On May 28, 2025, the IIAC responded to the Canadian Investment Regulatory Organization (CIRO)’s Proposed-Amendments-Respecting-Contingent-Derivative-Orders (the “Proposed Amendments”).

The IIAC did not oppose the Proposed Amendments on the basis that they reflected TSX Rulebook Amendments, which were designed to facilitate contingent option trades that are linked to trades of options on the Montreal Exchange (“MX”). In addition, contingent option trades are likely to have a de minimis market impact. 

However, the incremental approach to the TSX Rulebook Amendments and CIRO’s Proposed Amendments presents opportunities for improvement in the public consultation process.

Price discovery is generally considered critical to determining fair value. It finds a fair market price through several interactions between buyers and sellers over time. Its diminishment is, therefore, generally considered harmful as it may reduce market efficiencies and returns. Caution and deep analysis should be exercised regarding any future carveouts.