DATA MANAGEMENT

Closing the gaps in record-keeping

Our data management tools reconcile, organize, and secure every order and trade record so nothing slips through the cracks.
Catch errors early by reconciling daily trade and order data across systems
Stay audit-ready with complete, exportable, WORM-compliant records
Protect your firm from misreports, missed alerts, and costly fines
Simplify oversight with centralized, organized data management

Relevant rules

Addresses specific requirements within SEC Rule 17a-3 and SEC 17a-4, which generally govern the creation, storage monitoring, and retention of records.

Common deficiencies

Failure to create and maintain a proper trade or order blotter, as well as other records utilized for surveillance or reporting, due to the lack of reconciliation between files produced by various vendors.
Failure to note that transactions are not being submitted to reporting venues such as CAT, LOPR, and OCC due to systematic errors.
Lacking an accessible and sortable trade and/or order blotter, aggregated from various sources (such as clearing firms, order management systems, etc.).

Knowtice’s prevention plan

Four tools that work together to securely collect, organize, store, and reconcile trade and order data, from file ingestion through WORM-compliant storage to regulator-ready auditing.
Key features:

SFTP File Management Service

  • Securely retrieves and organizes trade, order, and vendor files
  • Places files into the correct systems and folders for easy access
  • Operates as a back-end process to streamline workflows
  • Ensures reliable, consistent data flow across the firm
Key features:

Data Reconciliation Reports

  • Compares files from counterparties and vendors, even across different formats
  • Ensures data integrity across systems (OMS blotter, CAT files, clearing firm blotter, security positions)
  • Identifies mismatches or missing records before they create issues
  • Catches systemic errors in third-party systems that could lead to misreports, missed alerts, or incorrect order instructions
Key features:

Customized Trade/Order Blotter

  • Creates proprietary trade and order blotters by aggregating daily file drops from the various vendors (clearing firms, OMSs, etc.)
  • Fills gaps in third-party records fixing incomplete fields and removing non-relevant data
  • Customizable with relevant columns and keys for clarity and usability
  • Sortable by date range for quick research and analysis
  • Auditable and exportable to meet regulator requirements for readily available records
Key features:

File Explorer

  • Centralized hub for all broker-dealer electronic records
  • Searchable and organized for fast, easy access
  • WORM-compliant storage to meet SEC Rule 17a-4 requirements
  • Tracks and displays records for complete oversight and audit readiness
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Real findings. Real fines

Recent fines of broker-dealers highlight the necessity of utilizing technological solutions to manage data to support its compliance structure.
Broker-Dealers Fine
Date
May 2025
Broker-Dealer
BTG Pactual US Capital
Fine Amount
$400,000
Failure to establish and implement AML processes that could detect suspicious transactions.
Fine Amount
$1,450,000
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Date
May 2025
Broker-Dealer
Goldman Sachs & Co.

Failure to accurately report data to the Consolidated Audit Trail (CAT) Central Repository for 36.6 billion order events.

Fine Amount
$45,000,000
(various violations)
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Date
Broker-Dealer
Robinhood Securities & Robinhood Financial

Failure to maintain copies of core operational databases in a manner that ensured legally required records were protected from deletion or modification for the required length of time. For more than five years, failed to provide complete and accurate blue sheet data to the SEC.

Fine Amount
$825,000
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Date
May 2024
Broker-Dealer
Merrill Lynch, Pierce, Fenner & Smith Inc.

Among other things, failure to reasonably supervise the accuracy of memoranda for electronic orders.

Fine Amount
$140,000
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Date
November 2023
Broker-Dealer
Tradition Securities and Derivatives LLC

Failure to record transmission times and to include the correct exchange of execution on its order tickets.

Fine Amount
$300,000
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Date
January 2023
Broker-Dealer
Raymond James & Associates

Firm records inaccurately recorded the firm’s execution capacity or whether the trade was executed at an average price, or inaccurately disclosed or omitted its status as a market maker in the security.

Fine Amount
$2,800,000
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Date
June 2022
Broker-Dealer
Barclays Capital Inc.

Records contained inaccurate execution capacity, price or whether the trade was executed on an average price, as well as inaccurate market center of execution.

Fine Amount
$125,000
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Date
January 2025
Broker-Dealer
Wall Street Access

Failure to establish that the intermarket sweep orders (ISOs) it routed to certain market centers met the requirements for an ISO.

Fine Amount
$3,000,000
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Date
December 2024
Broker-Dealer
J.P. Morgan Securities LLC

Failure to accurately report short interest positions to FINRA.

Fine Amount
$900,000
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Date
December 2024
Broker-Dealer
Wells Fargo Clearing Services

Failure to submit approximately 22,000 blue sheets to FINRA that inaccurately reported one or more of 10 types of transaction information.

Fine Amount
$1,000,000
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Date
October 2024
Broker-Dealer
Citadel Securities

Failure to properly report data for billions of equity and option order events over 4 years to CAT.

Fine Amount
$1,200,000
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Date
October 2024
Broker-Dealer
IMC-Chicago, LLC dba IMC Financial Markets

Failure to timely and accurately report to CAT 28.7 billion equity and options order events.

Fine Amount
$300,000
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Date
September 2024
Broker-Dealer
TradeUP Securities

Failure to accurately report short interest positions to FINRA.

Fine Amount
$100,000
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Date
July 2024
Broker-Dealer
J.P. Morgan Securities

Failure to take reasonable steps to ensure that the intermarket sweep orders (ISOs) it routed met the requirements set forth in Regulation NMS.

Fine Amount
$6,000,000
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Date
September 2023
Broker-Dealer
Goldman Sachs & Co

Submitting blue sheets to FINRA that inaccurately reported one or more of 39 separate types of transaction information.

Fine Amount
$300,000
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Date
January 2023
Broker-Dealer
Scotia Capital (USA) Inc.

The firm erroneously included non-reportable short positions reflected in omnibus accounts in the firm’s short interest reports.

Fine Amount
$5,000,000
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Date
September 2022
Broker-Dealer
BofA Securities, Inc.

Failure to report over-the-counter (OTC) options positions to the Large Options Positions Reporting system (LOPR) in more than 7.4 million instances, including 26 positions that were over the applicable OTC position limit, and related supervisory failures.

Use our data management tools to prevent costly fines!

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