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Order Audit Trail System (OATS) An integrated audit trail of order, quote, and trade information for all NMS stocks and OTC equity securities Course: FRE-7211 Group#: 2 Submission#: Final Report Members: Mamoon Ismail Khalid (N11965449 / mik279) Viswanatha Mehta (N10196427 / vsm263) Sana Ghaus (N11380506 / sg4626)

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Page 1: FINRA Order audit trail system

Order Audit Trail System

(OATS)

An integrated audit trail of order, quote, and

trade information for all NMS stocks and

OTC equity securities

Course: FRE-7211 Group#: 2

Submission#: Final Report

Members: Mamoon Ismail Khalid (N11965449 / mik279)

Viswanatha Mehta (N10196427 / vsm263)

Sana Ghaus (N11380506 / sg4626)

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Contents Introduction ................................................................................................................................................... 3

The Scope ...................................................................................................................................................... 3

The Need for OATS ........................................................................................................................................ 4

Events Leading Up to OATS ....................................................................................................................... 5

The Objectives of OATS ............................................................................................................................. 6

Timeline Events ............................................................................................................................................. 7

FINRA Rules for OATS .................................................................................................................................... 7

Technology ................................................................................................................................................... 9

Information Flow .................................................................................................................................... 10

Order Life Cycle Creation ........................................................................................................................ 11

Information architecture and protocols ................................................................................................. 11

Report Formats ........................................................................................................................................... 12

Challenges of OATS ..................................................................................................................................... 13

Member firms responsibilities .................................................................................................................... 13

Exemptive Circumstances ....................................................................................................................... 15

Resources for member firms .................................................................................................................. 15

OATS in Action ............................................................................................................................................ 16

REFERNCES .................................................................................................................................................. 17

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Introduction The Order Audit Trail System (OATS) is part of an integrated audit trail of order, quote, and trade

information for all NMS stocks and OTC equity securities (“OATS reportable securities”). This audit trail

system, developed by NASD in response to the August 1996 settlement with the Securities and Exchange

Commission (SEC), is used in FINRA's surveillance activities. FINRA Rules 7400 through 7470 (OATS

Rules) and FINRA Rule 4554, require member firms to develop a means for electronically capturing and

reporting to OATS order data on specified events in the life cycle of each order for OATS reportable

securities, including convertible bonds, and to record the times of these events to the second. Figure 1

provides an overview of the Order Audit Trail System reporting process. In addition, OATS Rules require

member firms to synchronize all business clocks used to record the time and date of market events to a time

source designated by FINRA. [1]

Figure 1: An Overview of the OATS Reporting Process

The Scope

The current scope of OATS is used to regulate and monitor: 1) All orders:

received by FINRA member firms,

in NMS and OTC listed equity securities,

Whether received manually or electronically, are currently reportable to OATS.

2) Proprietary orders generated in the normal course of a firm’s market making activities are not reportable

to OATS. All other proprietary orders are reportable.

OATS requires that all orders in NASDAQ (and other exchanges) equity securities be reported to OATS,

including (but not limited to):

Orders received telephonically

Orders received via email

Orders received via Internet

Orders received at branch offices

Orders received by Instant Messenger

In total, the information collected on the OATS report includes 75 separate pieces of information. However, the OATS report specifically looks at (as listed on FINRA publication titled “OATS Reporting

Technical Specifications January 11, 2016”): [1]

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Customer or firm order,

Date and time of receipt,

Order ID,

Terms of the order (i.e. buy, sell, sell short, security, price, shares, account type and handling

instructions),

If the order was received manually or electronically,

If the order was routed manually or electronically,

Where the order was routed for execution,

Any modifications to the order including the date and time of any modifications,

Execution information including partial executions, price, date, time and capacity in which the firm

acted in the trade.

