OSC v. Paul Christopher Darrigo (churning, 2016)

Judgment entered

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In June 2016 an Ontario Securities Commission panel dismissed Paul Christopher Darrigo's application to review an IIROC decision that found his recommended trades caused unnecessary fees to clients and undue commissions to him, and that he borrowed money from clients. IIROC's sanctions stand: two fines of C$10,000 each, C$95,000 of disgorgement and 12 months of strict supervision on any re-registration.

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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Penalty as published

C$20k

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. This regulator states penalties in CAD. The figure is recorded as published and is not converted, so it does not appear in the USD totals or medians used elsewhere on this site.

What is alleged to have happened

The Ontario Securities Commission heard Paul Christopher Darrigo's application for hearing and review on May 11, 2016 and issued its Reasons and Decision on June 9, 2016. The notice of hearing is dated January 8, 2016. The respondent is Paul Christopher Darrigo (1 individual, 0 entities), a former registered investment representative regulated by the Investment Industry Regulatory Organization of Canada.

The application, not the underlying case, was dismissed. IIROC's hearing panel had found that transactions Darrigo recommended caused unnecessary fees to clients and undue commissions to him, a breach IIROC sanctioned under its guidelines for what is commonly called churning, and that his borrowing from clients was conduct unbecoming. The Commission panel found no denial of procedural fairness in refusing his adjournment, no ground to disturb liability and no reason to change the penalties. An earlier version of this record showed the matter as dismissed in Darrigo's favour; that was wrong.

The sanctions that stand are C$50,000 of commission disgorgement and a C$10,000 fine on the first count, C$45,000 of loan-proceeds disgorgement and a C$10,000 fine on the second, and 12 months of strict supervision on any re-registration. The fines, C$20,000 in total, are stored in the native-currency field; the C$95,000 disgorgement is not stored as a US dollar figure.

For the tribunal's own account, read the primary documents linked above.

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.

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

Timeline

1. 2016-01-08 Notice of Hearing
2. 2016-06-09 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
• Notice of Hearing
• 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.