CSTA - TIC - Jan 2011 Circuit Breakers - Results · 2012. 5. 22. · CSTA Trading Issues Survey Implementation of Single Stock Circuit Breakers January 2011 . 2. Please choose the

CSTA Trading Issues Survey - Circuit Breakers - December 2010

1. Which CSTA Affiliate are you currenlty a member of: Please choose the option below that best

describes your area of work:

Buy Side Trader Sell Side Trader Response

Totals

Institutional Equity Traders Association (of Toronto) 70.0% 84.4% 80.8%

(IETA) (21) (76) (97)

Montreal Institutional Equity Traders Association 20.0% 8.9% 11.7%

(MIETA) (6) (8) (14)

Vancouver Security Traders Association (VSTA) 10.0% 6.7% 7.5%

(3) (6) (9)

I am NOT a CSTA member (please specify) 0 replies 0 replies 0.0%

(0.0%) (0.0%) (0)

answered question 30 90 120

skipped question 0

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

2. Please choose the option below that best describes your area of work: Please choose the option below that best



Totals

Buy Side Trader 100.0% 0.0% 25.0%

(30) (0) (30)

Sell Side Trader 0.0% 100.0% 75.0%

(0) (90) (90)

Exchange / ATS 0.0% 0.0% 0.0%

(0) (0) (0)

Vendor 0.0% 0.0% 0.0%

(0) (0) (0)

Other (please specify) 0 replies 0 replies 0.0%

(0.0%) (0.0%) (0)


skipped question 0

3. What type of institution do you work for: Please choose the option below that best



Totals

Bank-Owned Dealer 0.0% 44.4% 44.4%

(0) (40) (40)

Non-Bank Owned Dealer 0.0% 53.3% 53.3%

(0) (48) (48)


(0.0%) (2.2%) (2)


skipped question 30

4. Which is your primary area of focus: Please choose the option below that best



Totals

Equities 100.0% 97.8% 98.3%

(30) (88) (118)

Derivative Products (options, futures,..) 0.0% 1.1% 0.8%

(0) (1) (1)

Fixed Income 0.0% 1.1% 0.8%

(0) (1) (1)

Currencies 0.0% 0.0% 0.0%

(0) (0) (0)

Commodities 0.0% 0.0% 0.0%

(0) (0) (0)


(0.0%) (0.0%) (0)


skipped question 0

5. Please select any of the following listed securities that you believe SSCBs should apply to: Please choose the option below that best



Totals

All Equities 80.0% 77.8% 78.3%

(24) (70) (94)

TSX Composite Equities 10.0% 21.1% 18.3%

(3) (19) (22)

TSX 60 Equities 6.7% 16.7% 14.2%

(2) (15) (17)

ETFs 13.3% 15.6% 15.0%

(4) (14) (18)

Convertible bonds 3.3% 1.1% 1.7%

(1) (1) (2)

NONE 10.0% 5.6% 6.7%

(3) (5) (8)


(0.0%) (4.4%) (4)


skipped question 0

6. Which approach do you believe is better for applying SSCBs (trigger point calculation is irrelevant in this question):

Please choose the option below that best



Totals

Limit Up/Limit Down (Stops the execution of any

order that would violate a SSCB trigger but allows 3.3% 22.2% 17.5%

other orders to continue trading for a specified (1) (20) (21)

amount of time at the SSCB price)

Halt (Stops the execution of all orders for a specified 60.0% 31.1% 38.3%

amount of time once a trade triggers a SSCB) (18) (28) (46)

Combination of Limit Up/Limit Down for a specific

amount of time followed by a Halt for an additional 33.3% 44.4% 41.7%

amount of time if the situation does not correct itself (10) (40) (50)

(assuming that there would be no "Regulatory Halt")

Other (please specify) 1 reply 2 replies 2.5%

(3.3%) (2.2%) (3)


skipped question 0

7. Is the identification of "Junior" (TSX-V or CNSX) and "Senior" (TSX) listings for the purpose of establishing different levels of trigger point for SSCBs appropriate?




