gts securities llcfirm profile class a member gts group us llc 75% or more no 10/2018 yes company...

BrokerCheck Report

GTS SECURITIES LLC

Section Title

Report Summary

Firm History

CRD# 149224

1

10

Firm Profile 2 - 9

Page(s)

Firm Operations 11 - 19

Disclosure Events 20

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GTS SECURITIES LLC

CRD# 149224

SEC# 8-68126

Main Office Location

545 MADISON AVENUE15TH FLOORNEW YORK, NY 10022Regulated by FINRA New York Office

Mailing Address

545 MADISON AVENUE15TH FLOORNEW YORK, NY 10022

Business Telephone Number

(212) 715-2830

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 22

Firm Profile

This firm is classified as a limited liability company.

This firm was formed in Delaware on 12/03/2008.

Its fiscal year ends in December.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 4 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm has referral or financial arrangements withother brokers or dealers.

This firm is registered with:

• the SEC• 21 Self-Regulatory Organizations• 1 U.S. state or territory

www.finra.org/brokercheck User Guidance

1©2020 FINRA. All rights reserved. Report about GTS SECURITIES LLC


http://www.finra.org/brokercheck

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This firm is classified as a limited liability company.

This firm was formed in Delaware on 12/03/2008.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in December.

GTS SECURITIES LLC

SEC#

149224

8-68126

Main Office Location

Mailing Address

Business Telephone Number

Doing business as GTS SECURITIES LLC

(212) 715-2830

Regulated by FINRA New York Office



Other Names of this Firm

Name Where is it used

GLOBAL TRADING SYSTEMS DE, NY

GTS MISCHLER DE, NY






This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

GTS FINANCIAL LLC

HOLDING COMPANY/MEMBER

75% or more

No

Domestic Entity

07/2006

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


AIRO, ROBERT

CHIEF OPERATING OFFICER

Less than 5%

No

Individual

04/2020

Yes

1350363



Position


Position Start Date

LIEBERMAN, DAVID ZALMAN

CO-FOUNDER

Less than 5%

Individual

03/2014

2936821








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


ROMANELLO, PATRICK JOSEPH

CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

03/2011

Yes

5378090



Position



Position Start Date


RUBENSTEIN, ARI M

CO-FOUNDER AND CHIEF EXECUTIVE OFFICER

Less than 5%

No

Individual

11/2008

Yes

4134798



TIRIOLO, CHRISTIAN JOHN

3063877







Direct Owners and Executive Officers (continued)

Firm Profile

Position



Position Start Date


FINOP, CHIEF FINANCIAL OFFICER, CHIEF OPERATIONS OFFICER

Less than 5%

No

Individual

12/2008

No

3063877







This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

GTS GROUP US LLC

CLASS A MEMBER

GTS FINANCIAL LLC

75% or more

No

Domestic Entity

01/2009

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established




GTS HOLDINGS GROUP LIMITED

CLASS A MEMBER

GTS INTERNATIONAL LIMITED

75% or more

No

Foreign Entity

10/2018

Yes









GTS INTERNATIONAL LIMITED

GTS GROUP US LLC

Foreign Entity









Indirect Owners (continued)

Firm Profile

CLASS A MEMBER

GTS GROUP US LLC

75% or more

No

10/2018

Yes







GTS MANAGEMENT PARTNERS LLC

MEMBER

LVS PARTNERS LIMITED

75% or more

No

Domestic Entity

07/2019

Yes









LVS PARTNERS LIMITED

CLASS A MEMBER

GTS HOLDINGS GROUP LIMITED

75% or more

Foreign Entity

10/2018






Percentage of Ownership7©2020 FINRA. All rights reserved. Report about GTS SECURITIES LLC






Firm Profile

75% or more

No

Yes




LIEBERMAN, DAVID ZALMAN

MEMBER


25% but less than 50%

No

Individual

11/2008

Yes

2936821









RUBENSTEIN, ARI M

MEMBER


25% but less than 50%

Individual

11/2008

Yes

4134798














Firm Profile

No








Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.






Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.

This firm is currently registered with the SEC, 21 SROs and 1 U.S state or territory.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 02/17/2009

Self-Regulatory Organization Status Date Effective

FINRA Approved 04/23/2014

BOX Exchange LLC Approved 02/11/2020

Cboe BYX Exchange, Inc. Approved 05/01/2012

Cboe BZX Exchange, Inc. Approved 12/17/2013

Cboe C2 Exchange, Inc. Approved 02/25/2020

Cboe EDGA Exchange, Inc. Approved 06/02/2014

Cboe EDGX Exchange, Inc. Approved 06/02/2014

Cboe Exchange, Inc. Approved 11/29/2019

Investors' Exchange LLC Approved 08/08/2016

MIAX PEARL, LLC Approved 02/25/2020

Miami International Securities Exchange,LLC

Approved 02/25/2020

NYSE American LLC Approved 03/26/2015

NYSE Arca, Inc. Approved 10/09/2014

NYSE Chicago, Inc. Approved 01/14/2016

NYSE National, Inc. Approved 10/22/2019






Nasdaq BX, Inc. Approved 05/22/2014

Nasdaq GEMX, LLC Approved 02/20/2020

Nasdaq ISE, LLC Approved 02/20/2020

Nasdaq PHLX LLC Approved 08/06/2015

Nasdaq Stock Market Approved 05/22/2014

New York Stock Exchange Approved 03/26/2015





Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

New York Approved 02/27/2017






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

Other Types of Business

This firm does effect transactions in commodities, commodity futures, or commodity options.This firm does engage in other non-securities business.

Non-Securities Business Description: THE APPLICANT ALSO ENGAGES IN FOREIGN CURRENCY TRADINGFOR ITS OWN ACCOUNT.

This firm currently conducts 4 types of businesses.

Types of Business

Exchange member engaged in floor activities

Broker or dealer retailing corporate equity securities over-the-counter

U S. government securities dealer

Trading securities for own account






Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers.

Name: GOLDMAN SACHS & CO. LLC

Business Address: 200 WEST STREETNEW YORK, NY 10282

CRD #: 361

Effective Date: 06/09/2017

Description: THE FIRM INTRODUCES CUSTOMERS TO GOLDMAN SACHS & CO.






Firm Operations

Industry Arrangements

This firm does not have books or records maintained by a third party.

This firm does have accounts, funds, or securities maintained by a third party.

Name: ABN AMRO CLEARING CHICAGO LLC

Business Address: 175 WEST JACKSON BLVDSTE 2050CHICAGO, IL 60604

CRD #: 14020


Description: MAINTAINS ACCOUNT FOR FIRM.

Name: BNP PARIBAS SECURITIES CORP.

Business Address: 787 SEVENTH AVENUENEW YORK, NY 10019

CRD #: 15794


Description: HOLDS AND CLEARS FX AND FUTURES ACCOUNTS FOR THEAPPLICANT

Name: CANTOR FITZGERALD & CO.

Business Address: 110 EAST 59TH STREET4TH FLOORNEW YORK, NY 10022

CRD #: 134


Description: US TREASURIES ARE CLEARED THROUGH CANTOR FITZGERALD & CO.

Name: GOLDMAN SACHS & CO. LLC

Business Address: 200 WEST STREETNEW YORK, NY 10282

CRD #: 361


Description: TRADES ARE CLEARED THROUGH GOLDMAN SACHS & CO.






Firm Operations

Industry Arrangements (continued)

This firm does not have customer accounts, funds, or securities maintained by a third party.

This firm does have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

Control Persons/Financing

Name: SG AMERICAS SECURITIES, LLC

Business Address: 245 PARK AVENUENEW YORK, NY 10167

CRD #: 128351


Description: TRADES CLEARED THROUGH SG AMERICA SECURITIES, LLC.

Name: E D & F MAN CAPITAL MARKETS INC.

Business Address: 140 EAST 45TH STREET42ND FLOORNEW YORK, NY 10017

CRD #: 161014


Description: FUTURES TRADES ARE CLEARED THROUGH E.D. & F. MANINTERNATIONAL INC.

Name: GTS MANAGEMENT COMPANY, LLC

Business Address: 545 MADISON AVENUE15TH FLOORNEW YORK, NY 10022


Description: GTS MANAGEMENT COMPANY, LLC IS THE NON-MEMBER MANAGER OFTHE APPLICANT UNDER THE LLC OPERATING AGREEMENT.






Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

No

Yes

No

06/26/2020


308066

CLEARLIST LLC is under common control with the firm.

UNDER COMMON CONTROL WITH THE APPLICANT AT THE GTSMANAGEMENT PARTNERS LLC LEVEL.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

No

02/18/2020

40 WALL STREET38TH FLOORNEW YORK, NY 10282

306364

GTS EXECUTION SERVICES LLC is under common control with the firm.

UNDER COMMON CONTROL BY ARI RUBENSTEIN AND DAVID LIEBERMANDescription:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)

UNDER COMMON CONTROL BY ARI RUBENSTEIN AND DAVID LIEBERMANDescription:

No

Yes

UK

Yes

12/29/2015

LEVEL 125 ALDERMANBURY SQUARELONDON, UK EC2V 7HR

GTS SECURITIES EUROPE LTD. is under common control with the firm.

COMMON CONTROL WITH APPLICANTARI M. RUBENSTEINDAVID Z. LIEBERMAN

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

This firm is not directly or indirectly, controlled by the following:

· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank






Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 22 0






Disclosure Event Details

What you should know about reported disclosure events:

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particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:

o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.

4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.

§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently

being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

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or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

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§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.

5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.

Regulatory - Final

This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.

Disclosure 1 of 22

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, GTS SECURITIES LLC("GTS" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THEENTRY OF FINDINGS THAT THE FIRM INCLUDED A FLOOR BROKER'S(FLOOR BROKER 1) ORDERS IN FIVE STOCKS IN THE CLOSING AUCTION,ALTHOUGH VERBAL INTEREST FOR THE ORDERS WERE NOTSUFFICIENTLY EXPRESSED PRIOR TO THE CLOSE OF TRADING, ANDTHEREFORE, FLOOR BROKER I WAS NOT ENTITLED TO PARTICIPATE INTHE CLOSING AUCTION.

THE FINDINGS STATED THAT ACCORDINGLY, THE FIRM VIOLATED NYSERULE 52 THAT PROVIDES THAT "NO MEMBER SHALL MAKE ANY BID, OFFEROR TRANSACTION ON THE EXCHANGE BEFORE OR AFTER" THEEXCHANGE'S HOURS OF BUSINESS, WHICH ENDED AT 4:00 P.M. ONNOVEMBER 30, 2018.

THE FINDINGS ALSO STATED THAT GTS FAILED TO ESTABLISH, MAINTAINAND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORYPROCEDURES ("WSPS") THAT WERE REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH THE NYSE RULES CONCERNING THE CLOSINGAUCTION RELATING TO EXPRESSION OF VERBAL INTEREST.ADDITIONALLY, GTS HAD NO SUPERVISORY SYSTEM OR WSPS IN PLACEDESCRIBING A NYSE EXECUTIVE FLOOR GOVERNOR'S ("EFG") ROLE INCONSULTING ABOUT AN "UNUSUAL SITUATION." IN ADDITION,NOTWITHSTANDING SUCH CONSULTATION, IT REMAINS THE DESIGNATEDMARKET MAKERS' ("DMMS") RESPONSIBILITY TO ENSURE THATCUSTOMER INTEREST IS ENTERED IN COMPLIANCE WITH EXCHANGERULES.

