Fines & Wines

13 Episodes

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Enforcement Trends - Year in Review 2024

2025-01-0219:11

The TRADEliance consultants have been hard at work this year, so it has been a while since we were able to make a new episode for you. In this episode, Jesy and Kat share their observations regarding FINRA enforcement trends for 2024 in the Capital Market space. Those trends include: Founders Jesy and Kat share updates from 2024Rule 605 & 606 reportsMarket AccessFixed Income Trade Reporting (TRACE and RTRS)Best ExecutionTrade ConfirmationsPrevailing Market PriceReg SHO...

Enforcement Year in Review 2023

2023-11-0925:39

This episode focuses on the trends in FINRA Enforcement over the course 2023. TRADEliance discusses a several high level trends before doing a more in depth discussion on two topics: Manipulative Trading and Market Access. Jesy and Kat crack open some mediocre bubbly to celebrate this episode.Firms should take note of conducting thorough testing to prevent and detect system issues.Many of the trends in enforcement also highlight the need for training.Other topics discussed i...

Testing, Testing and More Testing

2023-05-1822:44

Listen in as TRADEliance discusses considerations for a robust Testing Plan. Drink every time we say testing…. No, not really, don't do that!We encourage firms to create a testing plan that goes beyond a 3120/206-7 testing obligationWritten Supervisory Procedures vs Supervisory Controls Procedures Testing samples should be targeted and random and targeted Think of testing vendors, systems and data as three of the pillars that will support a thorough testing planFINRA Guidance ...

So an Asset Manager Prices Some Bonds

2023-04-1317:46

Totals in Fines: Disgorgement: $11,000,000 + Prejudgment Interest $3,375,072, Firm Civil Penalty: $4,400,000, and Adviser Civil Penalty: $600,000 Jesy is drinking wine in the laundry room 😊 RulesInvestment Advisers Act Rule 206-2Investment Company Act Section 17(A)1 and 17(A)2Investment Adviser Act uses anti-fraud for Best ExecutionThe Asset Management Company was pricing the bond trades, not the broker dealers Asset Manager prices the executions, executions impact the evaluat...

Best Ex vs. Fair Pricing vs. Reasonable Comp

2023-03-1521:11

This episode takes a slightly different approach! Listen in as TRADEliance discusses the difference between best ex, fair pricing and reasonable compensation while highlighting some cases that support these differences. Best Execution: How is the Order Handled ? Fair Pricing: What is the actual price to the client? Reasonable Compensation: What is the BD entitled to charge for that trade? Are you supervising these topics separately? The disciplinary case...

TRADEliance Takes on FINRA Exam Priorities

2023-02-0932:05

Listen to Jesy and Kat discuss the 2023 Report on FINRA's Examination and Risk Monitoring Program! We couldn't cover everything in the 75 page report, but we do manage to tackle the following topics: Market Integrity Books and Records Firm Short Positions and Fails to Receive in Municipal SecuritiesReg BICATBest Execution Disclosure of Routing Information Fixed Income Fair Pricing, Fractional Shares and Reg SHO.Also - Jesy is sick and drinking boxed wine, while...

Brainstorming on Regulation Best Execution

2023-01-0515:40

Listen in as TRADEliance brainstorms their comment letter for the Regulation Best Execution Proposal! Topics discussed include: The Antifraud Provisions of the Exchange Act as the mechanism for enforcementConflicted TransactionsImpacts to Introducing BrokersUse of Last Look The need for consistency in definitionsRead the Proposal here. www.tradeliance.com TRADEliance consultants have the knowledge and first hand experience to improve your firm's trading operations or complia...

I've Got 99 Problems...And TRACE is All of Them

2022-12-1518:46

$675,000 fine for issues related to TRACE Trade Reporting. Let’s start a book club! The ladies are currently reading the Bond King by Mary Childs and had a fangirl moment when she acknowledges them on LinkedinKat and Jesy are on a quest for a good box wineItemized TRACE Issues (It’s a lot) Late Trades No Remuneration Indicator Non-member Affiliate trade reportsFactored corporate bonds SupervisionMajor theme: Systemic IssuesMake sure you are supervising reject...

The Problem with Customer Account Statements and Disclosures

2022-11-1121:00

$850,000 fine for issues related to statements and required disclosures The ladies share their love of Snoop Dogg and the Bond Dealers of America National Fixed Income eventStatements can be hardVendor Oversight is harderNegligent is the case that they gave me, I’m fresh up out my certification to FINRA that my systems are compliant.Read the full AWC here. www.tradeliance.com TRADEliance consultants have the knowledge and first hand experience to improve your firm's trading operations or com...

A Review of the Wall Street WhatsApp Fine-a-pa-looza

2022-10-2617:43

$1.1 billion in Fines between 16 firms, most firms being individually fined $125 Million Jesy is a picky pinot drinkerThe girls reminisce on their visit to Woodinville Winery Town in Washington. Thanks Adam!The trouble with carpooling…Bad books and records due to employees using personal text, email, and WhatsAppBYOD (bring your own device) and a pandemicWho is empowered to impact policies and procedures?Read the Press Release for these cases here. Read the Press Release for JP Morgan...

Trade Reporting and the Omission of the Short Sale Indicator

2022-10-2617:45

$250,000 for missing trade reporting indicators Kat finally gets to go to the grocery store Jesy drinks mystery anniversary wineTrade reporting issues due to system programmingSpecification manuals are fun!Does your firm have a trade reporting committee?Read the full AWC here. www.tradeliance.com TRADEliance consultants have the knowledge and first hand experience to improve your firm's trading operations or compliance processes. https://www.buymeacoffee.com/finesandwines Support the s...

The Trade Confirm Sample Size Conundrum

2022-10-2619:33

$2.8 Million Fine for Trade Confirmation Issues Jesy and Kat review an AWC listed in the August 2022 FINRA disciplinary actions report Jesy finds her favorite wine for cheapKat buys wine from a gas stationTrade Confirms and SupervisionSystematic issues and misunderstanding of regulationRead the AWC here. www.tradeliance.com TRADEliance consultants have the knowledge and first hand experience to improve your firm's trading operations or compliance processes. https://www.buymeacof...

Meet Fines and Wines

2022-10-2503:04

Introduction to Fines and Wines Meet Jesy LeBlanc and Kat Miller, the founders of TRADEliance. This brief episode shares how Jesy and Kat met and their passion for talking about financial regulation while drinking wine. TRADEliance is a consulting firm for broker dealer and investment adviser firms in the areas of trading operations and compliance. www.tradeliance.com Support the show

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Fines & Wines