In anticipation of the Canadian Investment Regulatory Organization’s (CIRO’s) intention to revise short sale settlement amendments and guidance, the Investment Industry Association of Canada wrote to CIRO summarizing further recommendations.
Some of the recommendations call for CIRO to clarify that certain proposed language is not intended to add any extra obligations to existing requirements. The IIAC also took aim at suggestions made by regulators to prove compliance, such as “easy-to-borrow” lists or importing technologies from other jurisdictions, urging this is clarified as examples rather than requirements, or removed altogether.