by Howard Haykin

Over the past 2 months, the New York Stock Exchange issued sanctions against the following member firms:

CLEARPOOL EXECUTION SERVICES, a NYSE member since 2015 … agreed to a $35K fine to settle charges that it violated:  (i) NYSE Rule 123C [Cancellation of Market on Close (MOC), Limit on Close (LOC), and Closing Offset (CO) Orders]; and, (ii) NYSE Rule 3110 (Supervision).  [Case #2017-11-00120]

MERIDIAN EQUITY PARTNERS, a NYSE member since 2005 … agreed to a $17.5K fine to settle charges that it violated: (i) Rule 15c3-5 of the Securities Exchange Act of 1934 (“Exchange Act”) by failing to establish, document, and maintain an adequate system of risk management controls and supervisory procedures, including those in connection with setting and adjusting credit limits and monitoring trading for potentially manipulative or otherwise violative activity; and, (ii) NYSE Rule 3110 by failing to establish and maintain WSPs and adequate supervisory policies and procedures.  [Case #2018-04-00047]

CREDIT SUISSE SECURITIES, a NYSE member since 1982 … agreed to a $12.5K fine to settle charges that it violated:  NYSE Rule 3110(b)(4) by failing to reasonably evidence the actions taken by the Firm as a result of any significant regulatory issues identified from its reviews of employee e-communications.  [Case #2017-05-00036]

RAYMOND JAMES & ASSOCIATES, a NYSE member since 1973 … agreed to a $400K fine to settle charges that it violated: (i) Rule 15c3-5 of the Exchange Act, by failing to establish, document, and maintain an adequate system of risk management controls and supervisory procedures; and, (ii) NYSE Rule 3110 and former NYSE Rule 342 (Supervision) in connection with its: (1) calculation and implementation of certain customer credit limits; (2) determination of certain erroneous order controls; and (3) conducting of annual reviews.  [Case #2016-07-01067]

QUATTRO M SECURITIES, et al … agreed to a $95K fine to settle charges that it and others violated: (i) Section 15(c)(3) of the Exchange Act and Rules 15c3-5(n) and (c)(2) thereunder, and NYSE Rules 342, 3110, and 3120 by failing to establish, maintain and enforce an adequate supervisory system and controls reasonably designed to achieve compliance with applicable laws, regs, and rules; (ii) NYSE Rules 342, 3110 and 2010 for failing to, among other things, have in place adequate supervisory system, including WSPs, to supervise handling of customer orders; (iii) NYSE Rules 405 and 2090 for failing to use due diligence to learn the essential facts relative to its customers and its customers’ orders and order handling instructions; and, (iv) Section 15(c)(3) of the Exchange Act … and NYSE Rules 342, 3110 and 3120 for failures to establish, maintain and enforce a reasonably designed system of credit limits and pre-trade controls.  [Case #’s 2016-07-01288; 2018-06-00079]