global execution brokers, lp

BrokerCheck Report

GLOBAL EXECUTION BROKERS, LP

Section Title

Report Summary

Firm History

CRD# 126407

1

8

Firm Profile 2 - 7

Page(s)

Firm Operations 9 - 23

Disclosure Events 24

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CRD# 126407

SEC# 8-65878

Main Office Location

401 CITY AVENUEBALA CYNWYD, PA 19004

Mailing Address


Business Telephone Number

610-617-2600

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 16

Firm Profile

This firm is classified as a other types of legalformation.

This firm was formed in Delaware on 03/06/2003.

Its fiscal year ends in December.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 4 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm does not have referral or financialarrangements with other brokers or dealers.

This firm is registered with:

• the SEC• 22 Self-Regulatory Organizations• 1 U.S. state or territory

www.finra.org/brokercheck User Guidance

1©2022 FINRA. All rights reserved. Report about GLOBAL EXECUTION BROKERS, LP


http://www.finra.org/brokercheck

http://www.finra.org/brokercheck_reports


This firm is classified as a other types of legal formation.

This firm was formed in Delaware on 03/06/2003.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in December.


SEC#

126407

8-65878

Main Office Location

Mailing Address

Business Telephone Number

Doing business as GLOBAL EXECUTION BROKERS, LP

610-617-2600








This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

SUSQUEHANNA INTERNATIONAL GROUP, LLP

LIMITED PARTNER

75% or more

No

Domestic Entity

03/2003

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


DOHERTY, MICHAEL PATRICK

CHIEF COMPLIANCE OFFICER, SROP, CROP, ROP

Less than 5%

No

Individual

01/2004

No

703900



Position


Position Start Date

JAMACA, MELISSA

FINOP

Less than 5%

Individual

02/2022

7478107








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


SACK, ROBERT CHRISTOPHER

TREASURER, SECRETARY

Less than 5%

No

Individual

03/2017

No

2633481



Position



Position Start Date


SELLITTO, JOSEPH

CEO & PRESIDENT

Less than 5%

No

Individual

04/2006

Yes

1408978



SFG PARTNER, LLC

Domestic EntityIs this a domestic or foreignentity or an individual?







Direct Owners and Executive Officers (continued)

Firm Profile

Position



Position Start Date


GENERAL PARTNER

Less than 5%

No

Domestic Entity

03/2003

Yes







This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

SEALHOLTZ HOLDINGS, LLC

GENERAL PARTNER


75% or more

No

Domestic Entity

03/2020

No



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established




SFG HOLDINGS, LLC

MEMBER

SFG PARTNER, LLC

75% or more

No

Domestic Entity

01/2011

Yes









SIG HOLDING, LLC

SEALHOLTZ HOLDINGS, LLC AND MAHANOY HOLDINGS, LLC

Domestic Entity









Indirect Owners (continued)

Firm Profile

SOLE MEMBER

SEALHOLTZ HOLDINGS, LLC AND MAHANOY HOLDINGS, LLC

75% or more

No

03/2020

Yes







MAHANOY HOLDINGS, LLC

GENERAL PARTNER


Other General Partners

No

Domestic Entity

03/2020

No














Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.






Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.

This firm is currently registered with the SEC, 22 SROs and 1 U.S state or territory.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

No

No

No

Federal Regulator Status Date Effective

SEC Approved 09/23/2003

Self-Regulatory Organization Status Date Effective

BOX Exchange LLC Approved 05/07/2012

Cboe BYX Exchange, Inc. Approved 10/05/2010

Cboe BZX Exchange, Inc. Approved 02/01/2010

Cboe C2 Exchange, Inc. Approved 09/24/2010

Cboe EDGA Exchange, Inc. Approved 12/01/2015

Cboe EDGX Exchange, Inc. Approved 10/15/2015

Cboe Exchange, Inc. Approved 09/23/2003

Investors' Exchange LLC Approved 08/02/2016

MEMX LLC Approved 09/10/2020

MIAX Emerald, LLC Approved 03/01/2019

MIAX PEARL, LLC Approved 02/06/2017

Miami International Securities Exchange,LLC

Approved 12/07/2012

NYSE American LLC Approved 06/01/2007

NYSE Arca, Inc. Approved 09/15/2008

NYSE Chicago, Inc. Approved 10/27/2016






NYSE National, Inc. Approved 05/18/2018

Nasdaq BX, Inc. Approved 02/02/2016

Nasdaq GEMX, LLC Approved 07/29/2013

Nasdaq ISE, LLC Approved 01/15/2004

Nasdaq MRX, LLC Approved 02/10/2016

Nasdaq PHLX LLC Approved 04/01/2008

Nasdaq Stock Market Approved 02/11/2016





Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Pennsylvania Approved 12/09/2003






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

Other Types of Business

This firm does effect transactions in commodities, commodity futures, or commodity options.This firm does not engage in other non-securities business.

Non-Securities Business Description:

This firm currently conducts 4 types of businesses.

Types of Business

Exchange member engaged in exchange commission business other than floor activities

Exchange member engaged in floor activities

Put and call broker or dealer or option writer

Other - OPTIONS BROKERAGE, VIRTUAL CURRENCY TRADING






Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does not refer or introduce customers to other brokers and dealers.






Firm Operations

Industry Arrangements

This firm does have books or records maintained by a third party.

This firm does have accounts, funds, or securities maintained by a third party.

This firm does not have customer accounts, funds, or securities maintained by a third party.

This firm does not have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

Control Persons/Financing

Name: MERRILL LYNCH PROFESSIONAL CLEARING CORP.

Business Address: 101 HUDSON ST.JERSEY CITY, NJ 07302

CRD #: 16139

Effective Date: 03/10/2003

Description: MERRIL LYNCH PROFESSIONAL CLEARING CORP. IS THE CLEARINGFIRM FOR GLOBAL EXCHANGE BROKERS.

Name: MERRILL LYNCH PROFESSIONAL CLEARING CORP.

Business Address: 101 HUDSON ST.JERSEY CITY, NJ 07302

CRD #: 16139

Effective Date: 03/10/2003

Description: MERRIL LYNCH PROFESSIONAL CLEARING CORP. IS THE CLEARINGFIRM FOR GLOBAL EXCHANGE BROKERS.






Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

No

Yes

CAYMAN ISLAND

Yes

07/14/2015

WINWARD 1REGATTA OFFICE PARKGRAND CAYMAN, CAYMAN ISLANDS KY1-1103

CVI INVESTMENTS, INC is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND CVI INVESTMENTS, INC. ARE SUBSTANTIALLY THE SAME

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

03/12/2014

1201 N ORANGE STWILMINGTON, DE 19801

SAL TRADING, LLC is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SAL TRADING, LLC ARE SUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

GEORGE'S DOCK HOUSE4TH FLOORIFSC DUBLIN 1, IRELAND KY1-1103

SUSQUEHANNA INTERNATIONAL GROUP LIMITED is under common control with the firm.

Business Address: 15©2022 FINRA. All rights reserved. Report about GLOBAL EXECUTION BROKERS, LP





Firm Operations

Organization Affiliates (continued)

No

Yes

IRELAND

Yes

03/12/2014

GEORGE'S DOCK HOUSE4TH FLOORIFSC DUBLIN 1, IRELAND KY1-1103

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SUSQUEHANNA INTERNATIONAL GROUP LIMITED ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

03/12/2014

401 CITY AVESUITE 220BALA CYNWYD, PA 19004

SUSQUEHANNA ADVISORS GROUP, INC. is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SUSQUEHANNA ADVISORS GROUP, INC. ARE SUBSTANTIALLY THESAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

03/12/2014


SUSQUEHANNA FUNDAMENTAL INVESTMENTS, LLC is under common control with the firm.


Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


No

Yes

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SUSQUEHANNA FUNDAMENTAL INVESTMENTS, LLC ARESUBSTANTIALLY THE SAME.

Description:



No

Yes

No

03/12/2014


HEIGHTS CAPITAL MANAGEMENT, INC. is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND HEIGHTS CAPITAL MANAGEMENT, INC. ARE SUBSTANTIALLY THESAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

03/12/2014


SUSQUEHANNA CLEARING, LLC is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SUSQUEHANNA CLEARING, LLC ARE SUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

111528

G1 EXECUTION SERVICES, LLC is under common control with the firm.

CRD #: 17©2022 FINRA. All rights reserved. Report about GLOBAL EXECUTION BROKERS, LP





Firm Operations


No

Yes

No

02/10/2014

440 S. LASALLE STREETSUITE 3030CHICAGO, IL 60605-1028

111528

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND G1 EXECUTION SERVICES, LLC ARE SUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

No

06/25/2003


SUSQUEHANNA GOVERNMENT PRODUCTS, LLLP is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SUSQUEHANNA GOVERNMENT PRODUCTS, LLLP ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

03/10/2003


35865

SUSQUEHANNA FINANCIAL GROUP, LLLP is under common control with the firm.


Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


No

Yes

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SUSQUEHANNA FINANCIAL GROUP, LLLP ARE SUBSTANTIALLY THESAME.

