It is likely this AWC could have been avoided had the firm adequately tested the impact of the technology change on its trading engine. The firm compounded its mistake by failing to carefully evaluate the internal rejection alerts that resulted when the firm’s initial orders were blocked by the firm’s systems. As discussed in the AWC, a contributing factor to this failure was the fact that the firm did not have written policies, procedures, or controls regarding the process and criteria for…
The AWC discussion regarding the firm’s supervisory failures and, in particular, the deficits in the firm’s WSPs highlight the need for procedures that go beyond the general (e.g., confirm that the prevailing market price is fair), as well as the need for appropriate training and supervision. Here the firm’s procedures did not seem to cover how the particular confirmation should have been made.
It also appears that the procedures failed to identify the documents and information…
Amendments to Rule 605 reflect significant changes in the speed and nature of trading NMS securities. Rule 605 was first adopted in the year 2000. Changes were long overdue. As by Commissioner Peirce, the process leading to the adoption of these amendments stretches back to 2010, when the SEC first requested comments on the fitness of Rule 605 to address changes in the marketplace. The fact that amendments were not made for an additional 14 years highlights the difficulty the SEC faces…
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It is likely this AWC could have been avoided had the firm adequately tested the impact of the technology change on its trading engine. The firm compounded its mistake by failing to carefully evaluate the internal rejection alerts that resulted when the firm’s initial orders were blocked by the firm’s systems. As discussed in the AWC, a contributing factor to this failure was the fact that the firm did not have written policies, procedures, or controls regarding the process and criteria for…
The AWC discussion regarding the firm’s supervisory failures and, in particular, the deficits in the firm’s WSPs highlight the need for procedures that go beyond the general (e.g., confirm that the prevailing market price is fair), as well as the need for appropriate training and supervision. Here the firm’s procedures did not seem to cover how the particular confirmation should have been made.
It also appears that the procedures failed to identify the documents and information…
Amendments to Rule 605 reflect significant changes in the speed and nature of trading NMS securities. Rule 605 was first adopted in the year 2000. Changes were long overdue. As by Commissioner Peirce, the process leading to the adoption of these amendments stretches back to 2010, when the SEC first requested comments on the fitness of Rule 605 to address changes in the marketplace. The fact that amendments were not made for an additional 14 years highlights the difficulty the SEC faces…