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For this reason, we stand by the compliance mechanism as proposed, including, in particular, as it relates to the methodology for tracking firm-up rates. He or she can then bump up the stock price by purchasing shares on the public market. While we agree that stringent firm-up standards are desirable and necessary, and while we are open to allowing the compliance mechanism to evolve over time, we decline to make any additions to it at this time.


There is no clear consensus as to whether the enforcement of the firm-up rate would be more appropriate at the Subscriber level as proposed or at the Trader ID level We have had discussions regarding this issue with numerous Subscribers, including many who have experience with conditional orders currently available in marketplaces outside of Canada e. One of the issues raised in the comment letter pertained to information leakage. Once conditional orders are implemented, we will consider modifications to the compliance mechanism, including additional or more onerous standards, but this will require observation of how conditional orders are being used over time.



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Comments (5)

  1. Many operators of dark pools use them to keep trades to themselves, a practice known as internalization.

  2. Dark pools fall into two main categories. For example, a large active buy order can trade against a passive dark order at the Canadian Best Offer.

  3. Number of shares in an average Match Now trade Sources: Sell dark passive order of 2, is still resting at a limit price of

  4. Story continues below advertisement For example, a high-frequency trader might go "fishing" in a dark pool by dispatching small sell orders for a particular stock. Trade of 1, at

  5. MATCHNow should incorporate average resting time metrics into the performance evaluation process to ensure that potential misuse is detected As part of the proposed change, MATCHNow has already undertaken to track average resting time and provide it to our Subscribers in their Conditionals reporting. Trade of 1, at

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