Current Status: Final






Initiated By: NEW YORK STOCK EXCHANGE

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 08/13/2019

Docket/Case Number: 2018-12-00030

Principal Product Type: Other

Other Product Type(s): UNSPECIFIED SECURITIES

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, GTS SECURITIES LLC("GTS" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THEENTRY OF FINDINGS THAT THE FIRM INCLUDED A FLOOR BROKER'S(FLOOR BROKER 1) ORDERS IN FIVE STOCKS IN THE CLOSING AUCTION,ALTHOUGH VERBAL INTEREST FOR THE ORDERS WERE NOTSUFFICIENTLY EXPRESSED PRIOR TO THE CLOSE OF TRADING, ANDTHEREFORE, FLOOR BROKER I WAS NOT ENTITLED TO PARTICIPATE INTHE CLOSING AUCTION.

THE FINDINGS STATED THAT ACCORDINGLY, THE FIRM VIOLATED NYSERULE 52 THAT PROVIDES THAT "NO MEMBER SHALL MAKE ANY BID, OFFEROR TRANSACTION ON THE EXCHANGE BEFORE OR AFTER" THEEXCHANGE'S HOURS OF BUSINESS, WHICH ENDED AT 4:00 P.M. ONNOVEMBER 30, 2018.

THE FINDINGS ALSO STATED THAT GTS FAILED TO ESTABLISH, MAINTAINAND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORYPROCEDURES ("WSPS") THAT WERE REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH THE NYSE RULES CONCERNING THE CLOSINGAUCTION RELATING TO EXPRESSION OF VERBAL INTEREST.ADDITIONALLY, GTS HAD NO SUPERVISORY SYSTEM OR WSPS IN PLACEDESCRIBING A NYSE EXECUTIVE FLOOR GOVERNOR'S ("EFG") ROLE INCONSULTING ABOUT AN "UNUSUAL SITUATION." IN ADDITION,NOTWITHSTANDING SUCH CONSULTATION, IT REMAINS THE DESIGNATEDMARKET MAKERS' ("DMMS") RESPONSIBILITY TO ENSURE THATCUSTOMER INTEREST IS ENTERED IN COMPLIANCE WITH EXCHANGERULES.

Resolution Date: 08/13/2019

Resolution:

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Acceptance, Waiver & Consent(AWC)






Other Sanctions Ordered: UNDERTAKING

Sanction Details: THE FIRM WAS CENSURED AND FINED $75,000.

AN UNDERTAKING BY THE FIRM, REQUIRING IT TO IMPROVE ITS WRITTENSUPERVISORY PROCEDURES ("WSPS") AND SUPERVISORY SYSTEMS ANDREVIEWS TO ADDRESS THE DEFICIENCIES, INCLUDING TO ENSURECOMPLIANCE WITH THE NYSE RULES AND GUIDANCE CONCERNINGEXPRESSION OF VERBAL INTEREST FOR INCLUSION IN THE CLOSINGAUCTION AND A NYSE EXECUTIVE FLOOR GOVERNOR'S ("EFG") ROLE INCONSULTATIONS. WITHIN 90 DAYS OF THE EXECUTION OF THE AWC (ORSUCH OTHER TIME AS MAY BE MUTUALLY AGREED TO WITH NYSEREGULATION STAFF), THE FIRM AGREES TO PROVIDE: (1) A CERTIFICATIONTHAT THE FIRM HAS REVISED ITS WSPS AND SUPERVISORY SYSTEMSAND REVIEWS TO ADDRESS THE DEFICIENCIES; AND (2) THE DATE THEREVISED PROCEDURES WERE IMPLEMENTED.


No

Sanctions Ordered: CensureMonetary/Fine $75,000.00

iReporting Source: Firm

Initiated By: NEW YORK STOCK EXCHANGE LLC



Allegations: GTS INCLUDED FLOOR BROKER'S ORDERS IN FIVE STOCKS IN THECLOSING AUCTION, ALTHOUGH VERBAL INTEREST FOR THE ORDERSWERE NOT SUFFICIENTLY EXPRESSED PRIOR TO THE CLOSE OFTRADING, AND THEREFORE, FLOOR BROKER WAS NOT ENTITLED TOPARTICIPATE IN THE CLOSING AUCTION. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS OR FINDINGS, GTS VIOLATED NYSE RULE 52.GTS FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORYSYSTEM AND WRITTEN SUPERVISORY PROCEDURES THAT WEREREASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE NYSERULES CONCERNING THE CLOSING AUCTION RELATING TO EXPRESSIONOF VERBAL INTEREST. WITHOUT ADMITTING OR DENYING THEALLEGATIONS OR FINDINGS, GTS VIOLATED NYSE RULE 3110(A) AND (B).








Censure


FINE AND UNDERTAKING TO UPDATE WSPS


Principal Product Type: Equity Listed (Common & Preferred Stock)

Other Product Type(s):


Resolution:

Other Sanctions Ordered: UNDERTAKING TO IMPROVE ITS WRITTEN SUPERVISORY PROCEDURES

Sanction Details: FINE OF $75,000.00 PAID TO THE NEW YORK STOCK EXCHANGE.

Firm Statement PLEASE SEE RESPONSE TO QUESTIONS 7 AND 12



Disclosure 2 of 22

i


Initiated By: CBOE BYX EXCHANGE, INC.


Other


Docket/Case Number: 2015046769207

Principal Product Type: Options


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMMISTAKENLY RELIED ON THE CROSSED MARKET EXCEPTION SET FORTHIN SEC RULE 611 (B)(4) RESULTING IN THE FIRM FAILING TO SENDINTERMARKET SWEEP ORDERS (ISOS) TO EXECUTE AGAINST THE FULLDISPLAYED SIZE OF CERTAIN PROTECTED QUOTATIONS. AS A RESULT OFSUCH CONDUCT, THE FIRM FAILED TO TAKE REASONABLE STEPS TOESTABLISH THAT ISOS MET THE REQUIREMENTS OF SEC RULE 600(B)(30)OF REGULATION NMS.








N/A


Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $136,000 TO BE PAIDJOINTLY TO CBOE BYX INC., CBOE BZX EXCHANGE, INC., CBOE EDGAEXCHANGE, INC. AND CBOE EDGX EXCHANGE, INC., OF WHICH $34,000 OFTHAT TOTAL AMOUNT SHALL BE PAID TO BYX.

THE DECISION IN THIS MATTER BECAME FINAL 20 BUSINESS DAYS AFTERTHE ISSUANCE OF THE DECISION. THEREFORE, THIS DECISION BECAMEFINAL FEBRUARY 1, 2019.


No




Initiated By: CBOE BYX EXCHANGE, INC.


Civil and Administrative Penalt(ies) /Fine(s)


CENSURE





Allegations: THE FIRM ALLEGEDLY MISTAKENLY RELIED ON THE SEC RULE 611(B)(4)CROSSED MARKET EXCEPTION, RESULTING IN THE FIRM FAILING TO SENDISOS TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAINPROTECTED QUOTES IN VIOLATION OF SEC RULE 611(C) AND BYX RULES11.9(D)(1) AND 11.9(D).








CENSURE


Resolution:

Other Sanctions Ordered: N/A

Sanction Details: $34,000 PAID TO THE EXCHANGE




Disclosure 3 of 22

i


Initiated By: CBOE EDGX EXCHANGE, INC.


Other


N/A








Resolution:


No








Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $136,000 TO BE PAIDJOINTLY TO CBOE EDGX EXCHANGE, INC., CBOE BZX EXCHANGE, INC.,CBOE BYX INC. AND CBOE EDGA EXCHANGE, INC., OF WHICH $34,000 OFTHAT TOTAL AMOUNT SHALL BE PAID TO EDGX.



No



Initiated By: CBOE EDGX EXCHANGE, INC.




CENSURE





Allegations: THE FIRM ALLEGEDLY MISTAKENLY RELIED ON THE SEC RULE 611(B)(4)CROSSED MARKET EXCEPTION, RESULTING IN THE FIRM FAILING TO SENDISOS TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAINPROTECTED QUOTES IN VIOLATION OF SEC RULE 611(C) AND EDGXRULES 11.5(D)(1).



Resolution:









Sanction Details: $34,000.00 PAID TO THE EXCHANGE



Disclosure 4 of 22

i


Initiated By: CBOE BZX EXCHANGE, INC.


Other


N/A








Resolution:


No









Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $136,000 TO BE PAIDJOINTLY TO CBOE BZX INC., CBOE BYX EXCHANGE, INC., CBOE EDGAEXCHANGE, INC. AND CBOE EDGX EXCHANGE, INC., OF WHICH $34,000 OFTHAT TOTAL AMOUNT SHALL BE PAID TO BZX.




Initiated By: CBOE BZX EXCHANGE, INC




CENSURE


Docket/Case Number: 20150467692-06



Allegations: THE FIRM ALLEGEDLY MISTAKENLY RELIED ON THE SEC RULE 611(B)(4)CROSSED MARKET EXCEPTION, RESULTING IN THE FIRM FAILING TO SENDISOS TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAINPROTECTED QUOTES IN VIOLATION OF SEC RULE 611(C) AND BZX RULES11.9(D)(1) AND 11.9(D).



Resolution:


Sanction Details: $34,000 PAID TO THE EXCHANGE










Disclosure 5 of 22

i


Initiated By: CBOE EDGA EXCHANGE, INC.


Other


N/A








Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $136,000 TO BE PAIDJOINTLY TO CBOE EDGA EXCHANGE, INC., CBOE BZX EXCHANGE, INC.,CBOE BYX INC. AND CBOE EDGX EXCHANGE, INC., OF WHICH $34,000 OFTHAT TOTAL AMOUNT SHALL BE PAID TO EDGA.



No








THE FIRM WAS CENSURED AND FINED A TOTAL OF $136,000 TO BE PAIDJOINTLY TO CBOE EDGA EXCHANGE, INC., CBOE BZX EXCHANGE, INC.,CBOE BYX INC. AND CBOE EDGX EXCHANGE, INC., OF WHICH $34,000 OFTHAT TOTAL AMOUNT SHALL BE PAID TO EDGA.



Initiated By: CBOE EDGA EXCHANGE, INC.




CENSURE





Allegations: THE FIRM ALLEGEDLY MISTAKENLY RELIED ON THE SEC RULE 611(B)(4)CROSSED MARKET EXCEPTION, RESULTING IN THE FIRM FAILING TO SENDISOS TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAINPROTECTED QUOTES IN VIOLATION OF SEC RULE 611(C) AND EDGARULES11.5(D)(1) AND 11.8(C).



Resolution:


Sanction Details: $34,000.00 PAID TO THE EXCHANGE




Disclosure 6 of 22

i








Initiated By: NASDAQ BX, INC.


