On May 18, 2017, IIROC published for comment proposed amendments to its Dealer Member Rules (DMRs) and Form 1 (collectively, the Proposed Amendments) in IIROC Rules Notice 17-0110. The primary objective of the Proposed Amendments was to codify DMR requirements that restrict linkages between a Dealer Member’s futures business and its other business lines to facilitate the adoption of a customer protection segregation and portability (Seg & Port) regime by Central Clearing Counterparties (CCPs) serving the futures market.

IIROC acknowledged, and commenters expressed concern, that there remain key issues that need to be resolved before the full implementation of the Canadian futures market Seg & Port regime. We based the Proposed Amendments on ICE Clear Canada’s (ICCA) Gross Customer Margin (GCM) segregation and portability model, with the understanding that Canadian Derivatives Clearing Corporation (CDCC) would implement a similar GCM model in the near future. ICCA has since transitioned the trading and clearing of its canola futures contracts to its U.S. operations1, and CDCC has extended the timeline for its projected implementation of a Seg & Port model.

• 1See ICE Clear Canada, “Transition of Canola Markets to ICE Futures US / ICE Clear US (May 1, 2018)”, (https://www.theice.com/publicdocs/clear_canada/notices/2018_05_01_Transition_of_Canola_Contract_ICCA.pdf)