notwithstanding its conclusions, HS&P started the SSM audit
engagement in 2017 as originally planned. Only when the 2017 OSC investigation
intensified did HS&P resign as SSM’s auditors.

[43] The SSM audit engagement files did not contain any documentation of the threats
to independence and there was no evidence that HS&P applied safeguards
sufficient to reduce these threats to an acceptable level.

C) Completion of the engagement work after the date of the engagement report

[44] The applicable audit standards clearly prescribe that the engagement partner must
perform his review on or before the date of the auditor’s report and must ensure
that sufficient appropriate audit evidence was obtained on or before that date.

[45] The date of HS&P’s audit and review opinions for the Engagements predates when
the files were internally reviewed by Mr. Hinchcliffe. Although Mr. Hinchcliffe
advised the investigators that sometimes a verbal confirmation is first obtained
prior to the issuance of the report, there is no evidence in the working paper files
that a verbal confirmation was obtained.

D) Communication with those charged with governance

[46] No deficiencies in internal control were communicated to management or those

charged with governance of SSM during the 2014 and 2015 audits. Specifically,
Mr. Hinchcliffe failed to document evidence of communications regarding the
overview of the planned scope and timing of the audit, which includes
communicating about the significant risks identified; he failed to communicate
deficiencies in the financial structure, record keeping, oversight and operation of
SSM LP; and he failed to communicate deficiencies in internal controls.

E) Regulatory requirements for SSM

[47] The SSM audit files do not contain any evidence that Mr. Hinchcliffe or anyone
else on the HS&P audit team conducted a validation of SSM’s compliance with
OSC and other regulatory requirements. The working paper files indicate that Mr.
Hinchcliffe relied on the principals’ assertions with respect to SSM’s legal and
regulatory status. Given the context and structure of SSM, it was necessary for
Mr. Hinchcliffe to validate more thoroughly whether SSM had regulatory

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 requirements with respect to the OSC or any other regulatory organization and to
obtain sufficient appropriate audit evidence to support his understanding.

F) Risk Assessment of SSM

[48] HS&P did not identify any high-risk accounts or class of transactions in performing
the SSM Audits. However, based on the nature of the industry and the operations
at SSM, it is reasonable to expect that a mortgage loans receivable, and units held
by SSM Trust, would be assessed as high risk. Had these balances been assessed
as high risk, HS&P would likely have modified the nature, timing, and extent of its
audit procedures.

[49] As engagement partner, Mr. Hinchcliffe was in a position to identify that the SSM
financial data lacked transparency with respect to its risk profile, yet he failed to
take any action.

G) Obtaining sufficient appropriate audit evidence to support balance sheet items

[50] Insufficient audit evidence was gathered by HS&P with respect to the mortgage
loans receivables valuation for SSM’s 2014 and 2015 financial statements and the
restatement of these financial statements. HS&P did not perform any work with
respect to the valuation assertion of the mortgage loans receivable. There were
no appraisals in the working paper file, nor evidence of alternative procedures such
as visiting the site of the projects, or obtaining the project financial forecasts.

[51] There was no audit work conducted in respect of the September 2016 restatement
of SSM LP’s 2014 and 2015 financial statements. Mr. Hinchcliffe was unable to
explain the reason for the restatement, other than it was done at the request of the
client. The restatement included additional recognition of management fees in
order to reduce taxes payable, which could be considered a manipulation of
management fees. Mr. Hinchcliffe failed to demonstrate any professional
skepticism in dealing with the management fees.

[52] With respect to the entry in SSM GP’s financial statements of deposits on real
estate, HS&P relied solely on management representations in assessing whether
the deposits were accurately presented in the financial statements. Mr. Hinchcliffe
should have ensured that HS&P corroborated management’s representations with
external audit evidence.

H) Missing Company “T” audit elements

[53] The financial statements of Company “T” are to be prepared in accordance with a
special purpose framework, and require an Emphasis of Matter paragraph alerting
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 users to this fact. Mr. Hinchcliffe failed to include an Emphasis of Matter paragraph
outlining the basis of accounting and a restriction on its distribution and use. In
addition, Mr. Hinchcliffe failed to design and perform analytical procedures near
the end of the audit when forming his overall conclusion as to whether the financial
statements are consistent with his understanding of the entity.

