Federal Information & News Dispatch, Inc. |
An
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"The market access rule is essential for protecting the markets, and
According to the
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*Did not have adequate controls at a point immediately prior to its submission of orders to the market, such as a control to compare orders leaving the router with those entered.
*Relied on financial risk controls that were not capable of preventing the entry of orders that exceeded pre-set capital thresholds for the firm in the aggregate.
*Did not link the account that received the executions on*Did not have adequate controls and procedures for code deployment and testing for its equity order router.
*Did not have sufficient controls and written procedures to guide employees' responses to significant technological and compliance incidents.
*Did not adequately review its business activity in connection with its market access to assure the overall effectiveness of its risk management controls and supervisory procedures. Its assessment largely focused on compiling an inventory of existing controls and ensuring they functioned as intended, instead of focusing on such risks as possible malfunctions in its automated order router. The firm also reacted to prior events too narrowly and did not adequately consider the root causes of previous incidents.
*Did not have an adequate written description of its risk management controls.
*Did not certify in its 2012 annual CEO certification that
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