We believe that the Proposed Rule is an important first step in a broader initiative to gather information on the Canadian debt market and build up a debt transaction database. It is vitally important as an investor protection measure that accurate, consistent and relevant information be shared with the broader investment community, as the Canadian debt market is not sufficiently transparent. As a result, it is extremely difficult for investors to determine if they are receiving fair pricing on any given debt transaction. The emphasis of the Proposed Rule should not be on data collection, but rather include more specifics on the intended use and distribution of that data as an investor protection measure.
Overview of the Council’s Comments:
The Canadian Advocacy Council1for Canadian CFA Institute2Societies (the CAC) appreciates the opportunity to comment on IIROC’s Proposed Rule 2800C –Transaction Reporting for Debt Securities as set out in IIROC Notice #13-0058.