Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Order Approving Proposed Rule Change, as Modified by Amendment No. 1, Relating to Self-Trades and FINRA Rule 5210 (Publication of Transactions and Quotations) May 1, 2014., 26293-26297 [2014-10384]
Download as PDF
Federal Register / Vol. 79, No. 88 / Wednesday, May 7, 2014 / Notices
to the Exchange; NYSE Arca, Inc.;
CBOE; C2 Options Exchange,
Incorporated; International Securities
Exchange, LLC; NASDAQ; Phlx; BX;
BATS Exchange, Inc. (‘‘BATS’’); and
Miami International Securities
Exchange LLC. Because market data
users can thus find suitable substitutes
for most proprietary market data
products,22 a market that overprices its
market data products stands a high risk
that users may substitute another source
of market data information for its own.
In addition to the competition and
price discipline described above, the
market for proprietary data products is
also highly contestable because market
entry is rapid, inexpensive, and
profitable. The history of electronic
trading is replete with examples of
entrants that swiftly grew into some of
the largest electronic trading platforms
and proprietary data producers:
Archipelago, Bloomberg Tradebook,
Island, RediBook, Attain, TrackECN,
BATS, and Direct Edge. Two new
options exchanges have been approved
by the SEC in the last two years alone.23
In establishing the proposed fees, the
Exchange considered the
competitiveness of the market for
proprietary options data and all of the
implications of that competition. The
Exchange believes that it has considered
all relevant factors and has not
considered irrelevant factors in order to
establish fair, reasonable, and not
unreasonably discriminatory fees and an
equitable allocation of fees among all
users. The existence of numerous
alternatives to the Exchange’s products,
including proprietary data from other
sources, ensures that the Exchange
cannot set unreasonable fees, or fees
that are unreasonably discriminatory,
when vendors and subscribers can elect
these alternatives or choose not to
purchase a specific proprietary data
product if its cost to purchase is not
justified by the returns any particular
vendor or subscriber would achieve
through the purchase.
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C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
No written comments were solicited
or received with respect to the proposed
rule change.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change is effective
upon filing pursuant to Section
19(b)(3)(A) 24 of the Act and
subparagraph (f)(2) of Rule 19b–4 25
thereunder, because it establishes a due,
fee, or other charge imposed by the
Exchange.
At any time within 60 days of the
filing of such proposed rule change, the
Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is necessary or appropriate in the
public interest, for the protection of
investors, or otherwise in furtherance of
the purposes of the Act. If the
Commission takes such action, the
Commission shall institute proceedings
under Section 19(b)(2)(B) 26 of the Act to
determine whether the proposed rule
change should be approved or
disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
NYSEMKT–2014–40 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–NYSEMKT–2014–40. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
U.S.C. 78s(b)(3)(A).
CFR 240.19b–4(f)(2).
26 15 U.S.C. 78s(b)(2)(B).
supra note 18.
23 See supra note 21.
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printing in the Commission’s Public
Reference Section, 100 F Street NE.,
Washington, DC 20549–1090, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing will also be available for
inspection and copying at the NYSE’s
principal office and on its Internet Web
site at www.nyse.com. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–
NYSEMKT–2014–40 and should be
submitted on or before May 28, 2014.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.27
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–10389 Filed 5–6–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–72067; File No. SR–FINRA–
2013–036]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Order Approving
Proposed Rule Change, as Modified by
Amendment No. 1, Relating to SelfTrades and FINRA Rule 5210
(Publication of Transactions and
Quotations) May 1, 2014.
I. Introduction
On August 15, 2013, the Financial
Industry Regulatory Authority, Inc.
(‘‘FINRA’’) filed with the Securities and
Exchange Commission (the
‘‘Commission’’) pursuant to Section
19(b)(1) of the Securities Exchange Act
of 1934 (the ‘‘Act’’) 1 and Rule 19b–4
thereunder,2 a proposed rule change to
add Supplementary Material .02 to
FINRA Rule 5210 (Publication of
Transactions and Quotations) to
emphasize that wash sale transactions
are generally non-bona fide transactions
and that members have an obligation to
have policies and procedures in place to
review their trading activity for, and
prevent, wash sale transactions. The
proposed rule change was published for
comment in the Federal Register on
September 4, 2013.3 The Commission
27 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See Securities Exchange Act Release No. 70276
(August 28, 2013), 78 FR 54502 (‘‘Notice’’).
1 15
24 15
22 See
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26293
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received five comment letters on the
proposed rule change.4 On October 4,
2013, the Commission extended the
time period for Commission action to
December 3, 2013.5 On December 2,
2013, FINRA submitted a response to
the comment letters 6 and filed
Amendment No. 1 to the proposed rule
change. On December 3, 2013, the
Commission published for comment
both Amendment No. 1 and an order
instituting proceedings under Section
19(b)(2)(B) of the Act 7 to determine
whether to approve or disapprove the
proposed rule change, as modified by
Amendment No. 1.8 The Commission
received three comment letters on the
Notice of Filing of Amendment No. 1
and Order Instituting Proceedings.9 On
February 24, 2014, FINRA submitted a
response to the comment letters.10 This
order approves the proposed rule
change, as modified by Amendment
No. 1.
4 See letter from Anonymous to Elizabeth M.
Murphy, Secretary, Commission, dated September
9, 2013 (‘‘Anonymous Letter’’); letter from William
A. Jacobson, Clinical Professor of Law, and Director,
Cornell Securities Law Clinic, and Jimin Lee,
Cornell University Law School, to Elizabeth M.
Murphy, Secretary, Commission, dated September
25, 2013 (‘‘Cornell Letter’’); letter from Stuart J.
Kaswell, Executive Vice President, Managing
Director and General Counsel, Managed Funds
Association, to Elizabeth M. Murphy, Secretary,
Commission, dated September 25, 2013 (‘‘MFA
Letter’’); letter from Manisha Kimmel, Executive
Director, Financial Industry Forum, to Elizabeth M.
Murphy, Secretary, Commission, dated September
25, 2013 (‘‘FIF Letter’’); and letter from Theodore
R. Lazo, Managing Director and Associate General
Counsel, Securities Industry and Financial Markets
Association, to Elizabeth M. Murphy, Secretary,
Commission, dated October 4, 2013 (‘‘SIFMA
Letter’’). For a discussion of these comment letters,
see Notice of Filing of Amendment No. 1 and Order
Instituting Proceedings, infra note 8, at 73902–
73903.
5 See Securities Exchange Act Release No. 70613
(October 4, 2013), 78 FR 62784 (October 22, 2013).
6 See letter from Brant K. Brown, Associate
General Counsel, FINRA, to Elizabeth M. Murphy,
Secretary, Commission, dated December 2, 2013
(‘‘FINRA Response 1’’).
7 15 U.S.C. 78s(b)(2)(B).
8 See Securities Exchange Act Release No. 70966
(December 3, 2013), 78 FR 73900 (December 9,
2013) (‘‘Notice of Filing of Amendment No. 1 and
Order Instituting Proceedings’’).