The Need for OATS

Failure to properly regulate the market system has more than once caused deep hardship across the globe,

a recent example would the flash crash of 2010. As the world moves into the post-information age, the data collection and processing prowess are at

unforeseen highs. Although Wall Street had always been in the business of data analysis, the collection & Analysis of billions

of transactions, especially for regulatory services,this grew in tandem with Moore’s law. As the computing power exponentiated, so did the market & regulators thirst for data collection & Analysis. In this new paradigm, digitizing the financial markets has led to an explosive growth in the volume of

trades. To keep up with the ability of computers to trade at inhuman speeds required regulators to collect

data at inhuman speeds. [2] This requires a suitable connection to the data, a place to put the data, and the means to analyze the

data.

Figure 2: NYSE Trade Volume Data

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The regulators’ need for data is primarily two-fold: (1) To be able to recreate market conditions; and, (2) Detect and expose market abuses.

The ability to recreate market conditions empowers the regulators to piece together the facts, which when

coupled with other investigative techniques, leads to the determination of innocence or guilt or a systematic

market problem. The process of recreating the said conditions usually involved regulators requesting the information they

need from the entity or person they are investigating. This has two particular drawbacks in that it puts a burden on the investigated party who has to spend time

collecting and transporting the information and the burden on the investigators to then go through the

information to reach meaningful conclusions. Both of these drawbacks also add to the time taken to conduct and conclude an investigation. The difficulty of standardizing this information for completion and accuracy adds another layer to the

trustworthiness of the data collected. The recent gains in Big Data Science allows regulators to to use the power of greater market surveillance

in order to cut back on both drawbacks and curtail the issues of timeliness, accuracy, and a general lack of

collection coordination. Since the collection of the data in its entirety, requests wouldn't be one off expensive inquiries but rather

automated, efficient transfers of information. Thus the investigations boil down to being a proactive, rather than retroactive, system of regulation. [2]

Events Leading Up to OATS

The NASDAQ Price Collusion Scandal The article written in 1994 by William Christie and Paul Schultz entitled: “Why do NASDAQ Market

Makers Avoid Odd-Eighth Quotes?” can be traced as the seedling of the NASDAQ price collusion scandal’s

eventual uncovering. “As the title suggests, the authors noticed a distinct pattern in how quotes, and by extension, their spreads,

were made on NASDAQ. Their conclusion invokes game theory to posit the idea that tacit collusion among

the market makers is an equilibrium of the market structure at that time and indeed state that they are

“unable to envision any scenario in which 40 to 60 dealers who are competing for order flow would

simultaneously and consistently avoid using odd-eighths quotes without an implicit agreement to post

quotes only on the even price fractions.”[2] The SEC’s two yearlong investigation concluded in 1996 that there existed enough evidence to support the

tacit collusion on the NASDAQ market. NASD was sued by the SEC later on how they had not done enough to combat this issue. The report, remarked that:

In the course of the investigation, the Commission staff encountered significant difficulties

reconstructing activity in the Nasdaq market. Broker-dealer order tickets, among the most

fundamental of records, were too often unavailable or inconvenient to retrieve. Time stamping was

often unreliable for the purposes of determining compliance with applicable rules, such as the firm

quote rule and limit order protection rules.

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Creation of OATS The genesis of OATS begins in 1996 with the settlement between NASD and the SEC to resolve the myriad

issues found in the preceding price collusion scandal. For the next two years, the industry and SEC in

tandem set forth the rules and form of OATS and in March of 1998 the rules were approved by the SEC

giving them the force of law.

