Best Ex vs. Fair Pricing vs. Reasonable Comp

When Complex Rules Cause Complex Issues

In this episode, TRADEliance founders, Jesy and Kat, review a high-profile enforcement action with a lot to unpack.  So, pour yourself a glass of wine and listen as they discuss:  * Failing to reasonably supervise the firm’s maintenance and reporting of accurate and complete trade, order, and position data such as:    * Blue Sheets.  * Reporting fractional shares to TRF and CAT reporting.  * Mismarking option orders origin code.  * Customer option positions to LOPR.  * The firm's short interest positions. * Executing trades during trading halts and failing to comply with Reg NMS to address extraordinary market volatility. Also, send your recommendations for new wine openers to solutions@tradeliance.com [solutions@tradeliance.com]! Read the FINRA Press Release here [https://www.finra.org/media-center/newsreleases/2025/finra-orders-robinhood-financial-pay-375-million-restitution].   TRADEliance consultants have the practical experience in Trading Operations & Compliance that help you achieve results.  For a free needs assessment, contact solutions@tradeliance.com [solutions@tradeliance.com] Support the show [https://www.buymeacoffee.com/finesandwines] Support the show [https://www.buymeacoffee.com/finesandwines]

Enforcement Trends - Year in Review 2024

The TRADEliance consultants have been hard at work this year, so it has been a while since we were able to make a new episode for you.   In this episode, Jesy and Kat share their observations regarding FINRA enforcement trends for 2024 in the Capital Market space.  Those trends include:   * Founders Jesy and Kat share updates from 2024 * Rule 605 & 606 reports * Market Access * Fixed Income Trade Reporting (TRACE and RTRS) * Best Execution * Trade Confirmations * Prevailing Market Price * Reg SHO * Consolidated Audit Trail (CAT)   So sit back, pour yourself a glass of wine, and listen to us share our take-aways on the 2024 FINRA fines.    Support the show [https://www.buymeacoffee.com/finesandwines]

Enforcement Year in Review 2023

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 solutions@tradeliance.com [solutions@tradeliance.com] Support the show [https://www.buymeacoffee.com/finesandwines]

Testing, Testing and More Testing

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 [https://www.finra.org/rules-guidance/key-topics/supervision/faq ] Support the show [https://www.buymeacoffee.com/finesandwines]

Best Ex vs. Fair Pricing vs. Reasonable Comp

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 [https://www.finra.org/sites/default/files/fda_documents/2014041808601%20Barclays%20Capital%20Inc.%20CRD%2019714%20AWC%20va%20%282022-1667607612759%29.pdf] * Best Execution Case #2 [https://www.finra.org/sites/default/files/fda_documents/2014041813501%20Deutsche%20Bank%20Securities%20Inc.%20CRD%202525%20AWC%20sl%20%282022-1649377217179%29.pdf] * Best Execution Case #3   [https://www.finra.org/sites/default/files/fda_documents/2017054188601%20Aegis%20Capital%20Corp.%20CRD%2015007%20AWC%20jlg%20%282021-1618100403356%29.pdf] * Fair Pricing Case #4 [https://www.finra.org/sites/default/files/fda_documents/2012030738501%203-19206%20%20J.W.%20Korth%20%26%20Company%2C%20LP%20CRD%2026455%20SEC%20Decision%20jlg%20%282022-1651710178997%29.pdf] * Fair Pricing Case #5 [https://www.finra.org/sites/default/files/fda_documents/2016050321201%20The%20GMS%20Group%2C%20LLC%20CRD%208000%20AWC%20sl%20%282021-1616372396281%29.pdf] * Reasonableness of Compensation Case #6  [https://www.finra.org/sites/default/files/fda_documents/2019061634801%20Crescent%20Securities%20Group%2C%20Inc.%20CRD%20114993%20AWC%20gg%20%282022-1666830010932%29.pdf] * Reasonableness of Compensation Case #7  [https://www.finra.org/sites/default/files/fda_documents/2020065107401%20Robert%20W.%20Baird%20%26%20Co.%20Inc.%20CRD%208158%20AWC%20lmp%20%282022-1664670000349%29.pdf] Enjoy! Support the show [https://www.buymeacoffee.com/finesandwines] Support the show [https://www.buymeacoffee.com/finesandwines]