BMO Financial Group reported on Friday that mark-to-market commodity trading losses estimated at between $350 million and $450 million, pre-tax, will be recorded in the second quarter of its 2007 fiscal year.

The impact of this to BMO Financial Group’s second quarter earnings, which will be announced on May 23, is estimated in the range of 45¢-55¢ a share.

A number of factors contributed to these mark-to-market commodity trading losses. During the quarter, positions held by BMO in the energy market, primarily for natural gas, were negatively impacted by changes in market conditions. In particular, the market became increasingly illiquid and volatility dropped to historically low levels. In conjunction with this, there was a refinement in BMO’s approach to estimating the market value of this portfolio.

“The commodity trading losses were the result of decisions that did not adequately recognize the vulnerability of the portfolio to changes in market volatility,” said Bill Downe, president and CEO of BMO Financial Group. “We are conducting a thorough review and actions have been taken to address the current situation and reduce the likelihood of a recurrence. The commodity trading losses are particularly disappointing as our company continues to experience good operating momentum. We remain committed to providing the high level of service that our clients in the energy sector have come to expect from BMO Capital Markets.”

BMO will continue to reposition this portfolio to a lower and sustainable level, consistent with maintaining its core business of serving its energy client franchise. Going forward, the value of this portfolio will be subject to market conditions.

It is possible that as this portfolio is repositioned it could experience subsequent gains or losses depending on future market conditions. However, BMO’s expectation is that, even using adverse assumptions, any losses would be in a substantially lower range than those announced today.

BMO also said that its Tier 1 capital ratio at the end of the first quarter was 9.90% and the impact of these losses will be less than 20 basis points on that ratio. As a result this loss does not impair the ability of the company to pursue its strategic agenda.

On news that BMO would record the $350 million to $450 million trading loss, UBS Securities Canada Inc. says that this adds to a growing list of questions about the bank’s strategy.

UBS says it expects the stock to trade down, but that it should find support. “Stock will likely re-rate to a lower multiple relative to the group as concerns about management/oversight/strategy are raised,” it says, adding that dividend yield (currently at 3.6%) should also offer some support.

UBS notes that the charge reflects the impact of trading losses in commodities from “decisions that did not adequately recognize the vulnerability of the portfolio to changes in market volatility.

“On top of operational challenges in the domestic retail operations and a challenging operating environment and a shifting landscape for BMO’s U.S. retail strategy, we think this raises significant questions about BMO’s trading business/strategy and general risk oversight and management,” UBS adds.

There was a conference call for Bill Downe; Karen Maidment, chief financial and administrative officer; Yvan Bourdeau, CEO, BMO Capital Markets and head of investment banking group; and Bob McGlashan, chief risk officer, BMO Financial Group, to comment on this announcement and to respond to questions from the investor community on Friday from 9 a.m. to 9:30 a.m.

A replay of the conference call can be accessed until May 11 by calling 416-695-5275 (from within Toronto) or 1-888-509-0081 (toll-free outside Toronto) and entering passcode 643819 followed by the number sign.

A live Webcast of the call can be accessed on BMO Financial Group’s Web site. A replay can be accessed on the site until Thursday, July 12.