TA-1/A
: Filer Information
Submission Contact Information
The registrant may provide a single e-mail address for contact purposes.
| 1(f)(i).
Contact Name:
| | | 1(f)(ii).
Contact Phone Number:
| | | 1(f)(iii).
Contact E-Mail Address:
| |
Notification Information
The registrant may provide additional e-mail addresses for those persons
the filer would like to receive notification e-mails regarding the filing.
| 1(g).
Notification E-mail Address:
| |
TA-1/A
: Registrant Information
| 2.
Appropriate regulatory agency (check one):
| 
Securities and Exchange Commission
Federal Deposit Insurance Corporation
Comptroller of the Currency
|
| 3(a).
Full Name of Registrant:
| FIS Investor Services LLC /TA | | 3(a)(i).
Previous name, if being amended:
| SunGard Investor Services LLC /TA | | 3(b).
Financial Industry Number (FINS) number:
| 351841 |
3(c).
Address of principal office where transfer agent activities are, or
will be, performed:
| 3(c)(i).
Address 1
| 4249 Easton Way | | 3(c)(ii).
Address 2
| Suite 400 | | 3(c)(iii).
City
| Columbus | | 3(c)(iv).
State or Country
|
OHIO
| | 3(c)(v).
Postal Code
| 43219 | | 3(d).
Is Mailing address different from response to Question 3c?
If "yes" provide address(es):
|
Yes
No
| | 3(e).
Telephone Number (Include Area Code)
| 6143376605 | | 4.
Does Registrant conduct, or will it conduct, transfer agent
activities at any location other than that given in Questions
3(c) above? If "Yes" provide address (es):
|
Yes
No
| |
Other Business Location Record:
1 | | | 4(a)(i).
Address 1
| 3344 Quality Drive | | 4(a)(ii).
Address 2
| | | 4(a)(iii).
City
| Rancho Cordova | | 4(a)(iv).
State or Country
|
CALIFORNIA
| | 4(a)(v).
Postal Code
| 95670 | |
Other Business Location Record:
2 | | | 4(a)(i).
Address 1
| 100 Fountain Parkway | | 4(a)(ii).
Address 2
| | | 4(a)(iii).
City
| St Petersburg | | 4(a)(iv).
State or Country
|
FLORIDA
| | 4(a)(v).
Postal Code
| 33716 | |
Other Business Location Record:
3 | | | 4(a)(i).
Address 1
| Plot #18-23 Financial Dist Nanakramguda | | 4(a)(ii).
Address 2
| | | 4(a)(iii).
City
| Hyderabad | | 4(a)(iv).
State or Country
|
INDIA
| | 4(a)(v).
Postal Code
| 500019 | |
Other Business Location Record:
4 | | | 4(a)(i).
Address 1
| Nowy Rynek Complex, Building B | | 4(a)(ii).
Address 2
| Przemyslowa 3 str. | | 4(a)(iii).
City
| Poznan | | 4(a)(iv).
State or Country
|
POLAND
| | 4(a)(v).
Postal Code
| 61-579 | | 5.
Does registrant act, or will it act,
as a transfer agent solely for its own securities,
and/or securities of an affiliate(s)?
|
Yes
No
| | 6.
Has registrant, as a named transfer agent, engaged, or will it
engage, a service company to perform any transfer agent functions?
|
Yes
No
|
| 7.
Has registrant been engaged, or will it be engaged as a service
company by a named transfer agent to perform transfer agent
functions?
|
Yes
No
|
If "Yes" provide the name(s) and File Number(s) of the
named transfer agent(s) for which the registrant has been
engaged, or will be engaged, as a service company to perform
transfer agent functions:
Engaged transfer agent company information Related to item 7 Record:
1 | 7(a).
Name
| Victory Capital Transfer Agency, Inc. | | 7(b).
File Number
| | | 7(c)(i).
Address 1
| 9800 Fredericksburg Rd. | | 7(c)(ii).
Address 2
| | | 7(c)(iii).
