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Frequently Asked Questions



During the implementation period for the Amendments Respecting Client Identifiers (Amendments), IIROC staff will publish responses to “Frequently Asked Questions” concerning the implementation of the Amendments. The FAQs represent the views of IIROC staff and are intended to assist IIROC Dealer Members with the implementation of the Amendments. However, please note that the FAQs do not constitute rules or requirements and have not been approved by the IIROC Board or the Canadian Securities Administrators.

FAQ Topics:

Debt Securities:

Listed Securities:

Listed and Debt Securities:


Debt Securities: Bulk orders and allocations

  1. For reportable debt transactions, are dealers required to report allocations that occur after the transaction reporting deadline? (amended on 10/16/2019)

    Dealers should provide the most granular information that they have at the time of reporting.

    Dealers should report trade allocations if they have received the allocations at the time of reporting. For example, if at the time of reporting, the dealer has allocations for individual sub-funds that:

    • have separate LEIs
      • the dealer would report the allocations using each subfund’s LEI
    • do not have separate LEIs
      • the dealer would report each allocation using the parent’s LEI.

    Allocations made after the time of reporting do not need to be provided to IIROC. IIROC continues to have the ability to request this information at a later date and dealers should continue to maintain records of the allocations for audit trail purposes.

  2. Where the dealer does not have the allocations at the time of reporting, what identifier should the dealer include? (added on 10/16/2019)

    Dealers should provide the most granular information that they have at the time of reporting. For example:

    OEO client is: Dealer should report:
    Bulk account for a portfolio manager LEI of portfolio manager if supervised as an institutional client, otherwise the account number for the bulk account
    Funds that have a common parent entity LEI of parent entity

 

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Listed Securities: General

  1. Who is responsible for including client identifiers on an order? (added on 09/06/2019)

    The Amendments apply to all IIROC Dealer Members, which include executing Participants, as well as non-executing IIROC Dealer Members that are not Participants.

    A list of all IIROC Dealer Members can be found here.

  2. What should be reported on an order that is sent to a marketplace? (added on 10/15/2019)

    To help IIROC Dealer Members understand what needs to be on an order, staff created three documents:

     

     

    We also created a video to show how the Decision Tree and Scenario Chart work together. These two documents provide different ways of visualizing the same requirements. For example, each outcome from the Decision Tree has a number, and that number corresponds with the same scenario in the Scenario Chart.

    The outcomes from the Decision Tree are also color-coded to match the same colors in the Scenario Chart (under Column A).

  3. Where an account number is required under the rule, can a dealer can create and use a different unique identifier for a client? (added on 09/06/2019)

    No, if the rules require an account number as the client identifier, the IIROC Dealer Member must include an account number on the order.

  4. Which clients need to be identified under the Amendments? Is the IIROC Dealer Member expected to determine the ultimate end-client for an order? (added on 09/06/2019)

    No, the Amendments only affect the direct client of an IIROC Dealer Member, regardless of whether the reported entity is the ultimate end-client for the order.

    An IIROC Dealer Member may choose to send its order to another IIROC Dealer Member that is a Participant for execution on a marketplace. In that instance, the non-executing IIROC Dealer Member is still expected to comply with the requirements and include the identifier of its direct client when sending the order to the executing Participant.

  5. What are the specifications for the unique identifier for clients of a foreign dealer equivalent that use an algorithm to generate orders? (added on 02/11/2020)

    The FIX tag to be used for the unique identifier will be included in our FIX Specifications. The unique identifier only needs to be an alphanumeric code that is unique to the particular client within the foreign dealer equivalent, and does not need to take the form of an LEI/account number/client name etc. This field will be an alpha-numeric free format string that can be populated with any code as long as it has a minimum of 2 and a maximum of 20 alphanumeric characters.

    This field would not be encrypted but would still be a private regulatory field that is not publicly disclosed.

 

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Listed Securities: Order execution only

  1. If the dealer supervises all of its order-execution only clients on a retail platform, can the dealer use an account number as the client identifier? (added on 09/06/2019)

    Not necessarily. If any of the OEO clients are “identified OEO clients”, which is a defined term under the rules, then an LEI must be used as the client identifier.

    Identified OEO clients:

    • are active OEO clients that have more than an average of 500 orders a day, or
    • are registered as an adviser, or
    • act in a manner analogous to an adviser in a foreign jurisdiction.

 

OEO client is: What to include on the order
“identified OEO client” LEI if eligible to obtain one, otherwise an account number (and IIROC Dealer Member separately reports client name to IIROC)
Not an “identified OEO client” and supervised as a retail client Account number
Not an “identified OEO client” and supervised as an institutional client LEI

 

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Listed Securities: Bulk transactions

  1. What client identifier should a dealer use if it groups together orders for more than one client to send to a marketplace (added on 09/06/2019)

 

Order contains What to include on the order: Client Identifier What to include on the order: BU or MC Designation
Client order(s) combined with principal order(s) and/or non-client order(s) None Bundled order (BU) marker
More than one client order from clients that have a common parent entity (no principal or non-client order) LEI of parent entity None
More than one client order from clients that do not have a common parent entity (no principal or non-client order) None Multiple Client (MC) marker

 

In all cases for a bulk order – the IIROC Dealer Member is not required to report allocations after the execution of the trade.

