J.C. Hood Investment Counsel Inc. - s. 4.1 of Rule 31-502

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 31-501 Proficiency Requirements for Registrants, ss. 3.3(4), 4.1.

July 8, 2005

J.C. Hood Investment Counsel Inc. and Mr. Cory Venable

Order under Section 4.1 of Rule 31-502 of the Securities Act, R.S.O. 1990 c. S. 5,

as amended, that:

An application has been received on May 16, 2005 from J.C. Hood Investment Counsel Inc. (J.C. Hood) for an exemption from subsection 3.3(4) of the Ontario Securities Commission Rule 31-502 Proficiency Requirements for Registrants (the Rule).

J.C. Hood has represented to the Director that:

1. Cory Venable will be looking to join J.C. Hood's office in Barrie, Ontario, since Mr. Venable's client base is better served with him located in the Barrie office.

2. Trading authorization is only granted to John Hood, J.C. Hood's only advising officer, in J.C. Hood's Toronto office. Recommendations by Mr. Venable will be emailed or faxed to Mr. Hood and confirmed as to client suitability prior to any trades. All client accounts are reviewed by Mr. Hood for suitability, with all New Account documents, trade slips and statements being held in the Toronto office.

3. Mr. Venable's approach to technical analysis is as a risk management device not as a trading strategy, so that the trades are relatively infrequent and easy to monitor.

4. The Toronto office monitors any advertising, newsletters and stationary for compliance.

5. Mr. Venable will advise clients as to asset allocation and exchange-traded fund selection based on the J.C. Hood's asset allocation guidelines.

The Director is satisfied that it would not be prejudicial to the public interest to make the requested Order.

It is ordered under section 4.1 of Rule 31-502 that J.C. Hood and Mr. Cory Venable be exempt from subsection 3.3(4) of Rule 31-502 until

1. J.C. Hood ceases to be registered in the category of investment counsel and portfolio manager in the province of Ontario; or

2. Mr. Venable ceases to be employed by J.C. Hood.

"David M. Gilkes"