Our Trading Conduct Compliance staff assist in the development, introduction and education of users on new rules and policies, such as the Supervision of Trading Policy (see Policy 7.1
for more detail). This policy requires all applicable market participants to proactively monitor their compliance by completing internal reviews and addressing deficiencies. An IIROC Trading Conduct Examiner will examine the results of these reviews when a field review is conducted at the trading firm's office.
We focus on making sure firms have the proper systems to prevent and detect violations of the Universal Market Integrity Rules, or UMIR. The most common deficiencies that examiners find are the firm having insufficient procedures, missing quarterly reports and having incomplete audit trails.
When examiners discover problems, IIROC calls on the firm to correct them. If something manipulative or deceptive is detected, the matter is referred to Trading Review and Analysis for further review. The Trading Review and Analysis group will then review the data looking for infractions such as manipulation or frontrunning, which is when a dealer or registered individual trades ahead of his or her client, or short selling violations.
Where disciplinary action is required, the matter is then referred on to Enforcement. Learn more in How We Review & Analyze Trading
in the Market Monitoring & Analysis section. Need to know more? Dealer member firms seeking more information on Trading Conduct Compliance can contact IIROC: Mike Prior, Vice President, Surveillance [email protected]