Many commentators and the exchanges themselves have indicated that COVID 19 will not cause exchange and regulator oversight to cease. The ICE just punctuated that thought with a notice today of a two month suspension from exchange access for a trader.
The suspension is the result of placing orders without intent to execute (large orders on one side of the market while executing small orders on the other and then cancelling the large orders - classic spoofing) on one single day in December 2016. No monetary fine but a two month suspension. The notice is here
I would just like everyone to imagine the difficulty, cost, and risk associated with an exchange inquiry into your trading activity while you are in remote operations. How do you have the compliance officer manage the call with the trader? How do you get outside counsel access to your records? How does your compliance officer access phone recordings?
The ides of managing an inquiry in this environment is even more daunting than in normal circumstances. I think all compliance officers should think about how their business continuity plan addresses remote management of an inquiry. This also might recommend a note to all trading staff that even greater caution than usual might be a good thing.
DCM hopes all of you are staying safe and healthy and that all industry companies and staff can weather this with minimal impacts. Our best to all of you.
Please fell free to reach out to us for advice and questions in these difficult times - even if you have not been a client in the past, know that we feel all of us have to pitch in and help to keep everyone going these days.