Fines & Wines

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 obligation
• Written 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 plan

FINRA Guidance on Supervision Topics

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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 discussed in this episode are listed below:

• Best Execution Case #1
• Best Execution Case #2
• Best Execution Case #3
• Fair Pricing Case #4
• Fair Pricing Case #5
• Reasonableness of Compensation Case #6
• Reasonableness of Compensation Case #7

Enjoy!

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$675,000 fine for issues related to TRACE Trade Reporting.

• Let’s start a book club! The ladies are currently reading the Bond King by Mary Childs and had a fangirl moment when she acknowledges them on Linkedin
• Kat and Jesy are on a quest for a good box wine
• Itemized TRACE Issues (It’s a lot)
  
  • Late Trades
  • No Remuneration Indicator
  • Non-member Affiliate trade reports
  • Factored corporate bonds
  • Supervision
  • Major theme: Systemic Issues
• Make sure you are supervising rejected trades
• How inclusive is your supervisory reviews?

Read the AWC here.
www.tradeliance.com
TRADEliance consultants have the knowledge and first hand experience to improve your firm's trading operations or compliance processes.
https://www.buymeacoffee.com/finesandwines

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Introduction to Fines and Wines

Meet Jesy LeBlanc and Kat Miller, the founders of TRADEliance. This brief episode shares how Jesy and Kat met and their passion for talking about financial regulation while drinking wine.

TRADEliance is a consulting firm for broker dealer and investment adviser firms in the areas of trading operations and compliance.
www.tradeliance.com

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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 include:
  • Trade Confirmations
  • Recordkeeping
  • 605/606
  • TRACE Trade Reporting
  • LOPR
  • Private Placements
  • Reg Sho
  • Best Ex
  • Market Orders for New Issues in the Secondary Market
  • Marking to Market Surveillance
  • CAT
  • Oversubscription of Partial Tender Offers

For information on any of the cases discussed, contact [email protected]

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