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PACE Financial Limited, PACE Securities Corp., and First Hamilton Holdings Inc. Investor Claimants

IMPORTANT INFORMATION FOR: Individuals who purchased preferred shares of Pace Financial Limited or First Hamilton Holdings Inc. (together, the “Preferred Shares”) or units of Pace Capital Partners LP (together, the “Investor Claimants”):

On July 31, 2021, the court approved a $40 million settlement of claims by holders of the Preferred Shares:
On October 18, 2021, Representative Counsel will be re-attending before the court to obtain directions in respect of the following matters (the “Allocation Hearing”):

1. the allocation and distribution of the settlement funds to individual investors; and,

2. the approval of Representative Counsel’s fees and expenses (the “Professional Fees”), to be deducted from the settlement funds.

Representative Counsel will propose to the court that, after deduction of the Professional Fees, the settlement funds be distributed to Investor Claimants on a proportional (pro rata) basis, relative to the amount invested.  Representative Counsel will also recommend that any investor who received Preferred Shares as a gift (e.g. in exchange for opening a PSC account) will not receive a distribution in respect of these shares because they did not invest funds and have not suffered a loss in respect of those shares.

If the court accepts these recommendations, Representative Counsel expect that each investor will likely recover in excess of 70% of the principal amount invested.


On September 1, 2021, Representative Counsel mailed each Investor Claimant a package of information including. 

• a personal investment statement stating the amount that Representative Counsel understands to be each Investor Claimant’s holding in the Preferred Shares and the amount that they paid for them (the “Investor Amount”); and

• a list of required steps to be followed by an Investor Claimant to confirm (and, where necessary, correct) the Investor Amount

Investor Claimants are asked to confirm or correct the Investor Amount by September 21, 2021.


If you would like additional information, you may contact Representative Counsel by email or by leaving a message at the toll-free number, as indicated below.


Telephone: 1-(888) 974-1652

We anticipate that Representative Counsel’s motion record in respect of the Allocation Hearing will be posted on this site in mid September.  Investor Claimants who, after reviewing the motion record, wish to object to the relief being sought by Representative Counsel and/or make an argument before the Court at the hearing, should fill out this form and return it to Representative Counsel.  So that the hearing on October 18 can proceed in an orderly way, the Court has asked that objectors let Representative Counsel know of their intention by October 4, 2021 (although failure to do so will not preclude any investor from making submissions at the hearing).



FHH, Order of Justice Penny-19-OCT-2021
PACE, Order of Justice Penny-19-OCT-2021
Endorsement of Justice Penny-19-OCT-2021
Wayne Gould Objection part 1
Wayne Gould Objection part 2
Dave Miller Objection
Book of Authorities FHH-Representative Counsel-12-OCT-2021
Book of Authorities PACE-Representative Counsel-12-OCT-2021
Supplementary Motion Record PACE- Allocation Order-Representative Counsel-12-OCT-2021
Supplementary Motion Record FHH - Allocation Order-Representative Counsel-12-OCT-2021
Memorandum of Law and Argument PACE-Representative Counsel-12-OCT-2021
Memorandum of Law and Argument FHH-Representative Counsel-12-OCT-2021
Motion Record, Allocation Motion (FHH)
Motion Record, Allocation Motion (PACE)
2021.07.30 - REDACTED Email Endorsement of Justice Koehnen re Settlement Approval_Redacted
Second Report - MNP Ltd. - 27-JULY-2021 (1)
Fourth Report - Liquidator - Ernst & Young Inc. - 26-JUL-2021
FSRA Submissions for PSC Settlement Approval Motion
PACE_FHH, Factum of Investor Claimants on Motion for Settlement Approval
PACE, Supp Motion Record of the IC on Motion for Settlement Approval
FHH, Supp Motion Record of the IC on Motion for Settlement Approval
Motion Record-Moving Party-Investor Claimants FHH-7-JUL-21
Motion Record-Moving Party-Investor Claimants PFL-7-JUL-21
Notice of Objection
PFL - Order of Justice Conway (Notice to Investor Claimants), July 8, 2021
FHH - Order of Justice Conway (Notice to Investor Claimants), July 8, 2021
Notice of Orders Appointing PRRR as Representative Counsel
Illustrative List of Paliare Roland's Representative Engagements
FHH - Order of Justice Hainey (Appointment of Representative Counsel), August 6, 2020, Court File No. CV-20-00641372-00CL
PACE - Order of Justice Hainey (Appointment of Representative Counsel), August 6, 2020, Court File No. CV-20-00641059-00CL
Opt out Letter (.pdf version)
Opt out Letter (.docx version)
PACE Securities, Redacted Response to Complaint dated 2020.11.24

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