On November 27, 2019, IIROC’s Board of Directors (the Board) granted an exemption to a Dealer Member from the requirement to provide account numbers for reportable debt transactions for clients supervised as retail clients under Row 15 of subsection 2.4(c) of Dealer Member Rule 2800C.

1. Authority to Grant Exemptions

Dealer Member Rule 17.15 permits the Board to exempt a Dealer Member from any provision of the Dealer Member Rules where it is satisfied that to do so would not be prejudicial to the interests of Dealer Members, their clients or the public. In granting an exemption, the Board may impose such terms and conditions as are considered necessary.

1. Exemption granted and conditions

At its meeting of November 27, 2019, the Board granted relief to a Dealer Member from the requirement to provide account numbers for clients supervised as retail clients when reporting debt transactions under Dealer Member Rule 2800C Transaction Reporting for Debt Securities.

This exemption is subject to the following conditions:

• The Dealer Member shall provide a report to IIROC outlining its progress in implementing processes and systems changes in order to comply with the requirement to include account numbers for clients supervised as retail clients at every two month interval.
• The Dealer Member shall report the client account classification in  place of account numbers for clients supervised as retail clients when reporting debt transactions under Dealer Member Rule 2800C.
• The exemption shall cease to be available after the Dealer Member has completed changes to processes and systems to report account numbers under Row 15 of subsection 2.4(c) of Dealer Member Rule 2800C, or May 1, 2020, whichever comes first.

As is standard for exemption orders of this type, the exemption order also specified that:

• The Board can revoke this exemption at any time upon notice to the Dealer Member.
• This exemption order is void upon the earliest of the following taking place:
  • the Dealer Member’s breach of any of the representations made in its application, or
  • the Dealer Member’s breach of any of the conditions in the exemption order.

Staff will only recommend approval of an exemption of this type under exceptional circumstances, and where the Dealer Member demonstrates that it has taken all reasonable steps to comply with a new or amended requirement upon implementation.   

1. Questions and Further Information

For questions or further information concerning this Notice, please contact:

Kevin McCoy
Vice President, Market Policy and Trading Conduct Compliance
Telephone: 416.943.4659
Email: kmccoy@iiroc.ca