ARTICLE
27 April 2021

Firm Settles FINRA Charges For Mishandling Customer Limit Orders

CW
Cadwalader, Wickersham & Taft LLP
Contributor
Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
A firm settled FINRA charges for failing to immediately display customer limit orders, and for related supervisory violations.
United States Finance and Banking
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A firm settled FINRA charges for failing to immediately display customer limit orders and for related supervisory violations.

In a Letter of Acceptance, Waiver, and Consent, FINRA found that the firm manually reviewed some of its order flow, resulting in delays that caused the firm to not "fully and immediately display, route, execute, or cancel" orders. As a result, FINRA found that the firm violated FINRA Rule 6460 ("Display of Customer Limit Orders").

Further, FINRA found that the firm's supervisory reviews violated FINRA Rule 3110 ("Supervision") as the reviews:

  • focused only on whether an exception would be financially disadvantageous to a client instead of whether the exception violated FINRA Rule 6460; and
  • assessed amended orders for compliance based on the time of the amendment's acceptance and not the time of the request.

The above conduct also constituted a violation of FINRA Rule 2010 ("Standards of Commercial Honor and Principles of Trade").

To settle the charges, the firm agreed to (i) a censure and (ii) a $45,000 fine ($35,000 for violations of Rules 6460 and 2010, and $10,000 for violations of Rule 3110).

Primary Sources

  1. FINRA AWC: Maxim Group LLC

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

ARTICLE
27 April 2021

Firm Settles FINRA Charges For Mishandling Customer Limit Orders

United States Finance and Banking
Contributor
Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
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