On 22 March, IIROC issued guidance on short position calculation.

  • Participants, Access Persons must file short position reports, per UMIR 10.10.
  • Follows IIROC Dec. 2017 notice on calculation and reporting of short position.
  • Calculate and file report of short positions in each listed and quoted security.
  • Report as of the 15th day, and the last day of each month, (calculation date).
  • Process to file short position report with IIROC, and the expectations on filing.

Aggregate Reporting

  • Report aggregate short position of security from holding in separate account,
  • Calculate short position from each account separately; and not net positions
    from more than one account even where accounts for same beneficial owner.
  • Inclusion of odd-lot short positions, in calculation of reported short positions.
  • Calculate short positions using settlement date positions, (not on trade date).

Convertible Securities

  • A short position in a listed or quoted security which is covered by the holding
    of a convertible or exchangeable security, is still considered as short position.
  • This short position must be reported until the convertible has been tendered,
    or account holder has issued irrevocable instructions to convert or exchange.

Effectiveness

  • Effective date of guidance for short position reporting is November 30, 2018.