LAKE SHORE GOLD CORP 6.25 PCT DEBS T.LSG.DB

My experience with IIROC and OSC re ATH two weeks ago

[stock123]

Some of you might be interested in my experience dealing with IIROC and the OSC two weeks ago re ATH. I posted the following on ATH's message board on January 28, 2016: On January 21, I felt that the trading activity in ATH's stock smelled fishy. So, I decided to contact the IIROC on January 21 and the OSC on January 22 to bring the matter to their attention. Both the IIROC and the OSC were of the view that there was nothing unusual in the trading of ATH's stock and both therefore decided to do nothing. Last night, it looks like the pile of dung from which the foul smell was emanating last week may have been found. I wonder if the IIROC and the OSC will now open an investigation or close their eyes again and go back to sleep. Maybe their noses need to be put directly into the pile of dung before they will decide to do anything. Unfortunately, based on my experience, observations and limited dealings with both organizations, I wouldn't count on either of them, or any other regulatory bodies for that matter, to clean-up the mess. Like I posted last week, the situation surrounding the trading activity in ATH's stock on January 21 looks and smells like another possible case of illegal insider trading that will probably go unpunished. No wonder so many investors think that Canadian stock markets are run by scammers and that our regulators, including the IIROC, OSC, ASC, IIROC, TSX, etc. are truly incompetent. I contacted the IIROC (1877-442-4322) in the afternoon of January 21 to ask them why they were not halting ATH and requiring ATH to issue a statement to explain the unusual trading volume, which was 10x the average daily volume. I spoke with Gary Hickey, a Senior Complaints and Inquiries Specialist at IIROC. He asked me to send them my complaint by email, which I did before the close of the markets on January 21. The next day I was contacted by Debra Haggerty, another Senior Complaints and Inquiries Specialist at IIROC. Haggerty said that IIROC had decided a trade halt against ATH was not justified on January 21 because the trading volume in ATH was not unusual high when compared to the trading volume in other stocks on that day. Haggerty claimed that most stocks had abnormally high trading volume on January 21 and many traded 10x their average trading volume. I told Haggerty her claims were not supported by facts and IIRO's decision made absolutely no sense. When I asked Haggerty to name stocks other than ATH that had traded 10x their average trading volume on January 21, she refused to do so, probably because she couldn't name any. As an example, I pointed to Haggerty that Canadian Oil Sands (COS), a company similar in size and market cap to ATH had traded only 1.5x its average daily trading volume on January 21. I pointed to Haggerty that there were many past instances where IIROC had imposed trading halts on stocks even though the unusual trading volume was a lot less than 10x their daily average. Haggerty was unable to provide a sound rationale for IIROC's inconsistent decisions in those other cases. I told Haggerty that IIROC's behavior and actions seemed arbitrary and left a really bad taste in the mouths of small retail investors who, when a stock is displaying highly unusual trading activity, often do not have the resources and connections needed to determine the reason behind the activity. Haggerty and I argued back and forth for several minutes but Haggerty kept making the same unfounded claims. In my view, whatever IIROC's role may be, it clearly does not appear to include ensuring a level playing field and the protection of small investors. On January 22, I contacted the OSC (1-877-785-1555) to bring this matter to their attention. I spoke to David Dorego, Legal Inquiries Officer. Dorego was of the view that there was no reason for the OSC to intervene or launch an investigation into the matter. At a minimum, on January 21, the IIROC should have halted ATH's stock and required ATH's management to issue a statement in response to the unusual trading activity. I would not be surprised at all if leaks about the JV deals announced by ATH last night were behind the unusual trading activity that occurred in the stock last week. Even if my assumption were wrong, at the very least, IIROC's should have asked ATH to issue a release stating that ATH was unaware of any non-public material information to explain the unusual trading activity. There are many past instances where the IIROC's has imposed a trading halt on a stock, where the unusual trading activity was not as obvious as it was last week in ATH's stock. Why did the IIROC decide not to act?

[peep2]

Stock123, good try and very informative. Thanks!

[silver300]

stock123, in my opinion (I was in the industry) the hidden purpose of the OSC is to protect the industry, not the public. It appears to protect the public at times however it does so as a by-product of protecting the industry.