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ARTICLE · 01 JUNE 2021

Firm Settles NYSE Arca Charges For Order Control Supervisory Failures

Hogan Lovells Cadwalader
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A firm settled NYSE Arca charges for failing to maintain sufficient erroneous order controls and related written supervisory procedures.

United StatesFinance and Banking

A firm settled NYSE Arca charges for failing to maintain sufficient erroneous order controls and related written supervisory procedures ("WSPs").

In a Letter of Acceptance, Waiver and Consent, NYSE Arca alleged that the firm failed to:

  • maintain a hard-block price control, which enabled an erroneous order to go through;
  • provide NYSE Arca with an explanation as to why it chose its control settings and how they were reasonable, given the firm's trading activity;
  • implement written supervisory procedures with respect to intraday customer credit limit changes;
  • sufficiently document justifications for intraday changes to customer credit limits; and
  • include in its WSPs details as to how it conducts its annual SEA Rule 15c3-5 ("Risk Management Controls for Brokers or Dealers with Market Access") controls and procedures review process.

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