OSC v. Martin Bernholtz (insider trading, 2018)

Settled

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In 2019 the Ontario Securities Commission approved a settlement with Martin Bernholtz, a director of Titan Medical, who sold company shares ahead of overnight marketed offerings without pre-approval and without enough care about holding material non-public information. The order carries C$75,000 in costs and a bar of about three years on trading and acquiring securities.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Ontario Securities Commission filed its statement of allegations on March 28, 2018, alleging a breach of section 76(1) of the Securities Act; the settlement agreement is dated May 16, 2019 and the order followed on May 21, 2019.

The agreed facts are that Bernholtz, a Titan Medical director until March 2018, was told in advance of planned public offerings, sold shares shortly before each was announced and then bought back in the offering. In the settlement he accepted that he had not obtained pre-approval or taken sufficient care about the risk that he held material non-public information, and that this fell below the standard expected of a director and was contrary to the public interest.

The order imposes a trading and acquisition ban of three years and 45 days, a reprimand, a seven-year bar on acting as a director, officer or registrant and C$75,000 in costs. There is no administrative penalty.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Insider trading — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2018-03-28 Statement of Allegations
2. 2018-03-29 Notice of Hearing
3. 2018-04-27 Reasons and Decision
4. 2018-07-06 Reasons and Decision
5. 2018-09-11 Reasons and Decision
6. 2019-02-22 Reasons and Decision
7. 2019-05-16 Notice of Hearing
8. 2019-05-16 Settlement Agreement
9. 2019-05-21 Other
10. 2019-05-21 Reasons and Decision

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• Tribunal proceeding
• Statement of Allegations
• Notice of Hearing
• Reasons and Decision
• Reasons and Decision
• Reasons and Decision
• Reasons and Decision
• Notice of Hearing
• Settlement Agreement
• Other
• Reasons and Decision

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.