CSTA on Industry Issues

February 25, 2013
Re: Alpha Exchange Inc. – Amendments to the Alpha Exchange Trading Policies – Notice of Proposed Changes and Request for Feedback
View CSTA Responce to Alpha Exchange Inc.

October 29, 2012
Re: IIROC Notice 12-0221 Proposed Guidance on Certain Manipulative and Deceptive Trading Practices
View CSTA Responce to IIROC

August 27, 2012
Re: Alpha Exchange Inc. Notice of Proposed Changes and Request for Feedback
View CSTA - Alpha Exchange Inc.

July 23, 2012
Re: Provisions Respecting the Execution and Reporting of Certain “Off-Marketplace” Trades & Provisions Respecting Dark Liquidity.
View CSTA - Dark & Anti-Avoidance

March 2, 2012
Re: Notice of Proposed Changes and Request for Feedback on Changes to definition of “Retail Client”
View CSTA - Alpha Foreign Retail

February 17, 2012
Re: Request for Feedback on Changes to Order Allocation Methodology for Jitney Trades
View CSTA - Jitney Marker

February 13, 2012
Re: Request for Comments on Market-wide Circuit Breakers for the Canadian Marketplace
View CSTA - IIROC Circuit Breakers

October 27, 2011
Re: IIROC’s Provisions Respecting Dark Liquidity and the Joint CSA/IIROC Staff Notice 23-311: Regulatory Approach to Dark Liquidity in the Canadian Market

View CSTA Response to Joint CSA/IIROC Staff Notice 23-311: Regulatory Approach to Dark Liquidity in the Canadian Market

May 30, 2011
The intent of this letter is to respond to “IIROC Notice 11-0075: Provisions Respecting Regulation of Short Sales and Failed Trades” and to “IIROC Notice 11-0076: Proposed Guidance on “Short Sale” and “Short-Marking Exempt” Order Designations.”

View CSTA Response to IIROC Notice 11-0075:/IIROC Notice 11-0076:

March 22, 2011
The intent of this letter is to respond to the Joint Canadian Securities Administrators/IIROC “IIROC Notice 10-0331: Proposed Guidance on Regulatory Intervention for the Variation or Cancellation of Trades”.

View CSTA Response to IIROC Notice 10-0331: Proposed Guidance on Regulatory Intervention for the Variation or Cancellation of Trades

January 24, 2011
This letter serves as a response to the Joint Canadian Securities Administrators/IIROC “Position Paper 10-0298: Proposed Guidance Respecting the Implementatiion of Single Stock Circuit Breakers”.

View CSTA Response to Joint Canadian Securities Administrators/IIROC

View CSTA Trading Issues Survey Implementation of Single Stock Circuit Breakers January 2011

January 14, 2011
This letter serves as a response to the Joint Canadian Securities Administrators/IIROC “Position Paper 23-405: Dark Liquidity in the Canadian Market”.

View CSTA Response to Joint Canadian Securities Administrators/IIROC

View CSTA Trading Issues Survey – Dark Liquidity in Canada December 2011

May 14, 2010
This letter serves as a response to the extreme market move that occurred on Thursday, May 6th, 2010 between approximately 2:40pm and 2:50pm EDT. While the specific event that occurred was initiated in the US marketplace, the Canadian marketplace was directly affected.

View CSTA Response to M. St Gelais and Ms. Jensen

December 29, 2009
This letter is in response to the Joint Canadian Securities Administrators/IIROC Consultation Paper 23-404, “Dark Pools, Dark Orders, and Other Developments in Market Structure in Canada”.

View CSTA Response to M. St Gelais and Ms. Jensen
View Joint CSA/IIROC Consultation Paper 23-404 – Dark Pools, Dark Orders, and Other Developments

November 30, 2009
This letter intends to demonstrate that there are some anomalies that exist within the Canadian marketplace that the CSTA believes undermine the perceptions of market quality of our public markets.

