Electronic Transaction Clearing, Inc.
The findings stated that the firm had no supervisory system reasonably designed to check that it was correctly marking sell orders in compliance with Rule 200(g), and its WSPs were unreasonable because they did not describe any procedures for reviewing or testing orders to achieve compliance with order marking requirements.
The firm later implemented a supervisory system whereby it sampled orders for the correct marking of sell orders and updated its WSPs to contain a detailed description of the steps to conduct the review.
The findings also stated that the firm failed to reasonably monitor the orders of customers that used more than one Market Participant Identifier (MPID) to verify that the customers’ positions were aggregated for purposes of marking those orders accurately as required by Rule 200(g).
