Use of Identifiers and Notification Requirements Respecting Certain Order Execution Only and Direct Electronic Access Clients and Advisers 

1. Questions and Answers

The following are specific questions respecting the use of identifiers and notification requirements, and CIRO’s response to each question.

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

1.2 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:

• 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 not eligible to obtain an LEI 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.

1.3 How does a Participant or OEO Dealer notify CIRO 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 Forms and Templates section14 under the “For Firms” dropdown menu on the CIRO website. Once completed, Participants and OEO Dealers can submit the form to CIRO via ShareFile. Participants and OEO Dealers must submit a completed form each time a new identifier is required. CIRO expects Participants and OEO Dealers to report the identifier no later than 10 days following the month during which use of a new identifier is required.

2. Applicable Rules

UMIR and IDPC Rules this Guidance Note relates to:

• UMIR 1.1
• UMIR 6.2
• UMIR 7.13
• IDPC Rule 3241

3. Previous Guidance Note(s)

This Guidance Note replaces:

• CIRO Notice 21-0099 – Rules Notice – Guidance Note – UMIR and IDPC Rules – Use of Identifiers and Notification Requirements Respecting Certain Order Execution Only and Direct Electronic Access Clients and Advisers (May 25, 2021)

4. Related Documents

This Guidance Note is related to the following Guidance Notes:

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

5. Appendices

Appendix A - DEA & OES Notice Form

• 8Client account number to be included in Tag 8025 (non-crosses) or Tag 20201 and 20202 (crosses) on the order. Please see the FIX Specifications at Technical Specifications for Client Identifiers for more information. Dealer to separately report name of the DEA client to CIRO using Appendix A.
• 9OEO clients whose trading activity on marketplaces regulated by CIRO 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 20201 and 20202 (crosses) on the order. Please see the FIX Specifications at Technical Specifications for Client Identifiers for more information. Dealer to separately report name of the ‘active’ OEO client to CIRO using Appendix A.
• 11Client account number to be included in Tag 8025 (non-crosses) or Tag 20201 and 20202 (crosses) on the order. Please see the FIX Specifications at Technical Specifications for Client Identifiers for more information. Dealer to separately report name of adviser or foreign adviser equivalent to CIRO 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.
  Advisers or foreign adviser equivalents should not use their own proprietary account to trade for an OEO client, as the adviser or foreign adviser equivalent would not be able to allocate shares to the OEO client off-marketplace without creating a change of beneficial or economic ownership under UMIR 2.2.
• 14See Regulatory Reporting subsection in Forms and Templates at Forms and Templates.