Statement of Allegations: In the Matter of Brian Anderson et al.

IN THE MATTER OF THE
SECURITIES ACT R.S.O., c. S. 5, as amended


AND


IN THE MATTER OF
BRIAN ANDERSON, LESLIE BROWN, DOUGLAS BROWN, DAVID SLOAN AND FLAT ELECTRONIC DATA INTERCHANGE (a.k.a. F.E.D.I)



STATEMENT OF ALLEGATIONS
OF THE ONTARIO SECURITIES COMMISSION
 

Staff of the Ontario Securities Commission make the following allegations:

1. Brian Anderson is a person resident in White Rock, British Columbia who attends in the Province of Ontario for the purpose of making presentations to Ontario residents;
    
2. Leslie Brown is a person resident in Paris, Ontario;
    
3. Douglas Brown is a person resident in Paris, Ontario;
    
4. David Sloan was present in Ontario on June 4, 2003;
    
5. On the evening of June 4, 2003, the individual Respondents conducted a presentation (the Presentation) in respect the Flat Electronic Data Interchange ("F.E.D.I.") at the Wyndham Bristol Place Hotel, Etobicoke;
    
6. At the Presentation, the documents attached to this Statement of Allegations were made available to persons attending the seminar:
    
   1. "What is F.E.D.I. and How Do They Make Their Income?" (Schedule A)
   2. "F.E.D.I. Flow Chart" (Schedule B)
   3. "Bank Wire Coordinates" (Schedule C)
   4. "Bank Wire Transfer Procedure" (Schedule D)
   5. "Joint Venture Agreement" (Schedule E)
   6. "Email from Gordon Rothwell dated May 15, 2003" (Schedule F)
   7. "Email from bjanderson dated April 17, 2003" (Schedule G)
   8. "Email from Brian D. Anderson dated May 13, 2003" (Schedule H)
       
7. Persons who attended the Presentation were:
    
   1. told that F.E.D.I. is a scriptural based public trust;
   2. invited to participate in F.E.D.I., which was described as the Flat Electronic Data Interchange. It was purported that F.E.D.I. will become the world's fifth Electronic Data Interchange and that it would be the first such exchange to be backed by gold;
   3. told that F.E.D.I. will be servicing the Arab world and that it has been funded by contributions made by major Arab families in the amount of $500,000,000 (US), backed by gold;
   4. invited to participate in F.E.D.I. by making an investment of $125,000 (US), which investment would provide the investor with a seat or desk (the "Desk") on F.E.D.I.;
   5. told that F.E.D.I. would be operational in July, 2003;
   6. told that their investments would be fully insured by AON Reed Stenhouse of Canada;
   7. told that the opportunity to purchase a "Desk" was limited, that only 20 "Desks" remained and that their investment must be made by the weekend of June 7, 2003;
   8. told that their principal investment would be returned in October, 2003 and that they would receive income from their investment at the rate of 30% per month, for a ten year period;
       
8. As set out in Schedule E, the Joint Venture Agreement represents, among other representations, that:
   
   I [Brian Anderson] have done my due diligence and asked all the hard questions. There is no downside to this program. In the event of failure of any kind, our investment capital will be returned to us within 30 banking days..."
    
9. The "Desks" are securities as defined by the Securities Act,
    
10. Persons who attended the Presentation were not provided with a prospectus which would qualify a "Desk" for sale in Ontario;
     
11. The Respondents are not registered pursuant to the Securities Act for the purpose of trading securities in the Province of Ontario; and
     
12. The sales of "Desks" are being made in breach of sections 25 and 53 of the Securities Act, R.S.O. 1990 c.S.5.
    
    Conduct Contrary to the Public Interest
     
13. The Respondents conduct as described above is contrary to the public interest.
     
14. Such additional allegations as Staff may advise and the Commission permit.
    
     

Dated at Toronto this 11th day of June, 2003