The Organization filed exempt market distribution forms for two subscribers on January 17, 2020 and January 27, 2020. The filings inadvertently included copies of the two subscription agreements which disclosed the information at issue. Alberta Securities Commission (ASC) staff noted the first breach and had the file marked private on January 21, 2020. The ASC notified the Organization on January 27, 2020. On January, 28, 2020, the Organization reported the second incident to the ASC and requested that the filings be made private until such time as the Organization could complete a refiling.

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