TD Arranged Services LLC, formerly known as ATM Execution LLC, has accepted a disciplinary settlement with Nasdaq for maintaining inadequate supervisory systems designed to detect potentially manipulative trading between December 2021 and December 2024. The firm was censured and fined $29,166.64 as part of a broader $150,000 penalty resolution involving similar violations at other firms.
- Violation Period: December 2021 to December 2024
- Individual Fine: $29,166.64
- Total Penalty Resolution: $150,000
- Registration Status: Firm terminated Nasdaq registration on December 23, 2024
The New York-based broker-dealer failed to establish and maintain written supervisory procedures reasonably designed to monitor for prearranged trading, coordinated trading activity, momentum ignition, layering, spoofing, and marking the close. The firm routed foreign broker-dealers’ orders through omnibus accounts without adequate surveillance mechanisms, potentially allowing manipulative trading patterns to go undetected and unaddressed.
Nasdaq’s enforcement action highlighted specific instances where the firm’s failures proved consequential. On one trading day, TD Arranged Services executed trades in a low-priced security that doubled its price within an eight-minute window while representing significant total volume. In another case, trading in an omnibus account represented approximately 30 percent of a security’s market volume while its price surged from roughly $15 to $125. Despite generating trade alerts, the firm failed to timely investigate or respond to the activity, violating Nasdaq rules requiring members to observe high standards of commercial honor and maintain compliant supervisory systems.
The settlement was submitted without the firm admitting or denying the findings. TD Arranged Services had operated as a FINRA and Nasdaq member since March 2010 with approximately 10 registered representatives and reported no relevant disciplinary history prior to this enforcement action.