The Objectives of OATS

(1) Provide an accurate, time-sequenced record of orders and transactions, and (2) Provide for market-wide synchronization of clocks used in connection with the audit trail. Market data collection before OATS was plagued with an inaccurate clock system and a general lack of

standardization. “The OATS Rules currently impose obligations on FINRA member firms to record in electronic

form and report to FINRA on a daily basis certain information about orders originated, received,

transmitted, modified, canceled or executed by firms relating to OTC equity securities and equity securities

listed and traded on The Nasdaq Stock Market, Inc. (NASDAQ)”. OATS was “designed to prevent fraudulent and manipulative acts and practices” and to “protect investors

and the public interest.” This remains part of the fundamental goal of OATS beyond simply ensuring clock synchronization or

reporting standards. The data collected by OATS “would provide a substantially enhanced body of information regarding orders

and transactions that would improve the NASDR’s ability to conduct surveillance and investigations of

member firms for violations of Association rules.” [4]

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Timeline Events

These are events that transpired to create OATS: 1994: The paper “Why do NASDAQ Market Makers Avoid Odd-Eighth Quotes?” unhinges the NASDAQ

collusion 1994: The SEC launch an investigation on the NASDAQ collusion 1996: The SEC charges and sues the NASD for failing to reel in the collusion 1996: SEC settlement with the NASD turns into the Genesis of OATS 1998: SEC approves rules that govern OATS, thus empowering it with the force of Law.

OATS Rules became effective as follows: 1999, March 1, for electronic orders in Nasdaq–listed equity securities received at the trading desk of

market makers and for all electronic orders received by ECNs 1999, August 1, for all electronic orders in Nasdaq–listed equity securities 2006, July 10, for all orders in Nasdaq–listed equity securities 2008, February 4, for all orders in OTC equity securities 2011, October 17, for all orders in NMS stocks

FINRA Rules for OATS

1. FINRA Rule 7410 - Definitions

2. FINRA Rule 7420 - Applicability

3. FINRA Rule 7430 - Synchronization of Business Clocks

4. FINRA Rule 7440 - Recording Order Information

5. FINRA Rule 7450 - Order Data Transmission Requirements

6. FINRA Rule 7460 - Violation of OATS Rules

7. FINRA Rule 7470 - Exemption from Recording

FINRA Rule 7400 - Order Audit Trail System Rule 7400 is simply a place marker for the Order Audit

Trail System Rules. FINRA Rule 7410 - Definitions Rule 7410 lays out specific definitions of terms used for the purposes of

Rules 7400 - 7470. Terms not specifically defined shall have the same meaning as those defined in the By-

Laws and Rules of the Association. FINRA Rule 7420 - Applicability Rule 7420 applies the OATS Rules to all FINRA members. Further, the

rule requirements apply to all orders for OATS reportable securities whether they are executed or not. FINRA Rule 7430 - Synchronization of Member Business Clocks Rule 7430 requires any FINRA member

firm that records order, transaction or related data to synchronize all business clocks used to record the date

and time of any market event. Clocks, including computer system clocks and manual time stamp machines,

must record time in hours, minutes and seconds with to-the-second granularity and must be synchronized

to a source that is synchronized to within one second of the National Institute of Standards’ (NIST) atomic

clock. Clocks must be synchronized once a day prior to the opening of the market, and remain in synch

throughout the day. In addition, firms are to maintain a copy of their clock synchronization procedures on-

site. Clocks not used to record the date and time of market events need not be synchronized

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FINRA Rule 7440 - Recording of Order Information Rule 7440 requires each reporting member to record

the following types of order events: receipt or origination of an order (New Order Report); transmission of

the order within a firm (Desk Report); transmission of the order outside the firm (Route Report, Combined

Order/Route Report); cancellation or modification of the order (Cancel, Cancel/Replace Reports);

execution of the order (Execution Report, Combined Order/Execution Report). Each required record of

time shall be recorded in hours, minutes, and seconds and each order report is required to include specific

pieces of detailed information as outlined in the rule. FINRA Rule 7450 - Order Data Transmission Requirements All required order data must be transmitted

to FINRA in electronic format. Data may be transmitted electronically via FTP, SFTP, IFT, OATS Web