9 See letter from Manisha Kimmel, Executive
Director, Financial Industry Forum, to Elizabeth M.
Murphy, Secretary, Commission, dated December
23, 2013 (‘‘FIF Letter 2’’); letter from Mary Ann
Burns, Chief Operating Officer, Futures Industry
Association, to Elizabeth M. Murphy, Secretary,
Commission, dated January 6, 2014 (‘‘FIA PTG
Letter’’); and letter from Theodore R. Lazo,
Managing Director and Associate General Counsel,
Securities Industry and Financial Markets
Association, to Elizabeth M. Murphy, Secretary,
Commission, dated January 13, 2014 (‘SIFMA Letter
2’’).
10 See letter from Brant K. Brown, Associate
General Counsel, FINRA, to Elizabeth M. Murphy,
Secretary, Commission, dated February 24, 2014
(‘‘FINRA Response 2’’).
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II. Description of the Proposal, as
Modified by Amendment No. 1
FINRA proposes to add
Supplementary Material .02 to FINRA
Rule 5210 to address members’
obligations with respect to certain
securities transactions that result from
the unintentional interaction of orders
originating from the same firm (now
referred to by FINRA as ‘‘self-trades’’),
that involve no change in the beneficial
ownership of the security.11 The
proposed rule change requires FINRA
members to have policies and
procedures in place that are reasonably
designed to review their trading activity
for, and prevent, a pattern or practice of
self-trades resulting from orders
originating from a single algorithm or
trading desk, or from related algorithms
or trading desks. Additionally, the
proposed rule change states that
transactions resulting from orders that
originate from unrelated algorithms or
from separate and distinct trading
strategies within the same firm would
generally be considered bona fide selftrades.12 The proposed rule change also
establishes a presumption that
algorithms or trading strategies within
the most discrete unit of an effective
system of internal controls at a member
firm are related.
The proposed rule change is intended
to address self-trades that occur as a
result of orders sent by a single
algorithm or the interaction of multiple,
related algorithms operated by a single
firm. In a number of instances, FINRA
has found that these types of
transactions can account for a material
percentage (e.g., over 5%) of the
consolidated trading volume in a
security on a particular day, which can
distort the market information that is
publicly available for that security. In
FINRA’s view, even if not purposeful,
these transactions can create the
misimpression of active trading in a
security that could adversely affect the
price discovery process. Furthermore,
11 Securities transactions that do not result in a
change of beneficial ownership of the securities and
that are undertaken for the purpose of creating or
inducing a false or misleading appearance of
activity in the securities are already prohibited by
existing securities laws and FINRA rules. See note
14, infra.
The Commission notes that the original proposal
addressed wash sale transactions. Subsequently,
FINRA filed Amendment No. 1, which clarified that
the focus of the proposal was self-trades, rather than
wash sale transactions.
12 Transactions that originate from unrelated
algorithms or from separate or distinct trading
strategies, trading desks, or aggregation units that
are frequent or numerous may raise a presumption
that such transactions were undertaken with the
intent that they cross and may, therefore, be
intended as manipulative or fraudulent. See Notice,
supra note 3, at 54503.
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FINRA believes that, in these instances,
firms will continue to allow this type of
trading to occur rather than incur the
costs necessary to prevent it, even
though the trading activity may result in
instances where significant
misinformation is disseminated to the
market. The proposed rule change
requires members to adopt reasonable
policies and procedures to prohibit such
activity and would not, therefore, apply
to isolated self-trades resulting from
orders originating from a single
algorithm or trading desk, or from
related algorithms or trading desks,
provided the firm’s policies and
procedures were reasonably designed.13
FINRA rules and the federal securities
laws explicitly prohibit transactions in
securities that do not result in a change
of beneficial ownership of the securities
when there is a fraudulent or
manipulative purpose behind the
trading activity.14 In addition, FINRA
Rule 5210 provides that no member may
cause to be published or circulated any
report of a securities transaction unless
the member knows or has reason to
believe that the transaction was a bona
fide transaction. Supplementary
Material .01 states that ‘‘[i]t shall be
deemed inconsistent with Rules 2010
(Standards of Commercial Honor and
Principles of Trade), 2020 (Use of
Manipulative, Deceptive or Other
Fraudulent Devices) and 5210
(Publication of Transactions and
Quotations) for a member to publish or
circulate or cause to be published or
circulated, by any means whatsoever,
any report of any securities transaction
or of any purchase or sale of any
security unless such member knows or
has reason to believe that such
transaction was a bona fide transaction,
purchase or sale.’’ Thus, each FINRA
member has an existing obligation to
know, or have a basis to believe, that
transactions in which it participates are
bona fide.
III. Discussion and Commission
Findings
The Commission has carefully
considered the proposal, the comments
submitted, and FINRA’s response to the
comments, and believes that FINRA has
responded adequately to the concerns
raised by the commenters and by the
Commission in the Order Instituting
Proceedings. For the reasons discussed
below, the Commission finds that the
proposal is consistent with the
13 The proposed rule change would not change
member firms’ existing obligations under NASD
Rule 3010 and FINRA Rule 2010 with respect to
wash sales. See Notice, supra note 3, at 54503.
14 See, e.g., 15 U.S.C. 78i(a)(1); FINRA Rule
6140(b).
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requirements of the Act and the rules
and regulations thereunder applicable to
a national securities association.15 In
particular, the Commission finds that
the proposed rule change is consistent
with the provisions of Section 15A(b)(6)
of the Act,16 which requires, among
other things, that FINRA’s rules be
designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade, and, in general, to protect
investors and the public interest. The
proposal requires firms to adopt policies
and procedures reasonably designed to
prevent a pattern or practice of certain
types of self-trades, which could create
the misimpression of active trading and
adversely affect the price discovery
process. Thus, the proposed rule change
is designed to improve the quality of
transaction information that is
disseminated to the public.
As noted above, the Commission
received three comment letters in
response to the Notice of Filing of
Amendment No. 1 and Order Instituting
Proceedings 17 and FINRA responded to
the comments.18 Two comment letters
supported the approval of the proposed
rule change, as amended.19 The third
comment letter is generally supportive,
but requests modifications to the
proposal.20
Two commenters support FINRA’s
amendment to focus the proposed rule
change on ‘‘self-trades,’’ rather than
‘‘wash sales.’’ 21 One commenter
supports FINRA’s replacement of the
term ‘‘wash sale’’ with ‘‘self-trade,’’
explaining that, unlike wash sale
transactions, self-trades can be
inadvertent and bona fide.22 The
commenter believes that this change in
terminology recognizes that automated
trading can result in coincidental selftrades from independently initiated
orders that lack the requisite fraudulent
or manipulative intent to be classified as
‘‘wash sales.’’ 23 The other commenter
also supports the distinction and states
that the proposed rule better addresses
15 In approving the proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition and capital
formation. See 15 U.S.C. 78c(f).
16 15 U.S.C. 78o-3(b)(6).
