Policies and Procedures Regarding the Use of Universal Test Symbols

I. Purpose of Universal Test Symbols

Universal test symbols (UTS) enable marketplace participants to conduct limited testing in a marketplace's production environment. While limitations exist over this facility (discussed below under Use & Restrictions), it allows participants to better replicate the transaction logic they will encounter in production than may be possible in the user test environment (UAT).

The use of UTS is in furtherance of a marketplace's obligations under section 5.7 of NI 21-101 to take all reasonable steps to ensure that its operations do not interfere with fair and orderly markets. Providing a means for a marketplace participant to validate production deployments before turning them over to live trading should promote market integrity by mitigating risk for participants, marketplaces and the market as a whole.

The designated time window for use of the UTS facility is being limited in the initial stages of its introduction. It will likely be expanded at a later date as experience is gained by both the marketplaces and the dealers.

Where a participant misuses the UTS, the marketplace will inform the regulator who may take the appropriate actions under securities law.

II. Designated Test Symbols

The current set of test symbols used by the TSX has been designated by the regulator to be the UTS for the purpose of performing testing in production environments. These consist of five TSX symbols and four Venture symbols. See Appendix A for a list of the UTS.

Debt instruments such as debentures are not covered by this facility. Only equity transactions can be tested.

III. Use & Restrictions

Marketplaces must provide fair access to its marketplace participants to the UTS facility. Each marketplace participant will have access to the UTS in the production environment. At the same time, marketplace participants must ensure that they are using the facility appropriately. Misuse of this facility by marketplace participants may amount to the breach of the fair and orderly markets provisions of NI 23-103 Electronic Trading and Direct Electronic Access to Marketplaces and will be reported to the appropriate securities regulator.

The authorized use of the UTS facility is to enable network connectivity to be tested and the functional verification of various order types to be performed. No restriction is being placed on the order types that may be tested with UTS. However, the following are not permitted uses of the UTS facility:

Any type of capacity, volume or stress testing
Basic functional testing that can, and must, be performed in the UAT/GTE. The UTS facility may be used only after any bugs identified through basic functional testing have been resolved
Any use by vendors unless carried out on behalf of a marketplace participant
Any use by DEA clients unless specifically sponsored by a marketplace participant

In summary, a marketplace participant is fully responsible for any testing activity that takes place in a production environment.

IV. Availability & Notification

Use of the UTS is limited to a designated window. Initially, the window is daily between the hours of 8:00am and 9:00am. During this time, a marketplace will provide full support for marketplace participants conducting testing through the UTS facility.

At least 24 hour prior notification is required by a marketplace participant wishing to use the UTS facility. Notifications are to be sent by email to the designated representative at each marketplace to be impacted by the test. The same or different tests at a later date will require a separate notification.

At a minimum, the notification will contain the following:

the date and time of the test
the approximate volume of test transactions and messages
a brief description of what is to be tested
a contact name and number

Certain marketplaces may require completion of a UTS request form posted on their websites.

V. Suspension of Access

There are concerns that a marketplace participant could misuse a production environment for testing. In particular, a participant could flood a marketplace system with excessive volume of test orders, leaving a marketplace's systems susceptible to failure. The use of UTS is intended to facilitate the testing of functionality in a marketplace's production environment. It is not intended to enable stress testing by a marketplace participant.

A marketplace may suspend access to a test symbol where, in the view of the marketplace, the use of the test symbol in a particular circumstance reasonably represents undue risk to the operation or performance of the marketplace's production environment. In such instances, the marketplace has the authority to take appropriate action to protect the continuous integrity of its production environment. Depending on the circumstances, such action may include one or more of:

A phone call or email to the designated contact requesting a change in or a termination of the test
A throttling of test messages
Termination of the test by the marketplace

In the event that termination occurs, the marketplace will notify the appropriate securities regulator immediately so that appropriate follow-up action can be taken.

VI. UTS Start Date

The UTS facility will go live on October 1, 2015.

Appendix A — List of UTS

UTS for TSX listed stocks:

ZYZ.A
ZYZ.B
ZYZ.C
ZYZ.D
ZYZ.F

UTS for TSXV listed stocks:

ZYQ.Z
ZYQ.H
AYQ.A
AYQ.H