IIROC publishes first installment of plain language rule rewrite for comment

IIROC has issued a request for comments on proposed new rules 3100 - Business Conduct and 3200 - Client Accounts. The rules are part of an overall project to rewrite all IIROC rules, by-laws and policies in plain language and to reorder and reorganize them in a more coherent manner (full disclosure: I was retained to work on parts of this project).

The project also had the following goals:

• to eliminate unnecessary or obsolete provisions
• to clarify IIROC's expectation of its members
• to conform the rules to actual practice
• to ensure consistency with other rules and securities legislation, and
• to clarify those provisions that are mandatory (which are drafted as rules) from those that are suggestive (which are drafted as guidance notes).

In addition to the dealer rules, the universal market integrity rules will be included in this project.

As part of the rule rewrite project, a number of rules were identified which require substantive changes.

The rules are being released in 8 tranches with a longer than normal comment period (90 days versus the usual 30), in order to ensure opportunity for review and comment. Any proposed substantive changes are noted in the request for comment. In the case of rules 3100 and 3200, there are a number of substantive changes that are outlined in the request for comments.

The comment period is open until June 27, 2010. Comments should be directed to Sherry Tabesh-Ndreka, Policy Counsel, Member Regulation Policy.