IIROC “Tips For Traders”Mont Tremblant

August 22, 2015

Mike Prior

Vice-President, SurveillanceKevin McCoy

Acting Vice-President, Market Regulation Policy

IIROC Presenters

• Surveillance Rulings• Dark Anti-Avoidance• Un-protected Transparent

Marketplaces

Topics

IIROC Trade Rulings (per 100M Trades)

Surveillance Rulings

What is the better approach to an erroneous trade?

A. No rulings – trade remains on tape and dealer must settle trade

B. Erroneous trades beyond a tolerable threshold are cancelled from public record but dealers are required to settle

C. US Approach – erroneous trades beyond a tolerable threshold are cancelled

D. Current IIROC approach – erroneous trades beyond a tolerable threshold are price adjusted

A. B. C. D.

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SSCB Rulings

How should IIROC deal with unreasonable trades that occur after an SSCB is triggered but prior to the halt?A. No ruling – all trades stand regardless

of price

B. Trades beyond tolerable threshold are cancelled regardless of price movement following resumption (status quo)

C. Trades beyond tolerable threshold are price adjusted regardless of price movement following resumption

D. Wait until trading resumes then cancel if price has reverted; no ruling if price continues to move in the same direction

A. B. C. D.

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• Intended to further the policy objective of pre-trade transparency

supported by the Order Exposure Rule and to achieve consistency

in the application of the requirement to obtain a “better price” under

the Canadian dark liquidity framework

• Re-Publication was intended to foster public debate regarding the

best approach to balance the effects that an increase in order

routing away from Canadian markets would have on the health of

our markets as a whole

IIROC Dark Rule Anti-Avoidance

• IIROC hosted a roundtable to discuss alternatives to the dark rules

anti-avoidance provisions and solutions respecting routing of retail

orders to U.S Dealers

• 8 proposals were presented

• A summary of the roundtable discussions will be included in future

IIROC policy publications on this topic

IIROC Dark Rule Anti-Avoidance

What do you think would be the more effective solution in dealing with the threat of increased southbound order flow?

A. Eliminate or reduce maker/taker fees

B. Let marketplaces develop solutions

C. Re-evaluate or repeal dark rules

D. Enhance best execution requirements

E. No solution needed – there is no problem A. B. C. D. E.

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What would be the greatest negative impact if the Dark Rules Anti-Avoidance Proposal were to be implemented?

A. Not able to achieve best execution for clients

B. Technology build to comply with Proposal

C. Discourage northbound order flow

D. No material negative impact

A. B. C. D.

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In your opinion, how material of an impact does southbound routing of retail flow have on the Canadian market?

A. Significant impact

B. Moderate impact

C. Small impact

D. No impact

A. B. C. D.

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• Will accommodate the terms and conditions of the OSC approval of

amendments to Alpha Exchange Inc.'s trading policies

• Align with proposed amendments by the CSA to CP 23-101

regarding the interpretation of “protected order”

Un-Protected Transparent Marketplace

• Revise the definition of “protected marketplace”

• “Best bid price” and “best ask price”

• Best execution considerations

• Client-principal trading considerationso “Best Available Price”

Un-Protected Transparent Marketplaces

If the proposed changes related to unprotected transparent marketplaces and OPR are approved, what will be your firm’s approach in implementing these changes?A. Will disconnect immediately from

unprotected marketplaces

B. Will remain connected to unprotected marketplaces and make no revisions to routing tables

C. Will remain connected to unprotected marketplaces but lower their priority in the routing table A. B. C.

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What do you believe would be the more significant challenge associated with protected and unprotected lit marketplaces?

A. Dual quotes to consider (protected NBBO and consolidated NBBO)

B. On-going monitoring of un-protected marketplaces for compliance with Best-Execution

C. Managing client-principal trading compliance (UMIR 8.1)

A. B. C.

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• As a result of the NYSE system outage on July 8, 2015, regulators are looking at ways to respond should a similar incident occur in Canada

• While NYSE market share is now less than 25%, the TSX retains about 60% of market share by volume

• Is price discovery efficient when the TMX is off line?• Is it fair to continue trading while 60% of investors orders are captive

in an inaccessible market?• Is it feasible to move orders from a disabled market to other

marketplaces?

Preamble to bonus question eight

If a major marketplace shuts down as a result of technical problems, what is the more reasonable regulatory response?A. Do nothing. All remaining marketplaces

continue to trade. Captive orders are not protected and increased volatility is tolerated.

B. All remaining marketplaces continue to trade. Unreasonable trades that result from reduced liquidity are subject to IIROC rulings.

C. Halt trading on remaining marketplaces for the remainder of the day (or duration of the interruption). Trading on interlisted securities can continue on US markets.

A. B. C.

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Questions?