City
| San Antonio | | 7(c)(iv).
State or Country
|
TEXAS
| | 7(c)(v).
Postal Code
| 78288 |
Engaged transfer agent company information Related to item 7 Record:
2 | 7(a).
Name
| Franklin Templeton Investor Services LLC/TA | | 7(b).
File Number
| | | 7(c)(i).
Address 1
| 3344 Quality Drive | | 7(c)(ii).
Address 2
| | | 7(c)(iii).
City
| Rancho Cordova | | 7(c)(iv).
State or Country
|
CALIFORNIA
| | 7(c)(v).
Postal Code
| 95670 |
Engaged transfer agent company information Related to item 7 Record:
3 | 7(a).
Name
| The Northern Trust Company | | 7(b).
File Number
| | | 7(c)(i).
Address 1
| 333 S Wabash Ave 38th fl | | 7(c)(ii).
Address 2
| | | 7(c)(iii).
City
| Chicago | | 7(c)(iv).
State or Country
|
ILLINOIS
| | 7(c)(v).
Postal Code
| 60604 |
TA-1/A
: Independent, Non-Issuer Registrant Information
Completion of Question 8 on this form is required
by all independent, non-issuer registrants whose appropriate
regulatory authority is the Securities and Exchange Commission.
Those registrants who are not required to complete Question 8
should select "Not Applicable".
| 8.
Is registrant a:
| Other | Limited Liability Company |
Section for Initial Registration and for Amendments
Reporting Additional Persons.
Proprietor or other entity information Related to item 8 Record:
1 | 8(a)(i).
Full Name
| FIS Investor Services LLC | | 8(a)(ii).
Relationship Start Date
| 1/16/15 | | 8(a)(iii).
Title or Status
| LLC registered as a Transfer Agent | | 8(a)(iv).
Description of Authority
| SEC Registered Transfer Agent | | 8(a)(v).
Relationship End Date
| |
9. Does any person or entity not named in the answer to Question 8:
| 9(a).
directly or indirectly, through agreement or otherwise exercise or
have the power to exercise control over the management or policies of applicant, or;….
|
Yes
No
|
Entity information Related to item 9(a)
Record:
1 | 9(a)(i).
Exact name of each person or entity:
| FIS Investment Ventures LLC | | 9(a)(ii).
Description of the Agreement or other basis:
| 100% owner of FIS Investor Services LLC |
Entity information Related to item 9(a)
Record:
2 | 9(a)(i).
Exact name of each person or entity:
| FIS Data Systems Inc | | 9(a)(ii).
Description of the Agreement or other basis:
| 100% Owner of FIS Investment Ventures LLC |
Entity information Related to item 9(a)
Record:
3 | 9(a)(i).
Exact name of each person or entity:
| FIS-SG Holding Corp | | 9(a)(ii).
Description of the Agreement or other basis:
| 100% owner of FIS Data Systems Inc |
Entity information Related to item 9(a)
Record:
4 | 9(a)(i).
Exact name of each person or entity:
| Fidelity National Information Services, Inc | | 9(a)(ii).
Description of the Agreement or other basis:
| 100% owner of FIS-SG Holding Corp |
|
| 9(b).
wholly or partially finance the business of the applicant,
directly or indirectly, in any manner other than by a public
offering of securities made pursuant to the Securities Act of 1933
or by credit extended in the ordinary course of business by suppliers, banks and others?…..
|
Yes
No
|
TA-1/A
: 10. Applicant and Control Affiliate Disciplinary History
The following definitions apply for purposes of
answering this Question 10
| Control Affiliate | - An individual or firm that directly or indirectly controls, is under common control
with, or is controlled by applicant. Included are any employees identified in 8(a), 8(b), 8(c) of this form as exercising
control. Excluded are any employees who perform solely clerical, administrative support of similar functions, or who, regardless of
title, perform no executive duties or have no senior policy making authority.
| | Investment or investment related | - Pertaining to securities, commodities, banking, insurance, or real estate
(including, but not limited to, acting as or being associated with
a broker dealer, investment company, investment adviser, futures
sponsor, bank, or savings and loan association).
| | Involved | - Doing an act of aiding, abetting, counseling, commanding, inducing,
conspiring with or failing reasonably to supervise another in
doing an act. |
10(a).