17 See FIF Letter 2; FIA PTG Letter; SIFMA Letter
2, supra note 9. For a discussion of the comment
letters received by the Commission in response to
the Notice, see Notice of Filing of Amendment No.
1 and Order Instituting Proceedings, supra note 8,
at 73902–73903.
18 See FINRA Response 2, supra note 10.
19 See FIF Letter 2; SIFMA Letter 2, supra note
9.
20 See FIA PTG Letter, supra note 9.
21 See FIA PTG Letter, supra note 9, at 2; SIFMA
Letter 2, supra note 9, at 1.
22 See FIA PTG Letter, supra note 9, at 2.
23 Id.
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the concern raised in the original
proposal—that self-trades can distort
market information regarding a
security—by creating an obligation for
broker-dealers to avoid transactions that
unintentionally result in no change in
beneficial ownership and do not involve
manipulative or fraudulent intent.24
Because the proposal is intended to
address the unintentional interaction of
orders originating from the same firm
that involve no change in the beneficial
ownership of the security and can lead
to the dissemination of misinformation
to the marketplace and the public, the
Commission believes that modifying the
focus of the proposed rule from ‘‘wash
sales’’ to ‘‘self-trades’’ appropriately
tailors the scope of the proposed rule
and addresses potential confusion.
Two commenters support FINRA’s
requirement that members have policies
and procedures in place to review their
trading activity for, and prevent, a
pattern or practice of self-trades
resulting from orders originating from a
single algorithm or trading desk, or
related algorithms or trading desks.25
One commenter states, ‘‘Amendment
No. 1 strikes the right balance of
addressing a pattern and [sic] practice of
self-trading while acknowledging the
implementation issues inherent in
preventing every self-trade.’’ 26 This
commenter believes that the pattern or
practice standard addresses the problem
outlined in the proposal of self-trades
that distort the market information that
is publicly available for a security.27
The other commenter believes that the
pattern or practice standard would deter
broker-dealers from permitting large
numbers of self-trades from being
publicly reported.28
In its response, FINRA explains that
the proposed supplementary material is
primarily designed to address instances
where self-trades account for a
significant percent of volume in a
security, which may affect price
discovery.29 FINRA explains that its
proposed policies and procedures
requirement addresses its concern that
self-trades by a single algorithm or
trading desk, or related algorithms or
trading desks, may not reflect genuine
trading interest, especially when there is
a pattern or practice of such trading
24 See
SIFMA Letter 2, supra note 9, at 1–2.
FIF Letter 2, supra note 9, at 1–2; SIFMA
Letter 2, supra note 9, at 2. FIA PTG also supports
FINRA’s amended policies and procedures
requirement, but believes the requirement needs to
be clarified. See FIA PTG Letter, supra note 9, at
2, 7.
26 See FIF Letter 2, supra note 9, at 1.
27 See FIF Letter 2, at 2, supra note 9.
28 See SIFMA Letter 2, supra note 9, at 2.
29 See FINRA Response 2, supra note 10, at 3.
25 See
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26295
behavior.30 FINRA believes that its
proposal will allow FINRA to more
effectively deter self-trading that, while
not involving fraudulent or
manipulative intent, is disruptive to the
marketplace.31
Tailoring the limitation in the
supplementary material to a pattern or
practice of self-trades resulting from
orders originating from a single
algorithm or trading desk, or related
algorithms or trading desks, would not
prohibit isolated instances of selftrading, yet would address more
systematic self-trading that could result
in the dissemination of misleading
trading information to the marketplace.
The proposal would provide FINRA
with an enforceable rule specifically
targeting activity that rises to the level
of a pattern or practice of such selftrading, and requires firms to have
policies and procedures reasonably
designed to review their trading activity
for, and prevent, the same. The
Commission encourages FINRA to
surveil the efficacy of these policies and
procedures in reducing the volume of
self-trading, and to consider further
refinement of the rule if warranted.
One commenter requests that FINRA
clarify its distinction between bona fide
and non-bona fide self-trades.32 This
commenter notes that the proposed rule
states that self-trades that result from
orders originating from unrelated
algorithms or separate and distinct
trading strategies within the same firm
are generally bona fide, but that FINRA
also stated in the Notice that such
transactions, if frequent or regular, may
raise a presumption of manipulative or
fraudulent intent.33 The commenter
requests clarification of FINRA’s views
on frequent self-trades resulting from
unrelated trading strategies, and asserts
that it would be ‘‘inappropriate and
inaccurate to infer their relatedness or
the intent to self-trade based solely on
a volume threshold.’’ 34 Instead, the
commenter recommends that FINRA
adopt a wash sale approach described
by the Chicago Mercantile Exchange
Group (‘‘CME’’) in a recent CME Market
Regulation Advisory Notice to
determine whether trades between
unrelated algorithms are bona fide.35
The commenter explains that the CME
Market Regulation Advisory Notice
states that orders entered by an
independent trader in good faith for the
purpose of executing bona fide
30 Id.
31 Id.
32 See
FIA PTG Letter, supra note 9, at 3–4.
33 Id.
34 Id.
at 4.
35 Id.
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transactions, that are not prearranged
and are entered without knowledge of
the other trader’s order, will not violate
the CME’s prohibition on wash trades.36
Similarly, another commenter requests
that FINRA issue a Regulatory Notice
that states that self-trades resulting from
orders originating from unrelated
algorithms would not be deemed related
based solely on the fact that the
unrelated algorithms were being used by
traders on the same trading desk.37
In its response, FINRA reiterates its
position that, although self-trades
between unrelated trading desks or
algorithms are generally bona fide,
frequent self-trades may raise concerns
that they are intentional or undertaken
with manipulative or fraudulent
intent.38 FINRA also distinguishes its
proposal’s goals from those addressed
by the CME Market Regulation Advisory
Notice.39 FINRA notes that its proposal
is meant to address unintentional selftrading activity—not the regulation of
wash sale transactions.40 Further, unlike
the CME Market Regulation Advisory
Notice, FINRA states that its proposal
‘‘imposes specific additional obligations
on firms that engage in algorithmic
activity or use multiple algorithms or
trading desks as part of their trading
activity.’’ 41 The proposal is intended to
curb unintentional self-trades that result
in the dissemination of misinformation
to the public and negatively affect price
discovery.
One commenter states that FINRA’s
amended proposal would continue to
establish a rebuttable presumption that
algorithms within discrete units of a
firm’s internal controls are related,
regardless of comments that assert that
‘‘discrete units of a firm’s internal
controls are established for reasons
wholly separate from whether the
trading strategies and algorithms within
that unit are related.’’ 42 The commenter
believes that the proposal causes
confusion over whether the
presumption can be overcome.43 The
commenter requests that FINRA provide
clear guidance on the standards that
would rebut the presumption of
relatedness.44 In its response, FINRA
explains that the presumption is based
36 Id. In its comment letter, FIF noted that it
believes that FINRA’s pattern and practices
standard is consistent with the guidance provided
in the CME Market Regulation Advisory Notice. See
FIF Letter 2, supra note 9, at 2.
