National Instrument 24-101 provides a framework in securities legislation for ensuring more efficient and timely processing of institutional trades. It requires participants in the institutional trading process to have in place processes and procedures that allow trade matching within prescribed limits which will be phased in over the timeline indicated below.
To facilitate account servicing and to comply with the regulatory requirements of NI 24-101 of the Canadian Securities Administrators and their provincial counterparts, TD Securities (TDS), is required to ensure compliance with the central requirements of the instrument for all institutional trades. The rule becomes effective April 1, 2007 and reporting and documentation requirements are required by October 1, 2007. The regulation has been published by the Ontario Securities Commission and is available here.
The main requirements include:
- A Trade Matching Statement or Trade Matching Agreement
This document confirms that your entity has the processes and procedures in place, based on industry best practice that allows it to meet the transitional matching requirements set out. The regulation states that a registered broker dealer shall not open an account to execute a DAP/RAP trade for an institutional client or accept an order to execute a DAP/RAP trade for an account of an institutional client unless each trade-matching party entered into a trade matching agreement or provided a trade matching statement to the dealer (CSA Notice 24-101 Section 3.2).
- Transitional Matching Targets
|Q1 through Q4 ||12:00 PM (Noon) on T+1 ||90% matched by deadline |
* These targets are based on both the aggregate numbers of institutional trades and their aggregate dollar value.
In order to comply with the above requirements we will require a signed written statement from your entity confirming that it has established, maintains and enforces policies and procedures designed to achieve trade matching as soon as practical after a trade is executed.
TDS encourages all our clients to take the opportunity to view the web-casts of seminars held by the Canadian Capital Markets Association. Information regarding this regulation is available here.
At TDS, our objective is to deliver product and service excellence. We appreciate your assistance in ensuring compliance with National Instrument 24-101. On behalf of TDS, we welcome the opportunity to be of service and look forward to further developing our relationship.