SG Americas Securities, LLC
The findings stated that in six quarterly reports, the firm reported that it received a net payment of $0.04 per hundred shares from every listed options venue. The firm did not actually receive any such payments. Instead, the firm paid a $0.04 commission to an intermediary broker-dealer for those orders.
In one report, the firm erroneously disclosed receiving identical payments for order flow from twelve options venues when, in fact, the firm did not actually receive the same payments for order flow from those venues. Further in seven quarterly reports, the firm incorrectly identified two of the venues to which it routed the most non-directed orders for execution. Subsequently, the firm remediated these issues before publishing its next quarterly report.
The findings also stated that the firm's supervisory system, including written supervisory procedures (WSPs), was not reasonably designed to achieve compliance with Rule 606(a). While the firm's WSPs required a designated supervisor to meet quarterly with firm stakeholders to review the firm's Rule 606 reports prior to publication, the WSPs did not provide reasonable guidance on how such supervisory reviews should be conducted.
In practice, the firm did not conduct reasonable reviews to ensure the accuracy of its Rule 606 reports, such as comparing a sample of data in draft Rule 606 reports with transaction records. Ultimately, the firm amended its WSPs to address these deficiencies