Interface, or through a third party such as a service bureau or clearing firm. Any member that uses a third

party to transmit order data on their behalf must have a written agreement with the third party outlining the

respective functions and responsibilities of each party. The member firm retains ultimate responsibility to

ensure full compliance with the FINRA OATS Rules. FINRA Rule 7460 - Violation of Order Audit Trail System Rules Failure to comply with the OATS Rules

may be considered conduct that is inconsistent with high standards of commercial honor and just and

equitable principles of trade, in violation of Rule 2010. FINRA Rule 7470 - Exemption to the Order Recording and Data Transmission Requirements Rule 7470

authorizes staff to grant limited exemptive relief from the OATS reporting and recording requirements for

manual orders, if such exemption is consistent with the protection of investors and the public interest, and

the member meets the following criteria: 1. The member and current control affiliates and associated persons of the member have not

been subject within the last five years to any final disciplinary action, and within the last

ten years to any disciplinary action involving fraud;

2. The member has annual revenues of less than $2 million;

3. The member does not conduct any market making activities in NMS stocks or OTC equity

securities;

4. The member does not execute principal transactions with its customers (with limited

exception for principal transactions executed pursuant to error corrections); and

5. The member does not conduct clearing or carrying activities for other firms.

FINRA Rule 4554 - Alternative Trading Systems – Recording and Reporting Requirements of Order and

Execution Information for NMS Stocks Rule 4554 requires ATSs to record and report additional

information at the time of order receipt and at the time of order execution. Additional data elements are

required to be reported by ATSs that display subscriber orders and by those that are registered as ADF

Trading Centers [7]

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Technology

Figure 3: Premier Technology Solution

OATS is hosted on the Amazon Web Services cloud platform. The reasons for selecting AWS platform for

data processing etc are manyfold, some of which are below:

Scalable and elastic

– Massive scalability at commodity costs – Ability to scale up and down to match demand – Usage based billing

Reduced time to market and less capital

– No hardware procurement cycle – Technology refresh is “free” – Continued Price Improvement Gartner places AWS well ahead of the competition in both

vision and ability to execute Resilient infrastructure for extreme availability and geographic diversity

Highly secure

Mature – Amazon has more than fifteen years of experience delivering large-scale, global

infrastructure in a reliable, secure fashion

AWS is 5 times larger than next largest 13 competitors combined

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Information Flow

Figure 4: Information Flow

The OATS Reporting Technical Specifications has been created specifically to describe the technical

requirements for reporting order data to OATS. It provides detailed information about the required data

elements and formats, transmission methods, and OATS feedback. [3]

1. Order Sending Organizations (OSOs) generate Reportable Order Events records (ROEs) and

package them in Firm Order Report files (FOREs). They could also enter the ROEs directly into

the OATS Web Interface.

2. The OSO transmits the FOREs to OATS using FTP, SFTP, IFT, or the Web.

3. OATS validates the FOREs and ROEs.

4. OATS generates FORE status within one hour. It is available via the original method of

transmission or the Web. (NOTE: For files submitted via FTP, SFTP, or IFT, firms must “pull”

status from OATS. OATS will not “push” information to OSOs via FTP, SFTP, or IFT.) Firms may

obtain additional feedback, including ROE rejections and reporting statistics, via the Web, FTP,

SFTP, and IFT.

5. OSOs correct any rejected FOREs or ROEs.

6. OSOs generate new ROEs, repackage them in FOREs, and submit the new files to OATS.

Alternatively, OSOs can use the Web interface to repair ROE rejections and correct erroneous

ROEs already accepted by OATS

[9]

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Order Life Cycle Creation

Figure 5: Life Cycle Creation [13]

Information architecture and protocols

Figure 6: Information Architecture and Protocol

OATS uses internet protocols like FTP, SFTP. IFT, and Web interface to send and receive information from

the Order Sending Organizations. Security of information is catered to by these protocols as well by

advanced encryption of the reporting by FINRA OATS systems as well. [9]

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The following figure from FINRA specifies the limitations of the internet protocols in relevance to the

OATS architecture information flow.

