The document detailed several joint real estate ventures she invited several of her Investors Group clients to participate in. The clients received minority ownership interests in several real estate properties, funding them through cash savings, mutual fund redemptions from their non-registered investment accounts at the member and, for one set of clients, a line of credit secured against their home, based on Harmer’s recommendation.
In most of the real estate ventures, neither Harmer nor her company contributed capital towards the purchase price of the property concerned, but still received an ownership interest. The exception was when she, through her company, contributed $1 to purchase a 50% share of the net profit from one property.
“The Joint Venture Agreements were not investments approved by the Member to be offered for sale by its Approved Persons,” the MFDA said. “None of the investments by the Clients in the Joint Venture Agreements described above were carried on for the account or through the facilities of the Member.”
It also found that from 2013 to 2014, Harmer convinced clients to purchase exempt market products worth $100,000, which they redeemed from their RRSP. By September 2020, the combined value of those investments – which were not carried on for the account or through the facilities of Investors Group – had declined to roughly $24,966.
Between 2013 and 2014, she also worked as an independent distributor for a skin care company, Nucerity International, without disclosing it or obtaining approval from Investors Group.
