October 2017 - Mediant

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October 1, 2017

IN THIS ISSUE Take Action Now ................................................................................................................................ 2 SEC Implements Enforcement Initiatives to Combat Cyber-Based Threats .......................................... 3 FINRA Delays Implementation Date for New Margin Requirements ..................................................... 3 NASDAQ Enhances Closing Cross ...................................................................................................... 3 NYSE Delays Implementation of Advance-Notice Requirement ........................................................... 4 NYSE American Enhances Price Protections to ECOs ......................................................................... 4 NYSE American Proposes ECO Trading Modifications ........................................................................ 4 NYSE American Amends Risk Limitation Mechanism........................................................................... 5 NYSE American Adopts Theoretical Price Methodology ....................................................................... 5 NYSE American Updates and Clarifies Its Options Rules ..................................................................... 5 MSRB Proposes Clarification of CUSIP Rules ...................................................................................... 6 SEC Chairman Clayton Issues Statement on Cybersecurity ................................................................. 6 Fitzpatrick Named Chief Litigation Counsel .......................................................................................... 7 Butler Named NYRO Associate Regional Director for Examinations .................................................... 7 Notable Enforcement Actions ........................................................................................................... 8

TAKE ACTION NOW

Just in time for the impending 2018 proxy season, the SEC published an interpretive release, and the Staff of the Division of Corporation Finance issued guidance on calculation and presentation of the new CEO pay ratio disclosure requirements. The Staff also issued interpretive guidance on the consistently applied compensation measure (CACM). These publications should prove valuable resources as issuers work through the mathematics of aggregated employment, compensation, and CEO pay ratios, and their presentation. The releases also reflect that new leadership at the SEC is not backing away from the CEO pay ratio rule. Press Release: https://www.sec.gov/news/press-release/2017-172 The SEC interpretive guidance includes discussions on the use of reasonable estimates, assumptions, and methodologies and statistical sampling in identifying the median employee and calculating the median employee’s annual total compensation. SEC Interpretive Guidance: https://www.sec.gov/rules/interp/2017/33-10415.pdf The SEC Staff guidance, which includes examples illustrating how reasonable estimates and statistical methodologies may be used, is intended to assist companies with their compliance efforts and reduce the costs associated with preparing disclosures. Corp. Fin. Staff Guidance – Q&A: https://www.sec.gov/corpfin/announcement/guidance-

calculation-pay-ratio-disclosure Corporation Finance’s updated Compliance and Disclosure Interpretation (CD&I) on Section 128C-Item 402(u) discusses how a registrant that does not use annual total compensation may select another CACM to identify the median employee; prohibits exclusive use of hourly or annual pay rates as CACM; clarifies the time period that may be used when using CACM to identify the median employee; how to account for furloughed employees; and expressly allows registrants to use reasonable estimates. Corp. Fin. CD&I: https://www.sec.gov/divisions/corpfin/guidance/regs-kinterp.htm#128c.01

For more information please contact [email protected]

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Page 2 of 11

SEC IMPLEMENTS ENFORCEMENT INITIATIVES TO COMBAT CYBER-BASED THREATS On September 25, 2017, the SEC announced two new initiatives that will build on its Enforcement Division’s ongoing efforts to address cyber-based threats and protect retail investors. The creation of a Cyber Unit that will focus on targeting cyber-related misconduct and the establishment of a retail strategy task force that will implement initiatives that directly affect retail investors reflect SEC Chairman Jay Clayton’s priorities in these important areas. The Cyber Unit will target cyber-related misconduct, such as: o Market manipulation schemes involving false information spread via electronic and social media o Hacking to obtain material nonpublic information o Violations involving distributed ledger technology and initial coin offerings o Misconduct perpetrated using the dark web o Intrusions into retail brokerage accounts o Cyber-related threats to trading platforms and other critical market infrastructure The unit, which has been in the planning stages for months, complements the Chairman’s initiatives to implement an internal cybersecurity risk profile and create a cybersecurity working group to coordinate information sharing, risk monitoring, and incident response efforts throughout the agency. Press Release: https://www.sec.gov/news/press-release/2017-176 FINRA DELAYS IMPLEMENTATION DATE FOR NEW MARGIN REQUIREMENTS On September 26, 2017, the SEC granted immediate effectiveness to a FINRA proposal to delay, until June 25, 2018, the implementation date of the amendments to FINRA Rule 4210 (Margin Requirements) to establish margin requirements for (1) To Be Announced (TBA) transactions, inclusive of adjustable rate mortgage (ARM) transactions; (2) Specified Pool Transactions; and (3) transactions in Collateralized Mortgage Obligations (CMOs), issued in conformity with a program of an agency or GovernmentSponsored Enterprise (GSE), with forward settlement dates, as defined more fully in the filing. The proposed rule change would not make any changes to FINRA rules. Final Rule: https://www.sec.gov/rules/sro/finra/2017/34-81722.pdf NASDAQ ENHANCES CLOSING CROSS On September 8, 2017, the SEC granted accelerated approval to a Nasdaq proposal to enhance the operation of the Nasdaq Closing Cross by extending the time period during which members may submit LOC Orders, and to make other changes relating to the Nasdaq Closing Cross and the Nasdaq Opening Cross. Final Rule: https://www.sec.gov/rules/sro/nasdaq/2017/34-81556.pdf

