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SunGard Investor Services LLC/TA – ‘TA-1’ on 2/9/15

On:  Monday, 2/9/15, at 9:59am ET   ·   As of:  1/16/15   ·   Accession #:  950123-15-305   ·   File #:  84-06522

Previous ‘TA-1’:  None   ·   Next:  ‘TA-1/A’ on 12/22/15   ·   Latest:  ‘TA-1/A’ on 10/24/22

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  As Of                Filer                Filing    For·On·As Docs:Size              Issuer               Agent

 1/16/15  SunGard Investor Services LLC/TA  TA-1        2/09/15    1:27K                                    RR Donnelley/FA

Application for Registration as a Transfer Agent   —   Form TA-1
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: TA-1        Application for Registration as a Transfer Agent    HTML     28K 
                          -- primary_doc.xml/3.4


        

This ‘TA-1’ Document is an XML Data File that may be rendered in various formats:

  Form TA-1    –   Plain Text   –  SEC Website  –  EDGAR System  –    XML Data    –  <?xml?> File
 
 
Plain Text rendering:  Application for Registration by a Transfer Agent
 
                                                                                                                                                                                
EDGAR Submission
 
Schema Version:  X0304
Submission Type:  TA-1
Test or Live:  LIVE
Form Version:  3.4.0
Filer:
CIK:  1630490
File Number:
Regulatory Agency:  SEC
Registrant:
Entity Name:  SunGard Investor Services LLC
Previous Entity Name:
FINS Number:  351841
Principal Office Address:
Street 1:  3435 Stelzer Rd.
Street 2:
City:  Columbus
State or Country Code:  OH
State or Country:  OHIO
ZIP Code:  43219
Different Mailing Address?  No
Telephone Number:  (614) 470-8000
Conduct Business in Other Locations?  No
Self-Transfer Agent?  No
Engaged Service Company?  No
Engaged as Service Company?  Yes
As Service Company:
Entity Name:  Boston Trust & Investment Management, Inc.
File Number:  085-00174
As Service Company Address:
Street 1:  1 Beacon Street
Street 2:
City:  Boston
State or Country Code:  MA
State or Country:  MASSACHUSETTS
ZIP Code:  02108
As Service Company:
Entity Name:  Diamond Hill Capital Management, Inc.
File Number:  084-06385
As Service Company Address:
Street 1:  325 John H. McConnell Blvd.
Street 2:
City:  Columbus
State or Country Code:  OH
State or Country:  OHIO
ZIP Code:  43215
Registrant Type:  Other
Registrant Type Description:  Limited Liability Company
Sole Proprietorship Other Data:
Entity Name:  SunGard Investment Ventures LLC
Relationship Start Date:  12/23/14
Title or Status:  Sole stockholder
Authority Description:  Sole stockholder
Relationship End Date:
Other Control Management:
Other Entity?  Yes
Other Control Management Details:
Entity Name:  SunGard Capital Corp.
Agreement Description:  Indirect parent company
Other Control Management Details:
Entity Name:  SunGard Capital Corp. II
Agreement Description:  Indirect parent company
Other Control Management Details:
Entity Name:  SunGard Holdco LLC
Agreement Description:  Indirect parent company
Other Control Management Details:
Entity Name:  SunGard Data Systems Inc.
Agreement Description:  Indirect parent company
Other Control Management Details:
Entity Name:  SunGard Holding Corp.
Agreement Description:  Indirect parent company
Other Control Finance:
Other Entity?  No
Felony or Misdemeanor:
Involved?  No
Other Felony:
Involved?  No
Enjoined Investment Related Activity:
Involved?  No
Violation of Investment Related Regulation:
Involved?  No
False Statement or Omission:
Involved?  No
Violation of Regulations:
Involved?  No
Authorization Denied or Suspended:
Involved?  No
Registration Denied or Suspended:
Involved?  No
Federal or State Regulatory Agency:
FSR False Statement or Omission:
Involved?  No
FSR Violation of Investment Related Regulation:
Involved?  Yes
FSR Violation of Investment Related Regulation Details:
