On October 22, IIROC released draft guidance withdrawing its position that clearing arrangements are a type of introducing broker / carrying broker arrangement to which IIROC Dealer Rule 35 applies. In the absence of applicable rules, the notice sets out the practical considerations, outsourcing due diligence obligations and IIROC notification requirements that would apply to clearing arrangements. As we discussed in an earlier post, IIROC also released draft guidance regarding outsourcing arrangements on the same day. Comments on the notice are being accepted until January 20, 2013. For more information, see IIROC Notice 12-0312.