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within Intellectual Property, Food, Drugs, Healthcare, Life Sciences and International Law topic(s)
A broker-dealer settled FINRA charges for deficient Order
Audit Trail System ("OATS") reports and Regulation NMS
quarterly order routing disclosures.
According to FINRA, the firm failed to identify "Not
Held" orders (i.e., orders for which the firm had
price and time discretion) on certain OATS reports. The firm also
failed to report, as required by
Rule 606 of Regulation NMS ("Disclosure of order routing
information") and
FINRA Rule 2010, "the material aspects of the firm's
relationship with certain venues to which it routed non-directed
orders for execution, including any arrangements for payment for
order flow and any profit-sharing relationship." FINRA also
charged the firm with related supervisory violations.
To settle the charges, the firm agreed to (i) censure and (ii) a
fine of $90,000.
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