Other


N/A



Principal Product Type: No Product


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT MISTAKENLYRELIED ON THE CROSSED MARKET EXCEPTION SET FORTH IN SEC RULE611(B)(4). THE FINDINGS STATED THAT THIS RESULTED IN THE FIRMFAILING TO SEND INTERMARKET SWEEP ORDERS (ISOS) TO EXECUTEAGAINST THE FULL DISPLAYED SIZE OF CERTAIN PROTECTEDQUOTATIONS. AS A RESULT OF THE ABOVE CONDUCT, THE FIRM FAILED TOTAKE REASONABLE STEPS TO ESTABLISH THAT ISOS MET THEREQUIREMENTS OF RULE 600(B)(30) OF REGULATION NMS. THE CONDUCTDESCRIBED IN THIS PARAGRAPH CONSTITUTES A VIOLATION OF SECRULE 611(C) OF REGULATION NMS. THE FINDINGS ALSO STATED THATDURING THE SECOND AND THIRD REVIEW PERIODS, THE FIRM FAILED TOREASONABLY AVOID DISPLAYING, AND ENGAGED IN A PATTERN ORPRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED OR CROSSED APROTECTED QUOTATION. THE CONDUCT DESCRIBED IN THIS PARAGRAPHCONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF BX RULE4613(E)(2)(B). THE FINDINGS ALSO INCLUDED THAT DURING THE SECONDREVIEW PERIOD, THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDEFOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH BX RULE 4613(E)(2)(B). SPECIFICALLY, THE FIRM'S SUPERVISORYSYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURESPROVIDING FOR A STATEMENT OF ADEQUATE SUPERVISORY STEPS TOREVIEW FOR CANCELED DIRECTED ISOS. THE CONDUCT DESCRIBED INTHIS PARAGRAPH CONSTITUTES A VIOLATION OF BX RULES 3010 AND2110. IN ADDITION, DURING THE THIRD REVIEW PERIOD, THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH BX RULE4613(E)(2)(B). SPECIFICALLY, THE FIRM'S WRITTEN SUPERVISORYPROCEDURES DID NOT DESCRIBE SUPERVISORY STEPS TO ENSURE THATALL ORDER DATA IS FED INTO THE FIRM'S POST-TRADE COMPLIANCEREVIEW SYSTEM. THE CONDUCT DESCRIBED IN THIS PARAGRAPHCONSTITUTES A VIOLATION OF BX RULES 3010 AND 2110.








Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $97,500.00, $19,500.00 OF WHICH WILLBE PAID DIRECTLY TO NASDAQ BX, THE REST WILL BE SHARED AMONGOTHER EXCHANGES THAT HAD SIMILAR SETTLEMENTS. IN ADDITION, THEFIRM UNDERTAKES TO REVISE ITS WRITTEN SUPERVISORYPROCEDURES.

Regulator Statement THIS SETTLEMENT ALSO INCLUDES INVESTIGATIONS RELATED TOMATTER NOS. 20150468027 AND 20160492958.


No




Initiated By: NASDAQ BX, INC.




CENSURE AND UNDERTAKING TO REVISE THE FIRM'S WSP'S RELATED TOCERTAIN EXCHANGE RULES.





Allegations: THE FIRM ALLEGEDLY MISTAKENLY RELIED ON THE SEC RULE 611(B)(4)CROSSED MARKET EXCEPTION, RESULTING IN THE FIRM FAILING TO SENDISOS TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAINPROTECTED QUOTES IN VIOLATION OF SEC RULE 611(C). THE FIRM ALSOALLEGEDLY FAILED TO REASONABLY AVOID DISPLAYING, AND ENGAGED INA PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED ORCROSSED A PROTECTED QUOTATION IN VIOLATION OF NASDAQ BX RULES4613(E)(2)(B), 2110, AND 3110.










Resolution:

Other Sanctions Ordered: UNDERTAKING TO REVISE THE FIRM'S WSP'S RELATED TO CERTAINEXCHANGE RULES.

Sanction Details: FINE OF 19,500 PAID TO THE EXCHANGE




Disclosure 7 of 22

i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING THEFIRST REVIEW PERIOD, IT MISTAKENLY RELIED ON THE CROSSED MARKETEXCEPTION SET FORTH IN SEC RULE 611(B)(4). THE FINDINGS STATEDTHAT THIS RESULTED IN THE FIRM FAILING TO SEND ISOS TO EXECUTEAGAINST THE FULL DISPLAYED SIZE OF CERTAIN PROTECTEDQUOTATIONS. AS A RESULT OF THE ABOVE CONDUCT, THE FIRM FAILED TOTAKE REASONABLE STEPS TO ESTABLISH THAT ISOS MET THEREQUIREMENTS OF RULE 600(B)(30) OF REGULATION NMS. THE CONDUCTDESCRIBED IN THIS PARAGRAPH CONSTITUTES A VIOLATION OF SECRULE 611(C) OF REGULATION NMS. THE FINDINGS ALSO STATED THATDURING THE SECOND AND THIRD REVIEW PERIODS, THE FIRM FAILED TOREASONABLY AVOID DISPLAYING, AND ENGAGED IN A PATTERN ORPRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED OR CROSSED APROTECTED QUOTATION. THE CONDUCT DESCRIBED IN THIS PARAGRAPHCONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF PSX RULE3213(D)(2)(B). THE FINDINGS ALSO INCLUDED THAT DURING THE SECONDREVIEW PERIOD, THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDEFOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH PSX RULE 3213(D)(2)(B). SPECIFICALLY, THE FIRM'S SUPERVISORYSYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURESPROVIDING FOR A STATEMENT OF ADEQUATE SUPERVISORY STEPS TOREVIEW FOR CANCELED DIRECTED ISOS. THE CONDUCT DESCRIBED INTHIS PARAGRAPH CONSTITUTES A VIOLATION OF PHLX RULES 748 AND707. IN ADDITION, DURING THE THIRD REVIEW PERIOD, THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH PSX RULE3213(D)(2)(B). SPECIFICALLY, THE FIRM'S WRITTEN SUPERVISORYPROCEDURES DID NOT DESCRIBE SUPERVISORY STEPS TO ENSURE THATALL ORDER DATA IS FED INTO THE FIRM'S POST-TRADE COMPLIANCEREVIEW SYSTEM. THE CONDUCT DESCRIBED IN THIS PARAGRAPHCONSTITUTES A VIOLATION OF PHLX RULES 748 AND 707.







Initiated By: NASDAQ PHLX LLC


Other


N/A





WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING THEFIRST REVIEW PERIOD, IT MISTAKENLY RELIED ON THE CROSSED MARKETEXCEPTION SET FORTH IN SEC RULE 611(B)(4). THE FINDINGS STATEDTHAT THIS RESULTED IN THE FIRM FAILING TO SEND ISOS TO EXECUTEAGAINST THE FULL DISPLAYED SIZE OF CERTAIN PROTECTEDQUOTATIONS. AS A RESULT OF THE ABOVE CONDUCT, THE FIRM FAILED TOTAKE REASONABLE STEPS TO ESTABLISH THAT ISOS MET THEREQUIREMENTS OF RULE 600(B)(30) OF REGULATION NMS. THE CONDUCTDESCRIBED IN THIS PARAGRAPH CONSTITUTES A VIOLATION OF SECRULE 611(C) OF REGULATION NMS. THE FINDINGS ALSO STATED THATDURING THE SECOND AND THIRD REVIEW PERIODS, THE FIRM FAILED TOREASONABLY AVOID DISPLAYING, AND ENGAGED IN A PATTERN ORPRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED OR CROSSED APROTECTED QUOTATION. THE CONDUCT DESCRIBED IN THIS PARAGRAPHCONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF PSX RULE3213(D)(2)(B). THE FINDINGS ALSO INCLUDED THAT DURING THE SECONDREVIEW PERIOD, THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDEFOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH PSX RULE 3213(D)(2)(B). SPECIFICALLY, THE FIRM'S SUPERVISORYSYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURESPROVIDING FOR A STATEMENT OF ADEQUATE SUPERVISORY STEPS TOREVIEW FOR CANCELED DIRECTED ISOS. THE CONDUCT DESCRIBED INTHIS PARAGRAPH CONSTITUTES A VIOLATION OF PHLX RULES 748 AND707. IN ADDITION, DURING THE THIRD REVIEW PERIOD, THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH PSX RULE3213(D)(2)(B). SPECIFICALLY, THE FIRM'S WRITTEN SUPERVISORYPROCEDURES DID NOT DESCRIBE SUPERVISORY STEPS TO ENSURE THATALL ORDER DATA IS FED INTO THE FIRM'S POST-TRADE COMPLIANCEREVIEW SYSTEM. THE CONDUCT DESCRIBED IN THIS PARAGRAPHCONSTITUTES A VIOLATION OF PHLX RULES 748 AND 707.


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $97,500.00, OF WHICH $19,500SHALL BE PAID TO PHLX, THE REST WILL BE SHARED WITH OTHER SELF-REGULATORY ORGANIZATIONS IN SIMILAR SETTLEMENTS. THE FIRM ALSOUNDERTAKES TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES.

Regulator Statement THIS SETTLEMENT ALSO INVOLVES INVESTIGATIONS ASSOCIATED TOCASE NOS. 20150468027 AND 20160492958.


No










Initiated By: NASDAQ PHLX LLC









Allegations: THE FIRM ALLEGEDLY MISTAKENLY RELIED ON THE SEC RULE 611(B)(4)CROSSED MARKET EXCEPTION, RESULTING IN THE FIRM FAILING TO SENDISOS TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAINPROTECTED QUOTES IN VIOLATION OF SEC RULE 611(C). THE FIRM ALSOALLEGEDLY FAILED TO REASONABLY AVOID DISPLAYING, AND ENGAGED INA PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED ORCROSSED A PROTECTED QUOTATION IN VIOLATION OF PHLX RULE3213(D)(2)(B), 707, AND 748.


Resolution:



Firm Statement PLEASE SEE THE RESPONSES TO 7 AND 12



Disclosure 8 of 22

i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING THEFIRST REVIEW PERIOD, THE FIRM MISTAKENLY RELIED ON THE CROSSEDMARKET EXCEPTION SET FORTH IN SEC RULE 611(B)(4). THE FINDINGSSTATED THAT THIS RESULTED IN THE FIRM FAILING TO SEND ISOS TOEXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAIN PROTECTEDQUOTATIONS. AS A RESULT OF THE ABOVE CONDUCT, THE FIRM FAILED TOTAKE REASONABLE STEPS TO ESTABLISH THAT ISOS MET THEREQUIREMENTS OF RULE 600(B)(30) OF REGULATION NMS. THE CONDUCTDESCRIBED IN THIS PARAGRAPH CONSTITUTES A VIOLATION OF SECRULE 611(C) OF REGULATION NMS. THE FINDINGS ALSO STATED THATDURING THE SECOND AND THIRD REVIEW PERIODS, THE FIRM FAILED TOREASONABLY AVOID DISPLAYING, AND ENGAGED IN A PATTERN ORPRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED OR CROSSED APROTECTED QUOTATION. THE CONDUCT DESCRIBED IN THIS PARAGRAPHCONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASDAQ RULES4613(E)(2)(B), 4755(A)(4) (FOR CONDUCT PRIOR TO JUNE 22, 2015) AND4703(J) (FOR CONDUCT ON OR AFTER JUNE 22, 2015). THE FINDINGS ALSOINCLUDED THAT DURING THE SECOND REVIEW PERIOD, THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDAQ'S LOCKAND CROSS RULES. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEMDID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FORA STATEMENT OF ADEQUATE SUPERVISORY STEPS TO REVIEW FORCANCELED DIRECTED ISOS. THE CONDUCT DESCRIBED IN THISPARAGRAPH CONSTITUTES A VIOLATION OF NASDAQ RULES 3010 AND2010A. IN ADDITION, DURING THE THIRD REVIEW PERIOD, THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDAQ'S LOCKAND CROSS RULES. SPECIFICALLY, THE FIRM'S WRITTEN SUPERVISORYPROCEDURES DID NOT DESCRIBE SUPERVISORY STEPS TO ENSURE THATALL ORDER DATA IS FED INTO THE FIRM'S POST-TRADE COMPLIANCEREVIEW SYSTEM. THE CONDUCT DESCRIBED IN THIS PARAGRAPHCONSTITUTES A VIOLATION OF NASDAQ RULES 3010 AND 2010A.







