CFFiM supports the proposed TMX Ultra 10GB Connectivity if implemented equitably, transparently, and in a way that preserves balanced competition across all tiers of the Canadian market.

Key considerations are as follows:

1. Competition and Market Impact

• Ensure the new connectivity does not disproportionately favor latency-sensitive participants or disrupt smaller/less liquid markets.
• Assess effects across all three tiers of Canadian securities (inter-listed, senior non-inter-listed, and junior/venture equities).

2. Fairness and Equidistance

• All co-location connections must be equidistant from trading engines.
• Use uniform hardware standards and latency variance testing to maintain fairness.

3. Pricing Model

• A variable pricing structure (per message, client, or volume) to allow smaller participants to compete effectively.

4. Transparency and Monitoring

• Require disclosure of latency, hardware specs, architectural diagrams, and message traffic.
• Conduct ongoing monitoring of market impact and participant adoption.

5. Stakeholder Feedback

• Feedback should include volume representation and tier-specific impact, including participants not consulted.
  Full CFFiM recommendations are here.

Full CFFiM recommendations are ici.