In the past ten years has the applicant or a control affiliate
been convicted of or plead guilty or nolo contendere ("no contest")
to:
| 10(a)(1).
a felony or misdemeanor involving: investments or an
investment-related business, fraud, false statements or omissions,
wrongful taking of property, or bribery, forgery, counterfeiting,
or extortion?
|
Yes
No
|
| 10(a)(2).
any other felony?
|
Yes
No
|
| 10(b).
Has any court in the past ten years:
| | 10(b)(1).
enjoined the applicant or a control affiliate in connection with
any investment-related activity?
|
Yes
No
|
| 10(b)(2).
found that the applicant or control affiliate was involved in a
violation of investment-related statutes or regulations?
|
Yes
No
|
| 10 (c).
Has the U.S. Securities and Exchange Commission or the Commodity
Futures Trading Commission ever:
| | 10(c)(1).
found the applicant or control affiliate to have made a false
statement or omission?
|
Yes
No
|
| 10(c)(2).
found the applicant or control affiliate to have been involved in
a violation of its regulation or statutes?
|
Yes
No
|
| 10(c)(3).
found the applicant or control affiliate to have been a cause of
an investment-related business having its authorization to do
business denied, suspended, revoked or restricted?
|
Yes
No
|
| 10(c)(4).
entered an order denying, suspending or revoking the applicant’s
or control affiliate’s registration or otherwise disciplined it by
restricting its activities?
|
Yes
No
|
| 10(d).
Has any other Federal regulatory agency or any state regulatory
agency :
| | 10(d)(1).
ever found the applicant or control affiliate to have made a false
statement or omission or to have been dishonest, unfair, or
unethical?
|
Yes
No
|
| 10(d)(2).
ever found the applicant or control affiliate to have been
involved in a violation of investment-related regulations or
statutes?
|
Yes
No
|
Entity information Related to item 10(d)(2) Record:
1 | 10(d)(2)(i).
The individuals named in the Action
| Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC | | 10(d)(2)(ii).
Title of Action
| Case Number C109-304-BLM | | 10(d)(2)(iii).
Date of Action
| 5/23/11 | | 10(d)(2)(iv).
The Court or body taking the Action and its location
| State of Nevada Office of the Secretary of State Securities Division | | 10(d)(2)(v).
Description of the Action
| Fine and inspection of records fees paid for four unlicensed Nevada branch offices from 2003-2010 | | 10(d)(2)(vi).
The disposition of the proceeding
| $10,000 monetary fine and $1,000 fee paid for inspection of records |
| 10(d)(3).
ever found the applicant or control affiliate to have been a cause
of an investment-related business having its authorization to do
business Denied, suspended, revoked or restricted?
|
Yes
No
|
| 10(d)(4).
in the past ten years entered an order against the applicant or
control affiliate in connection with investment-related activity?
|
Yes
No
|
| 10(d)(5).
ever denied, suspended, or revoked applicant’s or control
affiliate’s registration or license, or prevented it from
associating with an investment-related business, or otherwise
disciplined it by restricting its activities?
|
Yes
No
|
| 10(d)(6).
ever revoked or suspended the applicant’s or a control affiliate’s
license as an attorney or accountant?
|
Yes
No
|
10(e). Has any self-regulatory organization or commodities exchange ever:
| 10(e)(1).
found the applicant or a control affiliate to have made a false
statement or omission?
|
Yes
No
|
| 10(e)(2).
found the applicant or a control affiliate to have been involved
in a violation of its rules?
|
Yes
No
|
Entity information Related to item 10(e)(2) Record:
1 | 10(e)(2)(i).
The individuals named in the Action
| SunGard Brokerage & Securities Services | | 10(e)(2)(ii).