37 See FIF Letter 2, supra note 9, at 2.
38 See FINRA Response 2, supra note 10, at 4.
39 Id.
40 Id.
41 Id.
42 See FIA PTG Letter, supra note 9, at 5.
43 Id., at 6.
44 Id.
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on the fact that generally firms have the
same people supervising algorithms or
trading desks within a discrete unit, and
that such algorithms or trading desks
communicate with each other.45 FINRA
states, however, that firms would be
able to rebut this presumption if they
can show, for example, that different
personnel are responsible for
supervising the algorithms or trading
desks.46 The Commission believes that
FINRA has taken a reasonable position
with respect to this presumption and
provided appropriate guidance with
respect to how it might be rebutted.
One commenter believes that the
proposed rule lacks clarity regarding the
types of self-trading for which firms
would need to review, and prevent,
patterns or practices.47 The commenter
requested more specificity from FINRA
about the amount of activity that would
constitute a pattern or practice.48 In
response to the commenter, FINRA
states that it ‘‘declines to establish a
specific threshold below which a firm
could continue to engage in unlimited
self-trading.’’ 49 FINRA reiterates that
isolated self-trades are generally bona
fide, but that a practice of self-trading
over time ‘‘whether of material volume,
regularity, or both,’’ would indicate a
pattern or practice.50 The Commission
believes that the proposed rule change,
as amended provides sufficient clarity
to member firms, and notes that the
concept of a pattern or practice is used
in a number of FINRA rules.51
In the Notice of Filing of Amendment
No. 1 and Order Instituting Proceedings,
the Commission expressed concern that
the proposed rule, as amended, would
continue to allow a significant number
of self-trades to be publicly reported.52
Specifically, the Commission noted
FINRA’s statement in its filing that only
those firms that engage in a pattern or
practice of effecting self-trades that
result in a material percentage of the
trading volume in a particular security
would generally violate the proposed
rule, as well as FINRA’s proposed
requirement that its members have
policies and procedures to prevent,
specifically, a pattern or practice of selftrades from orders originating from a
single or related algorithms or trading
45 See
FINRA Response 2, supra note 10, at 4.
46 Id.
47 See
FIA PTG Letter, supra note 9, at 7.
48 Id.
49 See
FINRA Response 2, supra note 10, at 5.
50 Id.
51 See,
e.g., FINRA Rule 6282, Supplementary
Material .02(b).
52 See Notice of Filing of Amendment No. 1 and
Order Instituting Proceedings, supra note 8, at
73904.
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desks.53 The Commission stated that the
proposed rule would appear to provide
substantial flexibility regarding the
required policies and procedures, such
that a significant number of self-trades
could continue to be publicly reported,
as orders originating from ‘‘unrelated’’
algorithms or ‘‘separate and distinct’’
trading strategies would not be subject
to the proposed rule, and because only
self-trades amounting to a material
percentage of a security’s trading
volume would constitute violative
activity.54 The Commission also noted
that FINRA provided little guidance on
its interpretations of what would
constitute ‘‘unrelated’’ algorithms or
‘‘separate and distinct’’ trading
strategies.55
In its response, FINRA explained that
the proposed rule is designed to strike
a balance between recognizing that selftrades may reflect genuine trading
interest and therefore be bona fide, and
imposing an obligation on firms to
prevent a pattern or practice of selftrading that rises to the level of
disruptive activity. While self-trades
may be unintentional, if the number of
self-trades by a firm constitutes a
material percentage of the volume in a
security, it could have a negative effect
on the price discovery process.56 FINRA
explained that the proposed rule would
allow it to better pursue self-trading
violations because the proposed rule
specifically addresses self-trades,
allowing FINRA to charge a firm with a
violation of the proposed rule for such
conduct, in addition to a supervisory
violation, and establishing a new
requirement for firms to monitor and
prevent self-trading activity from a
single algorithm or trading desk, or
related algorithms or trading desks.57
In response to the concern about a
lack of guidance on the types of selftrades that would violate the proposed
rule, FINRA stated its understanding
that discrete units within a firm’s
system of internal controls typically do
not coordinate their trading strategies or
objectives with other discrete units of
internal controls, but that multiple
algorithms or trading desks within a
discrete unit are permitted to
communicate or are under the
supervision of the same personnel and
thus, are presumed to be related.58
FINRA stated that the proposed rule
permits firms to rebut this presumption,
suggesting that a firm could demonstrate
53 Id.
54 Id.
55 Id.
56 See
FINRA Response 2, supra note 10, at 2–3.
57 Id.
58 Id.
E:\FR\FM\07MYN1.SGM
at 4.
07MYN1
26297
Federal Register / Vol. 79, No. 88 / Wednesday, May 7, 2014 / Notices
that ‘‘related’’ algorithms or trading
desks are in fact independent or are
subject to supervision or management
by separate personnel.59 FINRA
declined to specify a volume of trading
that would constitute a ‘‘pattern or
practice’’ for purposes of the proposed
rule, explaining that it preferred not to
‘‘establish a specific threshold below
which a firm could continue to engage
in unlimited self-trading,’’ 60 but urged
firms to examine their self-trading for
volume and frequency, which could
indicate a pattern or practice.61
Finally, FINRA noted that wash sales
will continue to be subject to the same
provisions in the federal securities laws
and FINRA rules.62 The Commission
believes that FINRA has sufficiently
addressed the Commission’s concerns.
For the reasons discussed above, the
Commission finds that the proposed
rule change is consistent with the Act.
IV. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,63 that the
proposed rule change (SR–FINRA–
2013–036), as modified by Amendment
No. 1, be, and hereby is, approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.64
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–10384 Filed 5–6–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[File No. S7–40–10; Release No. 72079]
Securities Exchange Act of 1934; In the
Matter of Exchange Act Rule 13p–1
and Form SD; Order Issuing Stay
May 2, 2014.
On April 14, 2014, the United States
Court of Appeals for the District of
Columbia Circuit issued a decision in
National Association of Manufacturers,
et al. v. SEC, et al., No. 13–5252 (D.C.
Cir. April 14, 2014). That case involved
a challenge to Exchange Act Rule 13p–
1 and Form SD.1 The rule and form were
adopted pursuant to Section 13(p) of the
Securities Exchange Act of 1934, which
was added by Section 1502 of the DoddFrank Wall Street Reform and Consumer
Protection Act.2 The Court of Appeals
rejected all of the challenges to the rule
based on the Administrative Procedure
Act and the Exchange Act. The Court of
Appeals, however, concluded that
Section 13(p) and Rule 13p–1 ‘‘violate
the First Amendment to the extent the
statute and rule require regulated
entities to report to the Commission and
to state on their Web site that any of
their products have ‘not been found to
be ‘DRC conflict free.’ ’ ’’ 3 In so
concluding, the Court of Appeals
specifically noted that there was no
‘‘First Amendment objection to any
other aspect of the conflict minerals
report or required disclosures.’’ 4 In an
order issued concurrently with the
decision, the Court of Appeals withheld
the issuance of its mandate until seven
days after disposition of any timely
petition for rehearing or petition for
rehearing en banc. As a result, the
earliest date on which the Court of
Appeals’s mandate is likely to issue is
June 5, 2014. Under Rule 13p–1, the
first reports are due to be filed on June
2, 2014.
