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NOTE: Offers of Settlement (OS) and Letters of Acceptance, Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions and to the entry of findings.

NBBO: National Best Bid or Offer

by Bill Singer bsinger@rrbdlaw.com

Mitchell Mark Almy (AWC/CMS030353/December 2003)
Entered NASDAQ limit orders through a member firm account at its clearing firm in order to improve NBBO through an ECN.  Then entered large orders on contra-side of market to buy/sell in firm's proprietary account through a clearing firm, knowing such orders would be routed to market makers whose automated execution systems were programmed to to react per NBBO (prices equal to or better). After obtaining such improved exectuions, he canceled the limit orders for a profit of $685.

  • Mitchell Mark Almy
    Fined $20,000; Suspended all capacities for one month

 

Steven Spiro Hecht (AWC/CMS030223/November 2003)
Hecht entered orders in NASDAQ securities into an electronic communications network (ECN) with the intention to improve (and did) NBBO, in that such orders would be reflected in the public quotation system as NBBO at which a market participant was willing to buy/sell.  After said entry, Hecht routed to other companies orders for such securities on behalf of a member firm's proprietary account. Following execution, Hecht canceled the orders. 

  • Steven Spiro Hecht 
    No fine in light of financial status; Suspended 90 days in all capacities.

 

Jeffrey Robert Casciano 
(AWC/CMS030206/November 2003)
Casiano entered priced limit orders in NASDAQ securities through member firm with the intention to improve (and did) NBBO.  After said entry, Casciano entered larger orders on the other side for a firm proprietary account or a firm customer account.  The orders were routed to market makers with automated execution systems programmed to buy/sell at NBBO or better.  Following execution, Casciano canceled the limit orders. 

  • Jeffrey Robert Casciano 
    Fined $15,000; Suspended 31 days in all capacities.







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