Title of Action
| Case Number 2014039942201 | | 10(e)(2)(iii).
Date of Action
| 12/30/15 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it transmitted reportable order events (roes) to the order audit trail system (oats) that contained inaccurate, incomplete, or improperly formatted data, and failed to record accurate and/or completed information on the memorandum of brokerage orders. | | 10(e)(2)(vi).
The disposition of the proceeding
| $17,500 monetary fine and censure |
Entity information Related to item 10(e)(2) Record:
2 | 10(e)(2)(i).
The individuals named in the Action
| SunGard Brokerage & Securities Services LLC | | 10(e)(2)(ii).
Title of Action
| Case Number 2013035829201 | | 10(e)(2)(iii).
Date of Action
| 4/15/15 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it transmitted reports that contained inaccurate, incomplete, or improperly formatted data to order audit trail system (oats). | | 10(e)(2)(vi).
The disposition of the proceeding
| $17,500 monetary fine and censure |
Entity information Related to item 10(e)(2) Record:
3 | 10(e)(2)(i).
The individuals named in the Action
| SunGard Brokerage & Securities Services LLC | | 10(e)(2)(ii).
Title of Action
| Case Number 2013035489101 | | 10(e)(2)(iii).
Date of Action
| 4/8/15 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that for a sample of settlement dates, the firm submitted its short interest position report to FINRA that included 39 short interest positions totaling 12,819,218 shares when the firm should have reported four short interest positions totaling 257,001 shares. | | 10(e)(2)(vi).
The disposition of the proceeding
| $15,000 monetary fine and censure. |
Entity information Related to item 10(e)(2) Record:
4 | 10(e)(2)(i).
The individuals named in the Action
| SunGard Brokerage & Securities Services LLC | | 10(e)(2)(ii).
Title of Action
| Case Number 2010025353101 | | 10(e)(2)(iii).
Date of Action
| 10/6/14 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it executed short sale transactions and failed to report each of these transactions to the FINRA/NASDAQ trade reporting facility with a short sale modifier. The findings stated that the firm, on 12,783 occasions, accepted a short sale order in an equity security from another person, or effected a short sale in an equity security for its own account, without: borrowing the security, or entering into a bona-fide arrangement to borrow the security; or having reasonable grounds to believe that the security could be borrowed so that it could be delivered on the date delivery is due; and documenting compliance with SEC Rule 203(b)(1) of regulation SHO. The firm failed to take reasonable steps to establish that the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in Rule 600(B)(30) of regulation NMS. | | 10(e)(2)(vi).
The disposition of the proceeding
| $40,000 monetary fine and censure. |
Entity information Related to item 10(e)(2) Record:
5 | 10(e)(2)(i).
The individuals named in the Action
| SunGard Brokerage & Securities Services LLC | | 10(e)(2)(ii).
Title of Action
| Case Number 201102999870 | | 10(e)(2)(iii).
Date of Action
| 5/30/14 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that in transactions for or with a customer, the firm failed to execute orders fully and promptly. The findings stated that as a result, the firm failed to use reasonable diligence to ascertain the best inter-dealer market in these transactions and, therefore, failed to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions. | | 10(e)(2)(vi).
The disposition of the proceeding
| $12,500 monetary fine, $399.75 restitution, plus interest, and censure. |
Entity information Related to item 10(e)(2) Record:
6 | 10(e)(2)(i).
The individuals named in the Action
| SunGard Brokerage & Securities Services LLC | | 10(e)(2)(ii).
Title of Action
| Case Number 2011030752101 | | 10(e)(2)(iii).
Date of Action
| 3/11/14 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish, maintain, and enforce written policies and procedures reasonably designed to prevent the execution or displays of a short sale order of a covered security as a price that is less than or equal to the current national best bid. | | 10(e)(2)(vi).
The disposition of the proceeding
| $15,000 monetary fine and censure. |
Entity information Related to item 10(e)(2) Record:
7 | 10(e)(2)(i).