Entity Name:  Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC)
Action Title:  Case Number C109-304-BLM
Action Date:  5/23/11
Court or Body Name and Location:  State of Nevada Office of the Secretary of State Securities Division
Action Description:  FINE AND INSPECTION OF RECORDS FEES PAID FOR FOUR UNLISENCED NEVADA BRANCH OFFICES FROM 2003-2010.
Disposition of Proceeding:  $10,000 Monetary Fine and $1,000 fee paid for inspection of records.
FSR Authorization Denied or Suspended:
Involved?  No
FSR Found Order Against Applicant:
Involved?  No
FSR Registration Denied or Suspended:
Involved?  No
FSR Revoked Suspended License:
Involved?  No
Self Regulatory Agency:
SRA False Statement or Omission:
Involved?  No
SRA Violation of Rules:
Involved?  Yes
SRA Violation of Rules Details:
Entity Name:  SunGard Brokerage & Securities Services LLC
Action Title:  Case Number 2010025353101
Action Date:  10/6/14
Court or Body Name and Location:  FINRA
Action Description:  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 WITHOUT 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 IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS.
Disposition of Proceeding:  $40,000 Monetary Fine and Censure.
SRA Violation of Rules Details:
Entity Name:  SunGard Brokerage & Securities Services LLC
Action Title:  Case Number 2011029998701
Action Date:  5/30/14
Court or Body Name and Location:  FINRA
Action Description:  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 CUSTOMERS WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS.
Disposition of Proceeding:  $12,500 Monetary Fine, $399.75 Restitution, plus interest, and Censure.
SRA Violation of Rules Details:
Entity Name:  SunGard Brokerage & Securities Services LLC
Action Title:  Case Number 2011030752101
Action Date:  3/11/14
Court or Body Name and Location:  FINRA
Action Description:  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 AT A PRICE THAT IS LESS THAN OR EQUAL TO THE CURRENT NATIONAL BEST BID.
Disposition of Proceeding:  $15,000 Monetary Fine and Censure.
SRA Violation of Rules Details:
Entity Name:  SunGard Brokerage & Securities Services LLC
Action Title:  Case Number 2011026107701
Action Date:  9/12/13
Court or Body Name and Location:  FINRA
Action Description:  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 REASONABLY 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. THE FIRM FAILED TO PROVIDE DOCUMENTARY EVIDENCE THAT IT PERFORMED THE SUPERVISORY REVIEWS SET FORTH IN ITS WSPS CONCERNING THE USE OF MULTIPLE MPIDS.
Disposition of Proceeding:  $30,000 Monetary Fine, Censure and required to revise its WSPS.
SRA Violation of Rules Details:
Entity Name:  SunGard Brokerage & Securities Services LLC
Action Title:  Case Number 12-0109
Action Date:  3/18/13
Court or Body Name and Location:  Chicago Board Options Exchange
Action Description:  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 IN WEBCRD BY NOVEMBER 5, 2011.
Disposition of Proceeding:  $5,000 Monetary Fine and Censure.
SRA Violation of Rules Details:
Entity Name:  SunGard Brokerage & Securities Services LLC
Action Title:  Case Number 2011026301801
Action Date:  3/6/13
Court or Body Name and Location:  NASDAQ Stock Market
Action Description:  SUNGARD BROKERAGE & SECURITIES SERVICES LLC FAILED TO REASONABLY AVOID DISPLAYING, AND ENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONS THAT LOCK OR CROSSED A PROTECTED QUOTATION, IN THAT, IT ENTERED INTERMARKET SWEEP OFFERS INTO THE NASDAQ SINGLE BOOK EXECUTION SYSTEM THAT LOCKED OR CROSSED 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.
Disposition of Proceeding:  $7,500 Monetary Fine and Censure.
SRA Violation of Rules Details:
Entity Name:  SunGard Brokerage & Securities Services LLC
Action Title:  Case Number 20110275360
Action Date:  10/21/11
Court or Body Name and Location:  FINRA on behalf of NYSE Regulation and NYSE Arca Options
