Investor Alert:
CIRO is issuing a warning to Canadian investors regarding Canada Token Trade.
Effective Date: December 31, 2021
The following guidelines were identified from reviews of Dealer Members (Dealers) having well developed and effective systems for containing confidential information so as to prevent it being used for illegal insider trading. Policies and procedures commonly used by registrants to monitor and/or restrict transactions include the use of “Grey” (or “Watch”) and “Restricted” Lists. These guidelines are being provided to assist Dealers that are implementing, revising or reviewing the effectiveness of their procedures. IIROC recognizes that such procedures will vary from Dealer to Dealer depending on factors such as the nature of the Dealer’s business, its size, clientele and the markets in which it conducts business.
The containment of confidential information is an issue for all Dealers, not just those engaged in corporate finance or investment banking activities. Dealers that are not involved in corporate finance or investment banking should identify the various means by which they, or their personnel, may come into possession of material non-public information that could be used for insider trading, such as through trading by issuers, research or relationships between personnel and corporate insiders.
Dealers must establish procedures to bring the receipt of such information to the attention of management and deal with it appropriately, using these guidelines. Dealers must implement, maintain and enforce robust policies and procedures to safeguard inside information.
Information Barriers are physical and procedural means of restricting access to confidential information to those needing to know it and of recording who gets access to it and when.
A Grey list is a highly confidential and limited-circulation list of issuers on which the Dealer and its staff have confidential information. The list is distributed to qualified staff to monitor any trading activity that suggests the information is being misused or has leaked.
The Restricted List is a list of issuers with whom the Dealer has a current, publicly disclosed involvement requiring restrictions on the Dealer’s trading or advising activities.
IIROC Rules this Guidance Note relates to:
This Guidance Note replaces MR0377 – Guidelines for Confidential Information Containment.
This Guidance Note was published under Notice 21-0190 - IIROC Rules, Form 1 and Guidance.