The EMDA has expressed serious concerns about the proposed exlcusion of EMDs under the new direct market access regime. The EMDA's comments and analysis was delivered in a formal submission to the CSA on July 8, 2011.
The proposed rules would exclude EMDs from eligibility as a direct market access clients and the EMDA believes the proposals reflect an unwarranted regulatory bias against EMDs. The EMDA has argued that EMDs should be eligible direct market access clients, rejects the unlevel playing field the proposed rules create, and the negative consequences for international dealers and EMDs who are also portfolio managers.