• When Complex Rules Cause Complex Issues
    May 16 2025

    In this episode, TRADEliance founders, Jesy and Kat, review a high-profile enforcement action with a lot to unpack. So, pour yourself a glass of wine and listen as they discuss:

    • Failing to reasonably supervise the firm’s maintenance and reporting of accurate and complete trade, order, and position data such as:
      • Blue Sheets.
      • Reporting fractional shares to TRF and CAT reporting.
      • Mismarking option orders origin code.
      • Customer option positions to LOPR.
      • The firm's short interest positions.
    • Executing trades during trading halts and failing to comply with Reg NMS to address extraordinary market volatility.

    Also, send your recommendations for new wine openers to solutions@tradeliance.com!

    Read the FINRA Press Release here.

    TRADEliance consultants have the practical experience in Trading Operations & Compliance that help you achieve results. For a free needs assessment, contact solutions@tradeliance.com

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    26 mins
  • Enforcement Trends - Year in Review 2024
    Jan 2 2025

    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 2024
    • Rule 605 & 606 reports
    • Market Access
    • Fixed Income Trade Reporting (TRACE and RTRS)
    • Best Execution
    • Trade Confirmations
    • Prevailing Market Price
    • Reg SHO
    • Consolidated Audit Trail (CAT)

    So sit back, pour yourself a glass of wine, and listen to us share our take-aways on the 2024 FINRA fines.

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    19 mins
  • Enforcement Year in Review 2023
    Nov 9 2023

    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 include:
      • Trade Confirmations
      • Recordkeeping
      • 605/606
      • TRACE Trade Reporting
      • LOPR
      • Private Placements
      • Reg Sho
      • Best Ex
      • Market Orders for New Issues in the Secondary Market
      • Marking to Market Surveillance
      • CAT
      • Oversubscription of Partial Tender Offers

    For information on any of the cases discussed, contact solutions@tradeliance.com

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    26 mins
  • Testing, Testing and More Testing
    May 18 2023

    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 obligation
    • Written 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 plan

    FINRA Guidance on Supervision Topics

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    23 mins
  • Best Ex vs. Fair Pricing vs. Reasonable Comp
    Mar 15 2023

    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 cases discussed in this episode are listed below:

    • Best Execution Case #1
    • Best Execution Case #2
    • Best Execution Case #3
    • Fair Pricing Case #4
    • Fair Pricing Case #5
    • Reasonableness of Compensation Case #6
    • Reasonableness of Compensation Case #7

    Enjoy!

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    21 mins
  • TRADEliance Takes on FINRA Exam Priorities
    Feb 9 2023

    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 Securities
    • Reg BI
    • CAT
    • Best Execution
    • Disclosure of Routing Information
    • Fixed Income Fair Pricing, Fractional Shares and
    • Reg SHO.

    Also - Jesy is sick and drinking boxed wine, while Kat gets fancy enjoying some Prosecco.

    The link to the AWC Jesy referred to during the podcast is here.

    Enjoy!

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    32 mins
  • Brainstorming on Regulation Best Execution
    Jan 5 2023

    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 enforcement
    • Conflicted Transactions
    • Impacts to Introducing Brokers
    • Use of Last Look
    • The need for consistency in definitions

    Read the Proposal 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

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    16 mins
  • I've Got 99 Problems...And TRACE is All of Them
    Dec 15 2022

    $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 Linkedin
    • Kat and Jesy are on a quest for a good box wine
    • Itemized TRACE Issues (It’s a lot)
      • Late Trades
      • No Remuneration Indicator
      • Non-member Affiliate trade reports
      • Factored corporate bonds
      • Supervision
      • Major theme: Systemic Issues
    • Make sure you are supervising rejected trades
    • How inclusive is your supervisory reviews?

    Read 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.buymeacoffee.com/finesandwines

    Support the show

    Support the show

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    19 mins