Totals

Yes, "Junior" listings are generally more volatile and 53.3% 62.2% 60.0%

should have wider volatility bands than "Senior"

(16) (56) (72)

listings

No, SSCBs should be the same for all securities 20.0% 14.4% 15.8%

(6) (13) (19)

No, SSCB should be a function of a securities 23.3% 18.9% 20.0%

liquidity and volatility rather than its market

(7) (17) (24)

capitilization bias.


(3.3%) (4.4%) (5)


skipped question 0

8. Do you believe that the historical volatility for a particular security would provide the most accurate SSCB trigger point? (even though there could be a loss of transparancy and certainty regarding the actual trigger points)




Totals

Yes 56.7% 54.4% 55.0%

(17) (49) (66)

No 40.0% 41.1% 40.8%

(12) (37) (49)


(3.3%) (4.4%) (5)


skipped question 0

9. Do you believe that general market sentiment should be considered when determining SSCBs? (even though there could be a loss of transparancy and certainty regarding the actual trigger points) (Ie. If the market is down 5%, then SSCBs would all be adjusted down 5%)




Totals

Yes 40.0% 58.9% 54.2%

(12) (53) (65)

No 56.7% 36.7% 41.7%

(17) (33) (50)


(3.3%) (4.4%) (5)


skipped question 0

10. Are the proposed SSCB triggers of 10%/10 trading increments in a 5-minute period for TSX-listed securities appropriate?




Totals

Yes 83.3% 80.0% 80.8%

(25) (72) (97)

No (please specify) 5 replies 18 replies 19.2%

(16.7%) (20.0%) (23)


skipped question 0

11. Are the proposed SSCB triggers of 20%/20 trading increments in a 5-minute period for TSX-V and CNSX-

listed securities appropriate?




Totals

Yes 76.7% 80.0% 79.2%

(23) (72) (95)


(23.3%) (20.0%) (25)


skipped question 0

12. IIROC proposes comparing each trade price of a security on a Canadian marketplace to a reference price. The reference price will be any transaction in that security in the five-minute period immediately preceding the potential "triggering" trade (generally establishing a "high" or "low" price during the relevant five-minute period). Is it appropriate to consider all executions (including dark executions) that occur within the NBBO (National Best Bid and Offer) during a 5-minute time period (or any other proposed time period) for the purpose of calculating trigger prices for SSCBs?




Totals

Yes 93.3% 92.9% 93.0%

(28) (79) (107)


(6.7%) (7.1%) (8)


skipped question 5

13. Is it appropriate to consider bids and offers for the purpose of calculating a SSCB where a security has not traded during the previous 5-minute period (or any other proposed time period)?




Totals

Yes, a bid/offer market that breaks the band 33.3% 35.3% 34.8%

requirement should force a SSCB halt even in the

(10) (30) (40)

event that a trade has not occurred

No, only trades at outlier prices should be used to 63.3% 60.0% 60.9%

trigger SSCBs (19) (51) (70)


(3.3%) (4.7%) (5)


skipped question 5

14. Regarding the duration of a trading halts (execution halt or price movement halt) for SSCBs, it is impossible to enumerate an exhaustive list of possible answers. We have provided a few examples, but please ensure to indicate a different answer if you wish to do so in the space provided: (Please note that if you do not agree with execution halts, prefering other options such as a Limit Up/Limit Down approach, this is not relevant to this question. Please indicate your opinion on the time involved for a halt in executions or price movement)




Totals

A 5-minute halt is appropriate for all securities 30.0% 34.5% 33.3%

(9) (29) (38)

A 5-minute halt for "Senior" securities and a 10-minute 26.7% 22.6% 23.7%

halt for "Junior" securities is appropriate (8) (19) (27)

I believe SSCBs should be a function of a securities

liquidity and volatility and I believe that trading halts 36.7% 33.3% 34.2%

should be 5-minutes for "liquid/non-volatile" securities (11) (28) (39)

and 10-minutes for "illiquid/volatile" securities.