The individuals named in the Action
| SunGard Brokerage & Securities Services LLC | | 10(e)(2)(ii).
Title of Action
| Case Number 2011026107701 | | 10(e)(2)(iii).
Date of Action
| 9/12/13 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| SunGard Brokerage & Securities Services LLC transmitted reports to the order audit trail system (oats) that contained inaccurate account type, member type and special handling codes; inaccurate market participant identifiers (MPIDS); and duplicative and/or inaccurate order reports. The firm's supervisory system did not provide for supervision reasonable designed to achieve compliance with applicable securities laws, regulations and/or FINRA rules addressing quality of market topics. The firm's written supervisory procedures (WSPS) failed to provide for minimum requirements for adequate supervisory procedures in order handling; disclosure of order routing information; sales transactions; affirmative determinations; and soft dollar accounts and trading: preparing records, operating outside SEC-established safe harbor, records of research or other services provided, monitoring research or services provided. The firm failed to provide documentary evidence that it performed the supervisory reviews set forth in its SWPS concerning the use of multiple MPIDS. | | 10(e)(2)(vi).
The disposition of the proceeding
| $30,000 monetary fine, censure and required to revise its WSPS. |
Entity information Related to item 10(e)(2) Record:
8 | 10(e)(2)(i).
The individuals named in the Action
| SunGard Brokerages & Securities Services LLC | | 10(e)(2)(ii).
Title of Action
| Case Number 12-0109 | | 10(e)(2)(iii).
Date of Action
| 3/18/13 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| Chicago Board Options Exchange | | 10(e)(2)(v).
Description of the Action
| SunGard Brokerage & Securities Services LLC, CBSX Trading Permit Holder, was censured and fined $5,000 for the following conduct: SunGard failed to register the minimum number of individuals required to register as a proprietary trader principal ("TP") in webcrd by November 5, 2011. Additionally, it is noted that SunGard updated its written supervisory procedures related to registration and qualification of associated persons in February 2013. (Exchange Rule 3.6A - Qualification and Registration of Trading Permit Holders and Associated persons) | | 10(e)(2)(vi).
The disposition of the proceeding
| $5,000 monetary fine and censure. |
Entity information Related to item 10(e)(2) Record:
9 | 10(e)(2)(i).
The individuals named in the Action
| SunGard Brokerage & Securities Services LLC | | 10(e)(2)(ii).
Title of Action
| Case Number 2011026301801 | | 10(e)(2)(iii).
Date of Action
| 3/6/13 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| NASDAQ Stock Market | | 10(e)(2)(v).
Description of the Action
| SunGard Brokerage & Securities Services LLC failed to reasonably avoid displaying, and engaged in a pattern or practice of displaying, quotations that locked or crossed a protected quotation, in that, it entered intermarket sweep offers into the NASDAQ single book execution system that locked or crossed a quotation previously disseminated pursuant to an effective national market system plan and failed to simultaneously route an intermarket sweep order to execute against the full displayed size of the locked or crossed protected quote. | | 10(e)(2)(vi).
The disposition of the proceeding
| $7,500 monetary fine and censure. |
Entity information Related to item 10(e)(2) Record:
10 | 10(e)(2)(i).
The individuals named in the Action
| SunGard Brokerage & Securities Services LLC | | 10(e)(2)(ii).
Title of Action
| Case Number 20110275360 | | 10(e)(2)(iii).
Date of Action
| 10/21/11 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA on behalf of NYSE Regulation and NYSE ARCA options | | 10(e)(2)(v).
Description of the Action
| FINRA Alleged that there was a minor market regulation violation- The firm's written supervisory procedures with regard to NYSE ARCA options Rule 6.6(a) in effect between January 19, 2010 and December 21, 2011 were inadequate in that they did not have a set of reviews in place for LOPR rejects or for insuring the accuracy of the firms' LOPR records. | | 10(e)(2)(vi).
