Prompt Response

A prompt, but hasty, response to a FSA letter cost Towry Investment Management Ltd (TIM) £494K in penalties. A ‘Dear CEO’ letter was sent out in January 2010 (see Regulatory Roundup 8 for further details) to firms that held client money and/or assets. The letter drew attention to the FSA’s [...]

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Transaction Reporting: Zen

A reminder for firms that transaction report that the Zen ‘hard go-live’ date is 13 November at the latest. The FSA’s surveillance and monitoring system, Sabre, is being replaced by Zen which has enhanced capabilities including support for transactions identified using the Alternative Instrument Identifier(Aii). In practical term firms will [...]

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Large Traders

A new SEC rule is coming into force which will impact on Large Traders (‘LT’) of NMS securities (the latter are basically any US exchange-listed securities including options. For the precise definition see ‘Rule 600(b)(46)’ on page 480 using link ‘NMS Security’) whether or not the LT is based in [...]

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Mercurius

Two related Final Notices have been published which are interesting in the miscellany of wrong-doings committed. Mercurius International was a Cayman based hedge fund with investment management undertaken by Mercurius Capital Management Ltd based in EC2. The subjects of the Notices are Mr Fagbulu (Compliance Officer and CFO) and Mr [...]

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PFOF

The FSA has issued consultative guidance on the practice of ‘payment for order flow’ (PFOF). PFOF is an arrangement whereby a broker receives payment, either in cash or other form, from a third party for directing order flow to the latter. However such arrangements could fall foul of the FSA’s [...]

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