(6.7%) (9.5%) (10)


skipped question 6

15. Please choose a trading hour time frame you believe to be appropriate for SSCBs: Please choose the option below that best



Totals

IIROC Proposed: 9:50 AM - 3:40 PM time frame 16.7% 29.8% 26.3%

(5) (25) (30)

US SSCBs: 9:45 AM - 3.35 PM 6.7% 19.0% 15.8%

(2) (16) (18)

Entire Trading Day: 9:30 AM – 4:00 PM 53.3% 32.1% 37.7%

(16) (27) (43)

Entire Trading Day: 9:30AM - 4:00PM (excluding MOO 20.0% 15.5% 16.7%

& MOC) (6) (13) (19)


(3.3%) (3.6%) (4)


skipped question 6

16. Should any trade which executes subsequent to a SSCB trigger and the time IIROC issues a halt (execution halt or price movement halt) be repriced to the price which triggered the SSCB?




Totals

Yes, they should be repriced to the trigger price 30.0% 29.8% 29.8%

(9) (25) (34)

No, they should be allowed to stand where they trade 20.0% 31.0% 28.1%

(6) (26) (32)

No, they should simply be cancelled as per the US 43.3% 35.7% 37.7%

model (13) (30) (43)


(6.7%) (3.6%) (5)


skipped question 6

17. Should SSCBs be implemented in phases?




Totals

Yes, SSBCs should be implemented in phases 43.3% 51.2% 49.1%

(13) (43) (56)

No, SSCBs should be implemented all at once as 50.0% 46.4% 47.4%

soon as possible (15) (39) (54)


(6.7%) (2.4%) (4)


skipped question 6

18. IIROC specifies special circumstances under which SSCBs should not be triggered. Please indicate any circumstances which you agree with and propose any other circumstances which you believe would be appropriate:




Totals

After the "general" market-wide circuit breakers have

been triggered (as the invocation of the general circuit 43.3% 61.9% 57.0%

breaker indicates that there is a previaling market

(13) (52) (65)

sentiment which is not related to liquidity issues for

that particular security)

After the SSCB has been invoked for that security

(as the previous invocation of the SSCB should have

acted as a warning to a market that there may be 16.7% 32.1% 28.1%

liquidity issues with that particular security and that (5) (27) (32)

market participants should be monitoring trading

developements in the security

After the imposition of a "regulatory halt" in the

trading of that security, particularly when the halt has

been imposed to permit the dissemination of "material 50.0% 53.6% 52.6%

news" (as the market should be allowed to react to the

(15) (45) (60)

news provided that the news has been properly

disseminated in accordance with applicable securities

legislation and marketplace requirements)

I do not believe there should be any special 23.3% 14.3% 16.7%

circumstances (7) (12) (19)

Other (please specify) 1 reply 1 reply 1.8%

(3.3%) (1.2%) (2)


skipped question 6

19. Are you concerned that there may be unintended negative consequences with the single stock circuit breakers (SSCBs) proposed by IIROC?




Totals

No 80.0% 81.0% 80.7%

(24) (68) (92)

Yes (please specify) 6 replies 16 replies 19.3%

(20.0%) (19.0%) (22)


skipped question 6

3. What type of institution do you work for:

Buy Side Sell Side Other (please specify)

Trader Trader

1 X other Jan 7, 2011 4:12 PM

2 X private bank Jan 7, 2011 7:19 PM

5. Please select any of the following listed securities that you believe SSCBs should apply to:

Buy Side Sell Side Other (please specify)

Trader Trader

1 X opening/closing trades should have different guidelines Dec 22, 2010 5:20 PM

2 X all equities on TSX (ie exlcuding venture) Dec 23, 2010 2:50 PM

3 X there should be a set of pretrade controls that are standard Dec 30, 2010 4:07 PM

across all exchanges. it would be better to stop errant trades

before they happen.

4 X Only non-interlisted stocks. ETFs should be pre-cluded Dec 31, 2010 3:37 PM

given they are sometimes tied to other products and could

cause an arbitrage situation.

