> In particular, FINRA claims that following the establishment of its OTC equity trading desk, the firm sought to program the desk’s trading systems to comply w

> In particular, FINRA claims that following the establishment of its OTC equity trading desk, the firm sought to program the desk’s trading systems to comply with the Trading Ahead and Limit Order Display Rules by providing customer orders automated order protection, quote display, and execution. > “The OTC Desk, however, implemented controls, settings and processes that removed hundreds of thousands of mostly larger customer orders from those logics. While those controls, settings and processes had multiple purposes, they shared a principal purpose of directing OTC customer orders for manual review and/or handling. Impacted orders were rendered inactive until the completion of a manual trader review,” FINRA said in the document earlier this month. How interesting. This is almost certainly a case of the lawyers/compliance talking to the programmers/ops and everyone thinking they’re on the same page with how the process needs to work only to find out years later that they weren’t. I wonder how this issue was even identified.