September 22, 2017
CNSX Markets Inc., (CSE or the Exchange) is filing this Notice in accordance with the process for the Review and Approval of Rules and Information Contained in Form 21-101F1 and the Exhibits Thereto attached as Appendix B to the Exchange’s recognition order (“Protocol”). The Exchange intends to implement enhancements to its trading system in response to customer feedback. The enhancements, including new order types and additional features for existing order types, are described below.
A. Description of the Proposed Changes
Primary Price Improvement Peg Order Type
Primary Price Improvement peg orders are dark orders that will be pegged to same side of the Protected NBBO with one increment1 of price improvement.
1increment is one tick or one half tick in the case of a $0.01 spread
Seek Dark Liquidity Only Order
Seek Dark Liquidity orders are active IOC orders that will trade against dark resting orders only.
Pegged Order - Post Only option
Support of the Post Only order option will be extended to pegged (dark) order types. Coincidental with the introduction of this option, pegged orders which are not marked as Post Only will be allowed to trade with tradeable opposing pegged orders already in the book.
Pegged Order - Minimum Quantity option
Minimum Quantity will be introduced as an option on pegged orders to restrict the pegged order to only trading with contra orders of a specified volume or greater.
Pegged Orders Outside the NBBO
The behaviour of pegged orders will be corrected so that when the limit of a pegged order moves outside the NBBO, the pegged order will no longer be cancelled.
Minimum Quantity Order
Minimum Quantity order is a visible order that will trade only against contra orders with a combined volume equal to or greater than the specified minimum.
Fade to Dark Order
Fade to Dark (FTD) orders are peg orders that, upon entry, trade against lit and/or dark resting orders at the NBBO before booking, then become hidden peg orders after a fixed display time of one second.
Step Limit Order
Step Limit orders are lit orders, similar to regular limit orders but with self-adjusting limit prices (moving only in the direction of less aggressive) triggered by partial fills.
B. Expected Implementation Date: Q1 2018
C. Rationale and Analysis
CSE is offering the Primary Price Improvement Peg Order Type, Seek Dark Liquidity Only Order, Pegged Order Minimum Quantity option and the Pegged Order Post Only option in response to customer demand. The demand is for the functionality as well as consistency with the other marketplaces in Canada that have offered similar order types and options.
The Step Limit Order and Fade to Dark Order will assist with meeting the challenges of participating in a market where automation continues to play a larger role in competition and cost reduction. These order types represent minimal automation of functions already performed manually by customers that do not have the technology to facilitate automation.
The Minimum Quantity Order will address the demand for functionality that was removed by marketplaces with the advent of multiple markets in Canada, primarily because of the technical challenges to marketplaces and vendors but also decline in demand owing to lower commission fees.
The use of these order types is optional for participants.
D. Expected Impact
The expected impact is a more seamless and simplified workflow for Industry stakeholders. The changes respond to customer demand, and provide competition with the offerings of other market places. The use of these order types is optional.
E. Systemic Risk
The CSE does not believe that any increase in systemic risk would be introduced with the approval or implementation of the proposed changes.
F. Compliance with Ontario Securities Law
There will be no impact on the CSE’s compliance with Ontario securities law. The changes do not alter any of the requirements for fair access or the maintenance of fair and orderly markets.
G. Consultation
The CSE has consulted with a number of dealers and industry stakeholders and considered the feedback received during informal dialogue.
H. Technology Changes
As many of the proposed features are supported on other Canadian marketplaces, there should be no material effort required. The new order types are optional and would require minimal effort to implement.
I. Alternatives
The proposed changes address the feedback provided by clients and comply with regulatory requirements.
J. Other Markets or Jurisdictions
Most of the proposed functionality already exists in Canada and is currently provided by one or more marketplaces.
K. Comments
Please submit comments on the proposed amendments no later than October 16, 2017 to:
Mark Faulkner Vice President, Listings and Regulation CNSX Markets Inc. 220 Bay Street, 9th Floor Toronto, ON, M5J 2W4 Fax: 416.572.4160 Email: [email protected] |
Market Regulation Branch Ontario Securities Commission 20 Queen Street West, 20th Floor Toronto, ON, M5H 3S8 Fax: 416.595.8940 Email: [email protected] |