Copyright © 2017 Mediant Communications Inc. All Rights Reserved.

Page 3 of 11

NYSE DELAYS IMPLEMENTATION OF ADVANCE-NOTICE REQUIREMENT On September 5, 2017, the SEC granted immediate effectiveness to an NYSE proposal to delay the implementation of its recently approved rule requiring listed companies to provide notice to the Exchange at least 10 minutes before making any public announcement with respect to a dividend or stock distribution in all cases. The new implementation date will be no later than February 1, 2018. Final Rule: https://www.sec.gov/rules/sro/nyse/2017/34-81531.pdf NYSE AMERICAN ENHANCES PRICE PROTECTIONS TO ECOS On September 6, 2017, the SEC granted immediate effectiveness to an NSYE American proposal to adopt Commentary .06 to Rule 980NY to enhance the price protections applicable to Electronic Complex Orders (or ECOs). The Exchange currently provides price protection to ECOs, which is designed to prevent the execution of orders at prices that are priced a certain percentage away from the current market and, therefore, are potentially erroneous. The Exchange is adding additional price protection that would be another check on whether an ECO’s limit price is correctly aligned to the complex strategy and would reject erroneously priced incoming ECOs (the “Reasonability Checks”). As discussed herein, the proposed price protections are materially identical to price protections available on other options exchanges, including Nasdaq ISE, LLC. Final Rule: https://www.sec.gov/rules/sro/nyseamer/2017/34-81537.pdf NYSE AMERICAN PROPOSES ECO TRADING MODIFICATIONS On September 21, 2017, the SEC published for comment an NYSE American proposal to amend Rule 980NY (Electronic Complex Order Trading) to clarify the priority of ECOs and to modify aspects of its Complex Order Auction Process. Rule 980NY sets forth how the Exchange conducts trading of ECOs in its Complex Matching Engine (CME). The Exchange proposes to streamline the rule text describing the execution of ECOs during Core Trading Hours to provide specificity and transparency regarding such order processing, without modifying the substance of such processing. The Exchange also proposes to amend the rules describing how ECOs that are eligible for a COA Process are executed and allocated to clarify the description of current functionality and to provide additional detail regarding order processing. The Exchange also proposes amendments to Rule 980NY to clarify and add transparency to the description of the COA Process. Comments Due: October 18, 2017 Proposed Rule Change: https://www.sec.gov/rules/sro/nyseamer/2017/34-81676.pdf