6. Which approach do you believe is better for applying SSCBs (trigger point calculation is irrelevant in this question): Buy Side Sell Side Other (please specify)

Trader Trader

1 X Not in favour of SSCBs Dec 22, 2010 3:46 PM

2 X no triggers period Jan 7, 2011 7:28 PM

3 X No triggers Jan 7, 2011 7:32 PM

7. Is the identification of "Junior" (TSX-V or CNSX) and "Senior" (TSX) listings for the purpose of establishing different levels of trigger point for SSCBs appropriate? Buy Side Sell Side Other (please specify)

Trader Trader


2 X junior listings should have an entirley different program Dec 23, 2010 2:51 PM


4 X Should be a liquidity issue just as much as a 'senior/junior' Jan 7, 2011 7:35 PM

issue i believe

5 X Sector & Market Cap. Names in the materials and energy Jan 7, 2011 7:45 PM

sector are typically much more volatile then the names in

Utilities or Consumers. Also, juniors tend to be more volatile

due to risk.

8. Do you believe that the historical volatility for a particular security would provide the most accurate SSCB trigger point? (even though there could be a loss of transparency and certainty regarding the actual trigger points) Buy Side Sell Side Other (please specify)

Trader Trader


2 X it would be better but would make it trickier to Dec 22, 2010 3:56 PM

calculate/know in advance (unless published)

3 X one % across all stocks does not work...too easy to game Dec 22, 2010 5:27 PM

the limit

4 X Yes, but not security specific...more sector specific as Jan 7, 2011 7:45 PM

mentioned above

5 X Yes; however in light of HFT in Canada and news, trading Jan 10, 2011 1:05 PM

patterns will change. Volitility on a specific stock will have to

consider all factors, I'd be curious to hear more about it.

9. Do you believe that general market sentiment should be considered when determining SSCBs? (even though there could be a loss of transparancy and certainty regarding the actual trigger points) (Ie. If the market is down 5%, then SSCBs would all be adjusted down 5%) Buy Side Sell Side Other (please specify)

Trader Trader


2 X Yes. Again, opening trades need different rules and one % Dec 22, 2010 5:27 PM

across all stocks does not work...unless the % is uses

VWAP then one % would be feasible

3 X Yes... It should be an Index relative SSCB. In an ideal Dec 31, 2010 3:42 PM

world, it would be a Sector Relative Limit, given the volatility

in the mining and oil and gas space.

4 X Should be relative to the market Open to avoid mass halts Jan 4, 2011 3:42 PM

after disjointed CAD/US holidays and overnight news that

has been properly disseminated, etc...

5 X Yes, but I also agree that there would be a loss of Jan 10, 2011 1:05 PM

transparancy.

10. Are the proposed SSCB triggers of 10%/10 trading increments in a 5-minute period for TSX-listed securities appropriate? Buy Side Sell Side No (please specify)

Trader Trader

1 X TOO LOW Dec 22, 2010 3:41 PM

2 X yes provided there is a look back algo. i.e if price rallies up Dec 22, 2010 3:41 PM

9% and then falls 11%, the 11% fall should not trigger a

breaker (since it is just back to the level it was just at) .

similarly after several minutes when the 9% rally up is at the

beginning of the window, no halt should be triggered.

3 X 10% could be too small for some issues. The trigger should Dec 22, 2010 3:42 PM

be based on a function of historical volatility


5 X 10% is too high Dec 22, 2010 3:49 PM

6 X should also depend on liquidity as per previous question Dec 22, 2010 4:18 PM

7 X see previous comments Dec 22, 2010 5:27 PM

8 X Historical volatility for a particular security would provide the Dec 22, 2010 7:17 PM

most accurate SSCB trigger point

9 X Not in favor of any sscb Dec 29, 2010 11:21 PM

10 X The parameters are too wide for a 5 minute move for stocks Dec 30, 2010 4:30 PM

trading above $10. It makes sense to use different %

triggers based on different stock price bands with higher

percentage moves permitted for lower priced stocks.

11 X too simple, will result in too many unnecessary halts. Jan 4, 2011 3:58 PM

12 X wider Jan 7, 2011 1:57 PM

13 X SImple 15% across the board Jan 7, 2011 6:01 PM

14 X 15% may be more fair Jan 7, 2011 7:22 PM

15 X 15% is better Jan 7, 2011 7:25 PM


17 X more time necessary Jan 7, 2011 7:32 PM

18 X no triggers Jan 7, 2011 7:33 PM

19 X too much for thin stocks Jan 7, 2011 7:35 PM

20 X Daily volatility should play more of a role, but 10% is a good Jan 7, 2011 7:46 PM

rule of thumb.

