As we first described in our April 2020 bulletin, securities commissions across the country granted exemptions to certain requirements in National Instrument 24-101 Institutional Trade Matching and Settlement (NI 24-101) to provide for a three-year moratorium on the trade match exception reporting requirement (Exception Reporting Requirement). Prior to the moratorium, registered dealers and advisers were required to file a Form 24-101F1 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 Canadian Securities Administrators (CSA) have also since published for comment proposed amendments to NI 24-101 intended to shorten the standard settlement cycle for institutional equity and long-term debt market trades from T+2 to T+1, as well as permanently repeal the Exception Reporting Requirement. These amendments are expected to come into force in May 2024 to coincide with Canada’s move to a T+1 settlement cycle.
On June 15, the CSA published a further temporary exemption on the applicability of the Exception Reporting Requirement through local blanket orders that are substantively harmonized across Canada. These exemptions will cease to be effective on the earlier of the effective date of the amendments to NI 24-101 and the date that is 18 months after the date of the blanket orders, unless further extended.
If you have any questions about the impact of this extension on the moratorium, please contact your usual lawyer at AUM Law.
June 30, 2023