Description:



No

Yes

No

03/10/2003

1201 N. ORANGE ST.WILMINGTON, DE 19801

DARBY FINANCIAL PRODUCTS is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND DARBY FINANCIAL PRODUCTS ARE SUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

03/10/2003

1201 N. ORANGE ST.SUITE 715WILMINGTON, DE 19801

SIG STRUCTURED PRODUCTS, LLC is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SIG STRUCTURED PRODUCTS, LLC ARE SUBSTANTIALLY THESAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

GEORGE'S DOCK HOUSE4TH FLOORDUBLIN 1, IRELAND K

SUSQUEHANNA INTERNATIONAL SECURITIES LIMITED is under common control with the firm.

Business Address:






Firm Operations


No

Yes

IRELAND

Yes

03/10/2003

GEORGE'S DOCK HOUSE4TH FLOORDUBLIN 1, IRELAND K

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SUSQUEHANNA INTERNATIONAL SECURITIES LIMITED ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

03/10/2003

140 BROADWAY47TH FLNEW YORK, NY 10005

100400

SIG BROKERAGE, LP is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SIG BROKERAGE, LP ARE SUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

IRELAND

Yes

03/10/2003

GEORGE DOCK HOUSEIFSCDUBLIN, DUBLIN KY1-1103

SUSQUEHANNA IRELAND LIMITED is under common control with the firm.


Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


No

Yes

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SUSQUEHANNA IRELAND LIMITED ARE SUBSTANTIALLY THE SAME.

Description:



No

Yes

AUSTRALIA

Yes

03/10/2003

2 CHIFLEY SQUARELEVEL 41SYDNEY-NSW 2000,, AUSTRALIA

SUSQUEHANNA PACIFIC PTY LTD is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SUSQUEHANNA PACIFIC PTY LIMITED ARE SUBSTANTIALLY THESAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

CAYMAN ISLANDS

Yes

03/10/2003

WINWARD 1REGATTA OFFICE PARKGRAND CAYMAN, CAYMAN ISLANDS KY1-1103

CAPITAL VENTURES INTERNATIONAL is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND CAPITAL VENTURES INTERNATIONAL ARE SUBSTANTIALLY THESAME

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

29337

SAL EQUITY TRADING, GP is under common control with the firm.

CRD #:






Firm Operations


No

Yes

No

03/10/2003

401 CITY LINE AVENUEBALA CYNWYD, PA 19004

29337

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SAL EQUITY TRADING, GP ARE SUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

No

03/10/2003

401 CITY AVEBALACYNWYD, PA 19004

35874

SUSQUEHANNA SECURITIES, LLC is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SUSQUEHANNA SECURITIES, LLC ARE SUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

No

03/10/2003

401 CITY AVEBALACYNWYD, PA 19004

33875

SUSQUEHANNA INVESTMENT GROUP is under common control with the firm.



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


No

THE ULTIMATE BENEFICIAL OWNERS OF GLOBAL EXECUTION BROKERS,LP AND SUSQUEHANNA INVESTMENT GROUP ARE SUBSTANTIALLY THESAME.

Description:


This firm is not directly or indirectly, controlled by the following:

· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank






Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 16 0






Disclosure Event Details

What you should know about reported disclosure events:

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2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a

particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:

o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.

4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.

§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently

being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,

or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

§ A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons.

§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.

5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.

Regulatory - Final

This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.

Disclosure 1 of 16

Reporting Source: Regulator

Allegations: GLOBAL EXECUTION BROKERS, LP VIOLATED SECTION 17(A) OF THEEXCHANGE ACT AND RULE 17A-3(A)(6)(I) THEREUNDER, AND EDGX RULES3.2, 18.1, 18.2, 20.7, AND 24.1 IN THAT THE FIRM EXECUTED ORDERS WITHMISMARKED ORIGIN CODES ON EDGX; VIOLATED EDGX RULE 5.1 IN THATTHE FIRM FAILED TO ESTABLISH AND MAINTAIN WRITTEN SUPERVISORYPROCEDURES AND SUPERVISORY SYSTEM PROTOCOLS THAT ENABLED ITTO PROPERLY SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONSAND ASSURE THEIR COMPLIANCE WITH SECTION 17(A) OF THE EXCHANGEACT AND RULE 17A-3(A)(6)(I) THEREUNDER, AND EDGX RULES 18.2, 20.7,AND 24.1, AS SUCH RULES RELATE TO ORIGIN CODE USAGE.

Current Status: Final






Initiated By: CBOE EDGX EXCHANGE, INC.

Principal Sanction(s)/ReliefSought:

Civil and Administrative Penalt(ies) /Fine(s)

Other Sanction(s)/ReliefSought:

Date Initiated: 04/28/2021

Docket/Case Number: FILE NOS. USRI-9064-04 AND USRI-8152-04

Principal Product Type: Options

Other Product Type(s):

Allegations: GLOBAL EXECUTION BROKERS, LP VIOLATED SECTION 17(A) OF THEEXCHANGE ACT AND RULE 17A-3(A)(6)(I) THEREUNDER, AND EDGX RULES3.2, 18.1, 18.2, 20.7, AND 24.1 IN THAT THE FIRM EXECUTED ORDERS WITHMISMARKED ORIGIN CODES ON EDGX; VIOLATED EDGX RULE 5.1 IN THATTHE FIRM FAILED TO ESTABLISH AND MAINTAIN WRITTEN SUPERVISORYPROCEDURES AND SUPERVISORY SYSTEM PROTOCOLS THAT ENABLED ITTO PROPERLY SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONSAND ASSURE THEIR COMPLIANCE WITH SECTION 17(A) OF THE EXCHANGEACT AND RULE 17A-3(A)(6)(I) THEREUNDER, AND EDGX RULES 18.2, 20.7,AND 24.1, AS SUCH RULES RELATE TO ORIGIN CODE USAGE.

Resolution Date: 05/04/2021

Resolution:

Other Sanctions Ordered:

Sanction Details: A CENSURE AND A MONETARY FINE OF $160,000, OF WHICH $6,500 SHALLBE PAID TO EDGX.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: CensureMonetary/Fine $6,500.00

Consent

iReporting Source: Firm

Allegations: FOR THE SOLE PURPOSE OF SETTLING THE DISCIPLINARY PROCEEDING,WITHOUT ADJUDICATING ANY ISSUES OF LAW OR FACT, AND WITHOUTADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, THE FIRMCONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITRECEIVED ORDERS WITH BROKER-DEALER CUSTOMER ORIGIN CODESAND EXECUTED SUCH ORDERS WITH A CUSTOMER ORIGIN CODE, ANDEXECUTED ORDERS IN CLASSES WHERE THE ORIGINATING FIRM WAS AREGISTERED MARKET MAKER ON THE BZX THAT WERE MARKED WITH AN "M" (MARKET-MAKER) ORIGIN CODE, HOWEVER, THE ORIGINATINGMARKET-MAKER ACCOUNTS NOTED ON THE ORDERS WERE NOTREGISTERED AS APPROVED MARKET- MAKERS WITH BZX. IN ADDITION,THE FIRM CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TOENSURE THAT ITS SYSTEM PROTOCOLS HAD BEEN UPDATED TO INCLUDETHE ADDITION OF THE BROKER-DEALER ORIGIN CODE, AND ITCONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH,MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES ANDSUPERVISORY SYSTEM PROTOCOLS REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH THE RULES RELATING TO ACCURATE ORIGIN CODEUSAGE IN THAT THEY DID NOT PROVIDE FOR A REVIEW FOR THEACCURACY OF ORIGINATING ACCOUNTS ASSOCIATED WITH ORIGINCODES.







Initiated By: CBOE EDGX EXCHANGE, INC.





Docket/Case Number: USRI-9604 AND USRI-8152-04





Resolution:


Sanction Details: A CENSURE AND A FINE OF $6500


Acceptance, Waiver & Consent(AWC)

Disclosure 2 of 16

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Initiated By: CBOE BZX EXCHANGE, INC.





Docket/Case Number: FILE NOS. USRI-9064-03 AND USRI-8152-03



Allegations: GLOBAL EXECUTION BROKERS, LP VIOLATED SECTION 17(A) OF THEEXCHANGE ACT AND RULE 17A-3(A)(6)(I) THEREUNDER, AND BZX RULES3.2, 18.1, 18.2, 20.7, AND 24.1 IN THAT THE FIRM EXECUTED ORDERS WITHMISMARKED ORIGIN CODES ON BZX; VIOLATED BZX RULE 5.1 IN THAT THEFIRM FAILED TO ESTABLISH AND MAINTAIN WRITTEN SUPERVISORYPROCEDURES AND SUPERVISORY SYSTEM PROTOCOLS THAT ENABLED ITTO PROPERLY SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONSAND ASSURE THEIR COMPLIANCE WITH SECTION 17(A) OF THE EXCHANGEACT AND RULE 17A-3(A)(6)(I) THEREUNDER, AND BZX RULES 18.2, 20.7, AND24.1, AS SUCH RULES RELATE TO ORIGIN CODE USAGE.



