Broker-Dealer Settles OATS Reporting and Regulation NMS Violations

A broker-dealer agreed to settle FINRA charges for Order Audit Trail System ("OATS") reporting and Regulation NMS violations.

According to the Letter of Acceptance, Waiver and Consent, the firm:

• failed to include an information barrier identifier in relevant OATS reports to indicate that the firm relied on information barriers to comply with restrictions on trading ahead of relevant customer orders;

• failed to submit certain execution reports to OATS; and

• improperly routed an "intermarket sweep order to a covered exchange priced outside of a least one protected quotation without simultaneously routing additional limit orders to execute against the full displayed size of any protected bid."

To settle the charges, the firm agreed to a censure and to a fine of $170,000 for all of the rule violations.