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Page 4 of 11

NYSE AMERICAN AMENDS RISK LIMITATION MECHANISM On September 25, 2017, the SEC granted immediate effectiveness to an NYSE American proposal to amend Rule 928NY (Risk Limitation Mechanism) to allow certain order types to be excluded from the risk limitation mechanism. Specifically, the Exchange will provide ATP Holders with the option to exclude Immediate-Or-Cancel (IOC) orders from being counted against risk limitation thresholds. Final Rule: https://www.sec.gov/rules/sro/nyseamer/2017/34-81716.pdf NYSE AMERICAN ADOPTS THEORETICAL PRICE METHODOLOGY On September 12, 2017, the SEC granted immediate effectiveness to an NYSE American proposal to amend Rule 975NY, relating to the adjustment and nullification of erroneous transactions, and Rule 953NY, regarding trading halts and suspensions. Among other things, the new rules improve the review of potentially erroneous transactions as well as their subsequent adjustment by creating an objective and universal way to determine Theoretical Price in the event a reliable NBBO is not available. The Exchange’s proposal is based on that of Bats BZX, which the Commission approved in July 2017, and those that the other options exchanges intend to file. Final Rule: https://www.sec.gov/rules/sro/nyseamer/2017/34-81582.pdf NYSE AMERICAN UPDATES AND CLARIFIES ITS OPTIONS RULES On September 21, 2017, the SEC granted immediate effectiveness to an NYSE American proposal to update and amend its options rules to: (1) update its rules governing the verification of compared trades and the reconciliation of uncompared trades, and simultaneously to conform the Exchange’s rules to the rules of NYSE Arca, its affiliated exchange, and to update the cross-references to various internal rules; (2) clarify the definition of Floor Market Maker; (3) replace an outdated reference to the Options Surveillance Department; (4) clarify the definition of Market Maker and to conform the Exchange’s rules to the rules of NYSE Arca; (5) replace the definition of “Professional Customer” with “Qualified Customer” in connection with the limited public business that qualified Floor Brokers and their Floor Clerks may conduct; (6) update the references to the current Order Protection Rule; (7) replace an outdated reference to a required timestamp synchronized to the “NIST Clock” with a reference to the current operative Consolidated Audit Trail (CAT) clock synchronization rule; and (8) conform the Exchange’s rule governing the priority of complex orders in open outcry to its rule governing electronic complex orders. The Exchange purpose for these rule changes is to update its rules, reduce complexity and provide clarification concerning its rules, delete outdated cross-references, and standardize and conform its rules to the rules of its affiliated exchange governing the same subject matter. Final Rule: https://www.sec.gov/rules/sro/nyseamer/2017/34-81670.pdf

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Page 5 of 11

MSRB PROPOSES CLARIFICATION OF CUSIP RULES On September 13, 2017, the SEC published for comment an MSRB proposal to amend MSRB Rule G-34, on CUSIP numbers, new issue, and market information requirements, to more clearly express in the rule language the MSRB’s longstanding interpretation that brokers, dealers and municipal securities dealers (collectively, “dealers”) when acting as a placement agent in a private placement of municipal securities are subject to the CUSIP number requirements under Rule G-34(a); to expand the application of the rule to cover not only dealer municipal advisors but also non-dealer municipal advisors in competitive sales of municipal securities; and to provide an exception from the requirements to apply for CUSIP numbers and to apply for depository eligibility. The MSRB requests that the proposed rule change be effective six months from the date of Commission approval. Comments Due: October 10, 2017 Proposed Rule Change: https://www.sec.gov/rules/sro/msrb/2017/34-81595.pdf SEC CHAIRMAN CLAYTON ISSUES STATEMENT ON CYBERSECURITY On September 20, 2017, SEC Chairman Jay Clayton issued a statement highlighting the importance of cybersecurity to the agency and market participants, and detailing the agency’s approach to cybersecurity as an organization and as a regulatory body. The statement is part of an ongoing assessment of the SEC’s cybersecurity risk profile that Chairman Clayton initiated upon taking office in May. Components of this initiative have included the creation of a senior-level cybersecurity working group to coordinate information sharing, risk monitoring, and incident response efforts throughout the agency. The statement provides an overview of the Commission’s collection and use of data and discusses key cyber risks faced by the agency, including a 2016 intrusion of the Commission’s EDGAR test filing system. In August 2017, the Commission learned that an incident previously detected in 2016 may have provided the basis for illicit gain through trading. Specifically, a software vulnerability in the test filing component of the Commission’s EDGAR system, which was patched promptly after discovery, was exploited and resulted in access to nonpublic information. It is believed the intrusion did not result in unauthorized access to personally identifiable information, jeopardize the operations of the Commission, or result in systemic risk. An internal investigation was commenced immediately at the direction of the Chairman. Press Release: https://www.sec.gov/news/press-release/2017-170 Chair Clayton’s Statement: https://www.sec.gov/news/public-statement/statement-clayton-2017-0920

