FINRA 2025 report. Partial info requiring firms to demonstrate written procedures. Here are some potential deficiencies being monitored:
Surveillance Deficiencies:
Not establishing and maintaining a surveillance system reasonably designed to monitor for potentially manipulative trading (e.g., potential layering, spoofing, wash trades, prearranged trades, marking the close, odd-lot manipulation) with parameters that are reasonably designed and documented.
Not adequately monitoring customer activity for patterns of potential manipulation, including potential prearranged trading across customers.
Not considering external sources for red flags (e.g., inquiries from regulators or service providers or publicly available information about known manipulators).
Not performing the timely review of surveillance alerts or exception reports.
Not dedicating sufficient resources and training to the review of surveillance alerts or exception reports.
Not documenting alert review findings.
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