We understand that IIROC is recommending a debt market regulation fee model where it would recover its debt regulation costs based on the number of trades in debt transactions. We agree with the principles espoused in the request for comments with respect to the Fee Model. Consistency and transparency for dealer members are important, as is capturing as many transactions as possible, and thus we support the particular transaction-based Option #1 fee model, which would be based on primary and secondary transactions including repo transactions. Transparency in the debt market should, over time, reduce transaction spreads and benefit investors. It is important to share pricing data with investors, particularly with respect to the bid/ask prices and volume.
Overview of the Council’s Comments:
We would support the imposition of a late reporting fee on dealers that report trades after the prescribed time. Any such penalty should be sufficient to effectively discourage late or selective transaction reporting and help ensure the integrity of the data collected.