IIROC is proposing amendments (“Proposed Amendments”) to the Order Exposure Rule that would limit the ability of a Participant to execute a client order of 50 standard trading units or less (a “small client order”) on a foreign organized regulated market (“FORM”) unless the order is entered on a market that displays order information (and the order is either displayed or executed on entry) or executed at a “better price” (“Proposed Anti-Avoidance Provision”).
The purpose of the Proposed Anti-Avoidance Provision is to further the policy objective of pretrade transparency supported by the Order Exposure Rule and achieve consistency in the application of the requirement to obtain a “better price” under the Canadian dark liquidity framework. We think that price improvement of anything less than what would constitute a “better price” is not sufficiently meaningful to deny the Canadian market the benefit of transparency.
Investment Industry Regulatory Organization – January 29, 2015.
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