Taking their annual incomes and net worth into account, those loans resulted in total debt service ratios (TDSR) that ranged from 35.52% to 114.41%, and loan to net worth ratios (LNWR) ranging from 41.67% to 1,477.63%.
“To facilitate the Leveraged Investment Strategy, the Respondent failed to use due diligence to learn or accurately record or intentionally misrepresented the clients’ Know-Your-Client (KYC) information on their account opening documents, net worth statements, and loan applications,” the MFDA said.
The SRO said Sadiq recorded the clients’ KYC information so that his recommendations appeared suitable for the clients – noting their investment knowledge as “good” when they actually had limited knowledge or none, recording their risk tolerance as predominantly high when it was lower, and substantially inflating their annual income and net worth.
He also allegedly submitted supporting financial documents in respect to four clients – including T4 and other pay statements, property tax statements, investment statements, and bank statements – that he knew or should have known contained false, incorrect, or misleading information.
“All 10 clients who implemented the Leveraged Investment Strategy relied entirely upon the distributions generated by the ROC Funds to pay all of the costs of servicing their investment loans,” the MFDA said, noting Sadiq led them to believe the strategy “was a safe and secure manner of investing.”