Wednesday, March 10, 2010 CSTA OPINION
 
 CSTA on Industry Issues
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