Amendments Respecting Client Identifiers for Reportable Debt Transactions

Type: Rules Notice> Approval/Implementation
Rule connection:
Legacy DMR Rules
Distribute internally to:
Legal and Compliance
Senior Management
Trading Desk


Theodora Lam
Senior Policy Counsel, Market Regulation Policy

Executive Summary

On October 15, 2019, the applicable securities regulatory authorities approved amendments (Amendments) to the Dealer Member Rules (DMR) to require Dealer Members to report the following client identifiers for transactions in debt securities:

  • Legal Entity Identifier (LEI) for a client supervised as an institutional client
  • account number for a client supervised as a retail client.

On July 11, 2019, IIROC published for comment proposed amendments in IIROC Notice 19-0118Proposed Amendments Respecting Client Identifiers in Reportable Debt Transactions. All relevant background, including the description and impact of the Amendments, is set out in this Notice.

Comments Received

We received two comment letters in response to IIROC Notice 19-0118. Appendix D provides a summary of the public comments received and our responses.

We have not made any revisions to the Amendments, as set out in Notice 19-0118.


Appendix A – Text of the Amendments

Appendix B – Blackline of the Dealer Member Rules to Reflect the Amendments

Appendix C – Blackline of the IIROC Rules to Reflect the Amendments

Appendix D – Summary of comments received and IIROC’s responses


The Amendments reduce the impacts on Dealer Members that supervise some institutional clients as retail clients by allowing them to use client account numbers as client identifiers for both debt and listed securities.

The Amendments are effective on October 18, 2019, being one day after the publication of this Notice.

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