Initiated By: NASDAQ STOCK MARKET


Other


N/A





WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING THEFIRST REVIEW PERIOD, THE FIRM MISTAKENLY RELIED ON THE CROSSEDMARKET EXCEPTION SET FORTH IN SEC RULE 611(B)(4). THE FINDINGSSTATED THAT THIS RESULTED IN THE FIRM FAILING TO SEND ISOS TOEXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAIN PROTECTEDQUOTATIONS. AS A RESULT OF THE ABOVE CONDUCT, THE FIRM FAILED TOTAKE REASONABLE STEPS TO ESTABLISH THAT ISOS MET THEREQUIREMENTS OF RULE 600(B)(30) OF REGULATION NMS. THE CONDUCTDESCRIBED IN THIS PARAGRAPH CONSTITUTES A VIOLATION OF SECRULE 611(C) OF REGULATION NMS. THE FINDINGS ALSO STATED THATDURING THE SECOND AND THIRD REVIEW PERIODS, THE FIRM FAILED TOREASONABLY AVOID DISPLAYING, AND ENGAGED IN A PATTERN ORPRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED OR CROSSED APROTECTED QUOTATION. THE CONDUCT DESCRIBED IN THIS PARAGRAPHCONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASDAQ RULES4613(E)(2)(B), 4755(A)(4) (FOR CONDUCT PRIOR TO JUNE 22, 2015) AND4703(J) (FOR CONDUCT ON OR AFTER JUNE 22, 2015). THE FINDINGS ALSOINCLUDED THAT DURING THE SECOND REVIEW PERIOD, THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDAQ'S LOCKAND CROSS RULES. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEMDID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FORA STATEMENT OF ADEQUATE SUPERVISORY STEPS TO REVIEW FORCANCELED DIRECTED ISOS. THE CONDUCT DESCRIBED IN THISPARAGRAPH CONSTITUTES A VIOLATION OF NASDAQ RULES 3010 AND2010A. IN ADDITION, DURING THE THIRD REVIEW PERIOD, THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDAQ'S LOCKAND CROSS RULES. SPECIFICALLY, THE FIRM'S WRITTEN SUPERVISORYPROCEDURES DID NOT DESCRIBE SUPERVISORY STEPS TO ENSURE THATALL ORDER DATA IS FED INTO THE FIRM'S POST-TRADE COMPLIANCEREVIEW SYSTEM. THE CONDUCT DESCRIBED IN THIS PARAGRAPHCONSTITUTES A VIOLATION OF NASDAQ RULES 3010 AND 2010A.


Resolution:


No








Sanction Details: THE FIRM WAS CENSURED AND FINED $97500.00, OF WHICH $19,500 SHALLBE PAID TO NASDAQ, THE REMAINING WILL BE SHARED WITH OTHERSELF-REGULATORY ORGANIZATIONS IN SIMILAR SETTLEMENTS. INADDITION, THE FIRM UNDERTAKES TO REVISE ITS WRITTENSUPERVISORY PROCEDURES.

Regulator Statement THIS SETTLEMENT IN THIS CASE ALSO INVOLVED INVESTIGATIONS INRELATED CASE NOS. 20150468027 AND 20160492958.


No



Initiated By: NASDAQ STOCK MARKET LLC









Allegations: THE FIRM ALLEGEDLY MISTAKENLY RELIED ON THE SEC RULE 611(B)(4)CROSSED MARKET EXCEPTION, RESULTING IN THE FIRM FAILING TO SENDISOS TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAINPROTECTED QUOTES IN VIOLATION OF SEC RULE 611(C). THE FIRM ALSOALLEGEDLY FAILED TO REASONABLY AVOID DISPLAYING, AND ENGAGED INA PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED ORCROSSED A PROTECTED QUOTATION IN VIOLATION OF NASDAQ RULES4613(E)(2)(B), 4755(A)(4), 4703(J), 3010, AND 2010A.



Resolution: Acceptance, Waiver & Consent(AWC)











Disclosure 9 of 22

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT MISTAKENLYRELIED ON THE CROSSED MARKET EXCEPTION SET FORTH IN SEC RULE611(B)(4). THE FINDINGS STATED THAT THIS RESULTED IN THE FIRMFAILING TO SEND INTERMARKET SWEEP ORDERS (ISOS) TO EXECUTEAGAINST THE FULL DISPLAYED SIZE OF CERTAIN PROTECTEDQUOTATIONS. AS A RESULT OF THE ABOVE CONDUCT, THE FIRM FAILED TOTAKE REASONABLE STEPS TO ESTABLISH THAT ISOS MET THEREQUIREMENTS OF RULE 600(B)(30) OF REGULATION NMS. THE CONDUCTDESCRIBED IN THIS PARAGRAPH CONSTITUTES A VIOLATION OF SECRULE 611(C) OF REGULATION NMS AND NYSE RULE 13(E)(3). THE FINDINGSALSO STATED THAT THE FIRM FAILED TO REASONABLY AVOID DISPLAYING,AND ENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONSTHAT LOCKED OR CROSSED A PROTECTED QUOTATION. THE CONDUCTDESCRIBED IN THIS PARAGRAPH CONSTITUTES SEPARATE AND DISTINCTVIOLATIONS OF NYSE RULE 19(B). THE FINDINGS ALSO INCLUDED THATTHE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULE19(B). SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOTINCLUDE WRITTEN SUPERVISORY PROCEDURES (WSPS) PROVIDING FORA STATEMENT OF ADEQUATE SUPERVISORY STEPS TO REVIEW FORCANCELED DIRECTED ISOS. THE CONDUCT DESCRIBED IN THISPARAGRAPH CONSTITUTES A VIOLATION OF NYSE RULES 342 (FORCONDUCT BEFORE DECEMBER 1, 2014), 3110 (FOR CONDUCT ON ORAFTER DECEMBER 1, 2014) AND 2010. ADDITIONALLY, THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULE19(B). SPECIFICALLY, THE FIRM'S WSPS DID NOT DESCRIBE SUPERVISORYSTEPS TO ENSURE THAT ALL ORDER DATA IS FED INTO THE FIRM'S POST-TRADE COMPLIANCE REVIEW SYSTEM. THE CONDUCT DESCRIBED IN THISPARAGRAPH CONSTITUTES A VIOLATION OF NYSE RULES 342 (FORCONDUCT BEFORE DECEMBER 1, 2014), 3110 (FOR CONDUCT ON ORAFTER DECEMBER 1, 2014) AND 2010.









Other


N/A





WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT MISTAKENLYRELIED ON THE CROSSED MARKET EXCEPTION SET FORTH IN SEC RULE611(B)(4). THE FINDINGS STATED THAT THIS RESULTED IN THE FIRMFAILING TO SEND INTERMARKET SWEEP ORDERS (ISOS) TO EXECUTEAGAINST THE FULL DISPLAYED SIZE OF CERTAIN PROTECTEDQUOTATIONS. AS A RESULT OF THE ABOVE CONDUCT, THE FIRM FAILED TOTAKE REASONABLE STEPS TO ESTABLISH THAT ISOS MET THEREQUIREMENTS OF RULE 600(B)(30) OF REGULATION NMS. THE CONDUCTDESCRIBED IN THIS PARAGRAPH CONSTITUTES A VIOLATION OF SECRULE 611(C) OF REGULATION NMS AND NYSE RULE 13(E)(3). THE FINDINGSALSO STATED THAT THE FIRM FAILED TO REASONABLY AVOID DISPLAYING,AND ENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONSTHAT LOCKED OR CROSSED A PROTECTED QUOTATION. THE CONDUCTDESCRIBED IN THIS PARAGRAPH CONSTITUTES SEPARATE AND DISTINCTVIOLATIONS OF NYSE RULE 19(B). THE FINDINGS ALSO INCLUDED THATTHE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULE19(B). SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOTINCLUDE WRITTEN SUPERVISORY PROCEDURES (WSPS) PROVIDING FORA STATEMENT OF ADEQUATE SUPERVISORY STEPS TO REVIEW FORCANCELED DIRECTED ISOS. THE CONDUCT DESCRIBED IN THISPARAGRAPH CONSTITUTES A VIOLATION OF NYSE RULES 342 (FORCONDUCT BEFORE DECEMBER 1, 2014), 3110 (FOR CONDUCT ON ORAFTER DECEMBER 1, 2014) AND 2010. ADDITIONALLY, THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULE19(B). SPECIFICALLY, THE FIRM'S WSPS DID NOT DESCRIBE SUPERVISORYSTEPS TO ENSURE THAT ALL ORDER DATA IS FED INTO THE FIRM'S POST-TRADE COMPLIANCE REVIEW SYSTEM. THE CONDUCT DESCRIBED IN THISPARAGRAPH CONSTITUTES A VIOLATION OF NYSE RULES 342 (FORCONDUCT BEFORE DECEMBER 1, 2014), 3110 (FOR CONDUCT ON ORAFTER DECEMBER 1, 2014) AND 2010.


Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $97,500, AND UNDERTAKES TO REVISEITS WSPS.

Regulator Statement THIS SETTLEMENT INCLUDES INVESTIGATIONS AS A PART OF CASE NOS.20150468027 AND 20160492958.


No




Allegations: THE FIRM ALLEGEDLY MISTAKENLY RELIED ON THE SEC RULE 611(B)(4)CROSSED MARKET EXCEPTION, RESULTING IN THE FIRM FAILING TO SENDISOS TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAINPROTECTED QUOTES IN VIOLATION OF SEC RULE 611(C) AND NYSE RULE13(E)(3). THE FIRM ALSO ALLEGEDLY FAILED TO REASONABLY AVOIDDISPLAYING, AND ENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING,QUOTATIONS THAT LOCKED OR CROSSED A PROTECTED QUOTATION INVIOLATION OF NYSE RULES 13(E)(3), 19(B), 342, 3110 AND 2010.















