According to the disciplinary action, Goldman is required to address its LOPR
deficiencies and ensure that it has implemented controls and procedures that are reasonably designed to achieve compliance with the applicable rules and regulations.
After identifying and remediating the firm's failure to report reportable conventional options positions to LOPR
, FINRA determined that the firm still failed to accurately report an unknown but significant number of conventional options positions to the LOPR
The agency said that the firm failed to maintain an adequate system of supervision, including systems of follow-up and review, that would achieve compliance in the reporting of options positions to the LOPR system.
The firm was unaware of the coding error that deleted expiring options on the expiration date from the LOPR and, as a result, it failed to find and prevent that deletion.
According to the agency, the firm failed to report some over-the-counter options positions to the LOPR, including transactions involving foreign underlying securities or in which the firm misclassified the counterparties.
Its supervisory system was not reasonably designed to achieve compliance with the rules on position limits and the reporting of positions to the LOPR, nor did it include sufficient written supervisory procedures to ensure the proper reporting of positions to the LOPR.
Capital One Sharebuilder was censured by FINRA and fined $100,000 after the agency found that the firm failed to correctly report options positions to the Large Options Positions Report (LOPR
) with the correct Clearing Member number.