Firm Settles FINRA Charges For OATS And OTCRF Reporting Failures

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Cadwalader, Wickersham & Taft LLP

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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 submit accurate trade information to the Order Audit Trail System ("OATS") and the Over-the-Counter Reporting Facility ("OTCRF").
United States Finance and Banking
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A firm settled FINRA charges for failing to submit accurate trade information to the Order Audit Trail System ("OATS") and the Over-the-Counter Reporting Facility ("OTCRF").

In a Letter of Acceptance, Waiver and Consent, FINRA found that the firm submitted reports to the OATS that contained inaccurate account type codes and order-received timestamps, in violation of FINRA Rules 7450(a) ("General Requirement") and 2010 ("Standards of Commercial Honor and Principles of Trade"). Additionally, FINRA found that the firm failed to include the riskless portion of the riskless-principal transactions in reports submitted to the OTCRF, in violation of FINRA Rule 6622(d)(3)(B) ("Reporting Principal and Riskless Principal Transactions - Exception"). The firm attributed all of the violations to its adoption of a new order management system.

To settle the charges, the firm agreed to (i) a censure and (ii) a $30,000 total fine, composed of a $16,000 fine for its violation of FINRA Rules 7450 and 2010, and a $14,000 fine for its violation of FINRA Rule 6622.

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