- within Intellectual Property, International Law, Litigation and Mediation & Arbitration topic(s)
A firm settled FINRA charges for failing to submit accurate trade information to the Order Audit Trail System ("OATS") and the Over-the-Counter Reporting Facility ("OTCRF").
In a Letter of Acceptance, Waiver and Consent, FINRA found that the firm submitted reports to the OATS that contained inaccurate account type codes and order-received timestamps, in violation of FINRA Rules 7450(a) ("General Requirement") and 2010 ("Standards of Commercial Honor and Principles of Trade"). Additionally, FINRA found that the firm failed to include the riskless portion of the riskless-principal transactions in reports submitted to the OTCRF, in violation of FINRA Rule 6622(d)(3)(B) ("Reporting Principal and Riskless Principal Transactions - Exception"). The firm attributed all of the violations to its adoption of a new order management system.
To settle the charges, the firm agreed to (i) a censure and (ii) a $30,000 total fine, composed of a $16,000 fine for its violation of FINRA Rules 7450 and 2010, and a $14,000 fine for its violation of FINRA Rule 6622.
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