V: PROCEDURAL UNFAIRNESS
 In addition to their challenge to the conclusions of the
Panel regarding insider trading and tipping, some of the appel-
lants also contend that the hearing before the Panel was tainted
by various instances of procedural unfairness. I will deal with
each of those contentions in turn.
(a) Lack of Particulars
 Finkelstein complains that the findings of the Panel fall
outside the statement of allegations made by the respondent
against him. For example, in respect of the Dynatec allegations,
Finkelstein says that the respondent knew what the material
non-public information was, but did not include it in the statement of allegations. Finkelstein contends that this type of conduct constitutes a procedural unfairness to him.
 I do not accept that contention. The statement of allegations contained sufficient particularity that it allowed Finkelstein to respond to the allegations. In each of the three instances
where insider trading/tipping occurred, the statement of allegations was clear that it was the fact of the Masonite transaction,
or the Dynatec transaction, or the Legacy transaction, that was
material non-public information. Finkelstein could not have
been confused or uncertain as to what the respondent was alleging against him.
 I would also note that, while there was some skirmishing in advance of the actual hearing regarding the alleged lack
of particulars, the hearing proceeded without any real issue
being raised on that point.
 In any event, assuming for the moment that Finkelstein
was uncertain of what he was alleged to have passed along in
terms of material non-public information, and that, as a consequence, he was being hampered in his ability to respond, Finkelstein was entitled to seek an order, from the Panel, that
particulars be provided. Specifically, rule 4.2 of the Rules of Procedure of the Ontario Securities Commission reads:
4.2 At any stage in a proceeding, the Panel may order that a party:
(a) provide to another party and to the Panel any particulars that the
Panel considers necessary for a full and satisfactory understand-
ing of the subject of the proceeding; and
(b) make any other disclosure required by this Rule, within the time
limits and on any conditions that the Panel may specify.
 No such request was made of the Panel by Finkelstein.
Nor is there anything in the record of the hearing that