1. Questions and Answers

The following are specific questions and IIROC’s response to each question.

1. The following entities require a separate notification to IIROC in addition to using the correct identifier on the order. What form of identifier is IIROC requiring on the order and how it is transmitted on each applicable order?

1. What kind of unique identifier should be used for an adviser or foreign adviser equivalent that manages an OEO account?

The unique identifier for the adviser or foreign adviser equivalent can be one of the following:

• Legal Entity Identifier (LEI) of the adviser or foreign adviser equivalent,
• trading account number of the adviser or foreign adviser equivalent13 ,
• a unique identifier created and assigned by the OEO Dealer to the adviser or foreign adviser equivalent, or
• account number of the OEO client managed by the adviser or foreign adviser equivalent.

If the OEO Dealer uses the LEI of the adviser or foreign adviser equivalent as the unique identifier on orders sent to a marketplace, there is no need to separately report the name of the adviser/foreign adviser equivalent using the “DEA & OES Notice Form” in Appendix A.

If the OEO Dealer creates and assigns a unique identifier to the adviser or foreign adviser equivalent to be included on orders sent to a marketplace, the OEO Dealer must use the same identifier for all OEO accounts at the OEO Dealer that are managed by the adviser or foreign adviser equivalent.

1. How does a Participant or OEO Dealer notify IIROC of the identifiers and corresponding identity for the entities listed in Item 1.1 of this Notice?

Participants and OEO Dealers should use the DEA & OES Notice Form in Appendix A, which is available through the Regulatory Reporting tab on the IIROC website. Once completed, Participants and OEO Dealers can submit the form to IIROC via ShareFile.14 Participants and OEO Dealers must submit a completed form each time a new identifier is required. IIROC continues to expect that Participants and OEO Dealers would report the identifier no later than 10 days following the month during which use of a new identifier is required.

1. Applicable Rules

UMIR and DMRs/IIROC Rules this Guidance Note relates to:

• UMIR 1.1
• UMIR 6.2
• UMIR 7.13
• DMR 3200 [section 3241 of the IIROC Rules]

1. Previous Guidance Note(s)

This Guidance repeals and replaces the following Guidance or sections of the following Guidance as shown:

• IIROC Notice 13-0290 – Rules Notice – Technical – UMIR – Gatekeeper and Notice Requirements For Direct Electronic Access and Routing Arrangements (December 3, 2013); Part A in reference to Rule 7.13(6): Notification of DEA or Routing Arrangement.
• IIROC Notice 14-0264 – Rules Notice – Guidance Note – UMIR and Dealer Member Rules – Guidance Respecting Order Execution Services as a Form of Third-Party Electronic Access to Marketplaces (November 13, 2014); Item 4 in reference to client account numbers in ACCOUNT_ID field of each order; Q. 1 in Item 5.
• IIROC Notice 19-0133 – Rules Notice – Technical – DMR – Use of Identifiers and Notification Requirements Respecting Certain Order Execution Only Client Accounts (August 6, 2019).

1. Related Documents

This Guidance Note is related to the following Notices:

• IIROC Notice 19-0071 – Rule Notice – Notice of Approval – UMIR and DMR – Amendments Respecting Client Identifiers (April 18, 2019).
• IIROC Notice 19-0101 – Rules Notice – Notice of Approval – Dealer Member Rules – Amendments to Provisions Respecting Order Execution Service Eligibility and Adviser Identifiers (June 6, 2019).
• IIROC Notice 20-0251 – Rules Notice - Technical Notice - UMIR and DMR/IIROC Rules - Upcoming Implementation of Client Identifier Amendments for Listed Securities (November 25, 2020).

1. Appendix A – DEA & OES Notice Form

Form for Identification of Direct Electronic Access Client (DEA), Active Order Execution Only Client, or Registered Adviser/Foreign Adviser Equivalent
(Please submit via ShareFile)

Instructions:

If you used a Legal Entity Identifier (LEI) on orders sent to a marketplace, you do not need to complete this form.

If you did not use an LEI on orders sent to a marketplace, please use this form to report:

1. Direct Electronic Access client that is ineligible to obtain an LEI under GLEIF standards
2. "Active" order execution only (OEO) client whose trading activity on marketplaces regulated by IIROC exceeds a daily average of 500 orders per trading day in any calendar month.
3. Adviser or foreign adviser equivalent that either holds an OEO account, or has control over /manages an OEO account.

Tab 1 – DEA Client

Tab 2 – Active OEO Client

Tab 3 – Adviser or Foreign Adviser Equivalent

• 8Client account number to be included in Tag 8025 (non-crosses) or Tag 2021 and 20202 (crosses) on the order. Please see the FIX Specifications for Client Identifiers for more information. Dealer to separately report name of the DEA client to IIROC using Appendix A.
• 9OEO clients whose trading activity on marketplaces regulated by IIROC exceeds a daily average of 500 orders per trading day in any calendar month.
• 10Client account number to be included in Tag 8025 (non-crosses) or Tag 2021 and 20202 (crosses) on the order. Please see the FIX Specifications for Client Identifiers for more information. Dealer to separately report name of the “active” OEO client to IIROC using Appendix A.
• 11Client account number to be included in Tag 8025 (non-crosses) or Tag 2021 and 20202 (crosses) on the order. Please see the FIX Specifications for Client Identifiers for more information. Dealer to separately report name of adviser or foreign adviser equivalent to IIROC using Appendix A.
• 12Unique identifier of adviser or foreign adviser equivalent to be included in Tag 1 on the order.
• 13Trading accounts would not include proprietary accounts of the Adviser or Foreign Adviser Equivalent.
• 14See IIROC Notice 14-0186 – Rules Notice – UMIR and DMR – Technical – Requirements for Secure Electronic Regulatory Communication (July 24, 2014).