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27 April 2021

Firm Settles FINRA Charges For Mishandling Customer Limit Orders

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Hogan Lovells Cadwalader

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A firm settled FINRA charges for failing to immediately display customer limit orders, and for related supervisory violations.
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A firm settled FINRA charges for failing to immediately display customer limit orders and for related supervisory violations.

In a Letter of Acceptance, Waiver, and Consent, FINRA found that the firm manually reviewed some of its order flow, resulting in delays that caused the firm to not "fully and immediately display, route, execute, or cancel" orders. As a result, FINRA found that the firm violated FINRA Rule 6460 ("Display of Customer Limit Orders").

Further, FINRA found that the firm's supervisory reviews violated FINRA Rule 3110 ("Supervision") as the reviews:

  • focused only on whether an exception would be financially disadvantageous to a client instead of whether the exception violated FINRA Rule 6460; and
  • assessed amended orders for compliance based on the time of the amendment's acceptance and not the time of the request.

The above conduct also constituted a violation of FINRA Rule 2010 ("Standards of Commercial Honor and Principles of Trade").

To settle the charges, the firm agreed to (i) a censure and (ii) a $45,000 fine ($35,000 for violations of Rules 6460 and 2010, and $10,000 for violations of Rule 3110).

Primary Sources

  1. FINRA AWC: Maxim Group LLC

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