Hello all.

Below is the reply I received from the IIROC. I've left the person's name and contact information in the event anyone wants clarification.

Hi Steven,

Thank you for your email about HPQ Silicon Resources Inc. (HPQ)

The information you have provided will be reviewed and assessed.

IIROC’s Market Surveillance, and trade review analysis ensures that trading is carried out according to UMIR (Universal Market Integrity Rules) and applicable provincial securities law.  IIROC continuously monitors all trading on all 14 Canadian equity marketplaces and alternative trading systems.  (For a full list, click here.)

IIROC uses a state-of-the-art advanced technology system known as the Surveillance Technology Enhancement Platform (STEP), which offers a unique consolidated view of trading on all marketplaces that helps to detect unusual activity.  STEP gives IIROC the tools, including real time capability, to monitor and identify possible violations of UMIR across all Canadian trading platforms.  For your convenience, I am also including a link to our website that speaks about how IIROC monitors trading activity:Surveillance of Trading Activity.

IIROC has confidential investigation procedures and as such staff cannot comment on any reviews we may be conducting or a potential investigation unless it becomes a matter of public record.  By keeping information confidential, we protect the integrity of our investigation, ensure the complaint process is not used to affect the market and maintain fairness to those who may be the subject of a complaint that does not result in an investigation or sanction. 

One of the primary roles of IIROC in reviewing any complaint is to determine whether there is sufficient evidence that supports a potential breach of UMIR, to warrant further investigation and potential regulatory action.  If there are no indications of violations of UMIR, IIROC will close the file with no action taken.  If there are indications of potential violations of UMIR, IIROC will take appropriate action against the dealer member or its registered employees.  Appropriate action may involve formal disciplinary proceedings or other measures such as a cautionary letter or a warning letter.  Formal disciplinary proceedings become matters of public record, however other measures taken by IIROC are not.

Anonymous trading – 001

With reference to the 001 trading number – anonymous trading marker:  Each participating organization (IIROC member firm/PO)  on Canadian marketplaces has a unique numeric identifier (ID) that is automatically included on all trade tickets and order reports.  The ability to use the anonymous trading number is a function of the exchange, not IIROC.  PO’s and/or their retail clients (including yourself) may elect to use the anonymous marker (001) on certain orders as part of their trading strategy, thus making the order or trade unattributed or “anonymous” i.e. Broker ID “001”.  The election to use the anonymous marker is potentially open to all participants (institutional and retail clients) in the marketplace (consult with your broker about the use of 001).  In essence, “anonymous” may be one or many different brokers and/or their clients who choose to use the “001” anonymous marker as part of their trading strategy.

A significant part of IIROC’s role is to develop, administer, surveil and enforce the trading rules known as the Universal Market Integrity Rules, in the Canadian securities market. You may find out more about UMIR by visiting our website at www.iiroc.ca.  The link to UMIR is in the right navigation pane under “Rule Book”.

Sincerely,

Johnny Ngo
Senior Complaints & Inquiries Specialist
Investment Industry Regulatory Organization of Canada

Spécialiste Sénior de Plaintes et Renseignements

Organisme Canadien de Réglementation du Commerce des Valeurs Mobilières

5 Place Ville Marie, Suite 1550

Montréal, Quebec

H3B 2G2

1.877.442.4322

F: 514 878-3860