Section 705 of the Administrative
Procedure Act provides that an agency
may postpone the effective date of an
action taken by it pending judicial
review when it finds that ‘‘justice so
requires.’’ 5 U.S.C. 705. In light of the
Court of Appeals’s decision, the
Commission finds that it is consistent
with what justice requires to stay the
effective date for compliance with those
portions of Rule 13p–1 and Form SD
that would require the statements by
issuers that the Court of Appeals held
would violate the First Amendment.
Among other things, a stay of those
portions of the rule avoids the risk of
First Amendment harm pending further
proceedings. Moreover, limiting the stay
to those portions of the rule requiring
the disclosures that the Court of
Appeals held would impinge on issuers’
First Amendment rights furthers the
public’s interest in having issuers
comply with the remainder of the rule,
which was mandated by Congress in
Section 1502 and upheld by the Court
of Appeals.
Accordingly, it is ordered, pursuant to
Section 705 of the Administrative
Procedure Act, that the effective date for
compliance with those portions of Rule
13p–1 and Form SD subject to the Court
of Appeals’s constitutional holding are
hereby stayed pending the completion
of judicial review, at which point the
stay will terminate. For more detailed
guidance regarding compliance, issuers
should refer to the statement issued by
the staff on April 29, 2014, and any
further guidance subsequently
provided.5
By the Commission.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–10437 Filed 5–6–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[ File No. 500–1]
In the Matter of: Genosys, Inc.: Order
of Suspension of Trading
May 5, 2014.
It appears to the Securities and
Exchange Commission that there is a
lack of current and accurate information
concerning the securities of GeNOsys,
Inc. (‘‘Genosys’’) because Genosys has
not submitted the following required
periodic filings:
pmangrum on DSK3VPTVN1PROD with NOTICES
Filing
Due date
Annual report on Form 10–K for period ended Nov. 30, 2011 .................................................................................................
Quarterly report on Form 10–Q for period ended Feb. 29, 2012 .............................................................................................
Quarterly report on Form 10–Q for period ended May 31, 2012 .............................................................................................
Quarterly report on Form 10–Q for period ended August 31, 2012 .........................................................................................
Annual report on Form 10–K for period ended Nov. 30, 2012 .................................................................................................
Quarterly report on Form 10–Q for period ended Feb. 28, 2013 .............................................................................................
Quarterly report on Form 10–Q for period ended May 31, 2013 .............................................................................................
Quarterly report on Form 10–Q for period ended August 31, 2013 .........................................................................................
Annual report on Form 10–K for period ended Nov. 30, 2013 .................................................................................................
59 Id.
60 Id.
at 5.
61 Id.
62 See
FINRA Response 2, supra note 10, at 3.
U.S.C. 78s(b)(2).
64 17 CFR 200.30–3(a)(12).
63 15
VerDate Mar<15>2010
17:28 May 06, 2014
Jkt 232001
1 Conflict Minerals, 77 FR 56,274 (Sept. 12, 2012)
(codified at 17 CFR 240, 249b).
2 Public Law 111–203, 124 Stat. 1376, 2213
(2010).
3 Slip. Op. at 23.
4 Slip. Op. at 17 n.8.
PO 00000
Frm 00099
Fmt 4703
Sfmt 4703
February 28, 2012.
April 16, 2012.
July 16, 2012.
October 15, 2012.
February 28, 2013.
April 15, 2013.
July 15, 2013.
October 15, 2013.
February 28, 2014.
5 On April 30, 2014, the National Association of
Manufacturers, the Chamber of Commerce, and
Business Roundtable filed a motion requesting that
the Commission stay Rule 13p–1 in its entirety. In
accordance with the above order, the motion is
denied.
E:\FR\FM\07MYN1.SGM
07MYN1
Agencies
[Federal Register Volume 79, Number 88 (Wednesday, May 7, 2014)]
[Notices]
[Pages 26293-26297]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-10384]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-72067; File No. SR-FINRA-2013-036]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Order Approving Proposed Rule Change, as Modified by
Amendment No. 1, Relating to Self-Trades and FINRA Rule 5210
(Publication of Transactions and Quotations) May 1, 2014.
I. Introduction
On August 15, 2013, the Financial Industry Regulatory Authority,
Inc. (``FINRA'') filed with the Securities and Exchange Commission (the
``Commission'') pursuant to Section 19(b)(1) of the Securities Exchange
Act of 1934 (the ``Act'') \1\ and Rule 19b-4 thereunder,\2\ a proposed
rule change to add Supplementary Material .02 to FINRA Rule 5210
(Publication of Transactions and Quotations) to emphasize that wash
sale transactions are generally non-bona fide transactions and that
members have an obligation to have policies and procedures in place to
review their trading activity for, and prevent, wash sale transactions.
The proposed rule change was published for comment in the Federal
Register on September 4, 2013.\3\ The Commission
[[Page 26294]]
received five comment letters on the proposed rule change.\4\ On
October 4, 2013, the Commission extended the time period for Commission
action to December 3, 2013.\5\ On December 2, 2013, FINRA submitted a
response to the comment letters \6\ and filed Amendment No. 1 to the
proposed rule change. On December 3, 2013, the Commission published for
comment both Amendment No. 1 and an order instituting proceedings under
Section 19(b)(2)(B) of the Act \7\ to determine whether to approve or
disapprove the proposed rule change, as modified by Amendment No. 1.\8\
The Commission received three comment letters on the Notice of Filing
of Amendment No. 1 and Order Instituting Proceedings.\9\ On February
24, 2014, FINRA submitted a response to the comment letters.\10\ This
order approves the proposed rule change, as modified by Amendment No.
1.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 70276 (August 28,
2013), 78 FR 54502 (``Notice'').
\4\ See letter from Anonymous to Elizabeth M. Murphy, Secretary,
Commission, dated September 9, 2013 (``Anonymous Letter''); letter
from William A. Jacobson, Clinical Professor of Law, and Director,
Cornell Securities Law Clinic, and Jimin Lee, Cornell University Law
School, to Elizabeth M. Murphy, Secretary, Commission, dated
September 25, 2013 (``Cornell Letter''); letter from Stuart J.
Kaswell, Executive Vice President, Managing Director and General
Counsel, Managed Funds Association, to Elizabeth M. Murphy,
Secretary, Commission, dated September 25, 2013 (``MFA Letter'');
letter from Manisha Kimmel, Executive Director, Financial Industry
Forum, to Elizabeth M. Murphy, Secretary, Commission, dated
September 25, 2013 (``FIF Letter''); and letter from Theodore R.
Lazo, Managing Director and Associate General Counsel, Securities
Industry and Financial Markets Association, to Elizabeth M. Murphy,
Secretary, Commission, dated October 4, 2013 (``SIFMA Letter''). For
a discussion of these comment letters, see Notice of Filing of
Amendment No. 1 and Order Instituting Proceedings, infra note 8, at
73902-73903.