Resolution:


Sanction Details: A CENSURE AND A MONETARY FINE OF $160,000, OF WHICH $153,500SHALL BE PAID TO BZX.


No


Consent

iReporting Source:






Reporting Source: Firm

Initiated By: CBOE BZX EXCHANGE, INC.





Docket/Case Number: USRI-9064-03 AND USRI-8152-03






Resolution:


Sanction Details: A CENSURE AND A FINE OF $153,500








Sanction Details: A CENSURE AND A FINE OF $153,500

Disclosure 3 of 16

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Initiated By: NYSE ARCA, INC.



Docket/Case Number: 2017-06-00062, 2017-10-00077, 2018-03-00051, 2019-01-00011



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATEDNYSE ARCA RULE 11.18 BY FAILING TO ESTABLISH AND MAINTAINADEQUATE SUPERVISORY SYSTEMS AND WRITTEN PROCEDURES THATWERE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH NYSEARCA RULES RELATING TO TRADE NULLIFICATION AND ADJUSTMENT ANDIN CONNECTION WITH EXECUTING CUSTOMER ORDERS. THE FINDINGSSTATED THAT THE FIRM'S WSPS DID NOT ADDRESS BUST AND ADJUSTREQUIREMENTS AND THE FIRM DID NOT HAVE ANY REVIEWS IN PLACERELATED TO COMPLIANCE WITH ITS BUST/ADJUST OBLIGATION.ADDITIONALLY, THE FIRM FAILED TO HAVE SUPERVISORY SYSTEMSREASONABLY DESIGNED TO COMPLY WITH ITS OBLIGATIONS INCONNECTION WITH EXECUTING CUSTOMER ORDERS. SPECIFICALLY, INTWO TIED-TO-STOCK OPTION ORDERS, A TRADER FOR AN OPTIONSMARKET MAKER AND LIQUIDITY PROVIDER (SUS) INSTRUCTED A FIRMCLERK TO SHOW ONLY THE OPTION LEG OF THE ORDER TO AN NYSEFLOOR BROKER, AND IN ONE TWO-LEGGED OPTION TRADE, THE SUSTRADER INSTRUCTED ANOTHER FIRM CLERK TO EXECUTE ONE LEG ONNYSE ARCA AND ONE ON ANOTHER EXCHANGE. THE SUS TRADER, WHOREPRESENTED THE COUNTERPARTY ON EACH OF THESE TRANSACTIONS,TESTIFIED THAT HE MADE ALL OF THOSE DECISIONS, NOT THE FIRM ORTHE BROKER/SALES TRADER AFFILIATE (SFG) FOR WHOM THE FIRM ACTSAS AGENCY BROKER, AND THAT HE MADE THEM WITH THE BESTINTERESTS OF SFG'S CUSTOMERS IN MIND. HOWEVER, SUS DOES NOTOWE A DUTY OF BEST EXECUTION TO SFG'S CUSTOMER, AND THEREFORESHOULD NOT BE THE PARTY MAKING DECISIONS ABOUT WHAT'S IN THEBEST INTERESTS OF THE CUSTOMER. RATHER, THE FIRM AND SFGSHOULD BE MAKING THOSE DECISIONS.










Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: THE FIRM IS CENSURED, FINED $70,000, AND AGREES TO PROVIDE ACERTIFICATION THAT IT HAS DEVELOPED AND IMPLEMENTED CONTROLSAND PROCEDURES REASONABLY DESIGNED TO ADDRESS THEDEFICIENCIES DESCRIBED IN THE AWC.


No




Initiated By: NYSE ARCA, INC.





Docket/Case Number: 2017-06-00062, 2017-01-00077, 2018-03-00051, 25019-01-0001



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTSTO SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTENSUPERVISORY PROCEDURES REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH ITS BUST AND ADJUST OBLIGATIONS, AND ITSOBLIGATIONS IN CONNECTION WITH EXECUTING CLIENT ORDERS.









Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: CENSURE, FINE IN THE AMOUNT OF $70,000, AND AN UNDERTAKING TOPROVIDE A CERTIFICATION THAT THE FIRM HAS DEVELOPED ANDIMPLEMENTED CONTROLS AND PROCEDURES REASONABLY DESIGNEDTO ADDRESS THE ALLEGED DEFICIENCIES DESCRIBED IN THE ENTRY OFFINDINGS.



Disclosure 4 of 16

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Initiated By: CHICAGO BOARD OPTIONS EXCHANGE





Docket/Case Number: 17-0044/ 20150472707



Allegations: GLOBAL EXECUTION BROKERS, LP, AN EXCHANGE TPH ORGANIZATIONWAS CENSURED AND FINED $10,000 FOR: (I) SUBMITTING AIM ORDERS INMULTIPLE VIX OPTIONS SERIES WITH AN APPOINTED MARKET-MAKER ONTHE MATCHED ORDER, RESULTING IN THE IMPROPER EXECUTIONS OFAPPROXIMATELY 4,706 OPTION CONTRACTS; (II) FAILED TO ESTABLISH,MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND ASYSTEM FOR APPLYING SUCH PROCEDURES AS THEY RELATE TOEXCHANGE RULE 6.74A; AND (III) FAILED TO ADEQUATELY SUPERVISE ITSASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH EXCHANGE RULE6.74A. (EXCHANGE RULES 4.2 - ADHERENCE TO LAW, 4.24 - SUPERVISIONAND 6.74A - AUTOMATED IMPROVEMENT MECHANISM ("AIM") WERE INFULL FORCE AND EFFECT.)









Resolution:


Sanction Details: A $10,000 FINE AND A CENSURE.


Consent


Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA")ON BEHALF OFTHE CHICAGO OPTIONS EXCHANGE, INCORPORATED ("CBOE")





Docket/Case Number: 20150472707



Allegations: SHOULD READ: WITHOUT ADMITTING OR DENYING THE FINDINGS, GEBCONSENTS TO SANCTIONS AND TO THE ENTRY OF FINDINGS THAT,DURING THE APPROXIMATE TIME PERIOD FROM ON OR ABOUT JULY 1,2015 THROUGH ON OR ABOUT DECEMBER 31, 2015, ON APPROXIMATELY1,214 AIM AUCTIONS, GEB SUBMITTED AIM ORDERS IN MULTIPLE VIXOPTIONS SERIES WITH AN APPOINTED MARKET MAKER ON THE MATCHEDORDER, RESULTING IN THE IMPROPER EXECUTION OF APPROXIMATELY4,706 OPTION CONTRACTS, AND FAILED TO ESTABLISH, MAINTAIN ANDENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM FORAPPLYING SUCH PROCEDURES AS THEY RELATE TO CBOE RULE 6.74A.GEB ALSO CONSENTS TO THE FINDINGS THAT, DURING THE APPROXIMATEPERIOD FROM ON OR ABOUT MARCH 11, 2016 THROUGH ON OR ABOUTJULY 22, 2016, GEB FAILED TO ADEQUATELY SUPERVISE IT'S ASSOCIATEDPERSONS TO ASSURE COMPLIANCE WITH CBOE RULE 6.74A.


Resolution: Consent33©2022 FINRA. All rights reserved. Report about GLOBAL EXECUTION BROKERS, LP






Resolution:


Sanction Details: A CENSURE AND A FINE FOR $10,000.00


Consent

Disclosure 5 of 16

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Docket/Case Number: 17-0040/ 20150466716



Allegations: IT IS ALLEGED THAT GEB: (I) ON NUMEROUS OCCASIONS, FAILED TOGRANT PRIORITY TO THE HIGHEST BID AND/OR LOWEST OFFER WHENSUCH BID OR OFFER WAS AVAILABLE; (II) ON NUMEROUS OCCASIONS,TRADED THROUGH THE NATIONAL BEST BID OR OFFER; AND (III) FAILEDTO SUPERVISE ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITHEXCHANGE RULES 6.45B AND 6.81. (VIOLATIONS OF EXCHANGE RULE 4.2,6.45B AND 6.81)

Current Status: Pending


Allegations: WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, THEFIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGSTHAT, ON MULTIPLE OCCASIONS, IT FAILED TO GRANT PRIORITY TO THEHIGHEST BID AND/OR LOWEST OFFER WHEN SUCH BID OR OFFER WASAVAILABLE, FAILED TO USE DUE DILIGENCE TO EXERCISE ORDERS AT THEBEST PRICES AVAILABLE, TRADED THROUGH THE NATIONAL BEST BID OROFFER; AND FAILED ASSURE COMPLIANCE WITH CBOE RULES 6.45B AND6.73, AND SUPERVISE ITS ASSOCIATED PERSONS TO ASSURECOMPLIANCE WITH CBOE RULES 6.45B AND 6.81.







Initiated By: CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED





Docket/Case Number: 15-0016 AND 17-0040 / 20150439259 AND 20150466716



WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, THEFIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGSTHAT, ON MULTIPLE OCCASIONS, IT FAILED TO GRANT PRIORITY TO THEHIGHEST BID AND/OR LOWEST OFFER WHEN SUCH BID OR OFFER WASAVAILABLE, FAILED TO USE DUE DILIGENCE TO EXERCISE ORDERS AT THEBEST PRICES AVAILABLE, TRADED THROUGH THE NATIONAL BEST BID OROFFER; AND FAILED ASSURE COMPLIANCE WITH CBOE RULES 6.45B AND6.73, AND SUPERVISE ITS ASSOCIATED PERSONS TO ASSURECOMPLIANCE WITH CBOE RULES 6.45B AND 6.81.


