Fines & Wines TRADEliance

This episode focuses on the trends in FINRA Enforcement over the course 2023. TRADEliance discusses a several high level trends before doing a more in depth discussion on two topics: Manipulative Trading and Market Access. Jesy and Kat crack open some mediocre bubbly to celebrate this episode.Firms should take note of conducting thorough testing to prevent and detect system issues.Many of the trends in enforcement also highlight the need for training.Other topics discussed in...

Listen in as TRADEliance discusses considerations for a robust Testing Plan.Drink every time we say testing…. No, not really, don't do that!We encourage firms to create a testing plan that goes beyond a 3120/206-7 testing obligationWritten Supervisory Procedures vs Supervisory Controls Procedures Testing samples should be targeted and random and targeted Think of testing vendors, systems and data as three of the pillars that will support a thorough testing planFINRA Guidance o...

Totals in Fines: Disgorgement: $11,000,000 + Prejudgment Interest $3,375,072, Firm Civil Penalty: $4,400,000, and Adviser Civil Penalty: $600,000Jesy is drinking wine in the laundry room 😊 RulesInvestment Advisers Act Rule 206-2Investment Company Act Section 17(A)1 and 17(A)2Investment Adviser Act uses anti-fraud for Best ExecutionThe Asset Management Company was pricing the bond trades, not the broker dealers Asset Manager prices the executions, executions impact the evaluate...

This episode takes a slightly different approach! Listen in as TRADEliance discusses the difference between best ex, fair pricing and reasonable compensation while highlighting some cases that support these differences. Best Execution: How is the Order Handled ? Fair Pricing: What is the actual price to the client? Reasonable Compensation: What is the BD entitled to charge for that trade? Are you supervising these topics separately? The disciplinary cases...

Listen to Jesy and Kat discuss the 2023 Report on FINRA's Examination and Risk Monitoring Program!We couldn't cover everything in the 75 page report, but we do manage to tackle the following topics: Market Integrity Books and Records Firm Short Positions and Fails to Receive in Municipal SecuritiesReg BICATBest Execution Disclosure of Routing Information Fixed Income Fair Pricing, Fractional Shares and Reg SHO.Also - Jesy is sick and drinking boxed wine, while Ka...

Listen in as TRADEliance brainstorms their comment letter for the Regulation Best Execution Proposal! Topics discussed include: The Antifraud Provisions of the Exchange Act as the mechanism for enforcementConflicted TransactionsImpacts to Introducing BrokersUse of Last Look The need for consistency in definitionsRead the Proposal here.www.tradeliance.comTRADEliance consultants have the knowledge and first hand experience to improve your firm's trading operations or compliance ...