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Toronto After The Close Seminar - October 3, 2019
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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.
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Relevant Publications & Rules
IIROC DMR Best Execution of Client Orders Guidance Notice IIROC Guidance on Best Execution
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Overview of Best Execution
Policies and procedures Governance Training Disclosure Non-executing dealers
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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”
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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
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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
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Governance Must outline a process to review policies and procedures
How routing decisions are made Unprotected markets?
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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
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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
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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
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Questions! On behalf of the entire CCLS Education Sub-Committee, thank you very much for your attendance and attention today!
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