Resolution:


Sanction Details: A FINE OF $5000.00 AND A CENSURE.

Firm Statement 20150466716 AND 201504939259 WERE COMBINED.



Disclosure 6 of 16

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Allegations: DURING THE REVIEW PERIOD, ON MULTIPLE OCCASIONS, AN AFFILIATE OFGLOBAL EXECUTION BROKERS ("GEB") RECEIVED CUSTOMER ORDERSVIA THE TELEPHONE AND WITHOUT CREATING A RECORD OF THE ORDER,COMMUNICATED THE DETAILS OF THE ORDER TO A CLERK AT GEB. THEGEB CLERK WOULD THEN COMMUNICATE THE PARAMETERS OF THEORDER TO A BLOCK FACILITATION TRADER AT ANOTHER AFFILIATE, ALSOWITHOUT CREATING A RECORD OF THE ORDER. FOLLOWING THEEXECUTION OF THE CUSTOMER ORDER, THE GEB CLERK WOULDTHEREAFTER CREATE AN ORDER TICKET WHICH IDENTIFIED THEPARAMETER OF THE ORDER, AS WELL AS THE EXECUTION DETAILS.HOWEVER NO RECORD OF THE ORDER WAS CREATED AT THE TIME THEORDER WAS RECEIVED.

THIS CONDUCT VIOLATES EXCHANGE ACT RULE 17A3(A)(6)(I), AND ISERULES 401 AND 1400(A).







Initiated By: INTERNATIONAL SECURITIES EXCHANGE





Docket/Case Number: 2012-067



DURING THE REVIEW PERIOD, ON MULTIPLE OCCASIONS, AN AFFILIATE OFGLOBAL EXECUTION BROKERS ("GEB") RECEIVED CUSTOMER ORDERSVIA THE TELEPHONE AND WITHOUT CREATING A RECORD OF THE ORDER,COMMUNICATED THE DETAILS OF THE ORDER TO A CLERK AT GEB. THEGEB CLERK WOULD THEN COMMUNICATE THE PARAMETERS OF THEORDER TO A BLOCK FACILITATION TRADER AT ANOTHER AFFILIATE, ALSOWITHOUT CREATING A RECORD OF THE ORDER. FOLLOWING THEEXECUTION OF THE CUSTOMER ORDER, THE GEB CLERK WOULDTHEREAFTER CREATE AN ORDER TICKET WHICH IDENTIFIED THEPARAMETER OF THE ORDER, AS WELL AS THE EXECUTION DETAILS.HOWEVER NO RECORD OF THE ORDER WAS CREATED AT THE TIME THEORDER WAS RECEIVED.

THIS CONDUCT VIOLATES EXCHANGE ACT RULE 17A3(A)(6)(I), AND ISERULES 401 AND 1400(A).


Resolution:


Sanction Details: FIRM FINED $55,000. GEB ALSO REQUIRED TO REVISE ITS POLICIES &PROCEDURES.


No




Allegations: DURING THE PERIOD OF JUNE 2010 AND OCTOBER 2014 (THE "REVIEWPERIOD"), THE FIRM FAILED TO CONSISTENTLY, MAKE AND KEEP AMEMORANDUM OF EACH BROKERAGE ORDER SHOWING, AMONG OTHERTHINGS, THE TIME THE ORDER IS TRANSMITTED FOR EXECUTION, ANDTHE TIME OF EXECUTION OR CANCELLATION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT") AND ISE RULES 401 AND 1400(A).







Initiated By: INTERNATIONAL SECURITIES EXCHANGE, LLC









Resolution:

Other Sanctions Ordered: REVISE ITS POLICIES AND PROCEDURES INCLUDING ITS WRITTENSUPERVISORY PROCEDURES TO ENSURE SUFFICIENT OVERSIGHT ANDREVIEW BY THE FIRM WITH RESPECT TO THE MAKING AND KEEPING OF, ACURRENT MEMORANDUM AT THE TIME OF ENTRY, OF EACH BROKERAGEORDER SHOWING, AMONG OTHER THINGS, THE CORRECT TIME THEORDER WAS RECEIVED.

Sanction Details: A FINE OF $55,000



Disclosure 7 of 16

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Allegations: GLOBAL EXECUTION BROKERS, LP ("GEB"), AN EXCHANGE TPHORGANIZATION, WAS CENSURED AND FINED $20,000 FOR THE CONDUCTDESCRIBED BELOW. GEB: (I) FAILED TO REGISTER THREE (3) ASSOCIATEDPERSONS AS A PROPRIETARY TRADER (PT) WITH THE EXCHANGE INWEBCRD; (II) FAILED TO REGISTER THE MINIMUM NUMBER OFINDIVIDUALS REQUIRED TO REGISTER AS A PROPRIETARY TRADERPRINCIPAL (TP) WITH THE EXCHANGE IN WEBCRD; (III) FAILED TOREGISTER ONE (1) ASSOCIATED PERSON AS A PROPRIETARY TRADERPRINCIPAL (TP) WITH THE EXCHANGE IN WEBCRD; (IV) FAILED TOREGISTER ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADERCOMPLIANCE OFFICER (CT) WITH THE EXCHANGE IN WEBCRD; AND (IV)FAILED TO REGISTER ITS FINANCIAL AND OPERATIONS PRINCIPAL AS AFINANCIAL AND OPERATIONS PRINCIPAL (FN) WITH THE EXCHANGE INWEBCRD. (EXCHANGE RULE 3.4 - QUALIFICATION AND REGISTRATION)







Initiated By: C2 OPTIONS EXCHANGE, INCORPORATED





Docket/Case Number: C2 15-0009/STAR 20150459662



GLOBAL EXECUTION BROKERS, LP ("GEB"), AN EXCHANGE TPHORGANIZATION, WAS CENSURED AND FINED $20,000 FOR THE CONDUCTDESCRIBED BELOW. GEB: (I) FAILED TO REGISTER THREE (3) ASSOCIATEDPERSONS AS A PROPRIETARY TRADER (PT) WITH THE EXCHANGE INWEBCRD; (II) FAILED TO REGISTER THE MINIMUM NUMBER OFINDIVIDUALS REQUIRED TO REGISTER AS A PROPRIETARY TRADERPRINCIPAL (TP) WITH THE EXCHANGE IN WEBCRD; (III) FAILED TOREGISTER ONE (1) ASSOCIATED PERSON AS A PROPRIETARY TRADERPRINCIPAL (TP) WITH THE EXCHANGE IN WEBCRD; (IV) FAILED TOREGISTER ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADERCOMPLIANCE OFFICER (CT) WITH THE EXCHANGE IN WEBCRD; AND (IV)FAILED TO REGISTER ITS FINANCIAL AND OPERATIONS PRINCIPAL AS AFINANCIAL AND OPERATIONS PRINCIPAL (FN) WITH THE EXCHANGE INWEBCRD. (EXCHANGE RULE 3.4 - QUALIFICATION AND REGISTRATION)


Resolution:




Decision & Order of Offer of Settlement


Initiated By: C2 OPTIONS EXCHANGE, INCORPORATED



Allegations: IT IS ALLEGED THAT THE FIRM, FROM ON OR ABOUT MAY 21, 2014THROUGH ON OR ABOUT MARCH 18, 2015, FAILED TO REGISTER THREEASSOCIATED PERSONS AS PROPRIETARY TRADER WITH THE EXCHANGEIN WEBCRD. IT IS ALSO ALLEGED THAT THE FIRM, FROM ON OR ABOUTMAY 21, 2014 THROUGH ON OR ABOUT FEBRUARY 12, 2015, FAILED TOREGISTER THE MINIMUM NUMBER OF INDIVIDUALS REQUIRED TOREGISTER AS PROPRIETARY TRADER PRINCIPAL, ONE ASSOCIATEDPERSON AS A PROPRIETARY TRADER PRINCIPAL, ITS CHIEF COMPLIANCEOFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER, AND ITSFINANCIAL AND OPERATIONS PRINCIPAL AS A FINANCIAL AND OPERATIONSPRINCIPAL WITH THE EXCHANGE IN WEBCRD.













Resolution:





Disclosure 8 of 16

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Allegations: THE FIRM: (I) ON MULTIPLE OCCASIONS, FAILED TO GRANT PRIORITY TOTHE HIGHEST BID AND/OR LOWEST OFFER WHEN SUCH BID OR OFFERWAS AVAILABLE AND, ON MULTIPLE OCCASIONS, FAILED TO USE DUEDILIGENCE TO EXECUTE ORDERS AT THE BEST PRICES AVAILABLE; (II) ONMULTIPLE OCCASIONS, FAILED TO GRANT PRIORITY TO THE HIGHEST BIDAND/OR LOWEST OFFER WHEN SUCH BID OR OFFER WAS AVAILABLE; (III)ON MULTIPLE OCCASIONS, TRADED THROUGH THE NATIONAL BEST BIDOR OFFER; (IV) FAILED TO ASSURE COMPLIANCE WITH EXCHANGE RULES6.45B AND 6.73; AND (V) FAILED TO SUPERVISE ITS ASSOCIATED PERSONSTO ASSURE COMPLIANCE WITH EXCHANGE RULES 6.45B AND 6.81.VIOLATIONS OF EXCHANGE RULES 4.2, 6.45B, 6.73 AND 6.81.