 

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Listed Securities: Managed accounts

 

  1. If a portfolio manager makes investment decisions for multiple managed accounts, how should the IIROC Dealer Member report the client identifiers? (added on 09/06/2019)

    The Amendments focus on who holds the account, rather than who makes the investment decisions for the account.

IIROC Dealer Member’s client is: Which client identifier to include on the order
Portfolio Manager (PM) Accesses the marketplace as a DEA, RA or Identified OEO client LEI if eligible to obtain one, otherwise an account number (IIROC Dealer Member separately reports PM’s name to IIROC)
Supervised as an institutional client by the IIROC Dealer Member LEI
Supervised as a retail client by the IIROC Dealer Member Account number
Managed Account(i.e. PM works at the IIROC Dealer Member) Accesses the marketplace as a DEA, RA or Identified OEO client LEI if eligible to obtain one, otherwise an account number (IIROC Dealer Member separately reports holder of managed account to IIROC)
Supervised as an institutional client by the IIROC Dealer Member LEI
Supervised as a retail client by the IIROC Dealer Member Account number

 

IIROC Dealer Member groups together an order from a PM or a Managed Account with another order
The other order(s) is/are: What to include on the order:
Principal and/or Non-Client order(s) Bundled order (BU) marker
From another client(s) that shares the same parent entity LEI of parent entity
From another client(s) that do not share the same parent entity Multiple client order (MC) marker

 

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Listed Securities: Encryption
  1. Which FIX tags/fields needs to be encrypted? (added on 09/20/2019)

    Client LEIs (including LEI of the foreign dealer equivalent) will be encrypted.

    The LEI of a Dealer Member that is not a Participant would not be encrypted, as non-Participant Dealer Members are similar to jitney Participants, which have never been included as an encrypted field.

  2. When would a Dealer Member encrypt a client LEI on an order? (added on 09/20/2019)

    Encryption is mandatory for client LEIs at the point when an order is sent to the marketplace.

    Non-executing dealers may choose to:

    • encrypt the client LEI before sending the order to an executing Participant, or
    • allow the executing Participant to encrypt the client LEI.

     

  3. If a client does not want to randomize the encryption counter block with respect to encrypting its LEI, can the Dealer Member use the same counter block values for encrypting its LEI which will result in same set of values of the 52-character string on every order message sent to a marketplace for that client? (added on 01/28/2020)

    Yes, the client can use the same counter block without randomization as long as the client understands that its encrypted LEI as seen by the marketplaces will have the same string value.

  4. What are IIROC’s expectations on client LEI encryption for open orders that stay on the marketplace past an encryption key renewal date? Would Dealer Members be required to re-encrypt client LEIs for open orders using the new encryption key?

    Example: On December 28, 2020, a Dealer Member encrypts a client LEI using the 2020 encryption key and enters a good-till-cancel order on the marketplace. At the end of 2020, the GTC order remains unexecuted on the marketplace, the 2020 encryption key expired and the Dealer Member was provided with 2021 encryption keys. Does the Dealer Member need to re-encrypt the client LEI using 2021 encryption keys for open orders that stayed in the marketplace from 2020?

    No, the Dealer Member is not required to re-encrypt client LEIs for open orders that stay on the marketplace after the expiry of encryption keys. An exception is where the Dealer Member wants to amend the open order (e.g. change the price), in which case the Dealer Member should also re-encrypt the client LEI using the new encryption key.

 

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Listed and Debt Securities: General

  1. How should the dealer proceed if there are legal barriers preventing the reporting of client LEIs in the client’s jurisdiction? (amended on 09/24/2019)

    The dealer would need to apply for an exemption from the requirement to provide an LEI for its client. Exemption applications should include the following information:

    • Account documentation for the client, which includes at a minimum:
      • Name of client
      • Account number of client
      • Location of client.
    • Evidence of reasonable efforts by the dealer to obtain the client LEI, which may include:
      • Dealer’s policies and procedures regarding its process on client outreach, and
      • Correspondence between the dealer and the client.
    • Explanation of the legal barrier preventing the dealer from providing the client LEI, which may be in the form of a legal opinion.

     

    For information on the exemption application process, please see IIROC Notice 18-0080 – Rules Notice – Exemption applications relating to IIROC Dealer Member rules. As set out in Notice 18-0080, please send your application to IIROC’s General Counsel’s Office at [email protected].

 

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