21 X refer to previous question which refers to sentiment of Jan 7, 2011 7:50 PM

overall market... Thus triggers should be adjusted

22 X YES, however sometimes news comes out on companies Jan 7, 2011 7:51 PM

(pre-market and during market hours) that justifies a 10+%

move ... traders should be rewarded for being aggressive in

accumulating shares during this circumstances ... how do

you differentiate between "fat finger" price moves and

legitimate bid/offer orders?

23 X Takeover announcements where the announced premium Jan 8, 2011 11:33 AM

was significantly above the last price would cause a halt

under these proposed rules...this may not be appropriate

11. Are the proposed SSCB triggers of 20%/20 trading increments in a 5-minute period for TSX-V and CNSX- listed securities appropriate?

Buy Side Sell Side No (please specify)

Trader Trader

1 X s/b the same as TSX Dec 22, 2010 3:40 PM

2 X TOO LOW Dec 22, 2010 3:41 PM

3 X The trigger should be based on a function of historical Dec 22, 2010 3:42 PM

volatility


5 X keep it consistent at 10% Dec 22, 2010 3:56 PM

6 X should also depend on liquidity as per previous question Dec 22, 2010 4:18 PM

7 X see previous comments Dec 22, 2010 5:27 PM

8 X Too wide Dec 22, 2010 6:55 PM

9 X Historical volatility for a particular security would provide the Dec 22, 2010 7:17 PM

most accurate SSCB trigger point

10 X should be the same Dec 23, 2010 3:20 PM

11 X should be same as #9..10%/10 Dec 29, 2010 8:32 PM

12 X Not in favor of any sscb Dec 29, 2010 11:21 PM

13 X Should be a function of liquidity as well, due to the illiquid Dec 31, 2010 3:44 PM

nature of the stocks and the large bid ask spreads.

14 X too simple, will result in too many unnecessary halts. Jan 4, 2011 3:58 PM

15 X wider Jan 7, 2011 1:57 PM

16 X 10% fine Jan 7, 2011 7:25 PM

17 X I think 10%/10 could apply here as well Jan 7, 2011 7:27 PM


19 X should be the same as TSX Jan 7, 2011 7:28 PM

20 X more time Jan 7, 2011 7:32 PM

21 X SSCB's should be the same for all securities Jan 7, 2011 7:45 PM

22 X Daily volatility should play more of a role, 15% maybe more Jan 7, 2011 7:46 PM

practical as a rule of thumb.

23 X refer to previous question which refers to sentiment of Jan 7, 2011 7:50 PM

overall market... Thus triggers should be adjusted

24 X see above Jan 7, 2011 7:51 PM

25 X same as above Jan 8, 2011 11:33 AM

12. IIROC proposes comparing each trade price of a security on a Canadian marketplace to a reference price. The reference price will be any transaction in that security in the five-minute period immediately preceding the potential "triggering" trade (generally establishing a "high" or "low" price during the relevant five-minute period). Is it appropriate to consider all executions (including dark executions) that occur within the NBBO (National Best Bid and Offer) during a 5-minute time period (or any other proposed time period) for the purpose of calculating trigger prices for SSCBs? Buy Side Sell Side No (please specify)

Trader Trader

1 X Not in favour of SSCBs. Traders should be responsible for Dec 22, 2010 3:48 PM

their actions, and establishing good practices will help

alleviate the perceived problem.

2 X for the reason provided before Dec 22, 2010 3:50 PM

3 X Special Block Trades Dec 29, 2010 8:35 PM

4 X omit dark unless that specific dark pool has demonstrated Dec 30, 2010 3:18 PM

reasonable liquidity


6 X leave dark pools out of everything Jan 7, 2011 7:36 PM

7 X dark executions should not be considered Jan 7, 2011 7:54 PM

8 X Exclude dark executions Jan 10, 2011 4:27 PM

13. Is it appropriate to consider bids and offers for the purpose of calculating a SSCB where a security has not traded during the previous 5-minute period (or any other proposed time period)? Buy Side Sell Side Other (please specify)

Trader Trader


2 X with a limit up/down concept it makes sense to impose Dec 22, 2010 3:50 PM

min/max offers and bids

3 X a security can move without trading and legitmate price Dec 22, 2010 5:29 PM

action

4 X last trade should be referenced then Jan 7, 2011 7:34 PM

5 X Good question, mostly for the Juniors where there's Jan 10, 2011 1:07 PM

traditionally less liquidity and larger spreads. The 20%

should account for it, so I think only outliers should be

considered.