Resolution:














Allegations: WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, THEFIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGSTHAT, ON MULTIPLE OCCASIONS, IT FAILED TO GRANT PRIORITY TO THEHIGHEST BID AND/OR LOWEST OFFER WHEN SUCH BID OR OFFER WASAVAILABLE, FAILED TO USE DUE DILIGENCE TO EXERCISE ORDERS AT THEBEST PRICES AVAILABLE, TRADED THROUGH THE NATIONAL BEST BID OROFFER; AND FAILED ASSURE COMPLIANCE WITH CBOE RULES 6.45B AND6.73, AND SUPERVISE ITS ASSOCIATED PERSONS TO ASSURECOMPLIANCE WITH CBOE RULES 6.45B AND 6.81.



Resolution:










Sanction Details: THE FIRM WAS FINED $5,000.00 AND A CENSURE.

Firm Statement 20150466716 AND 201504939259 WERE COMBINED.

Disclosure 9 of 16

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Docket/Case Number: 15-0013 / 20150442172



Allegations: GLOBAL EXECUTION BROKERS, LP ("GEB"), AN EXCHANGE TPHORGANIZATION, WAS CENSURED AND FINED $5,000 FOR THE FOLLOWINGCONDUCT. FROM IN OR ABOUT MAY 2012 THROUGH IN OR ABOUTSEPTEMBER 2014, GEB EXECUTED 9 MATCHED ORDERS FORAPPROXIMATELY 14,364 CONTRACTS ON AIM, IN WHICH THE MARKET-MAKERS ON THE MATCHED ORDERS HELD AN APPOINTMENT IN THERELEVANT OPTION CLASSES. (EXCHANGE RULE 6.74A - AUTOMATEDIMPROVEMENT MECHANISM (AIM))



Resolution:

















Docket/Case Number: 15-0013/20150442172



Allegations: IT IS ALLEGED THAT THE FIRM, FROM IN OR ABOUT MAY 2012 THROUGH INOR ABOUT SEPTEMBER 2014, EXECUTED 9 MATCHED ORDERS FORAPPROXIMATELY 14,364 CONTRACTS ON AIM, IN WHICH THE MARKET-MAKERS ON THE MATCHED ORDERS HELD AN APPOINTMENT IN THERELEVANT OPTION CLASSES.


Resolution:


Sanction Details: A $5,000 FINE AND A CENSURE



Disclosure 10 of 16

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT OF ORDERSSAMPLED, THOSE EXECUTED ON THE BOSTON OPTIONS EXCHANGE(BOX) CONTAINED THE FOLLOWING DEFICIENCIES: 23 FAILED TO SHOWORDER RECEIPT TIMES; 26 FAILED TO DESIGNATE THE ORDERS ASMARKET OR LIMIT ORDERS; EIGHT FAILED TO INDICATE WHETHER THEORDERS WERE SOLICITED OR UNSOLICITED; AND 43 FAILED TO STATEWHETHER THE ORDERS WERE HELD OR NOT HELD. THE FINDINGSSTATED THAT ALTHOUGH THE FIRM'S BUSINESS MODEL INVOLVESNEGOTIATING THE EXECUTION OF INDIVIDUAL ORDERS AMONG ITSELF,TWO OF ITS AFFILIATES, AND ITS CUSTOMER, ITS ORDER RECORDS DIDNOT REFLECT ANY SUCH AGREEMENTS. OF A SAMPLE OF RECORDS FORORDERS THE FIRM HAD EXECUTED ACROSS MULTIPLE MARKETS,INCLUDING BOX, ON DECEMBER 12 AND 13, 2011, SIX OF THESE ORDERSWERE EXECUTED ON BOX, AND ALL SIX OMITTED THE ORDER RECEIPTTIME. INSTEAD, THEY SHOWED THE TIMES AT WHICH THE FIRM HADTRANSMITTED THE ORDERS TO BOX FOR EXECUTION. THE FINDINGSALSO STATED THAT THE FIRM FAILED TO MAINTAIN WRITTENSUPERVISORY PROCEDURES (WSPS) WITH RESPECT TO COMPLIANCEWITH SECURITIES EXCHANGE ACT OF 1934 RULE 17A-3(A)(6)(I), ANDCHAPTER V, SECTION 15(A) AND CHAPTER VIII, SECTION 1(A) OF THE BOXTRADING RULES. IN ADDITION, IT FAILED TO SUPERVISE ADEQUATELY TOENSURE THE FIRM COMPLIED WITH THESE RULES. THE FIRM FAILED TOESTABLISH AND IMPLEMENT WRITTEN PROCEDURES PROVIDING FORREVIEWS TO ENSURE THE FIRM DOCUMENTED THE COMPLETE TERMS OFORDERS. BEFORE OCTOBER 2011, THE FIRM'S PROCEDURES FAILED TOIDENTIFY ANYONE RESPONSIBLE FOR REVIEWING ORDER RECORDS,FAILED TO IDENTIFY THE REVIEWS THEY WERE TO CONDUCT, FAILED TOSTATE THE FREQUENCY OF THE REVIEWS OF ORDER RECORDS, ANDFAILED TO STATE HOW THE FIRM WOULD DOCUMENT THE REVIEWS.ONCE THE FIRM INSTITUTED A WSP IN OCTOBER 2011 THAT PROVIDEDFOR A REVIEW, THE PROCEDURE WAS STILL DEFICIENT IN THAT IT FAILEDTO REQUIRE THE FIRM'S PERSONNEL TO CREATE AND MAINTAIN AMEMORANDUM FOR EACH ORDER THAT CONTAINED ALL THE TERMS ANDCONDITIONS OF THE ORDERS AND THE ORDER RECEIPT ANDTRANSMISSION TIMES. THE FIRM ALSO FAILED TO ENSURE THAT ITSEMPLOYEES DOCUMENTED THE COMPLETE TERMS OF ORDERS. THEFIRM VIOLATED SECURITIES EXCHANGE ACT OF 1934 RULE 17A-3(A)(6)(I),AS WELL AS CHAPTER III, SECTIONS 1, 2(A) AND 2(A)(I), CHAPTER V,SECTION 15(A), CHAPTER VIII, SECTION 1(A) AND CHAPTER XI, SECTION10(A) OF THE BOX TRADING RULES.







Initiated By: NASDAQ OMX BX, INC.





Principal Product Type: Other

Other Product Type(s): UNSPECIFIED SECURITIES

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT OF ORDERSSAMPLED, THOSE EXECUTED ON THE BOSTON OPTIONS EXCHANGE(BOX) CONTAINED THE FOLLOWING DEFICIENCIES: 23 FAILED TO SHOWORDER RECEIPT TIMES; 26 FAILED TO DESIGNATE THE ORDERS ASMARKET OR LIMIT ORDERS; EIGHT FAILED TO INDICATE WHETHER THEORDERS WERE SOLICITED OR UNSOLICITED; AND 43 FAILED TO STATEWHETHER THE ORDERS WERE HELD OR NOT HELD. THE FINDINGSSTATED THAT ALTHOUGH THE FIRM'S BUSINESS MODEL INVOLVESNEGOTIATING THE EXECUTION OF INDIVIDUAL ORDERS AMONG ITSELF,TWO OF ITS AFFILIATES, AND ITS CUSTOMER, ITS ORDER RECORDS DIDNOT REFLECT ANY SUCH AGREEMENTS. OF A SAMPLE OF RECORDS FORORDERS THE FIRM HAD EXECUTED ACROSS MULTIPLE MARKETS,INCLUDING BOX, ON DECEMBER 12 AND 13, 2011, SIX OF THESE ORDERSWERE EXECUTED ON BOX, AND ALL SIX OMITTED THE ORDER RECEIPTTIME. INSTEAD, THEY SHOWED THE TIMES AT WHICH THE FIRM HADTRANSMITTED THE ORDERS TO BOX FOR EXECUTION. THE FINDINGSALSO STATED THAT THE FIRM FAILED TO MAINTAIN WRITTENSUPERVISORY PROCEDURES (WSPS) WITH RESPECT TO COMPLIANCEWITH SECURITIES EXCHANGE ACT OF 1934 RULE 17A-3(A)(6)(I), ANDCHAPTER V, SECTION 15(A) AND CHAPTER VIII, SECTION 1(A) OF THE BOXTRADING RULES. IN ADDITION, IT FAILED TO SUPERVISE ADEQUATELY TOENSURE THE FIRM COMPLIED WITH THESE RULES. THE FIRM FAILED TOESTABLISH AND IMPLEMENT WRITTEN PROCEDURES PROVIDING FORREVIEWS TO ENSURE THE FIRM DOCUMENTED THE COMPLETE TERMS OFORDERS. BEFORE OCTOBER 2011, THE FIRM'S PROCEDURES FAILED TOIDENTIFY ANYONE RESPONSIBLE FOR REVIEWING ORDER RECORDS,FAILED TO IDENTIFY THE REVIEWS THEY WERE TO CONDUCT, FAILED TOSTATE THE FREQUENCY OF THE REVIEWS OF ORDER RECORDS, ANDFAILED TO STATE HOW THE FIRM WOULD DOCUMENT THE REVIEWS.ONCE THE FIRM INSTITUTED A WSP IN OCTOBER 2011 THAT PROVIDEDFOR A REVIEW, THE PROCEDURE WAS STILL DEFICIENT IN THAT IT FAILEDTO REQUIRE THE FIRM'S PERSONNEL TO CREATE AND MAINTAIN AMEMORANDUM FOR EACH ORDER THAT CONTAINED ALL THE TERMS ANDCONDITIONS OF THE ORDERS AND THE ORDER RECEIPT ANDTRANSMISSION TIMES. THE FIRM ALSO FAILED TO ENSURE THAT ITSEMPLOYEES DOCUMENTED THE COMPLETE TERMS OF ORDERS. THEFIRM VIOLATED SECURITIES EXCHANGE ACT OF 1934 RULE 17A-3(A)(6)(I),AS WELL AS CHAPTER III, SECTIONS 1, 2(A) AND 2(A)(I), CHAPTER V,SECTION 15(A), CHAPTER VIII, SECTION 1(A) AND CHAPTER XI, SECTION10(A) OF THE BOX TRADING RULES.


