The Canadian Securities Exchange’s Proposal to introduce CSE2 Odd Lot Liquidity Allocating (OLLA) Order Type (the Proposal) acts as a hybrid between dark pegged liquidity and special terms. It’s efforts to protect small sized orders are admirable. The Proposal could erode the transparency of the order book, alter the pricing of client limit orders, and shift certain dealer functions to the marketplace, without a comprehensive cost-benefit assessment.

The CFFiM provides a series of considerations to achieve a scalable and transparent model for continuous odd lot liquidity which lowers maintenance costs for dealers and improves investor access.

The CFFiM’s recommendations continue to illustrate principles of market fairness, transparency, regulatory prudence, and balance of economic interests, as also found here:

CFFiM: TMX Ultra-10gb Connectivity – Ensuring Fair. Competitive-and-Transparent Market Access

CFFiM: Nasdaq Proposed Changes – Pause for Costs, Benefits and Competitiveness

CFFiM: TMX Sliding Scale Fee Model – Addressing Risks and Rewards