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Letter Summary:
We are generally supportive of the Proposed Amendments, which we understand are intended to accommodate certain existing practices and help larger orders gain access to upstairs liquidity pools in the United States. We think the consultations that IIROC staff have held with market participants has been helpful and as a result, the Proposed Amendments are responsive to concerns raised about market efficiency and the practical implications of requiring larger orders to be executed on a foreign organized regulated market.
Overview of the Council’s Comments:
We agree that the regulation of foreign trade reporting facilities such as FINRA’s Over-TheCounter Reporting Facility and the FINRA/Nasdaq Trade Reporting Facility is similar enough to marketplace regulation in Canada such that the Proposed Amendments should not have any negative impact on market integrity or investor protection.