Open to the Public Investing, Inc.

Open to the Public Investing was fined $500,000 for failing to meet its best execution obligations.

The findings stated that the firm did not conduct reasonable reviews of the execution quality of its customers’ orders.

Further, the firm’s reviews of its customers’ execution quality were limited to reviewing its clearing firm’s quarterly reports prepared pursuant to Rule 606 under the Exchange Act. These reports did not provide any data specific to the firm’s execution quality or the quality of the executions it could have obtained from competing markets.

The findings also stated that the firm failed to establish and maintain a supervisory system, including WSPs, reasonably designed to achieve compliance with its best execution obligations. The firm’s supervisory reviews were not reasonably designed to evaluate whether the firm was meeting its best execution obligations, and its WSPs did not provide any procedures for conducting execution quality reviews. The firm’s WSPs were not tailored to the firm’s business.

The WSPs did not address equity trading, even though the firm only provided equity trading. Instead, the WSPs addressed best execution obligations for fixed-income securities, which the firm did not offer. As such, the procedures did not provide guidance as to how the firm should conduct execution quality reviews for its business.

The findings also included that the firm failed to disclose in writing at account opening or annually thereafter that it received payment for order flow through its routing arrangements.