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Page 6 of 11

FITZPATRICK NAMED CHIEF LITIGATION COUNSEL On September 7, 2017, the SEC announced the leadership of the agency’s trial unit. Bridget Fitzpatrick has been named Chief Litigation Counsel of the SEC and David Gottesman will continue to serve as the agency’s Deputy Chief Litigation Counsel. Since December 2016, Ms. Fitzpatrick and Mr. Gottesman have served as Co-Acting Chief Litigation Counsel. In that role, they were jointly responsible for supervising the trial unit at the agency’s Washington D.C. headquarters as well as coordinating with litigators in the SEC’s 11 regional offices around the country. In her new role, Ms. Fitzpatrick will oversee the agency’s national litigation program and, as Deputy, Mr. Gottesman’s responsibilities will include oversight of all trial lawyers in the SEC’s Washington, D.C., headquarters. Press Release: https://www.sec.gov/news/press-release/2017-161 BUTLER NAMED NYRO ASSOCIATE REGIONAL DIRECTOR FOR EXAMINATIONS On September 20, 2017, the SEC announced that Thomas J. Butler has been named an Associate Regional Director for the Investment Adviser and Investment Company examination program in the agency's New York Regional Office. Mr. Butler is leaving his current position as Director of the SEC's Office of Credit Ratings (OCR), a position he has held since June 2012. Jessica Kane, Director of the SEC's Office of Municipal Securities (OMS), has been appointed to serve as Acting Director of OCR on an interim basis following Mr. Butler's departure. In turn, Rebecca Olsen, Deputy Director of OMS, will serve as Acting Director of that office while Ms. Kane is assigned to OCR. Press Release: https://www.sec.gov/news/press-release/2017-169

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Page 7 of 11

NOTABLE ENFORCEMENT ACTIONS As recent enforcement actions indicate, FINRA continues to impose significant fines for failing to appropriately maintain required books and records stored electronically and for trade reporting errors. In each action, FINRA also finds supervisory failures. Firms should inventory and review all systems and platforms used, and develop detailed supervisory procedures for each category of records and reports to ensure compliance. An AWC was issued in which the firm was censured, fined $1,500,000, and required to conduct a comprehensive review of the adequacy of its relevant policies and procedures (written and otherwise) for failing to maintain electronic brokerage records in non-erasable and non-rewritable format, known as “write once, read many” (WORM), that is intended to prevent the alteration or destruction of broker-dealer records stored electronically. The findings stated that the firm failed to maintain in WORM format brokerage records pivotal to its business, including approximately 86 million records of orders placed by certain of its institutional clients through one business line and approximately 45.5 million records of orders placed by certain of its institutional clients through another business line. The vast majority of these records were unexecuted orders placed by institutional clients through the firm’s alternative trading system (ATS) trading platform. The findings also stated that the firm failed to store separately from the original, duplicate copies of approximately 244.5 million records of orders placed by its customers, records of orders executed by the firm and electronic communications. The findings also included that the firm did not have an audit system as required by Securities Exchange Act of 1934 Rule 17a-4(f)(3) for those records it failed to maintain in WORM format. FINRA found that the firm failed to establish, maintain and enforce WSPs reasonably designed to achieve compliance with Exchange Act Rule 17a-4. Although the firm’s WSPs contained provisions for storing electronic records in WORM format, it failed to adequately enforce these procedures to ensure that all such records were maintained in WORM format. (FINRA Case#2016051821601) http://www.finra.org/sites/default/files/fda_documents/2016051821601_FDA_RB7X3589.pdf An AWC was issued in which the firm was censured, fined $175,000, and required to conduct a comprehensive review of the adequacy of its relevant policies and procedures (written and otherwise). A lower fine was imposed after considering, among other things, the firm’s revenues and financial resources. The firm failed to maintain approximately 10 million electronic brokerdealer records in WORM format. The findings stated that this deficiency affected 22 categories of records spanning many aspects of the firm’s brokerage business, including order tickets, trade confirmations, statements and other transaction-related records. The findings also stated that the firm failed to provide the required 90-day notice to its designated examining authority (FINRA), prior to retaining a vendor to provide electronic storage. The findings also included that the firm did not have an audit system as required by Securities Exchange Act of 1934 Rule 17a-4(f)(3) for those records it failed to maintain in WORM format. (FINRA Case #2016052098301) http://www.finra.org/sites/default/files/fda_documents/2016052098301_FDA_RB7X3583.pdf

