Barrantagh Investment Management Inc.

IN THE MATTER OF

NATIONAL INSTRUMENT 31-103 REGISTRATION REQUIREMENTS, EXEMPTIONS

AND ONGOING REGISTRANT OBLIGATIONS

AND

IN THE MATTER OF

BARRANTAGH INVESTMENT MANAGEMENT INC. (THE LEAD FILER)

AND ANY OTHER PERSON OR COMPANY THAT WAS A REGISTERED FIRM

IN ONTARIO ON SEPTEMBER 28, 2009

DECISION

Interpretation

1. Unless otherwise defined in this decision or the context otherwise requires, terms used in this decision that are defined in the Securities Act (Ontario), National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103) or National Instrument 14-101 Definitions have the same meaning in this decision.

Background

2. Under section 13.16 [dispute resolution service] of NI 31-103, a registered firm must ensure that independent dispute resolution or mediation services are made available, at the firm's expense, to a client to resolve a complaint made by the client about any trading or advising activity of the firm or one of its representatives and must inform the client as soon as possible of how to contact and use the dispute resolution or mediation services which are provided to the firm's clients.

3. Except in Québec, section 16.16 of NI 31-103 provides temporary relief from the application of section 13.16 of NI 31-103, until September 28, 2012, to a person or company that was a registered firm in a jurisdiction of Canada on September 28, 2009 (the Transition Period).

4. The Ontario Securities Commission (the Commission) and the Canadian Securities Administrators (the CSA) are currently reviewing the dispute resolution provisions of NI 31-103 and the Commission wishes to extend the Transition Period.

Application

5. The Lead Filer has applied to the Director, under section 15.1 of NI 31-103, for exemptions for itself and each person or company that was a registered firm in a jurisdiction of Canada on September 28, 2009, from section 13.16 of NI 31-103, subject to the conditions and restrictions set out in this decision.

6. The Lead Filer represents that, if it is required to comply with section 13.16 of NI 31-103 on September 28, 2012, in view of the fact that it appears that the Commission and the CSA will publish amendments to the dispute resolution requirements of NI 31-103, and in the absence of specific guidance relating to same, it would be unduly burdensome on the Filer to modify or unwind an already-implemented dispute resolution system, should the CSA amendments prescribe a particular dispute resolution provider.

Decision

7. Section 13.16 of NI 31-103 does not apply to the Lead Filer and each person or company that was a registered firm in a jurisdiction of Canada on September 28, 2009.

8. This decision comes into force on September 28, 2012 and expires on the earlier of:

(a) the coming into force of amendments to section 13.16 of NI 31-103; and

(b) September 28, 2014.

June 28, 2012