CANADIAN SECURITY TRADERS ASSOCIATION, INC.
P.O. Box 3, 31 Adelaide Street East
Toronto, Ontario M5C 2H8
James Twiss, Chief Policy Counsel
Market Regulation Services Inc.
145 King Street West, Suite 900
Toronto, Ontario M5H 1J8
Dear Mr. Twiss,
RE: Market Integrity Notice No. 2008-09 Provisions Respecting the “Best Price“ Obligation
The Canadian Security Traders Association, Inc. (CSTA) would like to have an extension to the June 9, 2008 deadline to respond to the aforementioned notice.
The CSTA commends Market Regulation Services (RS) for addressing the need for amendments to the current rules and regulations governing “best price obligations”. As you are aware this has been a very contentious issue for our association, representing over 900 Canadian equity traders. The greatest challenge for our group is to comply with the outdated rules now that there are multiple electronic marketplaces in Canada.
We are concerned that the “Interim Amendments” that have now been implemented could result in being the permanent regulations. The Board of the CSTA has a fiduciary duty to represent the best interests of our members. Accordingly, we do not feel that the short timeframe that was presented in this notice is sufficient, in order for us to examine and respond to these amendments.
We therefore request an extension to June 27, 2008 in order to complete our due diligence in this matter.
A timely response to our request would be greatly appreciated.
c.c. Susan Greenglass, Manager, Market Regulation Department,
Ontario Securities Commission
20 Queen Street West, Suite 1903, Toronto ON M5H 3S8
sgreenglass@osc.gov.on.ca c.c. M. Jean St Gelais, Chair, Canadian Securities Administrators
Tour de la Bourse, 800, Square Victoria, Suite 4130, Montreal, Quebec H4Z 1J2
jean.st-gelais@lautorite.qc.ca