Thursday, May 31, 2007

 

Rik Parkhill                                                                                         Â
President, TSX Markets
P.O. Box 450
3rd Floor, 130 King Street W.
Toronto, ON
M5X 1J2
Canada

 

Email   rik.parkhill@tsx.com

 

Dear Mr. Parkhill,

 

The Canadian Securities Traders` Association (CSTA) would like to take this opportunity to respond to your recent survey of West Coast participants of their views on a 9:00 ET opening on the TSX.

Our organization works to improve the ethics, business standards and working environment for members who are engaged in the buying, selling and trading of securities (mainly equities).

Our membership consists of 850 traders from across Canada, including those employed by your PO’s as well as for investment managers, mutual funds, and hedge funds. We speak to industry developments and on trading issues based on input from our membership; this from the perspectives of both your constituents as well as your customers.

 

The CSTA raises the following concerns regarding an earlier opening:

 

-       ÂMost trading desks both buy and sell-side, have certain responsibilities that must be completed pre and post market, i.e. morning meetings. These would have to be moved to an earlier time to compensate for the earlier opening, resulting in an even longer day for traders.

-       ÂWest Coast participants will have to start their working day at approximately 4 am PT or earlier adding more duress to the family circle.

-       ÂEarlier hours will impact not only traders, but will adversely impact all levels of the brokerage industry including analysts, portfolio managers, investor relations and retail investors.

-       ÂAn earlier opening would also have an impact on support staff who have responsibilities of settling any clearing issues from the previous day of trade.

 

 

The concentration of trading volumes is usually in the first and last hour of the trading day. There is no indication that overall volume will increase or that there will be more liquidity simply by expanding the trading day, we believe that the extending the length of the trading day will in fact diminish the liquidity as there are only so many orders generated by the buy-side on any given day we would argue that there would be less liquidity as orders are spread out over a longer day

 

We believe that the Official opening to the trading day should remain 9:30 EST

 

The Security Traders Association of which CSTA isÂa member, represents traders globally,Âresponded as well, as didÂmany of its’ affiliates to  NYSE’sÂJohn Thains’ commentsÂabout opening earlierÂin the springÂof 2006, with many of the same points that we have presented . We will gladly forward them to you if you would like to see them.

 

The representatives of the Canadian Security Traders Association, Inc. would be happy to discuss our position with you at any time and we appreciate the opportunity to respond to your survey.

 

Sincerely,

 

GW (Sonny) Lennon

 

G.W. (Sonny) Lennon

President