Table 1: limitations of IAP

Report Formats

OATS has defined certain report types in which the corresponding events and information is listed. These

reports are then used to generate lifecycle of orders. Some of these order reports are below: [5] Type: New Order Report Event: Order Receipt or Origination/ Transmittal to a Desk or Department within a Firm/ Order Cancellation OATS Rule: 7440 (b) 7440 © 7440 (d) Type: Route Report Event: Order Transmittal/Route to another Member/ECN, Non-Member or National Securities Exchange Rule: 7440 © Type: Desk Report Event: Transmittal to a Desk or Department within a Firm OATS Rule: 7440 © Type: Execution Report Event: Order Execution OATS Rule: 7440(d) Type: Cancel Report Event: Order Cancellation OATS Rule: 7440(d) Type: Cancel/Replace Report Event: Order Modification

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OATS Rule: 7440(d) Type: Combined Order/Execution Report Event: Order Receipt or Origination and Order Execution OATS Rule: 7440(b), 7440(d) Type: Combined Order/Route Report Event: Order Receipt or Origination and Order Transmittal/Route to Another Member/ECN, NonMember

or National Securities Exchange OATS Rule: 7440(b), 7440(c)

Challenges of OATS

1. Data inaccuracy and reporting complexities

These complexities arise because OATS is a costly and complicated process that requires the Data to be

found, recorder, transformed, reported and stored. Hence the probability of inaccuracies increase.

2. Data storage and Real-time Monitoring

OATS requires various parameters like account type code, display indicator, limit price, routing firm MP

ID, routed order ID, etc. to be not only reported timely but accurately and this increases the storage demand.

3. Diverse Markets and Trading Systems

Firms always look to diversify and expand their business but this becomes a challenge since FINRA

requires a unique record for every order and hence each system has to report OATS individually that leads

to more data and inaccuracies.

4. Changing requirements and high costs

Firms try to avoid complex and changing reporting techniques by sticking to a single system approach but

then it becomes a challenge to OATS as its increases the cost and needs to be updated for existing business

models. [5]

Member firms responsibilities

1. Synchronize Business Clocks Any and all FINRA member firms are required under FINRA and/or NASDAQ rules to record

the date and time of any market event. In order to make sure that the date/time recorded are

synchronized (especially when the volume of trades in fraction of a second can be worth a lot of

money) FINRA requires al member firms to synchronize their system clocks within three seconds

of National Institute of Standards and Technology (NIST) Atomic Clock, with to-the-second

granularity. NIST Atomic clock is a highly accurate clock, incapable of a 1 second error for up

to 600 years. Member firms required to do this daily, prior to the official market opening time. They are also

required to check for drift in clock synchronization throughout day and re-synchronize time as

necessary

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2. Submission Deadlines

The FINRA member firms must comply to submission of the different reports to the OATS system

in a timely manner. The OATS Business Day and Reporting Days are defined by FINRA as:

OATS Business Day ŸBegins after the close of the NASDAQ Stock Exchange on one market day (16:00:01 ET) ŸEnds at the close of the NASDAQ Stock Exchange on the next market day (16:00:00 ET) OATS Reporting Day ŸEvents occurring during an OATS Business Day must be submitted to OATS by 08:00:00 ET

the next calendar day or be considered late by FINRA Ÿ OATS system Late Validation - looks at the time the individual record was submitted in relation

to its event timestamp. OATS does not consider in late processing if the FORE was submitted

timely by the member firm. As we shall see in later sections this is a common error/source of fine

for member firms.

3. ROE Reject Repair Any Reporting Member, or member firm having data submitted on their behalf, to FINRA must

access the feedback sent by FINRA after processing the reports submitted and then must “fix” the

reporting errors and shortcomings within a timely fashion and report it back to the FINRA Firm

Gateway portal (https://firms.finra.org). On a daily basis, FINRA reject reports and feedback are

available within 24 hours of processing. Rejections stemming from Syntax errors/incompliance

are available even more fast (within 4 hours)

4. Review of Web Site Any and all FINRA member firms are required to monitor the OATS Web Interface on a Daily

Basis. The metrics/information that member firms are specifically guided by FINRA to keep an

active track of in order to avoid fines are:

ŸFORE Status Notification: Available within 1 hour of submission

ŸFirm Reporting Statistics: Usually available within 24 hours of processing.