The disposition of the proceeding
| $3,500 monetary fine, and required to review its WSPS. |
Entity information Related to item 10(e)(2) Record:
11 | 10(e)(2)(i).
The individuals named in the Action
| Assent LLC ( later acquired by SunGard Brokerage & Securities Services LLC) | | 10(e)(2)(ii).
Title of Action
| Case Number 2011026800801 | | 10(e)(2)(iii).
Date of Action
| 10/12/12 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| The firm failed to timely report to the order audit trail system (oats) reportable order events; transmitted to oats certain route and/or combined order/route reports that the oats system was unable to link to the related order routed to NASDAQ or to the corresponding new order transmitted by the destination member firm or to proceeding route or combined order/route reports transmitted by other member firms due to inaccurate, incomplete or improperly formatted data; transmitted to oats route or combined order/route reports that the oats system was unable to link to the corresponding new order transmitted by the destination member firm due to inaccurate, incomplete or improperly formatted data; and transmitted to oats new order reports that the oats system was unable to link to the preceding route or combined order/route reports transmitted by other member firms due to inaccurate, incomplete or improperly formatted data. | | 10(e)(2)(vi).
The disposition of the proceeding
| $10,000 monetary fine and censure |
Entity information Related to item 10(e)(2) Record:
12 | 10(e)(2)(i).
The individuals named in the Action
| Assent LLC ( later acquired by SunGard Brokerage & Securities Services LLC) | | 10(e)(2)(ii).
Title of Action
| Case Number 2010021587601 | | 10(e)(2)(iii).
Date of Action
| 2/17/11 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Assent LLC transmitted to the order audit trail system (oats) reports that contained inaccurate, incomplete or improperly formatted data; reports(3)(B); other trading rules- NASD Rule 3340 and FINRA rule 6460-Trading through a trading halt; other rules- SEC rule 612(A)- Sub penny transactions; Multiple market participant identifiers- FINRA rule 6160; and communications networks- SEC rule 201(B)- Charging inconsistent fees, 5% threshold, 20% threshold and ATS trade reporting facility reporting. | | 10(e)(2)(vi).
The disposition of the proceeding
| $37,500 monetary fine, censure and required to review its WSPS. |
Entity information Related to item 10(e)(2) Record:
13 | 10(e)(2)(i).
The individuals named in the Action
| Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC) | | 10(e)(2)(ii).
Title of Action
| Case Number 10-0033 | | 10(e)(2)(iii).
Date of Action
| 11/1/10 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| Chicago Board Options Exchange | | 10(e)(2)(v).
Description of the Action
| Assent LLC, a CBOE Stock Exchange trading permit holder registered to conduct a proprietary trading business, was censured and fined $75,000 for the following conduct. Assent failed to adhere to just and equitable principles of trade through its associated person (prop trader). During this period (prop trader) effected numerous transactions in which he purchased and sold (or sold short and purchased) numerous shares of stock, including of liquid securities, over a short duration of time which, in certain instances, briefly effected the price of the underlying security and subsequently, (prop trader) purchased and or sold numerous corresponding options' contracts in that security. As a result, (prop trader) inappropriately capitalized on price movements in corresponding options. In addition, Assent failed to adequately supervise (prop trader) by failing to enforce a trading restriction implemented by Assent. | | 10(e)(2)(vi).
The disposition of the proceeding
| $75,000 monetary fine and censure. |
Entity information Related to item 10(e)(2) Record:
14 | 10(e)(2)(i).
The individuals named in the Action
| Assent LLC ( later acquired by SunGard Brokerage & Securities Services LLC) | | 10(e)(2)(ii).
Title of Action
| Case Number 2006006204501 | | 10(e)(2)(iii).
