Gatekeeper Requirements For Direct Electronic Access and Routing Arrangements

1. Background

Participants that provide DEA or enter a routing arrangement must establish:

• standards to manage the attendant risks;
• a written agreement between the Participant and the client, investment dealer or foreign dealer equivalent to which it will provide access; and
• gatekeeper procedures for reporting to CIRO non-compliance by the client, investment dealer or foreign dealer equivalent with the standards or written agreement.

Rule 7.13(6) provides that a Participant shall forthwith notify the Market Regulator:

1. upon entering into a written agreement respecting DEA, of the name of the client that is not eligible to obtain a Legal Entity Identifier under standards set by the Global Legal Entity Identifier System; and
2. of any change in the information described in clause (a);

Rule 10.18(2) provides that a Participant that has provided access to a marketplace pursuant to DEA or through a routing arrangement shall forthwith report to the Market Regulator the fact that the Participant:

1. has terminated the access of the client under the arrangement for DEA or of the investment dealer or foreign dealer equivalent through a routing arrangement; or
2. knows or has reason to believe that the client, investment dealer or foreign dealer equivalent has or may have breached a material provision of:
   1. any standard established by the Participant for the granting of DEA or a routing arrangement, or
   2. the written agreement between the Participant and the client regarding the DEA, or the investment dealer or foreign dealer equivalent regarding a routing arrangement.

2. Questions and Answers

The following are specific questions respecting gatekeeping requirements and CIRO’s response to each question.

2.1 When must a gatekeeper report be submitted to CIRO by a Participant under Rule 10.18?

A Participant should submit a gatekeeper report immediately upon having knowledge of, or reason to believe, that there has or may have been a breach of a material provision of a standard or the agreement established under Rule 7.13.

2.2 How does a Participant provide a gatekeeper report to CIRO respecting DEA or a routing arrangement?

A Participant can submit a report through CIRO Services2.

3. Applicable Rules

UMIR Rules this Guidance Note relates to:

• UMIR 6.2
• UMIR 7.13
• UMIR 10.15
• UMIR 10.18

4. Previous Guidance Note(s)

This Guidance Note replaces Guidance Note 13-0290 – Rules Notice – Technical – UMIR – Gatekeeper and Notice Requirements for Direct Electronic Access and Routing Arrangements (December 3, 2013).

5. Related Documents

This Guidance Note is related to the following Guidance Notes:

• CIRO Notice 13-0184 – Rules Notice – Notice of Approval – UMIR and IDPC Rules – Provisions Respecting Third-Party Electronic Access to Marketplaces (July 4, 2013).
• CIRO Notice GN-URPART7-26-0004 – Guidance Note – UMIR – Guidance Respecting Supervision over Third Party Electronic Access to Marketplaces (March 24, 2026).

• 2CIRO Services can be accessed at: servicesint.ciro.ca