14. Regarding the duration of a trading halts (execution halt or price movement halt) for SSCBs, it is impossible to enumerate an exhaustive list of possible answers. We have provided a few examples, but please ensure to indicate a different answer if you wish to do so in the space provided: (Please note that if you do not agree with execution halts, preferring other options such as a Limit Up/Limit Down approach, this is not relevant to this question. Please indicate your opinion on the time involved for a halt in executions or price movement) Buy Side Sell Side Other (please specify)

Trader Trader


2 X na Dec 22, 2010 3:50 PM

3 X Halt should be in place until due dilligence is done, due to Dec 22, 2010 3:51 PM

US interlisted etc.

4 X limit up/down preferred Dec 22, 2010 5:30 PM

5 X 5 minutes is too long. I would suggest 1 min. Dec 23, 2010 2:59 PM

6 X prefer combo of limit up/limit down. Dec 30, 2010 2:18 PM

7 X Simple Rule 10- min across the board Jan 7, 2011 6:04 PM

8 X no halts Jan 7, 2011 7:34 PM

9 X more time needed for both Jan 7, 2011 7:35 PM

10 X I like answer 3, but think 5 and 10 minutes maybe too long. Jan 7, 2011 7:56 PM

Maybe 2 and 5 minutes, but extended if the prices do not

appear to be adjusting.

15. Please choose a trading hour time frame you believe to be appropriate for SSCBs: Buy Side Sell Side Other (please specify)

Trader Trader

1 X I certainly believe in letting the opening rotation take place, Dec 22, 2010 3:45 PM

and would feel better with a time closer to the opening, but

on the back end I think we have to move monitoring closer

to the close.


3 X as short a time frame as possible. Dec 22, 2010 3:50 PM

4 X 9:45 - 3:40 .... market should be able to react accordingly to Jan 7, 2011 7:56 PM

information impacting stocks overnight and therefore the

open plus 15 minutes is plenty of time. However, there was

a situation last week where a corporate action on PBG had

changed the closing value of the stock, but I believe the

exchanges had not corrected the previous closing price so

investors were buying a stock they thought was cheap (pre-

market) when in fact it was up over 10%. Prices were later

adjusted. Same with the close, investors have 20 minutes

to react and trade around MOC imbalances. Unless some

corporate action halts the stock, it is important for stocks to

close where the market allows.

16. Should any trade which executes subsequent to a SSCB trigger and the time IIROC issues a halt (execution halt or price movement halt) be repriced to the price which triggered the SSCB? Buy Side Sell Side Other (please specify)

Trader Trader


2 X no they should not be allowed to trade, and if they do they Dec 22, 2010 3:51 PM

should be allowed to stand

3 X Why would there be a delay? Dec 29, 2010 8:37 PM

4 X this should not be allowed to happen. IIROC and the Dec 30, 2010 2:20 PM

marketplaces should be the first line of defense for this and

not the 3rd in some combination of

participants/regulator/marketplace

5 X good question - I suppose each circumstance is different. Jan 7, 2011 9:49 PM

17. Should SSCBs be implemented in phases? Buy Side Sell Side Other (please specify)

Trader Trader


2 X No opinion Dec 29, 2010 8:37 PM

3 X either or Jan 7, 2011 7:57 PM

4 X TSX phase 1 Jan 7, 2011 7:59 PM

TSX V Phase 2 etc

18. IIROC specifies special circumstances under which SSCBs should not be triggered. Please indicate any circumstances which you agree with and propose any other circumstances which you believe would be appropriate: Buy Side Sell Side Other (please specify)

Trader Trader


2 X If the SSCB are market relative (market down 10%, SSCB Jan 7, 2011 8:03 PM

should be adjusted down as well), then market wide circuit

breakers shouldn't impact anyway.