Date of Action
| 9/24/10 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Assent LLC submitted short interest position reports in NASDAQ, OTC, AMEX and NYSE -listed securities to NASD that were incorrect. The firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with applicable securities laws, regulations and NASD rules concerning short interest reporting. The firm transmitted to the order audit trail system (OATS) reports that did not include the special handling code, contained inaccurate timestamps or contained inaccurate order receipt times. The firms' supervisory system did not provide for supervision reasonably designed to achieve compliance with applicable securities laws, Regulations and/or NASD rules addressing quality of market topics. The firm's written supervisory procedures failed to provide for minimum requirements for adequate written supervisory procedures in order handing SEC Rules 606(B)(65) & (73) and 602(B)(1) & (4); best execution NASD rules 2320 & 3110- Regular and rigorous review, three quote rule; sales transactions-reg SHO Rule 204T; SEC Rule 10b-21; information barriers - NASD Rule 3010 and FINRA Rule 2010: and books and records SEC Rule 17A-3 & 17A-4 and NASD rule 3110(b) | | 10(e)(2)(vi).
The disposition of the proceeding
| $65,000 monetary fine, censure and required to revise its WSPS |
Entity information Related to item 10(e)(2) Record:
15 | 10(e)(2)(i).
The individuals named in the Action
| Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC) | | 10(e)(2)(ii).
Title of Action
| Case Number 2007008882402 | | 10(e)(2)(iii).
Date of Action
| 7/28/10 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Assent LLC permitted a then proprietary trader and associated person to engage in proprietary firm options trading when he was not properly (and series 63 qualification) and provided for no exceptions unless approvals were obtained and the trader's activities were restricted until none of the licenses required by the firm nor were activities restricted. As a result, the firm failed to enforce its written supervisory procedures by allowing the associated person to disregard FINRA licensing requirements and the firm failed to enforce written internal firm trading limits that applied to the associated person to disregard FINRA licensing requirements and the firm's internal licensing requirements applicable to its proprietary traders. The firm failed to enforce written internal firm trading limits that applied to the associated person by failing to take adequate steps to ensure the associated person and other relevant associated persons of the firm understood the meaning and application of the terms of the associated person's individual trading limits and allowing the associated person to exceed his individual trading limits on several occasions. | | 10(e)(2)(vi).
The disposition of the proceeding
| $79,000 monetary fine and censure. |
Entity information Related to item 10(e)(2) Record:
16 | 10(e)(2)(i).
The individuals named in the Action
| Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC) | | 10(e)(2)(ii).
Title of Action
| Case Number 200801970801 | | 10(e)(2)(iii).
Date of Action
| 6/29/10 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| NASDAQ Stock Market | | 10(e)(2)(v).
Description of the Action
| Assent LLC'S supervisory system and written supervisory procedures were not reasonably designed to achieve compliance with applicable securities laws and regulations (including NASD Notice to Members 04-66) and NASDAQ rules concerning the prevention of erroneous orders and transactions and frivolous clearly erroneous transaction complaints. | | 10(e)(2)(vi).
The disposition of the proceeding
| $10,000 monetary fine, censure and required to revise its WSPS. |
Entity information Related to item 10(e)(2) Record:
17 | 10(e)(2)(i).
The individuals named in the Action
| Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC) | | 10(e)(2)(ii).
Title of Action
| Case Number 2004100004203 | | 10(e)(2)(iii).
Date of Action
| 9/28/07 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Assent LLC accepted customer short orders through a trading platform for institutional customers, and for each order, failed to make an affirmative determination that the firm would receive delivery of the security on behalf of the customer or that the firm could borrow the security on behalf of the customer for delivery by settlement date. | | 10(e)(2)(vi).
The disposition of the proceeding
| $16,000 monetary fine and censure. |
Entity information Related to item 10(e)(2) Record:
18 | 10(e)(2)(i).
The individuals named in the Action
| Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC) | | 10(e)(2)(ii).
Title of Action
| Case Number 2005001466801 | | 10(e)(2)(iii).
Date of Action
| 9/24/07 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Assent LLC transmitted to oats reports that contained inaccurate, incomplete or improperly formatted data in that oats was unable to match the reports to the identified receiving firm's related new order reports; OATS was unable to match the reports to the related reports in supermontage or selectnet; and the firm inaccurately denoted limit orders as market orders and failed to include the time-in-force in new order reports. The firm failed to report to the NASDAQ market center the correct symbol indicating whether the firm executed transactions in eligible securities in a principal or agency capacity. | | 10(e)(2)(vi).
