ARTICLE
14 February 2020

CME Sanctions Firm Settles Charges Of OATS And Regulation NMS Reporting DeficienciesTrader For Disruptive Trading Practices

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
A broker-dealer settled FINRA charges for deficient Order Audit Trail System ("OATS") reports and Regulation NMS quarterly order routing disclosures.
United States Finance and Banking

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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