IIROC Client Identifiers

September 26, 2018

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IIROC Client Identifiers

Letter Summary:

IIROC is proposing to amend UMIR and Dealer Member Rules to require client identifiers on each order sent to a marketplace and each reportable trade in a debt security. Currently, multiple identifiers are being used for the same client across different platforms. The identifier would take the form of a Legal Entity Identifier (LEI) or, for clients not eligible for an LEI, their account number. 

Overview of the Council’s Comments:

The CAC supports IIROC’s and the underlying theme behind this global initiative as it believes companies should be required to maintain and report the LEI. In short, this would increase investors’ and IIROC’s ability to identify and analyze the risks of registrants and their subsidiaries. Lastly, the CAC urged IIROC to prioritize the importance of protecting client privacy and ensuring implementation costs are not unduly burdensome on registrants.