First Several Pages of 19 Page Report "DARK LIQUIDITY IN THE CANADIAN MARKET"
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Nov 19, 2010 01:49PM
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Dave Webb sent me the PDF of this report, Cheers, Baires ............................................................................................. Joint CSA/IIROC - Position Paper 23-405 - Dark Liquidity in the Canadian Market JOINT CANADIAN SECURITIES ADMINISTRATORS/INVESTMENT INDUSTRY REGULATORY ORGANIZATION OF CANADA POSITION PAPER 23-405 DARK LIQUIDITY IN THE CANADIAN MARKET I. INTRODUCTION Developments in the Canadian capital markets have been both significant and rapid in recent years. Technological advancements have increased the speed and complexity of trading, innovation has introduced choice as to how and where to trade, and regulatory requirements have necessitated a greater awareness of execution opportunities and the prices at which they are available. As marketplaces look to expand the order types and features that they offer, and as market participants seek guidance on market structure policies, staff of the Canadian Securities Administrators (CSA staff) and staff of the Investment Industry Regulatory Organization of Canada (IIROC staff and, together with CSA staff, we) have undertaken a review of many of the issues which we believe need to be addressed immediately. These include issues relating to dark pools, electronic trading, and the regulation of marketplaces. Once our review is completed, we will seek feedback from the industry by publishing a number of different regulatory proposals or changes over subsequent months. This position paper (Position Paper) specifically deals with issues associated with Dark Pools and Dark Orders.
The views expressed take into account the consultations
conducted by the CSA and IIROC since the end of 2009.
2
For the purposes of this Position Paper, a Dark Order is defined as any order on any
marketplace that is entered with no pre-trade transparency and not required to be reported
to an information processor
3or data vendor under the applicable rules. In this Position
Paper, Dark Orders do not include reserve or iceberg orders, as a portion of these orders is always displayed, and contributes to the pre-trade price discovery process. Dark Orders can be entered on either a transparent marketplace or in a Dark Pool. A Dark Pool is a specific marketplace that offers no pre-trade transparency on any orders, and may be structured in a variety of ways including as a call market, continuous auction market, a
1
Note that for purposes of this paper, our definition of Dark Order is different than was used in previous
publications. See glossary for all definitions.
2
For more details regarding the consultations, see the discussion in the next section regarding the
Consultation Paper and the Forum.
3
Currently, the information processor for exchange-traded securities other than options is operated by the
Toronto Stock Exchange. The information processor collects order and trade information from all marketplaces and disseminates consolidated information.
2
hybrid of both continuous and call matching, or a negotiation system. Current practices
allow Dark Orders to be entered with a price:
•
determined by the marketplace participant4 entering the order;•
that could trigger a negotiation process; or•
that will be determined by reference to another publicly available price and not
directly determined by the counterparties to the trade. The reference price could be a price linked to another non-discretionary price such as the national best bid or best offer (NBBO)
or the volume weighted average price (VWAP).
(a) Background and Objectives of this Position Paper
The publication of this Position Paper is the next step in a process that we began in late
2009. In Joint CSA/IIROC Consultation Paper 23-404
Dark Pools, Dark Orders, and
Other Developments in Market Structure in Canada
(Consultation Paper), we identified
and sought comment on a number of issues, particularly the general impact of Dark Pools, the introduction of Dark Order types, and the introduction of smart order routers. The Consultation Paper discussed these issues and their potential impact on the Canadian markets, including their impact on market liquidity, transparency, price discovery, fairness and integrity.
These factors, when taken together, are used to assess the quality
of the market. We received 23 response letters to the Consultation Paper from a range of respondents including marketplaces, buy-side and sell-side representatives, and industry associations. On March 23, 2010, the CSA and IIROC hosted a forum (the Forum) to discuss the issues raised in the Consultation Paper and in the response letters. The themes discussed at the Forum included:
•
whether Dark Pools should be required to provide price improvement and if so,
what is meaningful price improvement;
•
the use of market pegged orders and whether those orders “free-ride” off the
visible market;
•
the use of sub-penny pricing;•
broker preferencing at the marketplace level and dealer internalization of order
flow;
•
the use of Indications of Interest (IOIs) by Dark Pools to attract order flow; and•
the fairness of a marketplace offering smart order router services that use
marketplace data that is not available to other marketplace participants.