Although the Request for Comments set out a deadline of August 26, 2014 for submitting comments, pursuant to a conversation between Mr. Michael Brady of the BCSC and Ms. Cecilia Wong, Chair of the CAC, the CAC obtained permission to submit comments by no later than September 12, 2014.
Overview of the Council’s Comments:
The CAC does not believe that order priority based on size rather than timing is a disadvantage for retail investors. As a starting point, it is not certain that larger orders are always placed by institutions rather than retail clients. However, even if it is assumed
that larger orders are placed by institutions, giving priority to such orders means that the market is reflecting the best price information rather than simply reflecting the pricing dictated by parties that are able to utilize speed advantages to obtain priority in the order queue.