Virtu Americas, LLC

Virtu Americas, LLC was fined $100,000 for failing to achieve compliance with the firm’s limit order display obligations. The findings stated that the firm’s supervisory reviews were not reasonably designed to detect potential violations of Reg National Market System (NMS) Rule 604 and FINRA Rule 6460.

After becoming aware that the automated exception reports used by the firm to detect potential violations of these rules had ceased functioning, it tasked an employee with conducting a manual review of limit orders to identify potential violations while the automated exception reports were not functioning. However, the firm could not reasonably rely on the manual review due to the volume of limit orders. Subsequently, the employee responsible for performing the manual reviews departed from the firm. As a result, from June 2021 until August 2022, the firm did not conduct any manual reviews for potential violations. In August 2022, the firm implemented a new automated exception report.

In addition, the firm’s WSPs did not describe what should be considered by firm personnel to determine whether any violations of Reg NMS Rule 604 or FINRA Rule 6460 had actually occurred. Further, the WSPs did not describe the manual review, including the steps to take in conducting the manual review such as the volume, frequency, or sampling methodology to be employed. Ultimately, the firm implemented updated WSPs to monitor for compliance with FINRA Rule 6460 and Reg NMS Rule 604 to ensure the firm’s automated systems designed to display customer orders were functioning properly.