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Page 8 of 11

An AWC was issued in which the firm was censured and fined $725,000 for failing to establish, maintain and enforce an adequate supervisory system, including written procedures, concerning the creation and dissemination of consolidated reports. The findings stated that during this time period, the firm made available to its registered representatives two centralized and automated tools, which provided templates for reports that could be used to, among other things, present comprehensive financial information to customers, including outside asset information. The two tools drew information from the firm’s centralized system to populate reports with information regarding assets held at the firm. Due to an unintentional vendor-created design flaw, one of the tools for a time allowed representatives to manually edit assets held at the firm. While the firm used internally approved templates, it did not have any system or written procedures in place reasonably designed to minimize the risk that the reports could contain inaccurate information that potentially could be misused. In addition, although representatives printed the reports and provided them to customers, the firm could track only whether a report was printed. It did not have any system or procedures to track whether reports were provided to customers. Representatives at the firm generated approximately 52 million reports using the two tools. The firm did not have any reasonably designed system or procedures in place to mitigate the risks described in FINRA Regulatory Notice 10-19, nor did it have in place a centralized review process. The firm did not have any policies or procedures to guide its registered representatives regarding the creation and use of the reports, and did not have any guidance regarding how representatives should include outside asset information in the reports, and whether steps should be taken to verify that information before it was included. Further, there were not any procedures or guidance regarding updating the outside information included in the reports, such as how often and with what source materials. Moreover, the firm did not have any ability to determine whether the reports generated by the representatives were actually delivered to customers. (FINRA Case #2016049783001) http://www.finra.org/sites/default/files/fda_documents/2016049783001_FDA_RB7X3595.pdf An AWC was issued in which the firm was censured; fined a total of $2,500,000, of which $1,425,000 is payable to FINRA; and required to address its Large Options Positions Reporting (LOPR) deficiencies and ensure that it has implemented controls and procedures that are reasonably designed to achieve compliance with the applicable rules and regulations. The firm failed to report more than 16,700 OTC options positions in at least approximately 6.8 million instances to the LOPR system, and failed to report an unknown number of intraday positions. The findings stated that the firm failed to report certain OTC options positions in approximately 1.6 million instances to the LOPR due to a failure to aggregate positions for acting in concert purposes in certain customer and firm accounts. The firm failed to report OTC options positions to the LOPR for a potentially significant but an unknown number of instances involving approximately 671,080 rejected records that were not resubmitted to the LOPR. The firm inaccurately reported OTC option positions to the LOPR in at least approximately 12.7 million instances. Specifically, the firm misreported approximately 673,970 options positions in 12,398,780 instances with various formatting issues, which included account names not identifiable; account names truncated; invalid street address; invalid or blank inputs for city, state or zip code; incorrect account type; and

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Page 9 of 11

invalid tax numbers; failed to properly identify and/or mark OTC option positions as acting in concert and erroneously marked at least 282 accounts with oscillating duplicative in concert identifications in the customer range in 259,793 instances; failed to report or underreported OTC options positions in 73,078 instances; over-reported OTC option positions in 15,410 instances; misreported LOPR imbalances in 33 symbols for an aggregate 186 days in an unknown number of positions and instances; and failed to delete positions from the LOPR with incorrect effective dates in an unknown number of positions and instances. The firm effected opening transactions for its proprietary account and for the account of a customer that exceeded the applicable position limit in one OTC option, that ranged from approximately 251 percent to 280 percent over the applicable limit for the security. The firm effected opening transactions for the account of a customer that exceeded the applicable position limit in one OTC option from April 25, 2016, through April 29, 2016, by 2,336 contracts, or .9344 percent. From at least August 2015, the firm effected an opening transaction for the account of a customer that exceeded the applicable position limit in one OTC option on both sides of the market from August 2015 through February 21, 2016, by 15,998 contracts or 64 percent. The findings also stated that the firm failed to establish and maintain an adequate supervisory system, including a system of follow-up and review that was reasonably designed to achieve compliance with the rules governing the reporting of options positions to the LOPR system and compliance with applicable position limits. In addition, the firm’s supervisory system did not include sufficient WSPs to ensure the proper reporting of positions to the LOPR. Prior to April 14, 2011, the WSPs failed to list any supervisory step(s) to be taken to review for the overall accuracy of submissions to the LOPR. Subsequently, the firm’s WSPs failed to list the supervisory step(s) to be taken to review for accounts acting in concert or to review rejected LOPR submissions to ensure that rejected records are resubmitted when required. (FINRA Case #2012031318001) http://www.finra.org/sites/default/files/fda_documents/2012031318001_FDA_JG412509.pdf An AWC was issued in which the firm was censured, fined $150,000, and required to revise its WSPs for failing to report Trade Reporting and Compliance Engine® (TRACE®)-eligible securitized products transactions to TRACE within the time prescribed by FINRA Rule 6730. The findings stated that the firm failed to report TRACE-eligible agency debt securities transactions to TRACE within the time permitted by Rule 6730. The findings also stated that the firm’s supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to certain applicable securities laws and regulations, and/or FINRA rules. Specifically, the firm’s WSPs failed to provide for one or more of the minimum requirements for adequate WSPs related to timely submission of accurate reports to TRACE. (FINRA Case #2015047655501) http://www.finra.org/sites/default/files/fda_documents/2015047655501_FDA_RB7X3579.pdf An AWC was issued in which the firm was censured and fined $110,000 for failing, on certain settlement dates, to report short interest positions, or incorrectly reported short interest positions. The inaccurate short interest reports occurred as a result of a software coding issue that reclassified long positions in certain accounts as short. The findings stated that the firm failed to report some of the short interest positions due to an error by the firm’s stock record department.

