REGULATION SHO MONITORING

Stay ahead of Regulation SHO risk

Automated oversight of order marking and locates so you can catch issues early, fix systemic gaps, and prevent costly violations.
Ensure that sales orders are correctly marked long or short
Verify that short sales have valid locates on a daily basis
Identify mismarking issues daily
Prevent accumulating systemic Regulation SHO issues

Relevant rules

Addresses the primary Regulation SHO requirements for broker-dealers that allow its client to effect short sales, specifically:
Rule 200(g), which requires broker-dealers monitor whether clients (or an order management system) is properly marking sale orders long or short.
Rule 203(b), which requires broker-dealers to monitor whether short sale orders for which there were no locates were prevented.

Common deficiencies

Order management system failure to properly mark sale orders long or short.
Order management system failure to prevent short sale orders for which there were no locates (either on the Easy-to-Borrow list or individually located).

Knowtice’s prevention plan

Knowtice’s Regulation SHO monitoring report continuously tracks intraday stock positions and orders, generating exceptions for any single mismarked sale order or missing locate.
Key features:

Daily order marking review

Screens sale orders to confirm they’re correctly marked “long” or “short.”
Key features:

Systemic issue detection

Identifies root causes (e.g., latency) and equips firms with evidence to resolve OMS/vendor errors quickly.
Key features:

Daily locate review

Confirms every short sale order is supported by a documented locate.
Key features:

Borrow list validation

Matches short orders against Easy-to-Borrow, Hard-to-Borrow, and ad hoc lists to flag violations or exceeded volumes.
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Real findings. Real fines

Recent fines of broker-dealers highlight the necessity of utilizing technological solutions to systematically monitor Regulation SHO compliance.
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
$45,000,000
(various violations)
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Date
January 2025

Rule 200(g) and Rule 203(b)

Fine Amount
$250,000
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Date
June 2024

Rule 203(b) – locates

Fine Amount
$400,000
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Date
May 2024
Broker-Dealer
M1 Finance

Rule 200(g) and Rule 203(b)

Fine Amount
$7 million
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Date
September 2023
Broker-Dealer
Citadel Securities

Rule 200(g) – order marking

Fine Amount
$50,000
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Date
June 2023
Broker-Dealer
BGC Financia

Rule 200(g) – order marking

Fine Amount
$3 million
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Date
April 2023
Broker-Dealer
Goldman Sachs

Rule 200(g) – order marking

Fine Amount
$100,000
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Date
August 2022
Broker-Dealer
Gar Wood Securities

Rule 203(b) – locates

Fine Amount
$70,000
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Date
May 2022

Rule 200(g) – order marking

Fine Amount
$100,000
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Date
January 2022

Rule 203(b) – locates

Fine Amount
$35,000
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Date
August 2021

Rule 203(b) – locates

Fine Amount
$300,000
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Date
June 2021

Rule 203(b) – locates

Fine Amount
$100,000
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Date
November 2020
Broker-Dealer
GTS Securities

Rule 203(b) – locates

Fine Amount
$180,000
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Date
November 2020
Broker-Dealer
Citadel Securities

Rule 200(g) – order marking

Fine Amount
$225,000
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Date
June 2020

Rule 203(b) – locates

Fine Amount
$225,000
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Date
January 2020

Rule 203(b) – locates

Fine Amount
$1.1 million
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Date
December 2019
Broker-Dealer
Wilson-Davis & Co.

Rule 203(b) – locates

Fine Amount
$2 million
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Date
March 2019
Broker-Dealer
Cantor Fitzgerald

Rule 200(g) and Rule 203(b)

Fine Amount
$5.5 million
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Date
August 2018
Broker-Dealer
Interactive Brokers

Rule 203(b)

Use our Regulation SHO Monitoring tool to prevent costly fines!

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