Resolution:


No








Sanction Details: THE FIRM WAS CENSURED AND FINED $14,000.


No



Initiated By: NASDAQ OMX BX, INC.


Other






Allegations: IT WAS ALLEGED THAT, ON CERTAIN DATES FROM APRIL 2009 THROUGHDECEMBER 2013, IT VIOLATED EXCHANGE ACT RULE 17A-3(A)(6), BOX(N/K/A NASDAQ OMX BX)RULE CHAPTER V, SEC.15(A) AND BOX RULECHAPTER VIII, SEC 1(A) BY OMITTING FROM ITS ORDER RECORDSCOMBINATIONS OF ORDER RECEIPT TIME, ORDER TRANSMISSION TIME,AND DESIGNATIONS AS MARKET ORDER OR LIMIT ORDER, AS HELD ORNOT HELD, OR AS SOLICITED OR UNSOLICITED; FAILING TO INSTITUTE ANADEQUATE SYSTEM OF SUPERVISION WITH RESPECT TO ORDERRECORDKEEPING; AND FAILING TO ESTABLISH AND IMPLEMENT WRITTENPROCEDURES FOR REVIEWING ORDER TICKETS TO ENSURE THEY ARECOMPLETED WITH SEC AND EXCHANGE TRADING RULES.



Resolution:








Other Sanctions Ordered: A FINE OF $14,000


Firm Statement CASE 20110266158 RELATES TO THE SAME AWC.


Disclosure 11 of 16

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Allegations: A FINRA HEARING OFFICER CONSIDERED A STIPULATION OF FACTS ANDCONSENT TO PENALTY ENTERED INTO BETWEEN FINRA ON BEHALF OFNYSE REGULATION, INC. AND THE FIRM. WITHOUT ADMITTING ORDENYING ANY ALLEGATIONS OR FINDINGS, THE FIRM STIPULATED TO THEFACTS AND FINDINGS THAT MARKET REGULATION COMMENCED THISINVESTIGATION AFTER RECEIVING REFERRALS FROM ITS TRADING ANDMARKET MAKING SURVEILLANCE GROUP, NOW KNOWN AS THE TRADINGAND FINANCIAL COMPLIANCE EXAMINATIONS (TFCE) GROUP. TFCEREVIEWED ORDER RECORDS FOR A SAMPLE OF ORDERS THAT THE FIRMHAD EXECUTED ACROSS MULTIPLE MARKETS DURING SEPARATEPERIODS. THE FIRM EXECUTED 29 THESE ORDERS AT LEAST PARTIALLYON NYSE MKT, AND OF THESE, 17 OMITTED THE ORDER RECEIPT TIME, 19OMITTED A DESIGNATION AS A MARKET OR LIMIT ORDER, 5 OMITTED ADESIGNATION OF SOLICITED OR UNSOLICITED, AND ALL 29 OMITTED ADESIGNATION AS HELD OR NOT HELD. ALSO, TFCE REVIEWED ORDERRECORDS FOR A SAMPLE OF ORDERS THAT THE FIRM HAD EXECUTEDACROSS MARKETS DURING A PERIOD. OF THOSE THAT WERE AT LEASTPARTIALLY EXECUTED ON NYSE MKT, EIGHT ORDERS OMITTED THEORDER RECEIPT TIME, AND ONE ORDER OMITTED THE ACCOUNT TYPE.AGAIN, TFCE REVIEWED ORDER RECORDS FOR A SAMPLE OF ORDERSTHAT THE FIRM HAD EXECUTED ACROSS MARKETS FROM DURINGANOTHER PERIOD. OF THOSE THAT WERE AT LEAST PARTIALLYEXECUTED ON NYSE MKT, THREE ORDERS OMITTED THE RECEIPT TIME,ONE ORDER OMITTED THE TRANSMISSION TIME, AND ONE ORDEROMITTED THE EXPIRATION MONTH. THE FIRM THEREBY VIOLATEDEXCHANGE ACT RULE 17A-3(A)(6) AND EXCHANGE RULES 324 AND956NY(A) AND 956NY. IN ADDITION, ALTHOUGH THE FIRM'S BUSINESSMODEL INVOLVES NEGOTIATING THE EXECUTION OF INDIVIDUAL ORDERSAMONG ITSELF, TWO OF ITS AFFILIATES, AND ITS CUSTOMER, ITS ORDERRECORDS DO NOT REFLECT ANY SUCH AGREEMENTS. THE FIRMTHEREBY VIOLATED EXCHANGE ACT RULE 17A-3(A)(6)(I) AND EXCHANGERULES 324 AND 956NY(A). THE FIRM VIOLATED EXCHANGE RULE 320 BYFAILING TO ESTABLISH AND IMPLEMENT WRITTEN PROCEDURESPROVIDING FOR REVIEWS TO ENSURE THAT IT DOCUMENTED THECOMPLETE TERMS OF ORDERS. BEFORE OCTOBER 2011, ITSPROCEDURES FAILED TO IDENTIFY ANYONE RESPONSIBLE FORREVIEWING ORDER RECORDS, FAILED TO IDENTIFY THE REVIEWS THEYWERE TO CONDUCT, FAILED TO STATE THE FREQUENCY OF REVIEWS OFORDER RECORDS, AND FAILED TO STATE HOW IT WOULD DOCUMENT THEREVIEWS. ONCE THE FIRM INSTITUTED A WRITTEN SUPERVISORYPROCEDURE IN OCTOBER 2011 THAT PROVIDED FOR A REVIEW, THEPROCEDURE WAS STILL DEFICIENT IN THAT IT FAILED TO REQUIRE ITSPERSONNEL TO CREATE AND MAINTAIN A MEMORANDUM FOR EACHORDER THAT CONTAINED ALL THE TERMS AND CONDITIONS OF THEORDERS AND THE ORDER RECEIPT AND TRANSMISSION TIMES. THUS, THEPROCEDURE WAS NOT REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH EXCHANGE ACT RULE 17A-3(A)(6)(I) OR EXCHANGERULES 324 OR 956NY. IN ADDITION, THE FIRM FAILED TO PROVIDEREASONABLE SUPERVISION IN THAT IT FAILED TO DETECT THAT ITSORDER RECORDS DID NOT COMPLY WITH EXCHANGE ACT RULE 17A-3(A)(6)(I) OR EXCHANGE RULES 324 AND 956NY.







