Actually, volatility is lower in the close-to-open vs open-to-close periods, while the drift is higher (for SPY since inception, for example):
'c2o' : { 'sd': 0.00620, 'mean': 0.00032 }
'o2c' : { 'sd' : 0.00972, 'mean': -0.00003 }
So it is kinda a real alpha, but it's so thin that it's not...