According to FINRA, Barclays Capital Inc. was censured and fined $175,000 for overstating its advertised trading volume in thousands of instances by approximately 147 million shares.
The firm used a proprietary system to calculate trade volume and transmit information to a market data provider for advertisement. The system suffered from several technology flaws causing errors that inflated the firm's trade volume calculations. These flaws included counting trades that were subsequently canceled or corrected, counting transactions between the firm's affiliates as if they were with non-affiliated entities, and double-counting trades executed in the market when there was a subsequent transfer in a riskless principal transaction. The system automatically transmitted these inflated calculations directly to the market data provider for public advertisement.
The firm's supervisory system and written procedures were not reasonably designed to achieve Rule 5210 compliance. The procedures addressed neither how the firm should calculate trading volume nor how to monitor advertised trading volumes for accuracy.
Advertised trading volume influences market participants' perceptions of a firm's market presence and liquidity provision. Inflated volume figures can mislead investors and other market participants about a firm's actual trading activity and market share.
After discovering these issues, the firm corrected the technology flaws and implemented new written supervisory procedures addressing advertised trading volume calculation and monitoring.
This case illustrates the critical importance of accuracy in market data and the need for robust controls over automated systems that generate public reporting. Firms must implement supervisory procedures to verify the accuracy of advertised information that could influence market perceptions.