Initiated By: NYSE MKT LLC


Other


N/A



Principal Product Type: Other

Other Product Type(s): UNSPECIFIED SECURITIES

A FINRA HEARING OFFICER CONSIDERED A STIPULATION OF FACTS ANDCONSENT TO PENALTY ENTERED INTO BETWEEN FINRA ON BEHALF OFNYSE REGULATION, INC. AND THE FIRM. WITHOUT ADMITTING ORDENYING ANY ALLEGATIONS OR FINDINGS, THE FIRM STIPULATED TO THEFACTS AND FINDINGS THAT MARKET REGULATION COMMENCED THISINVESTIGATION AFTER RECEIVING REFERRALS FROM ITS TRADING ANDMARKET MAKING SURVEILLANCE GROUP, NOW KNOWN AS THE TRADINGAND FINANCIAL COMPLIANCE EXAMINATIONS (TFCE) GROUP. TFCEREVIEWED ORDER RECORDS FOR A SAMPLE OF ORDERS THAT THE FIRMHAD EXECUTED ACROSS MULTIPLE MARKETS DURING SEPARATEPERIODS. THE FIRM EXECUTED 29 THESE ORDERS AT LEAST PARTIALLYON NYSE MKT, AND OF THESE, 17 OMITTED THE ORDER RECEIPT TIME, 19OMITTED A DESIGNATION AS A MARKET OR LIMIT ORDER, 5 OMITTED ADESIGNATION OF SOLICITED OR UNSOLICITED, AND ALL 29 OMITTED ADESIGNATION AS HELD OR NOT HELD. ALSO, TFCE REVIEWED ORDERRECORDS FOR A SAMPLE OF ORDERS THAT THE FIRM HAD EXECUTEDACROSS MARKETS DURING A PERIOD. OF THOSE THAT WERE AT LEASTPARTIALLY EXECUTED ON NYSE MKT, EIGHT ORDERS OMITTED THEORDER RECEIPT TIME, AND ONE ORDER OMITTED THE ACCOUNT TYPE.AGAIN, TFCE REVIEWED ORDER RECORDS FOR A SAMPLE OF ORDERSTHAT THE FIRM HAD EXECUTED ACROSS MARKETS FROM DURINGANOTHER PERIOD. OF THOSE THAT WERE AT LEAST PARTIALLYEXECUTED ON NYSE MKT, THREE ORDERS OMITTED THE RECEIPT TIME,ONE ORDER OMITTED THE TRANSMISSION TIME, AND ONE ORDEROMITTED THE EXPIRATION MONTH. THE FIRM THEREBY VIOLATEDEXCHANGE ACT RULE 17A-3(A)(6) AND EXCHANGE RULES 324 AND956NY(A) AND 956NY. IN ADDITION, ALTHOUGH THE FIRM'S BUSINESSMODEL INVOLVES NEGOTIATING THE EXECUTION OF INDIVIDUAL ORDERSAMONG ITSELF, TWO OF ITS AFFILIATES, AND ITS CUSTOMER, ITS ORDERRECORDS DO NOT REFLECT ANY SUCH AGREEMENTS. THE FIRMTHEREBY VIOLATED EXCHANGE ACT RULE 17A-3(A)(6)(I) AND EXCHANGERULES 324 AND 956NY(A). THE FIRM VIOLATED EXCHANGE RULE 320 BYFAILING TO ESTABLISH AND IMPLEMENT WRITTEN PROCEDURESPROVIDING FOR REVIEWS TO ENSURE THAT IT DOCUMENTED THECOMPLETE TERMS OF ORDERS. BEFORE OCTOBER 2011, ITSPROCEDURES FAILED TO IDENTIFY ANYONE RESPONSIBLE FORREVIEWING ORDER RECORDS, FAILED TO IDENTIFY THE REVIEWS THEYWERE TO CONDUCT, FAILED TO STATE THE FREQUENCY OF REVIEWS OFORDER RECORDS, AND FAILED TO STATE HOW IT WOULD DOCUMENT THEREVIEWS. ONCE THE FIRM INSTITUTED A WRITTEN SUPERVISORYPROCEDURE IN OCTOBER 2011 THAT PROVIDED FOR A REVIEW, THEPROCEDURE WAS STILL DEFICIENT IN THAT IT FAILED TO REQUIRE ITSPERSONNEL TO CREATE AND MAINTAIN A MEMORANDUM FOR EACHORDER THAT CONTAINED ALL THE TERMS AND CONDITIONS OF THEORDERS AND THE ORDER RECEIPT AND TRANSMISSION TIMES. THUS, THEPROCEDURE WAS NOT REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH EXCHANGE ACT RULE 17A-3(A)(6)(I) OR EXCHANGERULES 324 OR 956NY. IN ADDITION, THE FIRM FAILED TO PROVIDEREASONABLE SUPERVISION IN THAT IT FAILED TO DETECT THAT ITSORDER RECORDS DID NOT COMPLY WITH EXCHANGE ACT RULE 17A-3(A)(6)(I) OR EXCHANGE RULES 324 AND 956NY.


Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: THE FIRM IS CENSURED, FINED $14,000 AND ORDERED TO REVISE ITSWRITTEN SUPERVISORY PROCEDURES TO ADDRESS THE DEFICIENCIES.(TO ESTABLISH AND IMPLEMENT WRITTEN PROCEDURES PROVIDING FORREVIEWS TO ENSURE THAT THE FIRM DOCUMENTED THE COMPLETETERMS OF ORDERS, AND OTHER RELATED ASPECTS, AS WELL AS, TOPROVIDE REASONABLE SUPERVISION TO DETECT THAT ITS ORDERRECORDS COMPLY WITH EXCHANGE ACT RULE 17A-3(A)(6)(I) OREXCHANGE RULES 324 AND 956NY.) THE FINE WILL BE PAYABLE ON THEDATE ON WHICH THE DECISION BECOMES FINAL. THE FIRM IS REQUIREDTO PAY THE FINE WITHIN 45 DAYS OF THAT DATE, OR IT MAY FACESUMMARY SUSPENSION, PURSUANT TO NYSE RULE 476(K).


No


Decision






Sanction Details: THE FIRM IS CENSURED, FINED $14,000 AND ORDERED TO REVISE ITSWRITTEN SUPERVISORY PROCEDURES TO ADDRESS THE DEFICIENCIES.(TO ESTABLISH AND IMPLEMENT WRITTEN PROCEDURES PROVIDING FORREVIEWS TO ENSURE THAT THE FIRM DOCUMENTED THE COMPLETETERMS OF ORDERS, AND OTHER RELATED ASPECTS, AS WELL AS, TOPROVIDE REASONABLE SUPERVISION TO DETECT THAT ITS ORDERRECORDS COMPLY WITH EXCHANGE ACT RULE 17A-3(A)(6)(I) OREXCHANGE RULES 324 AND 956NY.) THE FINE WILL BE PAYABLE ON THEDATE ON WHICH THE DECISION BECOMES FINAL. THE FIRM IS REQUIREDTO PAY THE FINE WITHIN 45 DAYS OF THAT DATE, OR IT MAY FACESUMMARY SUSPENSION, PURSUANT TO NYSE RULE 476(K).

Regulator Statement HEARING OFFICER DECISION RENDERED NOVEMBER 19, 2014; THE FIRMVIOLATED: EXCHANGE ACT RULE 17A-3(A)(6)(I) AND EXCHANGE RULE 324BY FAILING TO MAKE AND KEEP CURRENT A MEMORANDUM FOR EACHORDER THAT INCLUDED THE ORDER RECEIPT TIME, THE ORDERTRANSMISSION TIME, THE TERMS AND CONDITIONS OF THE ORDER, ORANY COMBINATION THEREOF; EXCHANGE RULE 956NY BY FAILING TOKEEP COMPLETE BOOKS AND RECORDS THAT INCLUDE EITHER ORDERRECEIPT TIMES OR THE TERMS AND CONDITIONS OF ORDERS; ANDEXCHANGE RULE 320 BY FAILING TO REASONABLY SUPERVISE ANDIMPLEMENT ADEQUATE CONTROLS, INCLUDING A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH EXCHANGE ACT RULE 17A-3(A)(6)(I) AND EXCHANGERULES 324 AND 956NY. THE DECISION BECAME FINAL AT THE CLOSE OFBUSINESS ON DECEMBER 15, 2014.

THIS PROCEEDING INCLUDES PROCEEDING NUMBERS 20100222899,20110266158 AND 20130356216.



Allegations: GLOBAL EXECUTION BROKERS, LP WAS CENSURED AND FINED $14,000BASED ON ALLEGATIONS THAT, ON CERTAIN DATES FROM SEPTEMBER2009 THROUGH MAY 2013, IT VIOLATED EXCHANGE ACT RULE 17A-3(A)(6),NYSE MKT RULE 956NY, AND NYSE MKT RULE 324 BY OMITTING FROM ITSORDER RECORDS COMBINATIONS OF ORDER RECEIPT TIME, ORDERTRANSMISSION TIME, AND DESIGNATIONS AS MARKET ORDER OR LIMITORDER, AS HELD OR NOT HELD, OR AS SOLICITED OR UNSOLICITED; ANDTHAT IT FAILED TO INSTITUTE AN ADEQUATE SYSTEM OF SUPERVISIONWITH RESPECT TO ORDER RECORDKEEPING. IN ADDITION, THE FIRM HASAGREED TO AN UNDERTAKING TO REVIEW ITS WRITTEN SUPERVISORYPROCEDURES WITH RESPECT TO THESE AREAS.









Other







Resolution:

Other Sanctions Ordered: UNDERTAKING TO REVISE THE FIRM'S WRIITEN SUPERVISORYPROCEDURES WITH RESPECT TO ORDER RECORDS




Disclosure 12 of 16

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Initiated By: BATS Z-EXCHANGE, INC.




