I wonder if the recommendations were ever followed?
Findings
It is efficient for the TSX-V to use IIROC to monitor compliance with DMA access
requirements. However, it appears that:
the TSX-V does require sponsoring Members and POs to assign unique trading
identifiers to DMA clients and does provide information to IIROC to allow IIROC to
undertake real-time surveillance of DMA activity
the TSX-V does not have procedures for following up on IIROC trade conduct
compliance report findings. Where the IIROC reports indicate that some Members
and POs do not comply with the TSX-V’s DMA rules, and there is no evidence of
TSX-V regulatory actions
Risk implication
Non-compliance with DMA rules could result in
considerable risks to the TSX-V and TMX. In addition,
undocumented DMA access could present market integrity
concerns.
Recommendations
The TSX-V should document its staff’s compliance
with its internal procedures for approving and
providing access to DMA clients. While this
documentation does not need to be extensive, there
should be sufficient information to indicate TSX-V
staff activity when approving access and DMA client
connection.
The TSX-V should adopt and implement procedures to
review IIROC DMA reports and make investigation
and enforcement decisions when violations are
reported.