\5\ See Securities Exchange Act Release No. 70613 (October 4,
2013), 78 FR 62784 (October 22, 2013).
\6\ See letter from Brant K. Brown, Associate General Counsel,
FINRA, to Elizabeth M. Murphy, Secretary, Commission, dated December
2, 2013 (``FINRA Response 1'').
\7\ 15 U.S.C. 78s(b)(2)(B).
\8\ See Securities Exchange Act Release No. 70966 (December 3,
2013), 78 FR 73900 (December 9, 2013) (``Notice of Filing of
Amendment No. 1 and Order Instituting Proceedings'').
\9\ See letter from Manisha Kimmel, Executive Director,
Financial Industry Forum, to Elizabeth M. Murphy, Secretary,
Commission, dated December 23, 2013 (``FIF Letter 2''); letter from
Mary Ann Burns, Chief Operating Officer, Futures Industry
Association, to Elizabeth M. Murphy, Secretary, Commission, dated
January 6, 2014 (``FIA PTG Letter''); and letter from Theodore R.
Lazo, Managing Director and Associate General Counsel, Securities
Industry and Financial Markets Association, to Elizabeth M. Murphy,
Secretary, Commission, dated January 13, 2014 (`SIFMA Letter 2'').
\10\ See letter from Brant K. Brown, Associate General Counsel,
FINRA, to Elizabeth M. Murphy, Secretary, Commission, dated February
24, 2014 (``FINRA Response 2'').
---------------------------------------------------------------------------
II. Description of the Proposal, as Modified by Amendment No. 1
FINRA proposes to add Supplementary Material .02 to FINRA Rule 5210
to address members' obligations with respect to certain securities
transactions that result from the unintentional interaction of orders
originating from the same firm (now referred to by FINRA as ``self-
trades''), that involve no change in the beneficial ownership of the
security.\11\ The proposed rule change requires FINRA members to have
policies and procedures in place that are reasonably designed to review
their trading activity for, and prevent, a pattern or practice of self-
trades resulting from orders originating from a single algorithm or
trading desk, or from related algorithms or trading desks.
Additionally, the proposed rule change states that transactions
resulting from orders that originate from unrelated algorithms or from
separate and distinct trading strategies within the same firm would
generally be considered bona fide self-trades.\12\ The proposed rule
change also establishes a presumption that algorithms or trading
strategies within the most discrete unit of an effective system of
internal controls at a member firm are related.
---------------------------------------------------------------------------
\11\ Securities transactions that do not result in a change of
beneficial ownership of the securities and that are undertaken for
the purpose of creating or inducing a false or misleading appearance
of activity in the securities are already prohibited by existing
securities laws and FINRA rules. See note 14, infra.
The Commission notes that the original proposal addressed wash
sale transactions. Subsequently, FINRA filed Amendment No. 1, which
clarified that the focus of the proposal was self-trades, rather
than wash sale transactions.
\12\ Transactions that originate from unrelated algorithms or
from separate or distinct trading strategies, trading desks, or
aggregation units that are frequent or numerous may raise a
presumption that such transactions were undertaken with the intent
that they cross and may, therefore, be intended as manipulative or
fraudulent. See Notice, supra note 3, at 54503.
---------------------------------------------------------------------------
The proposed rule change is intended to address self-trades that
occur as a result of orders sent by a single algorithm or the
interaction of multiple, related algorithms operated by a single firm.
In a number of instances, FINRA has found that these types of
transactions can account for a material percentage (e.g., over 5%) of
the consolidated trading volume in a security on a particular day,
which can distort the market information that is publicly available for
that security. In FINRA's view, even if not purposeful, these
transactions can create the misimpression of active trading in a
security that could adversely affect the price discovery process.
Furthermore, FINRA believes that, in these instances, firms will
continue to allow this type of trading to occur rather than incur the
costs necessary to prevent it, even though the trading activity may
result in instances where significant misinformation is disseminated to
the market. The proposed rule change requires members to adopt
reasonable policies and procedures to prohibit such activity and would
not, therefore, apply to isolated self-trades resulting from orders
originating from a single algorithm or trading desk, or from related
algorithms or trading desks, provided the firm's policies and
procedures were reasonably designed.\13\
---------------------------------------------------------------------------
\13\ The proposed rule change would not change member firms'
existing obligations under NASD Rule 3010 and FINRA Rule 2010 with
respect to wash sales. See Notice, supra note 3, at 54503.
---------------------------------------------------------------------------
FINRA rules and the federal securities laws explicitly prohibit
transactions in securities that do not result in a change of beneficial
ownership of the securities when there is a fraudulent or manipulative
purpose behind the trading activity.\14\ In addition, FINRA Rule 5210
provides that no member may cause to be published or circulated any
report of a securities transaction unless the member knows or has
reason to believe that the transaction was a bona fide transaction.
Supplementary Material .01 states that ``[i]t shall be deemed
inconsistent with Rules 2010 (Standards of Commercial Honor and
Principles of Trade), 2020 (Use of Manipulative, Deceptive or Other
Fraudulent Devices) and 5210 (Publication of Transactions and
Quotations) for a member to publish or circulate or cause to be
published or circulated, by any means whatsoever, any report of any
securities transaction or of any purchase or sale of any security
unless such member knows or has reason to believe that such transaction
was a bona fide transaction, purchase or sale.'' Thus, each FINRA
member has an existing obligation to know, or have a basis to believe,
that transactions in which it participates are bona fide.
---------------------------------------------------------------------------
\14\ See, e.g., 15 U.S.C. 78i(a)(1); FINRA Rule 6140(b).
---------------------------------------------------------------------------
III. Discussion and Commission Findings
The Commission has carefully considered the proposal, the comments
submitted, and FINRA's response to the comments, and believes that
FINRA has responded adequately to the concerns raised by the commenters
and by the Commission in the Order Instituting Proceedings. For the
reasons discussed below, the Commission finds that the proposal is
consistent with the
[[Page 26295]]
requirements of the Act and the rules and regulations thereunder
applicable to a national securities association.\15\ In particular, the
Commission finds that the proposed rule change is consistent with the
provisions of Section 15A(b)(6) of the Act,\16\ which requires, among
other things, that FINRA's rules be designed to prevent fraudulent and
manipulative acts and practices, to promote just and equitable
principles of trade, and, in general, to protect investors and the
public interest. The proposal requires firms to adopt policies and
procedures reasonably designed to prevent a pattern or practice of
certain types of self-trades, which could create the misimpression of
active trading and adversely affect the price discovery process. Thus,
the proposed rule change is designed to improve the quality of
transaction information that is disseminated to the public.
---------------------------------------------------------------------------
\15\ In approving the proposed rule change, the Commission has
considered the proposed rule's impact on efficiency, competition and
capital formation. See 15 U.S.C. 78c(f).
\16\ 15 U.S.C. 78o-3(b)(6).
