Roundtable Capital Partners Inc. - s. 3.3(4) of OSC Rule 31-502 Proficiency Requirements for Registrants

Headnote

Application for exemption from subsection 3.3(4), whereby the designated registered representative, partner or officer shall be employed at the same location as the associate representative, partner or associate officer whose advice must be approved.

Rules Cited

Ontario Securities Commission Rule 31-502 -- Proficiency Requirements for Registrants, ss. 3.3(4) and s. 4.1.

December 19, 2007

IN THE MATTER OF

THE SECURITIES ACT,

R.S.O. 1990, c. S.5, AS AMENDED

(The "Act")

AND

IN THE MATTER OF

ROUNDTABLE CAPITAL PARTNERS INC.

DECISION

(Subsection 3.3(4) of Ontario Securities Commission

Rule 31-502 -- Proficiency Requirements for Registrants)

UPON the Director having received the application of Roundtable Capital Partners Inc. (the Applicant) for a decision pursuant to section 4.1 of Ontario Securities Commission Rule 31-502 -- Proficiency Requirements for Registrants (Rule 31-502) granting the Applicant relief from the provision in subsection 3.3(4) of Rule 31-502 requiring an associate advising officer to be supervised by an advising officer, partner or representative who is employed at the same location as the associate advising officer;

AND UPON considering the application and the recommendation of the staff of the Ontario Securities Commission (the Commission);

AND UPON the Applicant having represented to the Director as follows:

1. The Applicant is registered under the Act as a limited market dealer and investment counsel and portfolio manager. The Applicant's head office is located in Toronto. However, James Allan, the Applicant's only advising officer and Chief Compliance Officer works primarily from the Bahamas.

2. Jonathan Ross has applied for registration as an associate advising officer and trading officer with the Applicant. Mr. Ross is currently employed with the Applicant at its Toronto office and intends to continue working from this location upon registration.

3. Staff of the Commission have confirmed that Mr. Ross has demonstrated that he meets the proficiency requirements for registration as an associate advising officer and trading officer.

4. Rule 31-502 requires that the registered advising officer, partner or representative be employed at the same location as the associate advising representative, partner or officer whose advice must be approved (the requirement for supervision from the same location).

5. The Applicant has provided a description of its policies and procedures which combine the use of modern technology and frequent in person visits to the Toronto office to facilitate adequate supervision of Mr. Ross despite the physical distance between the primary working locations of Mr. Ross and Mr. Allan.

AND UPON the Director being satisfied that to do so would not be prejudicial to the public interest;

IT IS THE DECISION of the Director, pursuant to section 4.1 of Rule 31-502 that the Applicant is granted an exemption from the requirement from subsection 3.3(4) of Rule 31-502 for supervision from the same location for so long as:

A. The Applicant continues to be registered in the category of investment counsel and portfolio manager in the province of Ontario; or

B. Mr. Ross ceases to be employed by the Applicant.

DATED at Toronto, Ontario this19th day of December, 2007