Principal Product Type: No Product


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THOUGH ITWAS A MEMBER OF BOTH BATS EXCHANGE, INC. (BZX) AND BATS Y-EXCHANGE, INC. (BYX) AT THE TIME, THE FIRM FAILED TO PROVIDE BZXAND BYX COPIES OF ITS ANNUAL AUDIT FOR THE FISCAL YEAR ENDINGON DECEMBER 31, 2013 AS REQUIRED BY SECURITIES EXCHANGE ACT OF1934 RULE 17A-5(D)(6). AS A RESULT, THE FIRM VIOLATED SECURITIESEXCHANGE ACT OF 1934 RULE 17A-5(D)(6).










Resolution:




No




Initiated By: BATS EXCHANGE, INC.(BATS Z)


Other






Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, GLOBAL EXECUTIONBROKERS, LP CONSENTED TO THE ENTRY OF FINDINGS THAT IT HADFAILED TO PROVIDE TO BATS EXCHANGE, INC. COPIES OF ITS ANNUALAUDIT FOR THE FISCAL YEAR ENDING ON DECEMBER 31, 2013 ASREQUIRED BY SEA RULE 17A-5(D)(6).


Resolution: Acceptance, Waiver & Consent(AWC)49©2022 FINRA. All rights reserved. Report about GLOBAL EXECUTION BROKERS, LP






Resolution:


Sanction Details: A FINE OF $5000.00



Disclosure 13 of 16

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Initiated By: BATS Y-EXCHANGE, INC.





Principal Product Type: No Product


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THOUGH ITWAS A MEMBER OF BOTH BATS EXCHANGE, INC. (BZX) AND BATS Y-EXCHANGE, INC. (BYX) AT THE TIME, THE FIRM FAILED TO PROVIDE BZXAND BYX COPIES OF ITS ANNUAL AUDIT FOR THE FISCAL YEAR ENDINGON DECEMBER 31, 2013 AS REQUIRED BY SECURITIES EXCHANGE ACT OF1934 RULE 17A-5(D)(6). AS A RESULT, THE FIRM VIOLATED SECURITIESEXCHANGE ACT OF 1934 RULE 17A-5(D)(6).



Resolution:


No












Initiated By: BATS Y-EXCHANGE, INC.


Other






Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, GLOBAL EXECUTIONBROKERS, LP CONSENTED TO THE ENTRY OF FINDINGS THAT IT HADFAILED TO PROVIDE TO BATS Y-EXCHANGE, INC. COPIES OF ITS ANNUALAUDIT FOR THE FISCAL YEAR ENDING ON DECEMBER 31, 2013 ASREQUIRED BY SEA RULE 17A-5(D)(6).



Resolution:


Sanction Details: A FINE OF $5000.00



Disclosure 14 of 16

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Allegations: GLOBAL EXECUTION BROKERS, LP ("GLOBAL"), AN EXCHANGE MEMBERORGANIZATION, WAS CENSURED AND FINED $5,000 FOR THE FOLLOWINGCONDUCT. GLOBAL FAILED TO SYSTEMATIZE NUMEROUS OPTIONORDERS PRIOR TO REPRESENTATION AND EXECUTION. (VIOLATION OFEXCHANGE RULE 6.24)















Allegations: GLOBAL EXECUTION BROKERS, LP ("GLOBAL"), AN EXCHANGE MEMBERORGANIZATION, WAS CENSURED AND FINED $5,000 FOR THE FOLLOWINGCONDUCT. GLOBAL FAILED TO SYSTEMATIZE NUMEROUS OPTIONORDERS PRIOR TO REPRESENTATION AND EXECUTION. (VIOLATION OFEXCHANGE RULE 6.24)


Resolution:


Sanction Details: A FIVE THOUSAND DOLLAR ($5,000) FINE AND A CENSURE


No






Allegations: GLOBAL EXECUTION BROKERS, LP ("GLOBAL"), AN EXCHANGE MEMBERORGANIZATION, WAS CENSURED AND FINED $5,000 FOR THE FOLLOWINGCONDUCT. GLOBAL FAILED TO SYSTEMATIZE NUMEROUS OPTION ORDERSPRIOR TO REPRESENTATION AND EXECUTION. (VIOLATION OF EXCHANGERULE 6.24)















Resolution:


Sanction Details: A FIVE THOUSAND DOLLAR ($5,000) FINE AND A CENSURE



Disclosure 15 of 16

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Allegations: GLOBAL EXECUTION BROKERS, LP, AN EXCHANGE MEMBERORGANIZATION, WAS CENSURED AND FINED $20,000 FOR THE FOLLOWINGCONDUCT. GLOBAL, SUBMITTED, OR CAUSED TO BE SUBMITTED,NUMEROUS TRADES TO THE EXCHANGE FOR TRADE MATCH PURPOSESWHICH IDENTIFIED INACCURATE CLEARING FIRM INFORMATION. AS ARESULT, THE SUBMISSION OF SUCH INACCURATE CLEARINGINFORMATION COMPROMISED THE INTEGRITY OF THE EXCHANGE'S AUDITTRAIL. IN ADDITION, GLOBAL FAILED TO (I) ADEQUATELY SUPERVISE ITSASSOCIATED PERSONS IN CONNECTION WITH THE CONDUCT DESCRIBEDABOVE AND (II) ENFORCE GLOBAL'S INTERNAL POLICIES, REGULATIONSAND PROCEDURES FOR CAPTURING, RECORDING AND SUBMITTING FORCLEARANCE, ACCURATE CLEARING FIRM INFORMATION SO AS TOENSURE THE FIRM'S COMPLIANCE WITH EXCHANGE RULES. (CBOERULES 4.2 ADHERENCE TO LAW; 4.22 COMMUNICATIONS TO THEEXCHANGE OR THE CLEARING CORPORATION; 6.21 MUST GIVE UPCLEARING MEMBER; 6.50 SUBMISSION FOR CLEARANCE; AND 6.51(D)REPORTING DUTIES.)














Resolution:


Sanction Details: GLOBAL EXECUTION BROKERS, LP SHALL BE AND HEREBY IS CENSUREDAND FINED IN THE AMOUNT OF TWENTY THOUSAND DOLLARS ($20,000).







Allegations: GLOBAL EXECUTION BROKERS, LP, AN EXCHANGE MEMBERORGANIZATION, WAS CENSURED AND FINED $20,000 FOR THE FOLLOWINGCONDUCT. GLOBAL, SUBMITTED, OR CAUSED TO BE SUBMITTED,NUMEROUS TRADES TO THE EXCHANGE FOR TRADE MATCH PURPOSESWHICH IDENTIFIED INACCURATE CLEARING FIRM INFORMATION. AS ARESULT, THE SUBMISSION OF SUCH INACCURATE CLEARINGINFORMATION COMPROMISED THE INTEGRITY OF THE EXCHANGE'S AUDITTRAIL. IN ADDITION, GLOBAL FAILED TO (I) ADEQUATELY SUPERVISE ITSASSOCIATED PERSONS IN CONNECTION WITH THE CONDUCT DESCRIBEDABOVE AND (II) ENFORCE GLOBAL'S INTERNAL POLICIES, REGULATIONSAND PROCEDURES FOR CAPTURING, RECORDING AND SUBMITTING FORCLEARANCE, ACCURATE CLEARING FIRM INFORMATION SO AS TOENSURE THE FIRM'S COMPLIANCE WITH EXCHANGE RULES. (CBOE RULES4.2 ADHERENCE TO LAW; 4.22 COMMUNICATIONS TO THE EXCHANGE ORTHE CLEARING CORPORATION; 6.21 MUST GIVE UP CLEARING MEMBER;6.50 SUBMISSION FOR CLEARANCE; AND 6.51(D) REPORTING DUTIES)












Resolution:


Sanction Details: GLOBAL EXECUTION BROKERS, LP SHALL BE AND HEREBY IS CENSUREDAND FINED IN THE AMOUNT OF TWENTY THOUSAND DOLLARS ($20,000).



Disclosure 16 of 16

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Initiated By: PACIFIC STOCK EXCHANGE





Docket/Case Number: OS0412024



Allegations: OPTIONS TRADING PERMIT FIRM ENTERED MULTIPLE ORDERS ON THEPACIFIC EXCHANGE AUTO-EX SYSTEM WITHIN 15 SECONDS OF EACHOTHER, ON THE SAME SIDE OF THE MARKET, AND FOR THE SAMEBENEFICIAL OWNER.



Resolution:


No

Other







Sanction Details: $3,750.00 FINE WAS PAID ON NOVEMBER 10, 2005. THIS WAS A SECONDOFFENSE WITHIN TWO YEARS UNDER THE PACIFIC EXCHANGE'S MINORRULE PLAN.


No

Sanctions Ordered: Monetary/Fine $3,750.00


Initiated By: PACIFIC STOCK EXCHANGE




Docket/Case Number: OS0412024



Allegations: THE FIRM ENTERED MULTIPLE ORDERS ON THE PACIFIC EXCHANGEAUTO-EX SYSTEM WITHIN 15 SECONDS OF EACH OTHER, ON THE SAMESIDE OF THE MARKET, AND FOR THE SAME BENEFICIAL OWNER.



Resolution:


Sanction Details: $3,750 FINE WAS PAID ON NOVEMBER 10, 2005.

Sanctions Ordered: Monetary/Fine $3,750.00

Other






End of Report

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