Other Product Type(s): N/A

THE FIRM ALLEGEDLY MISTAKENLY RELIED ON THE SEC RULE 611(B)(4)CROSSED MARKET EXCEPTION, RESULTING IN THE FIRM FAILING TO SENDISOS TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAINPROTECTED QUOTES IN VIOLATION OF SEC RULE 611(C) AND NYSE RULE13(E)(3). THE FIRM ALSO ALLEGEDLY FAILED TO REASONABLY AVOIDDISPLAYING, AND ENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING,QUOTATIONS THAT LOCKED OR CROSSED A PROTECTED QUOTATION INVIOLATION OF NYSE RULES 13(E)(3), 19(B), 342, 3110 AND 2010.


Resolution:






Disclosure 10 of 22

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMVIOLATED SEC RULE 611(C) AND NYSE ARCA EQUITIES RULES 7.31(JJ) AND7.31(E)(2), BY FAILING TO TAKE REASONABLE STEPS TO ESTABLISH THATINTERMARKET SWEEP ORDERS MET THE REQUIREMENTS SET FORTH INSEC RULE 600(B)(30). THE FINDINGS STATED THAT THE FIRM VIOLATEDNYSE ARCA EQUITIES RULE 7.37(E)(2), BY FAILING TO AVOID DISPLAYING,OR ENGAGING IN A PATTERN OR PRACTICE OF DISPLAYING, ANYQUOTATIONS THAT LOCKED OR CROSSED A PROTECTED QUOTATION ANDVIOLATED NYSE ARCA EQUITIES RULE 6.18, BY FAILING TO ESTABLISH ASUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH NYSE ARCA EQUITIES RULE 7.37(E)(2).







Initiated By: NYSE ARCA, INC.


Other


N/A





WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMVIOLATED SEC RULE 611(C) AND NYSE ARCA EQUITIES RULES 7.31(JJ) AND7.31(E)(2), BY FAILING TO TAKE REASONABLE STEPS TO ESTABLISH THATINTERMARKET SWEEP ORDERS MET THE REQUIREMENTS SET FORTH INSEC RULE 600(B)(30). THE FINDINGS STATED THAT THE FIRM VIOLATEDNYSE ARCA EQUITIES RULE 7.37(E)(2), BY FAILING TO AVOID DISPLAYING,OR ENGAGING IN A PATTERN OR PRACTICE OF DISPLAYING, ANYQUOTATIONS THAT LOCKED OR CROSSED A PROTECTED QUOTATION ANDVIOLATED NYSE ARCA EQUITIES RULE 6.18, BY FAILING TO ESTABLISH ASUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH NYSE ARCA EQUITIES RULE 7.37(E)(2).


Resolution:


Sanction Details: THE FIRM IS CENSURED, FINED $19,500 AND UNDERTAKES TO REVISE ITSWSPS.

Regulator Statement THIS CASE INCLUDES MATTER NOS. 20150468027 AND 20160492958.

THIS MATTER IS FINAL UPON ISSUANCE OF THIS DECISION AND THESANCTIONS ARE EFFECTIVE IMMEDIATELY.

FINRA CONDUCTED THIS REVIEW ON BEHALF OF NYSE ARCA, INC.


No


Decision & Order of Offer of Settlement


Allegations: THE FIRM ALLEGEDLY MISTAKENLY RELIED ON THE SEC RULE 611(B)(4)CROSSED MARKET EXCEPTION, RESULTING IN THE FIRM FAILING TO SENDISOS TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAINPROTECTED QUOTES IN VIOLATION OF SEC RULE 611(C). THE FIRM ALSOALLEGEDLY FAILED TO REASONABLY AVOID DISPLAYING, AND ENGAGED INA PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED ORCROSSED A PROTECTED QUOTATION IN VIOLATION OF NYSE ARCAEQUITIES RULES 7.13, 7.37, 6.18, AND 2010.







Initiated By: NYSE ARCA INC.









THE FIRM ALLEGEDLY MISTAKENLY RELIED ON THE SEC RULE 611(B)(4)CROSSED MARKET EXCEPTION, RESULTING IN THE FIRM FAILING TO SENDISOS TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF CERTAINPROTECTED QUOTES IN VIOLATION OF SEC RULE 611(C). THE FIRM ALSOALLEGEDLY FAILED TO REASONABLY AVOID DISPLAYING, AND ENGAGED INA PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED ORCROSSED A PROTECTED QUOTATION IN VIOLATION OF NYSE ARCAEQUITIES RULES 7.13, 7.37, 6.18, AND 2010.


Resolution:


Sanction Details: FINE OF $19,500 PAID TO THE EXCHANGE




Disclosure 11 of 22

i


Allegations: WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, GTSSECURITIES LLC ("GTS" OR THE "FIRM") CONSENTED TO THE SANCTIONSAND TO THE ENTRY OF FINDINGS THAT CERTAIN ASSOCIATED PERSONSWITH THE FIRM'S DESIGNATED MARKET MAKER UNIT ("DMM" OR "DMMUNIT") USED UNAPPROVED CELLULAR WIRELESS DEVICES FROM THENYSE EXCHANGE FLOOR (THE "NYSE FLOOR").THE FINDINGS STATED THAT SPECIFICALLY, CERTAIN GTS DMM UNITASSOCIATED PERSONS USED THEIR CELLULAR WIRELESS DEVICES FROMTHE NYSE FLOOR THAT WERE NOT APPROVED BY THE EXCHANGE. THEGTS DMM UNIT ASSOCIATED PERSONS USED THEIR CELLULAR WIRELESSDEVICES TO, AMONG OTHER THINGS; SEND A LIMITED NUMBER OF TEXTMESSAGES WITH EACH OTHER. IN ADDITION, ONE OF THE GTS DMM UNITASSOCIATED PERSONS ALSO USED HIS CELLULAR WIRELESS DEVICE TORESPOND TO A LIMITED NUMBER OF COMMUNICATIONS HE RECEIVEDFROM AN EMPLOYEE AT ANOTHER DMM ON THE NYSE FLOOR. GTS ISRESPONSIBLE FOR THE CONDUCT OF ITS ASSOCIATED PERSONS.THE FINDINGS ALSO STATED THAT GTS DID NOT EXPLICITLY DESIGNATE AREGISTERED PRINCIPAL TO PERFORM REVIEWS DESIGNED TO ENSURECOMPLIANCE WITH NYSE RULE 36 (SUPPLEMENTARY MATERIAL .30AND .31) FOR THE DMM UNIT. IN ADDITION, GTS DID NOT DOCUMENT ANYSUPERVISORY REVIEWS IT UNDERTOOK CONCERNING THE POTENTIALUSE OF UNAUTHORIZED DEVICES BY DMM UNIT EMPLOYEES.














WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, GTSSECURITIES LLC ("GTS" OR THE "FIRM") CONSENTED TO THE SANCTIONSAND TO THE ENTRY OF FINDINGS THAT CERTAIN ASSOCIATED PERSONSWITH THE FIRM'S DESIGNATED MARKET MAKER UNIT ("DMM" OR "DMMUNIT") USED UNAPPROVED CELLULAR WIRELESS DEVICES FROM THENYSE EXCHANGE FLOOR (THE "NYSE FLOOR").THE FINDINGS STATED THAT SPECIFICALLY, CERTAIN GTS DMM UNITASSOCIATED PERSONS USED THEIR CELLULAR WIRELESS DEVICES FROMTHE NYSE FLOOR THAT WERE NOT APPROVED BY THE EXCHANGE. THEGTS DMM UNIT ASSOCIATED PERSONS USED THEIR CELLULAR WIRELESSDEVICES TO, AMONG OTHER THINGS; SEND A LIMITED NUMBER OF TEXTMESSAGES WITH EACH OTHER. IN ADDITION, ONE OF THE GTS DMM UNITASSOCIATED PERSONS ALSO USED HIS CELLULAR WIRELESS DEVICE TORESPOND TO A LIMITED NUMBER OF COMMUNICATIONS HE RECEIVEDFROM AN EMPLOYEE AT ANOTHER DMM ON THE NYSE FLOOR. GTS ISRESPONSIBLE FOR THE CONDUCT OF ITS ASSOCIATED PERSONS.THE FINDINGS ALSO STATED THAT GTS DID NOT EXPLICITLY DESIGNATE AREGISTERED PRINCIPAL TO PERFORM REVIEWS DESIGNED TO ENSURECOMPLIANCE WITH NYSE RULE 36 (SUPPLEMENTARY MATERIAL .30AND .31) FOR THE DMM UNIT. IN ADDITION, GTS DID NOT DOCUMENT ANYSUPERVISORY REVIEWS IT UNDERTOOK CONCERNING THE POTENTIALUSE OF UNAUTHORIZED DEVICES BY DMM UNIT EMPLOYEES.


Resolution:



Regulator Statement IN RESOLVING THIS MATTER, ENFORCEMENT TOOK INTO ACCOUNT THATTHE TEXT MESSAGES AT ISSUE OCCURRED ON A SINGLE DAY AND WERELIMITED IN NUMBER, AS WELL AS GTS'S TIMELY REMEDIATION.


No



iReporting Source:






Reporting Source: Firm





ACCESSED A FINE OF $45,000.00 AND A CENSURE




Other Product Type(s): NOT APPLICABLE

Allegations: VIOLATED RULE 36, SUPPLEMENTARY .30 AND .31. ON AUGUST 11, 2017,CERTAIN GTS DMM UNIT ASSOCIATED PERSONS USED THEIR CELLULARWIRELESS DEVICES FROM THE NYSE FLOOR THAT WERE NOT APPROVEDBY THE EXCHANGE. VIOLATED NYSE SUPERVISORY RULE 3110(A).


Appealed To and Date AppealFiled:

NOT APPLICABLE


Resolution:

Other Sanctions Ordered: NOT APPLICABLE

Sanction Details: A FINE OF $45,000 PAID TO THE EXCHANGE.




Disclosure 12 of 22

i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULTOF A CODING ERROR, THE FIRM SUBMITTED INACCURATE INFORMATIONTO THE NYSE, AS WELL AS TO MULTIPLE EQUITY EXCHANGES AND THEFINRA/NASDAQ TRADE REPORTING FACILITY ("FNTRF"), BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN A TOTAL OFAPPROXIMATELY 22 MILLION INSTANCES, OF WHICH APPROXIMATELY1,476,823 ORDERS WERE ENTERED ON THE NYSE. THESE INACCURACIESIMPACTED CERTAIN CROSS-MARKET SURVEILLANCE, BUT THERE WAS NOIDENTIFIED MARKET IMPACT OR HARM TO MARKET PARTICIPANTS.

THE FINDINGS STATED THAT THE FIRM FAILED TO ESTABLISH ANDMAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH CERTAIN APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND EXCHANGE RULES, WITH RESPECT TO SUBMISSIONOF ACCURATE CAPACITY CODES ON ORDERS SUBMITTED TO THEEXCHANGE. IN ADDITION, THE FIRM'S SUPERVISORY SYSTEM DID NOTINCLUDE SUFFICIENT WRITTEN SUPERVISORY PROCEDURES ("WSPS") TOENSURE SUBMISSION OF ACCURATE CAPACITY CODES. SPECIFICALLY,THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WSPS THATPROVIDED FOR: (I) THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLEFOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; (II) ASTATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THEIDENTIFIED PERSON(S); (III) A STATEMENT AS TO HOW OFTEN SUCHPERSON(S) SHOULD TAKE SUCH STEP(S); AND (IV) A STATEMENT AS TOHOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTENSUPERVISORY PROCEDURES SHOULD BE DOCUMENTED.














WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULTOF A CODING ERROR, THE FIRM SUBMITTED INACCURATE INFORMATIONTO THE NYSE, AS WELL AS TO MULTIPLE EQUITY EXCHANGES AND THEFINRA/NASDAQ TRADE REPORTING FACILITY ("FNTRF"), BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN A TOTAL OFAPPROXIMATELY 22 MILLION INSTANCES, OF WHICH APPROXIMATELY1,476,823 ORDERS WERE ENTERED ON THE NYSE. THESE INACCURACIESIMPACTED CERTAIN CROSS-MARKET SURVEILLANCE, BUT THERE WAS NOIDENTIFIED MARKET IMPACT OR HARM TO MARKET PARTICIPANTS.



Resolution:


No









Sanction Details: THE FIRM WAS CENSURED AND FINED THE AMOUNT OF $75,000, OFWHICH $5,000 IS PAYABLE TO NYSE.

PURSUANT TO NYSE RULE 9310(A)(1)(B), THIS AWC BECAME FINAL ONNOVEMBER 11, 2017.

Regulator Statement ACCEPTANCE OF THIS AWC IS CONDITIONED UPON ACCEPTANCE OFSIMILAR SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THEFIRM AND SOME OTHER SELF-REGULATORY ORGANIZATIONS.

IN DETERMINING TO RESOLVE THIS MATTER, THE EXCHANGE TOOK INTOCONSIDERATION THE FOLLOWING: (I) THE FIRM SELF-REPORTED ASIGNIFICANT NUMBER OF THE CAPACITY CODE VIOLATIONS; (II) THE FIRMPROVIDED SUBSTANTIAL ASSISTANCE TO MARKET REGULATION STAFF,INCLUDING PROVIDING THE STAFF WITH DATA QUANTIFYING THE NUMBEROF VIOLATIONS; AND (III) THE SUBSEQUENT REMEDIAL MEASURESIMPLEMENTED BY THE FIRM.





Censure


FINE OF $5,000.00





Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SUBMITTEDINACCURATE INFORMATION TO NYSE, SEVERAL EQUITIES EXCHANGES,AND THE FINRA/NASDAQ TRADE REPORTING FACILITY. THE FINDINGSSTATED THAT THE FIRM VIOLATED NYSE RULES 132(A), 132.30(9), ANDRELATED SUPERVISION RULES NYSE RULE 3110 BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN APPROXIMATELY 22MILLION INSTANCES, OF WHICH APPROXIMATELY 1,476,823 ORDERS WEREENTERED ON NYSE FROM JULY 15, 2015 THROUGH MAY 12, 2016.








FINE OF $5,000.00


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $5,000.00

Firm Statement THE FIRM WAS CENSURED AND FINED $5,000.00



Disclosure 13 of 22

i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULTOF A CODING ERROR, THE FIRM SUBMITTED INACCURATE INFORMATIONTO BYX, AS WELL AS TO MULTIPLE EQUITY EXCHANGES AND THEFINRA/NASDAQ TRADE REPORTING FACILITY ("FNTRF"), BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN A TOTAL OFAPPROXIMATELY 22 MILLION INSTANCES, OF WHICH APPROXIMATELY2,430,593 ORDERS WERE ENTERED ON BYX. THESE INACCURACIESIMPACTED CERTAIN CROSS-MARKET SURVEILLANCE, BUT THERE WAS NOIDENTIFIED MARKET IMPACT OR HARM TO MARKET PARTICIPANTS.

THE FINDINGS STATED THAT THE FIRM FAILED TO ESTABLISH ANDMAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH CERTAIN APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND EXCHANGE RULES, WITH RESPECT TO SUBMISSIONOF ACCURATE CAPACITY CODES ON ORDERS SUBMITTED TO THEEXCHANGE. IN ADDITION, THE FIRM'S SUPERVISORY SYSTEM DID NOTINCLUDE SUFFICIENT WRITTEN SUPERVISORY PROCEDURES ("WSPS") TOENSURE SUBMISSION OF ACCURATE CAPACITY CODES. SPECIFICALLY,THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WSPS THATPROVIDED FOR: (I) THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLEFOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; (II) ASTATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THEIDENTIFIED PERSON(S); (III) A STATEMENT AS TO HOW OFTEN SUCHPERSON(S) SHOULD TAKE SUCH STEP(S); AND (IV) A STATEMENT AS TOHOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WSPS SHOULDBE DOCUMENTED.







Initiated By: BATS BYX EXCHANGE, INC.







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULTOF A CODING ERROR, THE FIRM SUBMITTED INACCURATE INFORMATIONTO BYX, AS WELL AS TO MULTIPLE EQUITY EXCHANGES AND THEFINRA/NASDAQ TRADE REPORTING FACILITY ("FNTRF"), BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN A TOTAL OFAPPROXIMATELY 22 MILLION INSTANCES, OF WHICH APPROXIMATELY2,430,593 ORDERS WERE ENTERED ON BYX. THESE INACCURACIESIMPACTED CERTAIN CROSS-MARKET SURVEILLANCE, BUT THERE WAS NOIDENTIFIED MARKET IMPACT OR HARM TO MARKET PARTICIPANTS.



Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED THE AMOUNT OF $75,000, OFWHICH $8,000 IS PAYABLE TO THE EXCHANGE. THE BALANCE OF THESANCTION WILL BE PAID TO THE OTHER SELF-REGULATORYORGANIZATIONS INVOLVED WITH THE SETTLEMENT.ACCEPTANCE OF THIS AWC IS CONDITIONED UPON ACCEPTANCE OFSIMILAR SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THEFIRM AND THE OTHER SELF-REGULATORY ORGANIZATIONS.PURSUANT TO BYX RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE,THIS AWC BECAME FINAL NOVEMBER 23, 2017.

Regulator Statement IN DETERMINING TO RESOLVE THIS MATTER, THE EXCHANGE TOOK INTOCONSIDERATION THE FOLLOWING: (I) THE FIRM SELF-REPORTED ASIGNIFICANT NUMBER OF THE CAPACITY CODE VIOLATIONS; (II) THE FIRMPROVIDED SUBSTANTIAL ASSISTANCE TO MARKET REGULATION STAFF,INCLUDING PROVIDING THE STAFF WITH DATA QUANTIFYING THE NUMBEROF VIOLATIONS; AND (III) THE SUBSEQUENT REMEDIAL MEASURESIMPLEMENTED BY THE FIRM.


No











Censure


FINE OF $8,000.00





Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SUBMITTEDINACCURATE INFORMATION TO BYX, SEVERAL EQUITIES EXCHANGES,AND THE FINRA/NASDAQ TRADE REPORTING FACILITY. THE FINDINGSSTATED THAT THE FIRM VIOLATED BYX RULE 11.21 AND RELATED BYXSUPERVISION RULES 3.1 AND 5.1 BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN APPROXIMATELY 22 MILLION INSTANCES, OFWHICH APPROXIMATELY 2,430,593 ORDERS WERE ENTERED ON BYXFROM JULY 15, 2015 THROUGH MAY 12, 2016.



Resolution:






Disclosure 14 of 22

i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULTOF A CODING ERROR, THE FIRM SUBMITTED INACCURATE INFORMATIONTO BZX, AS WELL AS TO MULTIPLE EQUITY EXCHANGES AND THEFINRA/NASDAQ TRADE REPORTING FACILITY ("FNTRF"), BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN A TOTAL OFAPPROXIMATELY 22 MILLION INSTANCES, OF WHICH APPROXIMATELY3,525,008 ORDERS WERE ENTERED ON BZX. THESE INACCURACIESIMPACTED CERTAIN CROSS-MARKET SURVEILLANCE, BUT THERE WAS NOIDENTIFIED MARKET IMPACT OR HARM TO MARKET PARTICIPANTS.








Initiated By: BATS BZX EXCHANGE, INC.







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULTOF A CODING ERROR, THE FIRM SUBMITTED INACCURATE INFORMATIONTO BZX, AS WELL AS TO MULTIPLE EQUITY EXCHANGES AND THEFINRA/NASDAQ TRADE REPORTING FACILITY ("FNTRF"), BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN A TOTAL OFAPPROXIMATELY 22 MILLION INSTANCES, OF WHICH APPROXIMATELY3,525,008 ORDERS WERE ENTERED ON BZX. THESE INACCURACIESIMPACTED CERTAIN CROSS-MARKET SURVEILLANCE, BUT THERE WAS NOIDENTIFIED MARKET IMPACT OR HARM TO MARKET PARTICIPANTS.



Resolution:


No








Sanction Details: THE FIRM WAS CENSURED AND FINED THE AMOUNT OF $75,000, OFWHICH $12,000 IS PAYABLE TO THE EXCHANGE. THE BALANCE OF THESANCTION WILL BE PAID TO THE OTHER SELF-REGULATORYORGANIZATIONS INVOLVED WITH THE SETTLEMENT.ACCEPTANCE OF THIS AWC IS CONDITIONED UPON ACCEPTANCE OFSIMILAR SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THEFIRM AND THE OTHER SELF-REGULATORY ORGANIZATIONS.PURSUANT TO BZX RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE,THIS AWC BECAME FINAL NOVEMBER 23, 2017.



No



Initiated By: BATS BZX EXCHANGE, LNC.



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SUBMITTEDINACCURATE INFORMATION TO BZX, SEVERAL EQUITIES EXCHANGES,AND THE FINRA/NASDAQ TRADE REPORTING FACILITY. THE FINDINGSSTATED THAT THE FIRM VIOLATED BZX RULE 11.21 AND RELATED BZXSUPERVISION RULES 3.1 AND 5.1 BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN APPROXIMATELY 22 MILLION INSTANCES, OFWHICH APPROXIMATELY 3,525,008 ORDERS WERE ENTERED ON NASDAQFROM JULY 15, 2015 THROUGH MAY 12, 2016.








Censure


FINE OF $12,000.00





Resolution:






Disclosure 15 of 22

i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULTOF A CODING ERROR, THE FIRM SUBMITTED INACCURATE INFORMATIONTO THE EXCHANGE, AS WELL AS TO MULTIPLE EQUITY EXCHANGES ANDTHE FINRA/NASDAQ TRADE REPORTING FACILITY ("FNTRF"), BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN A TOTAL OFAPPROXIMATELY 22 MILLION INSTANCES, OF WHICH APPROXIMATELY5,142,306 ORDERS WERE ENTERED ON THE EXCHANGE. THESEINACCURACIES IMPACTED CERTAIN CROSS-MARKET SURVEILLANCE, BUTTHERE WAS NO IDENTIFIED MARKET IMPACT OR HARM TO MARKETPARTICIPANTS.