The disposition of the proceeding
| $110,000 monetary fine and censure. |
Entity information Related to item 10(e)(2) Record:
19 | 10(e)(2)(i).
The individuals named in the Action
| Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC) | | 10(e)(2)(ii).
Title of Action
| Case Number 2005000006001 | | 10(e)(2)(iii).
Date of Action
| 9/21/06 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| NASD | | 10(e)(2)(v).
Description of the Action
| Assent LLC submitted reports to oats that contained inaccurate, incomplete or improperly formatted data. | | 10(e)(2)(vi).
The disposition of the proceeding
| $7,500 monetary fine and censure |
Entity information Related to item 10(e)(2) Record:
20 | 10(e)(2)(i).
The individuals named in the Action
| Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC) | | 10(e)(2)(ii).
Title of Action
| Case Number 2005001765202 | | 10(e)(2)(iii).
Date of Action
| 6/15/07 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| NASD | | 10(e)(2)(v).
Description of the Action
| Assent LLC failed to submit accurate trading information through the submission of electronic blue sheets in response to requests from NASD; the inaccuracies were systemic and included the reporting of short sales as long sales. The firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with applicable securities laws, regulations and NASD rules concerning the submission of electronic blue sheet data as required by NASD rule 8211 and 8213. | | 10(e)(2)(vi).
The disposition of the proceeding
| $35,000 monetary fine and censure |
Entity information Related to item 10(e)(2) Record:
21 | 10(e)(2)(i).
The individuals named in the Action
| FIS Brokerage & Securities Services LLC | | 10(e)(2)(ii).
Title of Action
| Case Number 2016049884201 | | 10(e)(2)(iii).
Date of Action
| 9/29/20 | | 10(e)(2)(iv).
The Court or body taking the Action and its location
| FINRA | | 10(e)(2)(v).
Description of the Action
| Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that its supervisory system and pre trade risk management controls were not reasonably designed to prevent the entry of erroneous orders. | | 10(e)(2)(vi).
The disposition of the proceeding
| $48,000.00 monetary fine and censure |
| 10(e)(3).
found the applicant or a control affiliate to have been the cause
of an investment-related business losing its authorization to do
business?
|
Yes
No
|
| 10(e)(4).
disciplined the applicant or a control affiliate by expelling or
suspending it from membership, by barring or suspending its
association with other members, or by otherwise restricting its
activities?
|
Yes
No
|
| 10(f).
Has any foreign government, court, regulatory agency or exchange
ever entered an order against the applicant or a control affiliate
related to investments or fraud?
|
Yes
No
|
| 10(g).
Is the applicant or a control affiliate now the subject of a
proceeding that could result in a yes answer for questions 10(a) –
10(f) ?
|
Yes
No
|
| 10(h).
Has a bonding company denied, paid out on, or revoked a bond for
the applicant or a control affiliate?
|
Yes
No
|
| 10(i).
Does the applicant or a control affiliate have any unsatisfied
judgments or liens against it?
|
Yes
No
|
TA-1/A
: Signature
ATTENTION: INTENTIONAL MISSTATEMENTS OR OMISSIONS
OF FACT CONSTITUTE FEDERAL
CRIMINAL VIOLATIONS. See 18 U.S.C. 1001
and 15 U.S.C. 78ff(a)
SIGNATURE: The registrant submitting this form,
and as required, the SEC
supplement and Schedules A-D,
And the
executing official hereby represent that all the information
contained herein is true, correct and complete.
| 11(a).
Signature of Official responsible for Form:
| Bridget Ireland | | 11(b).
Telephone Number:
| 614.337.6605 | | 11(c).
Title of Signing Officer:
| CCO | | 11(d).
Date Signed (Month/Day/Year):
| 10/24/22 |
|
Yes