Tantallon,

In my opinion there is no doubt Penson is the buyer for ISM. Below is taken from the First Canada web site. If I am not mistaken, I also believe they are only allowed to use one company and are limited to one house.

First Canada Capital Partners Inc. is a correspondent broker. Securities transaction clearing and settlement services are provided to First Canada and their clients by Penson Financial Services Canada, the country’s largest independent provider of clearing services to the Canadian financial community. Penson Canada is a wholly owned subsidiary of Penson Worldwide, Inc. which has offices in Canada, the United States and Europe.

Penson Canada is governed by the various Provincial Securities Commissions in which they are a member across the country. They are also members of the IIROC (Investment Industry Regulatory Organization of Canada), The Canadian Investors Protection Fund, Toronto Stock Exchange and the Montreal Stock Exchange. They are also a clearing member of the Canadian Depository for Securities, the Depository Trust Company, the Canadian Derivatives Clearing Corporation and FundSERV Inc.

Just for your information if you didn't know, the TSX has put in a temporary exemption until March 31st of 2009 (due to the difficulties in world markets) allowing companies to buy back double the amount of shares on a daily basis than what was in the news release. I believe ISM is allowed 16,300 shares a day; now they are allowed almost 33,000 shares per day buy back. There is also block purchase excemptions up to 200,000 shares in a given week but (not to familiar with how this works)

In any case I think that is why you are seeing Penson averaging 25% of the net shares in any given day.

Best
Nickel77