Initiated By: NASDAQ STOCK MARKET







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULTOF A CODING ERROR, THE FIRM SUBMITTED INACCURATE INFORMATIONTO THE EXCHANGE, AS WELL AS TO MULTIPLE EQUITY EXCHANGES ANDTHE FINRA/NASDAQ TRADE REPORTING FACILITY ("FNTRF"), BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN A TOTAL OFAPPROXIMATELY 22 MILLION INSTANCES, OF WHICH APPROXIMATELY5,142,306 ORDERS WERE ENTERED ON THE EXCHANGE. THESEINACCURACIES IMPACTED CERTAIN CROSS-MARKET SURVEILLANCE, BUTTHERE WAS NO IDENTIFIED MARKET IMPACT OR HARM TO MARKETPARTICIPANTS.



Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED THE AMOUNT OF $75,000, OFWHICH $17,500 IS PAYABLE TO THE EXCHANGE.

ACCEPTANCE OF THIS AWC IS CONDITIONED UPON ACCEPTANCE OFSIMILAR SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THEFIRM AND SOME OTHER SELF-REGULATORY ORGANIZATIONS.



No








IN DETERMINING TO RESOLVE THIS MATTER, THE EXCHANGE TOOK INTOCONSIDERATION THE FOLLOWING: (I) THE FIRM SELF-REPORTED ASIGNIFICANT NUMBER OF THE CAPACITY CODE VIOLATIONS; (II) THE FIRMPROVIDED SUBSTANTIAL ASSISTANCE TO MARKET REGULATION STAFF,INCLUDING PROVIDING THE STAFF WITH DATA QUANTIFYING THE NUMBEROF VIOLATIONS; AND (III) THE SUBSEQUENT REMEDIAL MEASURESIMPLEMENTED BY THE FIRM.


Initiated By: THE NASDAQ STOCK MARKET LLC


Censure


FINE OF $17,500.00





Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SUBMITTEDINACCURATE INFORMATION TO NASDAQ, SEVERAL EQUITIES EXCHANGES,AND THE FINRA/NASDAQ TRADE REPORTING FACILITY. THE FINDINGSSTATED THAT THE FIRM VIOLATED NASDAQ RULE 4611(A)(6) AND RELATEDSUPERVISION RULES BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY"ORDERS IN APPROXIMATELY 22 MILLION INSTANCES, OF WHICHAPPROXIMATELY 5,142,306 ORDERS WERE ENTERED ON NASDAQ FROMJULY 15, 2015 THROUGH MAY 12, 2016.



Resolution:






Disclosure 16 of 22

i






Disclosure 16 of 22




Allegations: A FINRA HEARING OFFICER CONSIDERED AN OFFER OF SETTLEMENT ANDCONSENT ENTERED INTO BETWEEN FINRA ON BEHALF OF NYSE ARCAINC. AND THE FIRM.

THE FIRM ENTERED INTO AN OFFER OF SETTLEMENT AND CONSENT FORTHE SOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING,WITHOUT ADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUTADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS REFERRED TOIN THE OFFER OF SETTLEMENT.

THE HEARING OFFICER ACCEPTS THE OFFER OF SETTLEMENT ANDCONSENT AND ISSUES THIS DECISION THAT AS A RESULT OF A CODINGERROR, GTS SECURITIES LLC ("GTS SECURITIES" OR THE "FIRM")SUBMITTED INACCURATE INFORMATION TO THE EXCHANGE, AS WELL ASTO MULTIPLE EQUITY EXCHANGES AND THE FINRA/NASDAQ TRADEREPORTING FACILITY ("FNTRF"), BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS IN A TOTAL OF APPROXIMATELY 22 MILLIONINSTANCES, OF WHICH APPROXIMATELY 2,546,555 ORDERS WEREENTERED ON THE EXCHANGE. THESE INACCURACIES IMPACTED CERTAINCROSS-MARKET SURVEILLANCE, BUT THERE WAS NO IDENTIFIED MARKETIMPACT OR HARM TO MARKET PARTICIPANTS.

THE FINDINGS STATED THAT GTS SECURITIES FAILED TO ESTABLISH ANDMAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH CERTAIN APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND EXCHANGE RULES, WITH RESPECT TO SUBMISSIONOF ACCURATE CAPACITY CODES ON ORDERS SUBMITTED TO THEEXCHANGE. IN ADDITION, THE FIRM'S SUPERVISORY SYSTEM DID NOTINCLUDE SUFFICIENT WRITTEN SUPERVISORY PROCEDURES ("WSPS") TOENSURE SUBMISSION OF ACCURATE CAPACITY CODES. SPECIFICALLY,THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WSPS THATPROVIDED FOR: (I) THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLEFOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; (II) ASTATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THEIDENTIFIED PERSON(S); (III) A STATEMENT AS TO HOW OFTEN SUCHPERSON(S) SHOULD TAKE SUCH STEP(S); AND (IV) A STATEMENT AS TOHOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTENSUPERVISORY PROCEDURES SHOULD BE DOCUMENTED.













Resolution:



Regulator Statement THE FIRM VIOLATED (I) NYSE ARCA EQUITIES RULE 7.33 BY ENTERINGORDERS INTO THE NYSE ARCA MARKETPLACE THAT FAILED TO INDICATETHAT IT WAS ACTING IN A PRINCIPAL CAPACITY FOR THE ORDERS; AND (II)NYSE ARCA EQUITIES RULE 6.18 BY FAILING TO ESTABLISH AND MAINTAINA SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH NYSE ARCA EQUITIES RULE 7.33, AND APPLICABLESECURITIES LAWS AND REGULATIONS, REGARDING THE SUBMISSION OFACCURATE CAPACITY CODES.

IN DETERMINING TO RESOLVE THIS MATTER ON THE BASIS SET FORTHHEREIN, THE EXCHANGE TOOK INTO CONSIDERATION THE FOLLOWING: (I)THE FIRM SELF-REPORTED A SIGNIFICANT NUMBER OF THE CAPACITYCODE VIOLATIONS; (II) THE FIRM PROVIDED SUBSTANTIAL ASSISTANCE TOMARKET REGULATION STAFF, INCLUDING PROVIDING THE STAFF WITHDATA QUANTIFYING THE NUMBER OF VIOLATIONS; AND (III) THESUBSEQUENT REMEDIAL MEASURES IMPLEMENTED BY THE FIRM.

UNDER THE OFFER OF SETTLEMENT AND CONSENT, THE FIRM AGREEDTO PAY A TOTAL FINE OF $75,000, OF WHICH $9,000 SHALL BE PAID TO THEEXCHANGE AND THE REMAINING AMOUNT SHALL BE PAID TO EACH OFTHE OTHER SELF-REGULATORY ORGANIZATIONS IN ACCORDANCE WITHTHE TERMS OF PARALLEL SETTLEMENT AGREEMENTS IN RELATEDMATTERS BETWEEN THE FIRM AND EACH OF THESE SROS.


No








THE FIRM VIOLATED (I) NYSE ARCA EQUITIES RULE 7.33 BY ENTERINGORDERS INTO THE NYSE ARCA MARKETPLACE THAT FAILED TO INDICATETHAT IT WAS ACTING IN A PRINCIPAL CAPACITY FOR THE ORDERS; AND (II)NYSE ARCA EQUITIES RULE 6.18 BY FAILING TO ESTABLISH AND MAINTAINA SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH NYSE ARCA EQUITIES RULE 7.33, AND APPLICABLESECURITIES LAWS AND REGULATIONS, REGARDING THE SUBMISSION OFACCURATE CAPACITY CODES.

IN DETERMINING TO RESOLVE THIS MATTER ON THE BASIS SET FORTHHEREIN, THE EXCHANGE TOOK INTO CONSIDERATION THE FOLLOWING: (I)THE FIRM SELF-REPORTED A SIGNIFICANT NUMBER OF THE CAPACITYCODE VIOLATIONS; (II) THE FIRM PROVIDED SUBSTANTIAL ASSISTANCE TOMARKET REGULATION STAFF, INCLUDING PROVIDING THE STAFF WITHDATA QUANTIFYING THE NUMBER OF VIOLATIONS; AND (III) THESUBSEQUENT REMEDIAL MEASURES IMPLEMENTED BY THE FIRM.

UNDER THE OFFER OF SETTLEMENT AND CONSENT, THE FIRM AGREEDTO PAY A TOTAL FINE OF $75,000, OF WHICH $9,000 SHALL BE PAID TO THEEXCHANGE AND THE REMAINING AMOUNT SHALL BE PAID TO EACH OFTHE OTHER SELF-REGULATORY ORGANIZATIONS IN ACCORDANCE WITHTHE TERMS OF PARALLEL SETTLEMENT AGREEMENTS IN RELATEDMATTERS BETWEEN THE FIRM AND EACH OF THESE SROS.




Censure






Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SUBMITTEDINACCURATE INFORMATION TO NYSE ARCA, SEVERAL EQUITIESEXCHANGES, AND THE FINRA/NASDAQ TRADE REPORTING FACILITY. THEFINDINGS STATED THAT THE FIRM VIOLATED NYSE ARCA EQUITIES RULE7.33 AND RELATED SUPERVISION RULE NYSE ARCA RULE 6.18 BYENTERING "PRINCIPAL" ORDERS AS "AGENCY" ORDERS INAPPROXIMATELY 22 MILLION INSTANCES, OF WHICH APPROXIMATELY2,546,555 ORDERS WERE ENTERED ON NASDAQ FROM JULY 15,2015THROUGH MAY 12, 2016.



Resolution:






Disclosure 17 of 22

i







Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULTOF A CODING ERROR, IT SUBMITTED INACCURATE INFORMATION TO THEFINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) AND TO MULTIPLEEQUITY EXCHANGES BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY"ORDERS IN A TOTAL OF APPROXIMATELY 22 MILLION INSTANCES, OFWHICH APPROXIMATELY 6,937,587 ORDERS WERE ENTERED ON THEFNTRF. THESE INACCURACIES IMPACTED CERTAIN CROSS-MARKETSURVEILLANCE BUT THERE WAS NO IDENTIFIED MARKET IMPACT ORHARM TO MARKET PARTICIPANTS. THE FINDINGS STATED THAT THE FIRMFAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEMREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH CERTAINAPPLICABLE SECURITIES LAWS AND REGULATIONS, AND FINRA RULES,WITH RESPECT TO SUBMISSION OF ACCURATE CAPACITY CODES ONORDERS SUBMITTED TO THE FNTRF. IN ADDITION, THE FIRM'SSUPERVISORY SYSTEM DID NOT INCLUDE SUFFICIENT WRITTENSUPERVISORY PROCEDURES (WSPS) TO ENSURE SUBMISSION OFACCURATE CAPACITY CODES. SPECIFICALLY, THE FIRM'S SUPERVISORYSYSTEM DID NOT INCLUDE WSPS THAT PROVIDED FOR THEIDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISIONWITH RESPECT TO THE APPLICABLE RULES, A STATEMENT OF THESUPERVISORY STEP(S) TO BE TAKEN BY THE IDENTIFIED PERSON(S), ASTATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCHSTEP(S), AND A STATEMENT AS TO HOW THE COMPLETION OF THESTEP(S) INCLUDED IN THE WSPS SHOULD BE DOCUMENTED.



