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ARTICLE · 21 JUNE 2021

Firm Settles FINRA Charges For Best Execution And Supervisory Failures

Hogan Lovells Cadwalader
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A firm settled FINRA charges for failing to ensure the best execution of its customers' over-the-counter orders and related deficiencies in its supervisory system.

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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A firm settled FINRA charges for failing to ensure the best execution of its customers' over-the-counter ("OTC") orders and related deficiencies in its supervisory system.

In a Letter of Acceptance, Waiver and Consent, FINRA found that the firm had a manual process for comparing customer executions with prices available at the same time through messages in an inter-dealer quotation system. FINRA concluded that the firm did not (i) take reasonable steps to execute against the market-maker's quotation within 30 seconds following its receipt of a customer's order, resulting in orders that were not promptly handled, or (ii) as a result of technology failures, promptly display customer orders.

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