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: Provisions Respecting the Assignment of Identifiers and Symbols
The Canadian Security Traders Association, Inc. (CSTA) is a professional trade organization whose mission is to promote and improve the ethics, business standards and working environment for members who engage in the buying, selling and trading in securities. The CSTA represents over 900 traders nationwide in Canada and is led by Governors from each of three distinct regions. The organization was founded in 2000 to serve as a national voice for our affiliate organizations. The CSTA is also affiliated with the Security Traders Association (U.S.A.), which has 6,000 members globally.
We often comment on industry development and form opinions on trading issues based on input from our members.
The CSTA commends Market Regulation Services (“RS”) for the recognition that there is a need for a unique identifier for each Participant in the market places as well as a unique symbol for each security listed or quoted on a market place. With the advent of multiple market places, (“ATSS”), it has become more of an issue to have such requirements in place.
The CSTA is in agreement with the Proposed Amendments, whereas RS would assign a unique identifier to a market place for trading purposes upon being retained as the regulation services provider for the market place. The CSTA believes RS should assign a unique identifier to each Participant granted access to the trading system of a market place to ensure consistency among the market places and to be less burdensome for audit trail purposes.
The CSTA also recognizes the need for a unique symbol among the multiple market places. This implementation would assist Participants as well as Regulators in the issues of “trade through obligations, best execution” and the administrative burden of properly identifying trading information on a particular security from the various market places. As in the case of identifiers, the CSTA believes RS should be the regulator assigned to a designate a unique symbol for each security listed, quoted or traded on the market places.
The CSTA believes RS would be an unbiased registrar in the assignment of the Proposed Amendments for unique identifiers and symbols. We support a one year trial period following the implementation of the Proposed Amendments.
The Canadian Security Traders Association, Inc. would be pleased to discuss these matters in greater length.
Sincerely,
Susan Greenglass, Manager, Market Regulation Department
Ontario Securities Commission
20 Queen Street West, Suite 1903
Toronto ON M5H 3S8
sgreenglass@osc.gov.on.ca