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As a result of the error, the firm omitted or dropped securities from its short interest report. Other failures were due to the firm’s incorrect belief that warrants were not reportable. The remaining failures were the result of the firm’s misplaced reliance on a third-party website that indicated certain securities were not active and thus not reportable (non-listed). The findings also stated that the firm’s supervisory system did not provide for supervision reasonably designed to achieve compliance with NASD Rule 3360 and FINRA Rule 4560. (FINRA Case #2014039741201) http://www.finra.org/sites/default/files/fda_documents/2014039741201_FDA_JM992944.pdf An AWC was issued in which the firm was censured and fined $47,500 for failing to include foreignlisted securities in the firm’s short interest reports, from the time it began trading foreign-listed securities in August 2006 until it redressed this omission as of settlement date May 29, 2015. The findings stated that the firm’s supervisory system, including its WSPs, did not provide for supervision reasonably designed to achieve compliance with respect to short interest reporting requirements. (FINRA Case #2015044128801) http://www.finra.org/sites/default/files/fda_documents/2015044128801_FDA_DM932995.pdf An AWC was issued in which the firm was censured, fined $25,000, and required to revise its WSPs for failing to transmit ROEs to OATS on 211 business days. The findings stated that the firm’s supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to certain applicable securities laws and regulations, and/or FINRA rules. (FINRA Case #2016049037401) http://www.finra.org/sites/default/files/fda_documents/2016049037401_FDA_JM992936.pdf

An AWC was issued in which the firm was censured and fined $12,500 for failing to report municipal securities transactions to the real-time transaction reporting system (RTRS). The findings stated that the firm had contracted with its clearing firm to report its municipal securities transactions to the RTRS, with the firm maintaining final responsibility for accurate reporting to the RTRS under MSRB rules. Due to a coding error at the clearing firm, the firm’s municipal securities transactions were not reported to the RTRS. The firm conducted 87 municipal securities transactions during the relevant period but failed to report 13 of the customer trades and the 13 corresponding inventory trades to the RTRS. The findings also stated that the firm failed to establish and enforce a supervisory system reasonably designed to achieve compliance with its trade reporting obligations, in that it failed to enforce its WSPs related to the MSRB trade reporting required by MSRB Rule G-14. (FINRA Case #2016048224701) http://www.finra.org/sites/default/files/fda_documents/2016048224701_FDA_VA702330.pdf An AWC was issued in which the firm was censured and fined $10,000 for failing to transmit Reportable Order Events (ROEs) to the Order Audit Trail System (OATS). The findings stated that the firm’s supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities law and regulations, and FINRA rules, concerning OATS reporting. Specifically, the firm’s supervisory procedures did not provide for all steps that the individual responsible for OATS supervision should take when reviewing rejection repair, out-of-sequence events and late data. (FINRA Case #2016049203601) http://www.finra.org/sites/default/files/fda_documents/2016049203601_FDA_VA702283.pdf

Copyright © 2017 Mediant Communications Inc. All Rights Reserved.

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October 2017 - Mediant

For more information please contact [email protected] October 1, 2017 IN THIS ISSUE Take Action Now ...

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