C-TMX Unique Client Order Identifier

Updated on: Jul 1, 2024

Latest Event


  • Jun. 26, 2024 C-TMX FAQs
  • On Jun. 26, 2024, C-TMX published Circular 075-24, Client and order identifiers FAQs.
  • Update existing FAQs on Art. 3.5 (sponsored access), Art. 6.115 (order identification).

On Mar. 27, C-TMX proposed amendments to client, order identifiers.

  • C-TMX requested comment on proposed amendments to client, order identifier rules.
  • Agency proposed to updated rules to introduce a unique client identifier as well as identifying orders for sponsored access and orders that are generated algorithmically.
  • Aims to increase transparency, allow it to link client activity across multiple approved participants, foreign approved participants, improving market surveillance functions.
  • Follows C-TMX Jun. 2021 consultation paper on client identifier, orders, see #109909.
  • Proposed Amendments
  • Modified, moved legal entity identifier (LEI) definition in C-TMX 6.500 to C-TMX 1.101.
  • Introduced new client and order identification requirements under C-TMX 6.115.
  • Abrogated certain requirements in C-TMX 3.5 covered with C-TMX 6.115 amendments.
  • Redline version of changes are included in Appendix B, beginning on p. 15 of the PDF.
  • Client Identifier Proposal
  • Each participant would be required to assign a unique identifier to each direct client.
  • Unique identifier would be in the form of an integer from five to 4,294,967,296.
  • Identifiers cannot be reassigned, and need only be unique at the participant level.
  • Must assign unique identifier to each client of direct client that uses its own algorithm to automatically generate orders or quotes on a predetermined basis in integer form.
  • Included requirement to submit client identifier and unique identifier on order entry.
  • Prescribed rules for submitting each order, quote entered in electronic trading system.
  • Set out requirements for bulk orders, and for clients to report client information.
  • Required to be reported by 7 PM ET day client identifier was first used on order entry.
  • Also. set requirements to identify sponsored access orders, algorithmic orders.
  • Outlined requirement to submit corrections, to keep records, other requirements.
  • Intended Implementation
  • Following regulatory approval, intended to be implemented on or about Dec. 31, 2023.
  • Consultation
  • Comments on proposed amendments must be submitted at latest on May 27, 2023.
  • Dec. 2023 C-TMX Certification of Amendments
  • On Dec. 7, 2023, C-TMX issued Circular 144-23, self-certification of rule amendments.
  • Two modifications were made to amendments following publication on Mar. 27, 2023.
  • The requirement for approved participants to notify when a person ceases to be a sponsored access client was not repealed as part of these rule amendments.
  • Subparagraphs 6.115(h)(iv), (vi) modified to remove limitation to reassign identifier.
  • Redline version of amendments on pg. 2; comments received, responded to on pg. 13.
  • Rule amendments will become effective on Jun. 28, 2024, after market close; C-TMX expects compliance with these rule amendments by no later than Oct. 1, 2024.
  • Dec. 7, 2023 CSA Que Circular
  • On Dec. 7, 2023, CSA Que published TMX Circular 144-23 regarding rule certifications.
  • Feb. 2024 C-TMX Circular
  • On Feb. 13, 2024, C-TMX published TMX Circular 015-24 re client and order identifiers.
  • Provides short code scenarios document, examples to comply with the order entry and mapping requirements; file specifications document on short code mapping to TMX.
  • Mar. 2024 C-TMX Guidelines
  • On Mar. 28, 2024, C-TMX issued guidelines to complement client, order identifier rules.
  • Guidelines provide additional information, expectations re the identifier requirements.
  • Jun. 21, 2024 C-TMX Extended Compliance Deadline
  • On Jun. 21, 2024, C-TMX issued Circular 074-24, extended compliance deadline to Mar. 31, 2025, after receiving notice from participants expressing implementation delays.
  • Jun. 26, 2024 C-TMX FAQs
  • On Jun. 26, 2024, C-TMX published Circular 075-24, Client and order identifiers FAQs.
  • Update existing FAQs on Art. 3.5 (sponsored access), Art. 6.115 (order identification).
Regulators
C-TMX
Entity Types
Depo; Exch; FCM; OTC
Reference
FAQ, Cir 075-24, 6/26/2024; Cir 074-24, 6/21/2024; Cir 030-24, Gd, 3/28/2024; Cir 015-24, 2/13/2024; CSA Que: Bul Vol. 20 No. 48 p. 310, 12/7/2023; Cir 144-23, 12/7/2023; Cir 044-23, 3/27/2023; Citation: *C-TMX* 1.101, 3.5, 6.115, 6.500;
Functions
Compliance; Financial; Legal; Operations; Product Administration; Record Retention; Reporting; Trading
Countries
Canada
Category
State
N/A
Products
Clearing; Commodities; Derivatives; Fixed Income
Rule Type
Final
Regions
Am
Rule Date
Mar 27, 2023
Effective Date
Mar 31, 2025
Rule ID
167684
Linked to
Reg. Last Update
Jun 26, 2024
Report Section
US Investment