ŸRejections - Firms may view their rejections by: FORE, Summary, Rejection Type or in

Group Symbol Repair

ŸOrder / Trade Match Statistics and Order / Route and Interfirm matching Statistics:

Usually available for firms within 72 hours

ŸView Announcements if no status available

5. Supervision

FINRA has outlined the basic guidelines/thinking principles on what should be included in OATS

Written Supervisory Procedures that each member firm is responsible for catering to:

Who is responsible for supervising OATS reporting?

How will the member firm conduct reviews for OATS reporting?

When or how often will they conduct the supervisory reviews?

How will they evidence their supervisory reviews in writing?

Use Supervisory Logs - to make reporting accurate, fast, and easy

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Members should refer to NASD Notice to Members #98-65, 99-45 and 02-29 as well as

the OATS Reports on Supervision for additional guidance.

[11]

Exemptive Circumstances

Exemptive relief can be provided from the OATS reporting requirements for very specific circumtances

of manual orders to members that meet the following specified criteria (as specified by FINRA):

The member, current control affiliates and associated persons have not had a finalized

disciplinary action within the last five years and within 10 years for fraud

The member has annual revenue of less than $2 million

The member conducts no market making activities

The member does not execute principal transactions with its customers

The member does not conduct clearing or carrying activities

Resources for member firms

In order to further help the member firms comply with the FINRA requirements for OATS the following

resources are available to help:

www.finra.org/oats

– OATS Frequently Asked Questions – OATS Reporting Technical Specifications – OATS Subscriber Manual – OATS Report Index – OATS Registration Page – OATS for OTC Page

Report Cards

OATS Helpdesk 1-800-321-6273

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OATS in Action

FINRA uses the OATS data as an integral part of its automated market surveillance program to detect manipulative activity and other potential violations of FINRA rules and the federal securities laws. OATS has been a vital cornerstone in charging and fining big name institutes for violation of its responsibilities. A few examples: October 18, 2016 - FINRA Fines Merrill Lynch $2.8 Million for Systemic Reporting, Books and Records, and

Related Supervisory Violations [6] FINRA found that a system configuration error caused Merrill Lynch to, among other things,

inaccurately report millions of trades to a FINRA Trade Reporting Facility in which purchases were reported

as principal sales and agency crosses. Merrill Lynch also reported millions of trades it was not required to report. In addition, over the course of almost five years, the firm encountered a number of separate system errors

that caused it to report millions of inaccurate reportable order events to OATS, including inaccurate timestamps, broker-dealer orders reported as customer orders and a failure to report millions of execution reports.

Moreover, FINRA found that, for approximately three years, Merrill Lynch failed to record certain special

handling instructions, as well as the correct receipt and route timestamps on order tickets, which caused millions of records to be inaccurate. August 3, 2016 - FINRA Fines Barclays Capital Inc. $1.3 Million for Extensive OATS Reporting Violations

and Related Supervisory Failures [8] FINRA rules require firms to transmit to OATS complete and accurate data relating to events in the

lifecycle of an order, called Reportable Order Events (ROEs). FINRA found 15 system issues at Barclays Capital that gave rise to OATS reporting violations. Barclays Capital transmitted more than 3 billion inaccurate or

incomplete ROEs to OATS, including omitted special handling codes; inaccurate timestamps, execution

quantities and member type codes; and duplicate or erroneous reports. In addition, Barclays Capital failed to transmit millions of ROEs to OATS. FINRA also found that Barclays Capital’s supervisory system was not

reasonably designed to achieve compliance with its OATS reporting obligations. July 27, 2015 - Fines Goldman Sachs Execution & Clearing, L.P. $1.8 Million for OATS and Trade Reporting

