The Canadian Securities Administrators (CSA) recently issued
Notice 24-307 Exemption from Transitional Rule: Extension
of Transitional Phase-In Period in National Instrument 24-101
Institutional Trade Matching and Settlement. This notice
extends the transitional phase-in period, contained in National
Instrument 24-101 Institutional Trade Matching and
Settlement, for matching DAP/RAP trades by midnight on
trade date (T) by an additional 24 months to July 1, 2010.
In making its decision, the CSA cited concerns raised by the
Canadian Capital Markets Association (CCMA) as well as industry
working groups, which are borne out by trade matching
statistics compiled by CDS Clearing and Depository Services
Inc. (CDS), about the overall readiness of Canadian capital
markets participants to comply with the requirement to match
trades by midnight on T. CCMA contends that major new system
and process enhancements will be required by participants in
order for the securities industry to meet the improved matching
rates. Unless more time is provided for the transitional
phase-in period, the efficiency gains and cost benefits of
moving to T would be negatively impacted.
In addition to deferring the current July 1, 2008 effective
date in NI 24-101 for the midnight on T matching requirement to
July 1, 2010, the CSA have also extended the transitional
phase-in period in NI 24-101 for exception reporting by 24
months. The new transitional provisions for midnight on T
matching and exception reporting requirements of NI 24-101 that
apply to registered dealers and advisers are:
PERCENTAGE OF TRADES MATCHED
October 1, 2007 - December 31, 2007
By 12:00 p.m. on T+1: 80
January 1, 2008 – June 30, 2010
By 12:00 p.m. on T+1: 90
July 1, 2010 – December 31, 2010
By 11:59 p.m. on T: 70
January 1, 2011 - June 30, 2011
By 11:59 p.m. on T: 80
July 1, 2011 – December 31, 2011
By 11:59 p.m. on T: 90
January 1, 2012 and following
By 11:59 p.m. on T: 95
As is currently required, if the specified percentage is not
met in any quarter, registrants must file with the applicable
regulators an exception report, using the form specified in NI
24-101, within 45 days of each applicable calendar quarter-end.
If an exception report must be filed, the registrant must
describe the circumstances or underlying causes that resulted
in or contributed to the failure to achieve the matching
targets, along with the steps it will take to resolve any
future delays in the trade reporting and matching process.
The extension is being effected as of June 30, 2008 through
blanket orders in all jurisdictions except Ontario, which has
adopted local OSC Rule 24-502.
The Law Society of British Columbia’s Cloud Computing Working Group issued its Final Report on Cloud Computing on January 27, 2012, amending an earlier consultation report approved by the "Benchers" on July 15, 2011.
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