I) Shortfalls in review procedures for Company “E”

[54] Although in the planning process HS&P had identified a potential ‘going concern’
issue due to the impact of the COVID pandemic, during the performance of the
review engagement this was not identified as an area in the financial statements
where material misstatements were likely to arise. Mr. Hinchcliffe failed to
recognize that the ‘going concern’ assessment requirement was not addressed.

[55] Among the additional shortfalls in the review procedures, HS&P’s review report
does not include a description of the nature of the company’s business; the note
on revenue recognition is insufficient; HS&P did not document the date when those
in authority acknowledged taking responsibility for the financial statement; and
HS&P should have recognized an increased risk associated with the valuation of
accounts receivable.

Finding of Professional Misconduct

[56] Through the ASF Mr. Hinchcliffe admits that these facts constitute professional
misconduct.

[57] Specifically, Mr. Hinchcliffe admits that, in the period from October 8, 2015 to April
20, 2017, in issuing four audited financial statements and the restatement of the
financial statements of SSM, he failed to conduct himself with integrity, due care
and objectivity contrary to Rule 202 of the Rules and the Code.

[58] Mr. Hinchcliffe admits that, in the period from October 8, 2015 to April 20, 2017,
while acting as the engagement partner for the audits of the financial statements
of SSM LP and SSM GP for the years ended December 31, 2014 and 2015, the
consolidated financial statements for the SSM group for the year ended December
31, 2015 and for the restatement of the 2014 and 2015 audits of the financial
statements of SSM LP, he failed to adequately evaluate and safeguard against
threats to auditor independence arising from HS&P’s referral of investors in PEFC
for compensation, contrary to Rule 204.3 of the Rules and Code.

[59] Mr. Hinchcliffe admits that, while acting as the engagement partner with respect to
the Engagements, he failed to perform his professional services in accordance
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 with generally accepted standards of practice of the profession, including the
recommendations set out in the CPA Canada Handbook, contrary to Rule 206.1
of the Rules and the Code.

[60] The Panel concluded that the Allegations, having been proven on the evidence,
constituted breaches of Rules 202, 204.3 and 206.1 of the Rules and the Code
and constitute professional misconduct.

VII. DECISION AS TO SANCTION

[61] After considering the evidence, the law, and the joint submission of both parties,
the Panel concluded that the appropriate sanction was a written reprimand, a fine
of $50,000 payable by December 30, 2022, a suspension of Mr. Hinchcliffe’s
membership with CPA Ontario for a period of six months, a permanent restriction
of Mr. Hinchcliffe’s practice to performing only non-assurance engagements, and
the revocation of Mr. Hinchcliffe’s Public Accounting Licence.
[62] Notice of the decision is to be given to the membership, the Public Accountants
Council for the Province of Ontario and to all provincial bodies, and notice of the
practice restriction and Public Accounting Licence revocation is to be published on
the CPA Ontario website and in the Globe and Mail newspaper.
[63] If Mr. Hinchcliffe does not comply with the terms of the Panel's order, his
membership in CPA Ontario will be revoked.

VIII. REASONS FOR THE DECISION AS TO SANCTION

[64] The Panel accepted the position on sanction jointly submitted by the PCC and Mr.
Hinchcliffe.
[65] The Panel recognizes that a joint submission is entitled to a high level of deference.
A joint submission should be adopted unless it is contrary to the public interest or
would bring the regulatory process into disrepute because it was beyond the
reasonable range of sanction.
[66] In the case of R. v. Anthony Cook 1 the Supreme Court of Canada wrote at para.
34 that a joint submission should not be rejected lightly:

Rejection denotes a submission so unhinged from the circumstances

1 R. v. Anthony-Cook, 2016 SCC 43 ¶ 34

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 of the offence and the offender that its acceptance would lead
reasonable and informed persons, aware of all the relevant
circumstances, including the importance of promoting certainty in
resolution discussions, to believe that the proper functioning of the
justice system had broken down. This is an undeniably high
threshold.

