Pollitt & Co. Inc. - Exemption s. 4.1 of OSC Rule 31-507

Headnote

RuleCited

OSCRule 31-507 - SRO Membership - Securities Dealers and Brokers

INTHE MATTER OF

THESECURITIES ACT

R.S.O.1990, C. S.5, AS AMENDED (the "Act")

AND

INTHE MATTER OF

ONTARIOSECURITIES COMMISSION RULE 31-507

SROMEMBERSHIP - SECURITIES DEALERS AND BROKERS (the "Rule")

AND

INTHE MATTER OF

POLLITT& CO. INC.

EXEMPTION

(Section4.1 of OSC Rule 31-507)

UPON the Director having received an application (the"Application") from Pollitt & Co. Inc. ("Pollitt") seekinga decision pursuant to section 4.1 of the Rule to exempt, untilJune 1, 2002, Pollitt from the application of subsection 2.3of the Rule, which would require that Pollitt be a member ofa self-regulatory organization ("SRO") recognized by the OntarioSecurities Commission (the "Commission") under section 21.1of the Act ("Recognized SRO");

AND UPON considering the Application and the recommendationof staff of the Commission;

AND UPON Pollitt having represented to the Directorthat:

1. Pollitt is a corporation incorporated under the laws of Ontarioand is not a reporting issuer in any of the provinces or territoriesof Canada or in any other jurisdiction.

2. Pollittis registered under the Act as a dealer in the category of "broker".

3. Pollitt's registration under the Act as a dealer in the categoryof "broker" is subject to renewal on December 31, 2001 (the"Renewal Date").

4. Pollitt is a member of the Bourse de Montreal Inc. and TheToronto Stock Exchange Inc.

5. In the absence of this Decision, subsection 1.1(1) and section2.3 of the Rule would have the effect of requiring that, onor before the Renewal Date, Pollitt be a member of the InvestmentDealers Association of Canada (the "IDA"), in order to be registeredunder the Act as a "broker".

6. Pollitt is in the process of completing its application formembership in the IDA and expects to file a completed applicationon or before December 31, 2001.

7. It is unlikely that the IDA will be in a position to completeits review of Pollitt's application for membership prior tothe Renewal Date.

8. Pollitt has agreed to the imposition of the term and conditionon its registration as a "broker" set out in the attached Schedule"A", which term and condition will be effective as of the dateof this Exemption.

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

IT IS THE DECISION of the Director, pursuant to section4.1 of the Rule, that Pollitt is hereby exempt from the requirementof subsection 2.3 of the Rule that it be, by the Renewal Date,a member of a Recognized SRO, provided that this exemption willterminate on the earlier of the date that Pollitt's membershipin a Recognized SRO is approved and June 1, 2002. December 17, 2001 "Robert F. Kohl"

SCHEDULE"A"

TERMSAND CONDITIONS ON REGISTRATION OF POLLITT & CO. INC.

1. No later than December 31, 2001, Pollitt & Co. Inc. shallhave submitted an application for membership to the IDA thatis complete in all material respects.

2. Pollitt & Co. Inc. shall, immediately upon satisfyingthe term and condition set out in paragraph 1 above, providewritten notice of such event to the Ontario Securities Commission,attention: Allison McBain, Senior Registration Officer, or suchother person as the Manager, Registrant Regulation may advisefrom time to time.