In late March, the Ontario Securities Commission (OSC) submitted to the Minister of Finance amendments to National Instrument 24-101 Institutional Trade Matching and Settlements (NI 24-101) to provide for a three-year moratorium on the trade match exception reporting requirement (Exception Reporting Requirement). Currently, registered dealers and advisers must file Form 24-101F if less than 90% of trades executed by or for the firm in the preceding quarter matched within the time required in NI 24-101. The OSC’s decision flows from its regulatory burden reduction initiative. OSC staff agreed with a number of commentators who viewed the Exception Reporting Requirement as burdensome and no longer a meaningful contributor to regulatory oversight.
The OSC intends that the moratorium will take effect on July 1, 2020 and run until July 1, 2023. During the moratorium, the OSC will consider whether the moratorium should become permanent and whether any other changes to NI 24-101 are appropriate. In addition, staff of other members of the Canadian Securities Administrators are recommending that the same three-year moratorium be implemented through blanket orders. If you have any questions about the impact of this amendment on your operations, please contact your usual lawyer at AUM Law.
April 30, 2020