[67] The Panel finds that the joint submission of the parties falls well within the
reasonable range of sanction for the misconduct of Mr. Hinchcliffe and is not
contrary to the public interest.
[68] The Panel recognizes that Mr. Hinchcliffe has been co-operative through the CPA
investigation, and that it is not alleged in this proceeding that he acted dishonestly
in the conduct of the assurance engagements at issue or during the PCC’s
investigation. The Panel further recognizes that there is no evidence that Mr.
Hinchcliffe has a prior disciplinary history, and that he should be credited for
accepting responsibility for his misconduct by admitting the allegations and
agreeing to the statement of facts.
[69] The Panel finds that the fine of $50,000 ensures that the objectives of specific and
general deterrence are achieved, as a fine of this size cannot be said to simply
constitute the cost of doing business, but does reflect current economic realities
and social values.
[70] The Panel finds that a suspension of Mr. Hinchcliffe’s membership for six months
is appropriate. The Panel notes that in the case of MacNeil (2021) a suspension
was not imposed for professional misconduct relating to multiple audit failures in
the context of single audit of a small public company. In MacNeil the panel
indicated that while a suspension is not outside the appropriate range of sanctions
for a professional standards case, the isolated nature of the misconduct militated
against a suspension in that case. In contrast, the misconduct of Mr. Hinchcliffe
was not limited to a single audit: Mr. Hinchcliffe engaged in a pattern of misconduct
across several engagements over several years. Where the failure to comply with
professional standards is not isolated but constitutes a pattern of misconduct, a
suspension is within the range of appropriate penalties even absent a finding of
dishonesty or other moral turpitude.
[71] The Panel finds that the revocation of Mr. Hinchcliffe’s Public Accounting Licence
and the restriction that his practice permanently be limited to non-assurance
engagements is within the range of appropriate sanctions. Counsel for the PCC
identified several comparable professional standards cases and settlement
agreements with sanctions restricting the member’s practice to non-assurance
engagements.

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[72] In revoking Mr. Hinchcliffe’s Public Accounting Licence and permanently restricting
his practice to non-assurance engagements, the Panel sends a strong message
to Mr. Hinchcliffe, and to the membership at large, that the role of engagement
partner is a crucial one which cannot be abrogated or delegated. It is the
engagement partner who shall take responsibility for the overall quality on each
audit engagement to which that partner is assigned (CAS 220.8). It is the
engagement partner who shall take responsibility for the direction, supervision and
performance of the audit or review engagement in compliance with professional
standards and applicable legal and regulatory requirements (CAS 220.15, CSRE
2400.23).
[73] It does not matter the size of the firm, or whether the engagement partner places
exceptional trust in another partner’s abilities. Significant professional
responsibilities are assigned to the engagement partner and these responsibilities
must be met by the engagement partner personally and without exception. Failure
to abide by these professional responsibilities will lead to serious sanctions, up to
and including the revocation of the engagement partner’s Public Accounting
Licence.

IX. COSTS

[74] The law is settled that an order against Mr. Hinchcliffe for costs with respect to the
disciplinary proceeding is not a penalty. Costs are intended to indemnify the PCC,
based on the underlying principle that the profession as a whole should not bear
all of the costs of the investigation, prosecution and hearing arising from the
member’s misconduct.
[75] Costs are awarded at the discretion of the Discipline Committee. It has become
customary for the PCC to file a Costs Outline in the same form as used in civil
proceedings, and to seek 2/3 of the costs incurred in the investigation and
prosecution of the matter.
[76] The PCC Costs Outline is found at Exhibit 4. It totals $41,299. The PCC seeks 2/3
of this amount, approximately $27,257.
[77] The Panel finds this award to be reasonable in the circumstances and orders it be
paid by December 30, 2022.

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Dated this 8th day of June, 2022

David Handley
Discipline Committee – Deputy Chair

Members of the Panel

Richa Khanna, CPA, CA, LPA
Jeremy Cole, FCPA, FCA
Vincci So, CPA, CMA
Catherine Kenwell, Public Representative

Independent Legal Counsel

John Dent, Barrister & Solicitor

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