Action Description:  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 31, 2011 WERE INADEQUATE IN THAT THEY DID NOT HAVE A SET OF REVIEWS IN PLACE FOR LOPR REJECTS OR FOR ENSURING THE ACCURACY OF THE FIRM'S LOPR RECORDS.
Disposition of Proceeding:  $3,500 Monetary Fine, and required to revise its WSPS.
SRA Violation of Rules Details:
Entity Name:  SunGard Brokerage & Securities Services LLC
Action Title:  Case Number 2011026800801
Action Date:  10/12/12
Court or Body Name and Location:  FINRA
Action Description:  THE FIRM FAILED TO TIMELY REPORT TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS; TRANSMITTED TO OATS ROUTE AND COMBINED ORDER/ROUTE REPORTS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE RELATED ORDER ROUTED TO NASDAQ 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.
Disposition of Proceeding:  $10,000 Monetary Fine and Censure.
SRA Violation of Rules Details:
Entity Name:  Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC)
Action Title:  Case Number 2010021587601
Action Date:  2/17/11
Court or Body Name and Location:  FINRA
Action Description:  ASSENT LLC TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA; REPORTS CONTAINED INCORRECT CUSTOMER IDENTIFICATION FLAGS, INCORRECTLY INCLUDED IMMEDIATE OR CANCEL TIME IN FORCE INSTRUCTIONS, FAILED TO INCLUDE THE SPECIAL HANDLING CODE, AND ONE REPORT CONTAINED AN INACCURATE CANCELLATION TIME. THE FIRM FAILED TO TRANSMIT ONE CUSTOMER ORDER TO OATS. THE FIRM MADE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES IT RECEIVED FOR EXECUTION FROM ANY PERSON THAT INCLUDED INCORRECT INFORMATION AS TO THE NUMBER OF COVERED ORDERS. THE FIRM MADE PUBLICLY AVAILABLE A REPORT ON ITS ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITIES THAT INCLUDED INCOMPLETE INFORMATION AS TO OPTIONS LISTED SECURITIES. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO SEC RULES 611(A)(2) AND (C) OF REGULATION NMS. THE FIRM'S 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 HANDLING SEC RULE 606 AND SEC RULE 605; BEST EXECUTION NASD RULES 2320 AND 3110 - REGULAR AND RIGOROUS REVIEW, THREE QUOTE RULE; TRADE REPORTING MODIFIERS; SALES TRANSACTIONS - REGULATION SHO RULE 204(A)(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 RULES APPLICABLE TO ALTERNATIVE TRADING SYSTEMS AND ELECTRONIC COMMUNICATIONS NETWORKS - SEC RULE 201(B) - CHARGING INCONSISTENT FEES, 5% THRESHOLD, 20% THRESHOLD AND ATS TRADE REPORTING FACILITY REPORTING.
Disposition of Proceeding:  $37,500 Monetary Fine, Censure and required to revise its WSPS.
SRA Violation of Rules Details:
Entity Name:  Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC)
Action Title:  Case Number 10-0033
Action Date:  11/1/10
Court or Body Name and Location:  Chicago Board Options Exchange
Action Description:  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, [NAME REDACTED]. DURING THIS PERIOD, [NAME REDACTED] 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 AFFECTED THE PRICE OF THE UNDERLYING SECURITY AND, SUBSEQUENTLY, [NAME REDACTED] PURCHASED AND/OR SOLD NUMEROUS CORRESPONDING OPTIONS CONTRACTS IN THAT SECURITY. AS A RESULT [NAME REDACTED] INAPPROPRIATELY CAPITALIZED ON PRICE MOVEMENTS IN CORRESPONDING OPTIONS. IN ADDITION, ASSENT FAILED TO ADEQUATELY SUPERVISE [NAME REDACTED] BY FAILING TO ENFORCE A TRADING RESTRICTION IMPLEMENTED BY ASSENT.
Disposition of Proceeding:  $75,000 Monetary Fine and Censure.
SRA Violation of Rules Details:
Entity Name:  Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC)
Action Title:  Case Number 2006006204501
Action Date:  9/24/10
Court or Body Name and Location:  FINRA
Action Description:  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 FIRM'S 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) AND (73) AND 602(B)(1) AND (4); BEST EXECUTION NASD RULES 2320 AND 3110 - REGULAR AND RIGOROUS REVIEW, THREE QUOTE RULE; TRADE REPORTING MODIFIERS; SALES TRANSACTIONS - REGULATION SHO RULE 204(T); SEC RULE 10B-21; INFORMATION BARRIERS - NASD RULE 3010 AND FINRA RULE 2010; AND BOOKS AND RECORDS - SEC RULES 17A-3 AND 17A-4 AND NASD RULE 3110(B).
