ARTICLE
1 June 2021

Firm Settles NYSE Arca Charges For Order Control Supervisory Failures

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 firm settled NYSE Arca charges for failing to maintain sufficient erroneous order controls and related written supervisory procedures.
United States Finance and Banking

A firm settled NYSE Arca charges for failing to maintain sufficient erroneous order controls and related written supervisory procedures ("WSPs").

In a Letter of Acceptance, Waiver and Consent, NYSE Arca alleged that the firm failed to:

  • maintain a hard-block price control, which enabled an erroneous order to go through;
  • provide NYSE Arca with an explanation as to why it chose its control settings and how they were reasonable, given the firm's trading activity;
  • implement written supervisory procedures with respect to intraday customer credit limit changes;
  • sufficiently document justifications for intraday changes to customer credit limits; and
  • include in its WSPs details as to how it conducts its annual SEA Rule 15c3-5 ("Risk Management Controls for Brokers or Dealers with Market Access") controls and procedures review process.

As a result of its findings, NYSE Arca determined that the firm violated SEA Rules 15c3-5(c) and (e), and NYSE Arca Rule 11.18 ("Supervision").

To settle the charges, the firm agreed to (i) a censure and (ii) a $40,000 fine.

Primary Sources

  1. NYSE Arca AWC: JonesTrading Institutional Services LLC

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