View CSTA Response to Susan Greenglass

December 24, 2008
CSTA Re:Notice of Proposed Amendments to National Instrument 21-101 Market Place Operations And National Instruments 23-101 Trading Rules

View CSTA Response

July 15, 2008
CSTA letter to Honorable Thomas A. Hockin. Re:Letter from the Expert Panel on Securities Regulation

View letter to Honorable Thomas A. Hockin

June 30, 2008
CSTA letter to James Twiss, Market Regulations Services Inc. Re: Market Integrity Notice No. 2008-09 Provisions Respecting the “Best Price“ Obligation

View letter to James Twiss

May 27, 2008
CSTA letter to James Twiss, Market Regulations Services Inc. Re: Market Integrity Notice No. 2008-09 Provisions Respecting the “Best Price“ Obligation

View letter to James Twiss

April 21, 2008
CSTA letter to M. Jean St Gelais at CSA re request from Canadian regulators to “grant traders exemption from any trade-through violations”

View letter to M. Jean St Gelais

April 9, 2008
CSTA letter to James Twiss, Market Regulations Services Inc. re Provisions Respecting the Assignment of Identifiers and Symbols

View letter to James Twiss

January 16, 2008
CSTA letter to M. Jean St Gelais at CSA re “Application for Approval of an Exemption from Aspects of the Best Price Obligation”

View letter to M. Jean St Gelais

December 17, 2007
CSTA Comment letter to M. Jean St Gelais at CSA regarding TradeThroughs

View letter to M. Jean St Gelais
View Trader Comments

October 9, 2007
CSTA Letter to James Twiss, Market Regulations Services Inc. entitled Provisions respecting short sales and failed trades" – No 2007-17

View letter to James Twiss

May 31, 2007
CSTA Letter to Rik Parkhill, TSX, re Survey Early Opening

View letter to Rik Parkhill.

May 31, 2007
VSTA Letter to Rik Parkhill, TSX, re Survey Early Opening

View letter to Rik Parkhill.

December 7, 2006
CSTA Letter to James Twiss, Market Regulation Services Inc., re Provisions Respecting Competitive market Places No. 2006-19

View CSTA RS Reply Request.

December 1, 2006
CSTA comment letter to Nancy Morris, SEC re Notice of National Association of Securities dealers, Inc. Filing of Proposed Rule Change Relating to Amendments to Rule 2320(g) and Corresponding Recordkeeping Requirements Under Rule 3110(b) [Release No. 34-54650; File No. SR-NASD-2004-130]

View SEC comment letter

October 14, 2005
Verbal Commentary on Trade Through Obligations as presented to the Ontario Securities Commission.

View comment letter.

March 23, 2005
STA Letter to Chairman Donaldson - Reg NMS

View letter to Chairman Donaldson from the STA.

November 2004
CSTA Response to a Request for Comments from Regulation Services on Provisions Respecting "Off-Marketplace" Trades

View CSTA response letter.

November 11, 2004
FSA Policy Statement 04/23 "Bundled brokerage and soft commission arrangements: Update on issues arising from PS04/13"

The FSA had earlier this year published its findings on soft and bundled brokerage commission. The FSA had concluded that fund managers' use of commission should be limited to the purchase of 'execution' and 'research', and the FSA committed to clarifying the scope of these terms.
The FSA has today published Policy Statement 04/23 which sets out the FSA's conclusions on the scope of the terms 'execution' and 'research' and the types of goods and services that should be considered part of either. The FSA has stated that this should assist the industry to continue its progress towards a market-based solution to the transparency and accountability issues raised by soft and bundled brokerage commissions.

Policy Statement 04/23 can be found at http://www.fsa.gov.uk/pubs/policy/ps04_23.pdf and the accompanying newsletter can be found at http://www.fsa.gov.uk/pubs/policy/ps04_23_newsletter.pdf. The FSA's Press Release FSA/PN/093/2004 announcing the publication of Policy Statement 04/23 can be found at http://www.fsa.gov.uk/pubs/press/2004/093.html.

Herbert Smith