---------------------------------------------------------------------------
As noted above, the Commission received three comment letters in
response to the Notice of Filing of Amendment No. 1 and Order
Instituting Proceedings \17\ and FINRA responded to the comments.\18\
Two comment letters supported the approval of the proposed rule change,
as amended.\19\ The third comment letter is generally supportive, but
requests modifications to the proposal.\20\
---------------------------------------------------------------------------
\17\ See FIF Letter 2; FIA PTG Letter; SIFMA Letter 2, supra
note 9. For a discussion of the comment letters received by the
Commission in response to the Notice, see Notice of Filing of
Amendment No. 1 and Order Instituting Proceedings, supra note 8, at
73902-73903.
\18\ See FINRA Response 2, supra note 10.
\19\ See FIF Letter 2; SIFMA Letter 2, supra note 9.
\20\ See FIA PTG Letter, supra note 9.
---------------------------------------------------------------------------
Two commenters support FINRA's amendment to focus the proposed rule
change on ``self-trades,'' rather than ``wash sales.'' \21\ One
commenter supports FINRA's replacement of the term ``wash sale'' with
``self-trade,'' explaining that, unlike wash sale transactions, self-
trades can be inadvertent and bona fide.\22\ The commenter believes
that this change in terminology recognizes that automated trading can
result in coincidental self-trades from independently initiated orders
that lack the requisite fraudulent or manipulative intent to be
classified as ``wash sales.'' \23\ The other commenter also supports
the distinction and states that the proposed rule better addresses the
concern raised in the original proposal--that self-trades can distort
market information regarding a security--by creating an obligation for
broker-dealers to avoid transactions that unintentionally result in no
change in beneficial ownership and do not involve manipulative or
fraudulent intent.\24\
---------------------------------------------------------------------------
\21\ See FIA PTG Letter, supra note 9, at 2; SIFMA Letter 2,
supra note 9, at 1.
\22\ See FIA PTG Letter, supra note 9, at 2.
\23\ Id.
\24\ See SIFMA Letter 2, supra note 9, at 1-2.
---------------------------------------------------------------------------
Because the proposal is intended to address the unintentional
interaction of orders originating from the same firm that involve no
change in the beneficial ownership of the security and can lead to the
dissemination of misinformation to the marketplace and the public, the
Commission believes that modifying the focus of the proposed rule from
``wash sales'' to ``self-trades'' appropriately tailors the scope of
the proposed rule and addresses potential confusion.
Two commenters support FINRA's requirement that members have
policies and procedures in place to review their trading activity for,
and prevent, a pattern or practice of self-trades resulting from orders
originating from a single algorithm or trading desk, or related
algorithms or trading desks.\25\ One commenter states, ``Amendment No.
1 strikes the right balance of addressing a pattern and [sic] practice
of self-trading while acknowledging the implementation issues inherent
in preventing every self-trade.'' \26\ This commenter believes that the
pattern or practice standard addresses the problem outlined in the
proposal of self-trades that distort the market information that is
publicly available for a security.\27\ The other commenter believes
that the pattern or practice standard would deter broker-dealers from
permitting large numbers of self-trades from being publicly
reported.\28\
---------------------------------------------------------------------------
\25\ See FIF Letter 2, supra note 9, at 1-2; SIFMA Letter 2,
supra note 9, at 2. FIA PTG also supports FINRA's amended policies
and procedures requirement, but believes the requirement needs to be
clarified. See FIA PTG Letter, supra note 9, at 2, 7.
\26\ See FIF Letter 2, supra note 9, at 1.
\27\ See FIF Letter 2, at 2, supra note 9.
\28\ See SIFMA Letter 2, supra note 9, at 2.
---------------------------------------------------------------------------
In its response, FINRA explains that the proposed supplementary
material is primarily designed to address instances where self-trades
account for a significant percent of volume in a security, which may
affect price discovery.\29\ FINRA explains that its proposed policies
and procedures requirement addresses its concern that self-trades by a
single algorithm or trading desk, or related algorithms or trading
desks, may not reflect genuine trading interest, especially when there
is a pattern or practice of such trading behavior.\30\ FINRA believes
that its proposal will allow FINRA to more effectively deter self-
trading that, while not involving fraudulent or manipulative intent, is
disruptive to the marketplace.\31\
---------------------------------------------------------------------------
\29\ See FINRA Response 2, supra note 10, at 3.
\30\ Id.
\31\ Id.
---------------------------------------------------------------------------
Tailoring the limitation in the supplementary material to a pattern
or practice of self-trades resulting from orders originating from a
single algorithm or trading desk, or related algorithms or trading
desks, would not prohibit isolated instances of self-trading, yet would
address more systematic self-trading that could result in the
dissemination of misleading trading information to the marketplace. The
proposal would provide FINRA with an enforceable rule specifically
targeting activity that rises to the level of a pattern or practice of
such self-trading, and requires firms to have policies and procedures
reasonably designed to review their trading activity for, and prevent,
the same. The Commission encourages FINRA to surveil the efficacy of
these policies and procedures in reducing the volume of self-trading,
and to consider further refinement of the rule if warranted.
One commenter requests that FINRA clarify its distinction between
bona fide and non-bona fide self-trades.\32\ This commenter notes that
the proposed rule states that self-trades that result from orders
originating from unrelated algorithms or separate and distinct trading
strategies within the same firm are generally bona fide, but that FINRA
also stated in the Notice that such transactions, if frequent or
regular, may raise a presumption of manipulative or fraudulent
intent.\33\ The commenter requests clarification of FINRA's views on
frequent self-trades resulting from unrelated trading strategies, and
asserts that it would be ``inappropriate and inaccurate to infer their
relatedness or the intent to self-trade based solely on a volume
threshold.'' \34\ Instead, the commenter recommends that FINRA adopt a
wash sale approach described by the Chicago Mercantile Exchange Group
(``CME'') in a recent CME Market Regulation Advisory Notice to
determine whether trades between unrelated algorithms are bona
fide.\35\ The commenter explains that the CME Market Regulation
Advisory Notice states that orders entered by an independent trader in
good faith for the purpose of executing bona fide
[[Page 26296]]
transactions, that are not prearranged and are entered without
knowledge of the other trader's order, will not violate the CME's
prohibition on wash trades.\36\ Similarly, another commenter requests
that FINRA issue a Regulatory Notice that states that self-trades
resulting from orders originating from unrelated algorithms would not
be deemed related based solely on the fact that the unrelated
algorithms were being used by traders on the same trading desk.\37\
---------------------------------------------------------------------------
\32\ See FIA PTG Letter, supra note 9, at 3-4.
\33\ Id.
\34\ Id. at 4.
\35\ Id.
\36\ Id. In its comment letter, FIF noted that it believes that
FINRA's pattern and practices standard is consistent with the
guidance provided in the CME Market Regulation Advisory Notice. See
FIF Letter 2, supra note 9, at 2.
\37\ See FIF Letter 2, supra note 9, at 2.