Failures [12] FINRA found that Goldman Sachs Execution & Clearing failed to transmit a substantial number of order-related events to OATS for its Alternative Trading System (ATS) for approximately seven years, and the

firm transmitted inaccurate data for a large number of order-related events for more than eight years. In

addition, even though Goldman Sachs Execution & Clearing's ATS captured order event times in milliseconds, it failed to report order event timestamps in milliseconds for a 10-month period. The firm also submitted a large

number of inaccurate, incomplete or improperly formatted trade reports that did not report execution timestamps in milliseconds for a three-month period. During the period of review, Goldman Sachs Execution & Clearing

did not have adequate systems and controls in place to detect and prevent the violations. October 4, 2004 - NASD Sanctions 18 Firms for Order Audit Trail (OATS) Reporting and Supervision

Violations [10] NASD today announced it has censured and imposed fines totaling more than $1.2 million on 18 firms

for violations relating to NASD's Order Audit Trail ("OATS") rules and supervision. The largest single action was against SG Cowen, LLC of New York, NY, which was censured and fined $800,000 for failing to report

millions of orders over a four-year period. Further details about the 18 violators are available at [10].

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REFERNCES

[1] "OATS Reporting Technical Specifications." N.p., n.d. Web. <http://www.finra.org/sites/default/files/OATSTechSpec_01112016.pdf+>. [2] "OATS, CAT, and CARDS: Financial Regulation in the Era of Big Data." N.p., n.d. Web.

[3] "Consolidated Audit Trail." N.p., n.d. Web. <http://www.finra.org/sites/default/files/FINRA%20CAT%20SIFMA%20Presentation%2020140729%20FINAL%20v1%201_0_0_0.pdf+>.

[4] "Self-Regulatory Organizations; Notice of Filing of Proposed Rule Change by National Association of Securities Dealers, Inc. Relating to the Creation of New Rules 6900 Through 6970 or an Audit Trail System Owned and Operated by the National Association of Securities Dealers, Inc." Federal Register. N.p., 05 Sept. 1997. Web. 22 Dec. 2016. [5] Yogesh Pandit. "Overview of OATS Reporting." N.p., n.d. Web.

[6] "FINRA Fines Merrill Lynch $2.8 Million for Systemic Reporting, Books and Records, and Related Supervisory Violations." FINRA Fines Merrill Lynch $2.8 Million for Systemic Reporting, Books and Records, and Related Supervisory Violations | FINRA.org. N.p., n.d. Web. 22 Dec. 2016.

[7] "Order Audit Trail System (OATS) OATS Basics." Ppt Download. N.p., n.d. Web. 22 Dec. 2016.

[8] "FINRA Fines Barclays Capital Inc. $1.3 Million for Extensive OATS Reporting Violations and Related Supervisory Failures." FINRA Fines Barclays Capital Inc. $1.3 Million for Extensive OATS Reporting Violations and Related Supervisory Failures | FINRA.org. N.p., n.d. Web. 22 Dec. 2016. [9] "Leaf Springs. Technical Specifications." (n.d.): n. pag. Web.

[10] "NASD Sanctions 18 Firms for Order Audit Trail (OATS) Reporting and Supervision Violations." NASD Sanctions 18 Firms for Order Audit Trail (OATS) Reporting and Supervision Violations | FINRA.org. N.p., n.d. Web. 22 Dec. 2016.

[11] "Order Audit Trail System (OATS) OATS Basics." Ppt Download. N.p., n.d. Web. 22 Dec. 2016.

[12] "FINRA Fines Goldman Sachs Execution & Clearing, L.P. $1.8 Million for OATS and Trade Reporting Failures." FINRA Fines Goldman Sachs Execution & Clearing, L.P. $1.8 Million for OATS and Trade Reporting Failures | FINRA.org. N.p., n.d. Web. 22 Dec. 2016.

[13] "Order Audit Trail System (OATS) OATS Phase III Reporting Tool Demonstration." (n.d.): n. pag. Print.