7 May 2019
An AWC was issued in which the firm was censured and fined $25,000. Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it submitted Reportable Order Events (ROEs) to the Order Audit Trail System (OATS™) that contained inaccurate, incomplete, or improperly formatted data. The findings stated that the firm used a platform for its OATS reporting that was provided by a third-party vendor. The OATS violations were caused by system errors that developed when the firm’s vendor made changes to its platform. The errors were later remediated.