---------------------------------------------------------------------------
In its response, FINRA reiterates its position that, although self-
trades between unrelated trading desks or algorithms are generally bona
fide, frequent self-trades may raise concerns that they are intentional
or undertaken with manipulative or fraudulent intent.\38\ FINRA also
distinguishes its proposal's goals from those addressed by the CME
Market Regulation Advisory Notice.\39\ FINRA notes that its proposal is
meant to address unintentional self-trading activity--not the
regulation of wash sale transactions.\40\ Further, unlike the CME
Market Regulation Advisory Notice, FINRA states that its proposal
``imposes specific additional obligations on firms that engage in
algorithmic activity or use multiple algorithms or trading desks as
part of their trading activity.'' \41\ The proposal is intended to curb
unintentional self-trades that result in the dissemination of
misinformation to the public and negatively affect price discovery.
---------------------------------------------------------------------------
\38\ See FINRA Response 2, supra note 10, at 4.
\39\ Id.
\40\ Id.
\41\ Id.
---------------------------------------------------------------------------
One commenter states that FINRA's amended proposal would continue
to establish a rebuttable presumption that algorithms within discrete
units of a firm's internal controls are related, regardless of comments
that assert that ``discrete units of a firm's internal controls are
established for reasons wholly separate from whether the trading
strategies and algorithms within that unit are related.'' \42\ The
commenter believes that the proposal causes confusion over whether the
presumption can be overcome.\43\ The commenter requests that FINRA
provide clear guidance on the standards that would rebut the
presumption of relatedness.\44\ In its response, FINRA explains that
the presumption is based on the fact that generally firms have the same
people supervising algorithms or trading desks within a discrete unit,
and that such algorithms or trading desks communicate with each
other.\45\ FINRA states, however, that firms would be able to rebut
this presumption if they can show, for example, that different
personnel are responsible for supervising the algorithms or trading
desks.\46\ The Commission believes that FINRA has taken a reasonable
position with respect to this presumption and provided appropriate
guidance with respect to how it might be rebutted.
---------------------------------------------------------------------------
\42\ See FIA PTG Letter, supra note 9, at 5.
\43\ Id., at 6.
\44\ Id.
\45\ See FINRA Response 2, supra note 10, at 4.
\46\ Id.
---------------------------------------------------------------------------
One commenter believes that the proposed rule lacks clarity
regarding the types of self-trading for which firms would need to
review, and prevent, patterns or practices.\47\ The commenter requested
more specificity from FINRA about the amount of activity that would
constitute a pattern or practice.\48\ In response to the commenter,
FINRA states that it ``declines to establish a specific threshold below
which a firm could continue to engage in unlimited self-trading.'' \49\
FINRA reiterates that isolated self-trades are generally bona fide, but
that a practice of self-trading over time ``whether of material volume,
regularity, or both,'' would indicate a pattern or practice.\50\ The
Commission believes that the proposed rule change, as amended provides
sufficient clarity to member firms, and notes that the concept of a
pattern or practice is used in a number of FINRA rules.\51\
---------------------------------------------------------------------------
\47\ See FIA PTG Letter, supra note 9, at 7.
\48\ Id.
\49\ See FINRA Response 2, supra note 10, at 5.
\50\ Id.
\51\ See, e.g., FINRA Rule 6282, Supplementary Material .02(b).
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In the Notice of Filing of Amendment No. 1 and Order Instituting
Proceedings, the Commission expressed concern that the proposed rule,
as amended, would continue to allow a significant number of self-trades
to be publicly reported.\52\ Specifically, the Commission noted FINRA's
statement in its filing that only those firms that engage in a pattern
or practice of effecting self-trades that result in a material
percentage of the trading volume in a particular security would
generally violate the proposed rule, as well as FINRA's proposed
requirement that its members have policies and procedures to prevent,
specifically, a pattern or practice of self-trades from orders
originating from a single or related algorithms or trading desks.\53\
The Commission stated that the proposed rule would appear to provide
substantial flexibility regarding the required policies and procedures,
such that a significant number of self-trades could continue to be
publicly reported, as orders originating from ``unrelated'' algorithms
or ``separate and distinct'' trading strategies would not be subject to
the proposed rule, and because only self-trades amounting to a material
percentage of a security's trading volume would constitute violative
activity.\54\ The Commission also noted that FINRA provided little
guidance on its interpretations of what would constitute ``unrelated''
algorithms or ``separate and distinct'' trading strategies.\55\
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\52\ See Notice of Filing of Amendment No. 1 and Order
Instituting Proceedings, supra note 8, at 73904.
\53\ Id.
\54\ Id.
\55\ Id.
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In its response, FINRA explained that the proposed rule is designed
to strike a balance between recognizing that self-trades may reflect
genuine trading interest and therefore be bona fide, and imposing an
obligation on firms to prevent a pattern or practice of self-trading
that rises to the level of disruptive activity. While self-trades may
be unintentional, if the number of self-trades by a firm constitutes a
material percentage of the volume in a security, it could have a
negative effect on the price discovery process.\56\ FINRA explained
that the proposed rule would allow it to better pursue self-trading
violations because the proposed rule specifically addresses self-
trades, allowing FINRA to charge a firm with a violation of the
proposed rule for such conduct, in addition to a supervisory violation,
and establishing a new requirement for firms to monitor and prevent
self-trading activity from a single algorithm or trading desk, or
related algorithms or trading desks.\57\
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\56\ See FINRA Response 2, supra note 10, at 2-3.
\57\ Id.
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In response to the concern about a lack of guidance on the types of
self-trades that would violate the proposed rule, FINRA stated its
understanding that discrete units within a firm's system of internal
controls typically do not coordinate their trading strategies or
objectives with other discrete units of internal controls, but that
multiple algorithms or trading desks within a discrete unit are
permitted to communicate or are under the supervision of the same
personnel and thus, are presumed to be related.\58\ FINRA stated that
the proposed rule permits firms to rebut this presumption, suggesting
that a firm could demonstrate
[[Page 26297]]
that ``related'' algorithms or trading desks are in fact independent or
are subject to supervision or management by separate personnel.\59\
FINRA declined to specify a volume of trading that would constitute a
``pattern or practice'' for purposes of the proposed rule, explaining
that it preferred not to ``establish a specific threshold below which a
firm could continue to engage in unlimited self-trading,'' \60\ but
urged firms to examine their self-trading for volume and frequency,
which could indicate a pattern or practice.\61\
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\58\ Id. at 4.
\59\ Id.
\60\ Id. at 5.
\61\ Id.
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Finally, FINRA noted that wash sales will continue to be subject to
the same provisions in the federal securities laws and FINRA rules.\62\
The Commission believes that FINRA has sufficiently addressed the
Commission's concerns. For the reasons discussed above, the Commission
finds that the proposed rule change is consistent with the Act.
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\62\ See FINRA Response 2, supra note 10, at 3.
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IV. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\63\ that the proposed rule change (SR-FINRA-2013-036), as modified
by Amendment No. 1, be, and hereby is, approved.
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\63\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\64\
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\64\ 17 CFR 200.30-3(a)(12).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-10384 Filed 5-6-14; 8:45 am]
BILLING CODE 8011-01-P