The stock should be able to halt more than once, but the

trigger point should obviously be reset.

After regulatory halt there should be a set time period for the

market to adjust before the SSCB kicks in (30 minutes or an

hour).

19. Are you concerned that there may be unintended negative consequences with the single stock circuit breakers (SSCBs) proposed by IIROC?

Buy Side Sell Side Yes (please specify)

Trader Trader

1 X Concerned about interlisted trading in US mkts when the Dec 22, 2010 3:51 PM

breaker is invoked in Canada

2 X There is an implicit imposition of maximum bid/ask spreads Dec 22, 2010 3:52 PM

on stocks. Liquidity is a function of supply and demand.

There is a possibility that one may not be able to buy or sell

a certain security because of SSCB parameters, in spite of

one's genuine desire to do so.

3 X a simple market structure with predictable behaviour is best. Dec 22, 2010 3:53 PM

i.e a continuous limit order book. the next best thing is

imposing limit up/limit down prices that are easy to calculate

and are clearly disseminated. Any mechanism that is more

complicated will definitely have unintended negative

consequences.

4 X too many halts freezing stocks... ideally scenario should Dec 22, 2010 4:00 PM

have the risk check PRE-trade instead of post.

5 X gaming Dec 22, 2010 5:33 PM

6 X Trading in Index Products (eg XIUs) may be an inderiect Dec 29, 2010 8:39 PM

way to trade a halterd stock and therefore trade in an

unexpected way.

7 X Traders should be allowed to trade at any price the market Dec 29, 2010 11:36 PM

will bear in a free market economy

8 X Putting the onus on dealers first and then regulators and Dec 30, 2010 2:21 PM

exchanges is not the right approach and will lead to

problems, just like we had with trade throughs.

9 X But the only way to find them is to implement and then Dec 30, 2010 3:23 PM

address them as they come up.

10 X it would be better to have pretrade controls in @ the Dec 30, 2010 4:14 PM

exchanges that all follow identical rules.

11 X * IIROC has to be mindful of company press releases (would Dec 31, 2010 3:53 PM

impose more trading halts by the corporations)

* Only one SSCB per day should apply.

* M&A peer performance could be impacted. (i.e. we see

peers move higher/lower on the basis of an aquisition

announcement; refer to GCE.TO performance when Walter

Energy announced its intention to buy WTN.TO).

12 X policies affecting US inter-listed names are always a Jan 4, 2011 6:20 PM

concern when crafting such rules.

13 X during volitle days. monitoring multiple securities that have Jan 7, 2011 2:01 PM

halted (i.e. waiting for un-halt for each) will become

extreemly difficult as times will be different)

14 X Gaming around trigger points, re-pricing if trades post Jan 7, 2011 6:09 PM

SSCB's are deemed good. 2) Stocks unable to fully reflect

material market pricing - ie legitimate price moves.

15 X it may create more speculative trading as the mkt tries to Jan 7, 2011 7:36 PM

assume why their was a circuit breaker halt

19. Are you concerned that there may be unintended negative consequences with the single stock circuit breakers (SSCBs) proposed by IIROC? (CONTINUED) Buy Side Sell Side Yes (please specify)

Trader Trader

16 X All halts go against a free market....... by halting a stock it Jan 7, 2011 7:44 PM

now becomes a target for anyone who wasn't watching that

name........if it traded down hard causing a short halt which

will followed by more people pouncing on it as it reopens

thereby creating a vicious down cycle on thinly traded

names at least.

17 X -Can they be gamed? Have they been back tested? Can it Jan 7, 2011 7:59 PM

be pilot tested?

18 X a Jan 7, 2011 8:14 PM

19 X . Jan 7, 2011 8:26 PM

20 X We need to match up with the US model for consitency Jan 7, 2011 9:35 PM

w/interlisted

21 X However; we have no choice. It is worth a trial to see how it Jan 7, 2011 9:51 PM

is accepted.

22 X unknown Jan 10, 2011 5:36 PM

Documents

CSTA - TIC - Jan 2011 Circuit Breakers - Results · 2012. 5. 22. · CSTA Trading Issues Survey Implementation of Single Stock Circuit Breakers January 2011 . 2. Please choose the