Julia, a registered investment advisor, was employed at a stock brokerage in a junior capacity as a telemarketer of unlisted shares, making cold sales calls to prospective clients. Once she had made a sale, she passed the client on to a more senior advisor, who finished the paperwork and collected the payments for the shares. Where these shares were sold from the brokerage's own holdings of unlisted shares, she received a commission of 20 percent, and the senior advisor received some further amount, but that percentage was unknown to her. Her firm directed her to verify that prospective clients had an income of at least $50,000 per year, and also that each client possessed a personal net worth of at least $50,000. Julia made this verification in every case. After three years, Julia moved to another brokerage house and applied to the provincial regulator for authorization to sell shares on behalf of the new employer.

Imagine that you are the provincial regulator, and have been made aware of the circumstances of Julia's previous employment. Would you grant or refuse the application? Why?