Resolution:


No






https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2015045798103



Sanction Details: THE FIRM WAS CENSURED AND FINED THE AMOUNT OF $75,000, OFWHICH $23,500 IS PAYABLE TO FINRA AND THE BALANCE WILL BE PAID TOBATS BZX EXCHANGE, INC., BATS BYX EXCHANGE, INC., THE NASDAQSTOCK MARKET LLC, THE NEW YORK STOCK EXCHANGE, LLC, AND NYSEARCA, INC. FINES PAID IN FULL ON NOVEMBER 6, 2017.



No



Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY


Censure





Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SUBMITTEDINACCURATE INFORMATION TO SEVERAL EQUITIES EXCHANGES AND THEFINRA/NASDAQ TRADE REPORTING FACILITY ("FNTRF") AS THE RESULT OFA CODING ERROR. THE FINDINGS STATED THAT THE FIRM VIOLATED FINRARULE 7230A(D) AND RELATED SUPERVISION RULES FROM JULY 15, 2015TO MAY 12, 2016 BY ENTERING "PRINCIPAL" ORDERS AS "AGENCY"ORDERS IN APPROXIMATELY 22 MILLION INSTANCES, OF WHICHAPPROXIMATELY 6,937,587 ORDERS WERE ENTERED ON THE FNTRF.








Censure


FINE OF $23,500.00


Resolution:






Disclosure 18 of 22

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOTAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN INTERMARKETSWEEP ORDERS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SETFORTH IN SEC RULE 600(B)(30) OR REGULATION NMS.

THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO SEC RULE 611(C) OR REGULATION NMSAND BYX RULE 11.9.D.1 SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEMDID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FORTHE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FORSUPERVISION WITH RESPECT TO SEC RULE 611(C) OF' REGULATION NMSAND BYX RULE 11.9.D.1; A STATEMENT OF' THE SUPERVISORY STEP(S) TOBE TAKEN BY THE IDENTIFIED PERSON(S); A STATEMENT AS TO HOWOFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND A STATEMENTAS TO HOW THE COMPLETION OR THE STEP(S) INCLUDED IN THEWRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED.












Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $10,000 AND AN UNDERTAKING TOREVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITHRESPECT TO THE PROCEDURES PROVIDING FOR: THE IDENTIFICATION OFTHE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THEAPPLICABLE RULES; A STATEMENT OF THE SUPERVISORY STEP(S) TO BETAKEN BY THE IDENTIFIED PERSON(S); A STATEMENT AS TO HOW OFTENSUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND A STATEMENT AS TOHOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTENSUPERVISORY PROCEDURES SHOULD BE DOCUMENTED.

PURSUANT TO BYX RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE,THIS AWC BECAME FINAL JANUARY 19, 2017.


No




Initiated By: BATS BYX EXCHANGE, INC


Allegations: BATS BYX EXCHANGE INC ALLEGED VIOLATIONS OF REG NMS RULE 611,BYX RULE 11.9.D.1, AND BYX RULE 5.1 DURING THE REVIEW PERIOD OFMAY 11, 2012 THROUGH MAY 22, 2012.








Censure


FINE $10,000.00






Resolution:


Sanction Details: FINE OF $10,000.00 WAS PAID ON 12/28/2016 AND AN UNDERTAKING TOREVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WASCOMPLETED ON 03/01/2013.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMSUBMITTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT THATWAS ACCEPTED BY THE BATS BYX EXCHANGE, INC.



Disclosure 19 of 22

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Initiated By: CHICAGO BOARD OPTIONS EXCHANGE


Docket/Case Number: 14-0204 / 20150442449


Allegations: GTS SECURITIES, LLC ("GTS"), A CBSX TPH ORGANIZATION, WASCENSURED AND FINED $15,000 FOR THE FOLLOWING CONDUCT: GTS (I)FAILED TO ENTER AND MAINTAIN TWO-SIDED QUOTES IN ITS APPOINTEDSECURITIES DURING CBSX REGULAR TRADING HOURS; AND (II)DISSEMINATED QUOTES THAT EXCEEDED THE MAXIMUM ALLOWABLEBID/ASK WIDTH IN ITS APPOINTED SECURITIES DURING CBSX REGULARTRADING HOURS. (EXCHANGE RULE 53.23 - OBLIGATIONS OF CBSXREMOTE MARKET-MAKERS)













Resolution:


Sanction Details: A $15,000 FINE AND A CENSURE.


Consent




Censure


FINE $15,000





Allegations: CBOE ALLEGED THAT, FROM ON OR ABOUT NOVEMBER 21, 2011 THROUGHON OR ABOUT DECEMBER 1, 2011, GTS FAILED TO ENTER AND MAINTAINTWO-SIDED QUOTES IN ITS APPOINTED SECURITIES DURING CBSXREGULAR TRADING HOURS. IN ADDITION, FROM ON OR ABOUT FEBRUARY22, 2012, THROUGH ON OR ABOUT MAY 11, 2012, AND FOR THE MONTHS OFSEPTEMBER 2012, AND AUGUST 2013, GTS DISSEMINATED QUOTES THATEXCEEDED THE MAXIMUM ALLOWABLE BID/ASK WIDTH IN ITS APPOINTEDSECURITIES DURING CBSX REGULAR TRADING HOURS.



Resolution: Settled







Other Sanctions Ordered: NONE

Sanction Details: FINE OF $15,000.00 WAS PAID ON 04/01/2015

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMSUBMITTED AN OFFER OF SETTLEMENT THAT WAS ACCEPTED BY THECBOE.


Disclosure 20 of 22

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Allegations: GTS SECURITIES LLC ("GTS"), AN EXCHANGE TPH ORGANIZATION, WASCENSURED AND FINED $15,000 FOR THE FOLLOWING CONDUCT. GTSIMPROPERLY UTILIZED INDEPENDENT TRADING UNIT AGGREGATION INTHAT NUMEROUS INDIVIDUALS WERE ASSIGNED TO MORE THAN ONEAGGREGATION UNIT AT A TIME. AS A RESULT, THE FIRM FAILED TOPROPERLY DETERMINE ITS NET POSITIONS IN SECURITIES FOR THEPURPOSE OF MARKING SELL ORDERS "LONG" OR "SHORT." (EXCHANGERULE 4.2 - ADHERENCE TO LAW AND REGULATION SHO RULE 200 -DEFINITION OF "SHORT SALE" AND MARKING REQUIREMENTS,PROMULGATED UNDER THE SECURITIES AND EXCHANGE ACT OF 1934, ASAMENDED)



Resolution:


Consent












Censure


FINE $15,000.00





Allegations: CBOE ALLEGED THAT, FROM ON OR ABOUT MAY 1, 2013 THROUGH ON ORABOUT MAY 31, 2013, THE FIRM IMPROPERLY UTILIZED INDEPENDENTTRADING UNIT AGGREGATION IN THAT NUMEROUS INDIVIDUALS WEREASSIGNED TO MORE THAN ONE AGGREGATION UNIT AT A TIME. AS ARESULT, THE FIRM FAILED TO PROPERLY DETERMINE ITS NET POSITIONSIN SECURITIES FOR THE PURPOSE OF MARKING SELL ORDERS "LONG" OR "SHORT."INITIATED BY: CHICAGO BOARD OPTIONS EXCHANGE.



Resolution:

Other Sanctions Ordered: NONE

Sanction Details: FINE OF $15,000.00 WAS PAID ON 12/15/2014.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMSUBMITTED AN OFFER OF SETTLEMENT THAT WAS ACCEPTED BY THECBOE.


Settled

Disclosure 21 of 22

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Disclosure 21 of 22










Allegations: GTS SECURITIES LLC ("GTS"), A CBSX TRADING PERMIT HOLDER, WASCENSURED AND FINED $5,000 FOR THE FOLLOWING CONDUCT. GTSFAILED TO QUALIFY AND REGISTER ONE ASSOCIATED PERSON AS APROPRIETARY TRADER PRINCIPAL (TP) IN WEBCRD BY NOVEMBER 5, 2011.(EXCHANGE RULE 3.6A - QUALIFICATION AND REGISTRATION OF TRADINGPERMIT HOLDERS AND ASSOCIATED PERSONS)



Resolution:









Allegations: CBOE ALLEGED THAT GTS FAILED TO REGISTER AND QUALIFY ONEASSOCIATED PERSON AS A PROPRIETARY TRADER PRINCIPAL IN WEB CRDBY NOVEMBER 5TH, 2011.(ALLEGED VIOLATION OF EXCHANGE RULE 3.6A)













Resolution:


Sanction Details: CENSURE AND $5,000.00 FINE PAID TO THE CBOE ON 9/26/2013

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS GTS SECURITIES,LLC SUBMITTED AN OFFER OF SETTLEMENT WHICH WAS ACCEPTED BYTHE CBOE.



Disclosure 22 of 22

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Allegations: GTS SECURITIES, L.L.C. ("GTS"), CBOE STOCK EXCHANGE ("CBSX") PERMITHOLDER THAT CONDUCTS A PROPRIETARY TRADING BUSINESS IN STOCK,WAS FINED $5,000 FOR THE FOLLOWING CONDUCT. IN ACCEPTING THEOFFER OF SETTLEMENT, THE COMMITTEE CONSIDERED THAT THERESPONDENT CONDUCTED AML TRAINING FOR APPROPRIATE PERSONSUPON NOTICE OF THE DEFICIENCY BY THE EXCHANGE AND PRIOR TO THEEXIT INTERVIEW OF THE EXAMINATION. GTS FAILED TO CONDUCT AMLTRAINING FOR APPROPRIATE ASSOCIATED PERSONS. (CBOE RULES 4.2 -ADHERENCE TO LAW AND 4.20 - ANTI-MONEY LAUNDERING COMPLIANCEPROGRAM)











Resolution:


Sanction Details: GTS SECURITIES, L.L.C. SHALL BE AND HEREBY IS FINED IN THE AMOUNTOF FIVE THOUSAND DOLLARS ($5,000). IN ACCEPTING THE OFFER OFSETTLEMENT, THE COMMITTEE CONSIDERED THAT THE RESPONDENTCONDUCTED AML TRAINING FOR APPROPRIATE PERSONS UPON NOTICEOF THE DEFICIENCY BY THE EXCHANGE AND PRIOR TO THE EXITINTERVIEW OF THE EXAMINATION.

Sanctions Ordered: Monetary/Fine $5,000.00










Allegations: CBOE ALLEGED THAT GTS FAILED TO CONDUCT AML TRAINING FORCERTAIN ASSOCIATED PERSONS.



Resolution:


Sanction Details: MONETARY FINE OF $5,000.00 PAID TO THE CBOE ON JUNE 8TH, 2011.

Sanctions Ordered: Monetary/Fine $5,000.00







Sanction Details: MONETARY FINE OF $5,000.00 PAID TO THE CBOE ON JUNE 8TH, 2011.

Firm Statement GTS SECURITIES, LLC CONDUCTED AML TRAINING FOR THEAPPROPRIATE PERSONS UPON NOTICE OF THE DEFICIENCY BY THEEXCHANGE AND PRIOR TO THE CBOE'S EXIT INTERVIEW. GTS SECURITIES,LLC AGREED TO PAY A $5,000 FINE, BUT, DID NOT RECEIVE A CENSURE.






End of Report

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gts securities llcfirm profile class a member gts group us llc 75% or more no 10/2018 yes company...

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