Tradition Securities and Derivatives LLC

Tradition Securities and Derivatives LLC was fined $140,000 in that it failed to record transmission times and to include the correct exchange of execution on its order tickets.

The findings stated that by recording the incorrect exchanges on its order tickets, the firm created an inaccurate record of the orders.

The findings also stated that the firm failed to establish reasonably designed financial risk management controls and supervisory procedures.

The firms WSPs did not include a review to address the requirement that appropriate surveillance personnel receive immediate post-trade execution reports that result from market access and failed to demonstrate such reports were generated and provided to appropriate surveillance personnel.

In addition, the firm failed to document an annual review of its business activity in connection with market access to assure the overall effectiveness of its risk management controls and supervisory procedures. The firm’s records did not provide the date of the annual review, the individuals involved, or what was reviewed.

Moreover, the firm’s 2020 certification did not state that the Chief Executive Officer (CEO) certified that the firm’s risk management controls and supervisory procedures complied with applicable securities laws, or that the firm conducted such a review.