Disposition of Proceeding:  $65,000 Monetary Fine, Censure and required to revise its WSPS.
SRA Violation of Rules Details:
Entity Name:  Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC)
Action Title:  Case Number 20107008882402
Action Date:  7/28/10
Court or Body Name and Location:  FINRA
Action Description:  ASSENT LLC PERMITTED A THEN PROPRIETARY TRADER AND ASSOCIATED PERSON TO ENGAGE IN PROPRIETARY FIRM OPTIONS TRADING WHEN HE WAS NOT PROPERLY LICENSED TO DO SO AND, AS A RESULT THE FIRM FAILED TO REGISTER A PERSON ENGAGED IN ITS INVESTMENT BANKING OR SECURITIES BUSINESS IN THE CATEGORY OF REGISTRATION APPROPRIATE TO THE FUNCTION TO BE PERFORMED AS SPECIFIED IN NASD RULE 1032. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REQUIRED ALL PROPRIETARY TRADERS TO POSSESS THE SERIES 7 GENERAL SECURITIES REPRESENTATIVE AND SERIES 55 EQUITY TRADERS LIMITED REPRESENTATIVE LICENSE (AND SERIES 63 QUALIFICATION) AND PROVIDED FOR NO EXCEPTIONS UNLESS APPROVALS WERE OBTAINED AND THE TRADER'S ACTIVITIES WERE RESTRICTED UNTIL THE LICENSING DEFICIENCY WAS RECTIFIED; THE ASSOCIATED PERSON POSSESSED 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'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 ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES CONCERNING THE IMPOSITION OF INDIVIDUAL TRADING LIMITS ON PROPRIETARY TRADERS 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.
Disposition of Proceeding:  $79,000 Monetary Fine and Censure.
SRA Violation of Rules Details:
Entity Name:  Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC)
Action Title:  Case Number 200801970801
Action Date:  6/29/10
Court or Body Name and Location:  NASDAQ Stock Market
Action Description:  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 COMPLIANT.
Disposition of Proceeding:  $10,000 Monetary Fine, Censure and required to revise its WSPS.
SRA Violation of Rules Details:
Entity Name:  Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC)
Action Title:  Case Number 2004100004203
Action Date:  9/28/07
Court or Body Name and Location:  FINRA
Action Description:  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.
Disposition of Proceeding:  $16,000 Monetary Fine and Censure.
SRA Violation of Rules Details:
Entity Name:  Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC)
Action Title:  Case Number 2005001466801
Action Date:  9/24/07
Court or Body Name and Location:  FINRA
Action Description:  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.
Disposition of Proceeding:  $110,000 Monetary Fine and Censure.
SRA Violation of Rules Details:
Entity Name:  Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC)
Action Title:  Case Number 2005001765202
Action Date:  6/15/07
Court or Body Name and Location:  NASD
Action Description:  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 RULES 8211 AND 8213.
Disposition of Proceeding:  $35,000 Monetary Fine and Censure.
SRA Violation of Rules Details:
Entity Name:  Assent LLC (later acquired by SunGard Brokerage & Securities Services LLC)
Action Title:  Case Number 2005000006001
Action Date:  9/21/06
Court or Body Name and Location:  NASD
Action Description:  ASSENT LLC SUBMITTED REPORTS TO OATS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA.
Disposition of Proceeding:  $7,500 Monetary Fine and Censure.
SRA Authorization Denied or Suspended:
Involved?  No
SRA Revoked Suspended License:
Involved?  No
Foreign Agency:
Involved?  No
Subject of Proceedings:
Involved?  No
Revoked Bond:
Involved?  No
Unsatisfied Judgements or Liens:
Involved?  No
Signature Data:
Signature Name:  Fred Naddaff
Signature Title:  Managing Director
Signature Phone Number:  (617)-728-1122
Signature Date:  1/16/15


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