Toronto After The Close Seminar - October 3, 2019

Market Structure and Its Impact on Best Execution Panel Speakers Kevin McCoy, VP, Market Regulation Policy and Trading Conduct Compliance, IIROC Alex Perel, Director, Head of ETF Services, Scotia Capital Inc. Darren Molloy, Director, Retail Trading, GMP Securities L.P. Jeff Varey, VP, Wealth Management Equity Markets, RBC Dominion Securities Inc. Moderator Shailesh Ambike, Director, Advisory, Global Compliance, Scotia Capital Inc.

Relevant Publications & Rules IIROC DMR 3300 - Best Execution of Client Orders Guidance Notice 17-0138 - IIROC Guidance on Best Execution

Overview of Best Execution Policies and procedures Governance Training Disclosure Non-executing dealers

Best Execution Obligation Must establish, maintain and ensure compliance with written policies and procedures that are reasonably designed to achieve best execution when acting for a client Best execution means “obtaining the most advantageous execution terms reasonably available under the circumstances”

Policies and Procedures Requirement for all dealers to have policies and procedures Executing Dealers – policies and procedures must consider certain relevant factors and outline a process to achieve best execution

Policies and Procedures Not all factors may be equally relevant to each client execution or all asset classes Expect that each factor is weighted and applied as deemed appropriate

Governance Must outline a process to review policies and procedures How routing decisions are made Unprotected markets?

Disclosure Must clearly identify where to find disclosure on website Don’t expect disclosure to be highly granular Purpose is to provide clients with: sufficient information to make an informed decision a better understanding of the handling of their orders

Non-Executing Dealers Still need policies and procedures Must review written public disclosure of executing dealer and any subsequent changes Follow-up on any noted inconsistencies

Fair Pricing No changes to rule Best execution re OTC securities is considered to be achieved when a price that is fair and reasonable in relation to prevailing market conditions is obtained

Questions! On behalf of the entire CCLS Education Sub-Committee, thank you very much for your attendance and attention today!