RBC Capital Markets, LLC: investment adviser

Item 11 questions answered Yes

These questions cover the firm and its advisory affiliates.

• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have made a false statement or omission?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: entered an order against you or any advisory affiliate in connection with investment-related activity?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?
• Has any self-regulatory organization or commodities exchange ever: found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)?

Actions about the firm (127)

1. Aug 21, 2026
   Regulatory Action: New Hampshire Securities Regulation FinalSanctions: Cease and Desist; Fine, costs and undertakings · Fine: $25,000 · Begun Aug 21, 2026 · Resolved Aug 21, 2026 · Consent · Docket COM2024-0002

   In 2023, RBC agent's mom and step-dad became incapacitated and poa, agents brother, had authority over their investment accounts. Agent was conflicted because he was a named beneficiary and there was a family dispute over mom's affairs. Agent did not step away from the accounts and RBC allowed mom to make decisions over the accounts beneficiaries and the poa without obtaining a letter of renewed capacity from a physician.

   See above

2. Jul 28, 2026
   Regulatory Action: FINRA FinalFine: $275,000 · Begun Jul 28, 2026 · Resolved Jul 28, 2026 · Acceptance, Waiver & Consent(AWC) · Docket 2022075967301

   Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to develop and implement an AML compliance program reasonably designed to detect and cause the reporting of suspicious transactions. The findings stated that the firm introduced three new transaction monitoring rules that were intended to identify red flags of suspicious money movements. However, the firm configured the parameters and thresholds of these monitoring rules in a manner that did not capture many of the types of transactions the rules were intended to detect. The firm configured one monitoring rule to trigger alerts based on an account's margin balance, which was typically less than the minimum threshold balance, instead of the account balance. The second monitoring rule failed to trigger useful alerts because the thresholds for total credits were set too high. The third monitoring rule generated a high volume of false positives because it captured routine transfers between accounts belonging to the same person or related parties. Because the firm improperly configured the parameters and thresholds of these monitoring rules, they either failed to generate useful alerts or otherwise did not identify red flags of suspicious money movements that the firm should have investigated. In practice the firm failed to effectively review the monitoring rules to determine whether the rules were identifying suspicious money movements in customer accounts so as to enable the firm to investigate and report the suspicious transactions. In addition, the firm delegated to two different groups responsibilities for assessing the effectiveness of the transaction monitoring rules and for decommissioning ineffective rules, but the firm did not have procedures for the two groups to coordinate or escalate concerns. Consequently, the three rules that failed to generate useful alerts remained in place for years and the firm failed to identify, investigate, and report suspicious transactions that these rules were designed to detect. The firm ultimately updated its procedures to require periodic assessments of its automated transaction monitoring rules to determine whether they are effectively enabling the firm to detect and cause the reporting of suspicious transactions.

3. Jun 15, 2026
   Regulatory Action: Kentucky FinalSanctions: Cease and Desist; Censure. Restitution. Administrative fine. · Fine: $20,000 · Begun Jun 15, 2026 · Resolved Jun 15, 2026 · Consent · Docket 2025-DFI-0141

   Respondent's minimum commission practices for certain equity transactions failed to ensure transactions were executed at a fair and reasonable price. Respondent did not reasonably supervise transactions which applied the minimum equity commission.

4. Jun 3, 2026
   Regulatory Action: District of Columbia - Department of Insurance, Securities and Banking. FinalSanctions: Cease and Desist; Censure, restitution, civil and administrative fines · Fine: $20,000 · Begun Jun 3, 2026 · Resolved Jun 3, 2026 · Acceptance, Waiver & Consent(AWC) · Docket SB-CO-07-25

   The respondent charged commissions in excess of 5% of the principal amount on 89,000 equity transactions over a five-year period, totaling $3,400,000.00.

   The administrative fine of $20,000.00 received.

5. May 21, 2026
   Regulatory Action: Minnesota FinalSanctions: Cease and Desist; Censure; restitution; civil and administrative fines · Fine: $20,000 · Begun May 21, 2026 · Resolved May 21, 2026 · Acceptance, Waiver & Consent(AWC) · Docket 99069

   The respondent charged unreasonable commissions in excess of 5% of the principal amount on 89900 equity transactions over a five-year period totaling approximately $3400000.

6. Feb 27, 2026
   Regulatory Action: Vermont FinalSanctions: Restitution · Fine: $20,000 · Begun Feb 27, 2026 · Resolved Feb 27, 2026 · Stipulation and Consent · Docket 25-019-S

   The consent order is a result of a multistate investigation spearheaded by the north american securities administrators association, inc. the nasaa investigation revealed that from May 16, 2020, to May 16, 2025, the firm charged unreasonable fixed commissions of $95 on certain equity transactions for retail brokerage customers. The commission rate exceeded the 5% limit set out in FINRA rules. In VT, 169 equity transactions included an unreasonable commission, totaling $6872. The firm failed to establish and maintain a system to reasonably supervise its agents, in violation of V.S.R. 2-2(b)(2), incorporating FINRA rule 3110(a).

   See 13b

7. Feb 24, 2026
   Regulatory Action: South Dakota Division of Insurance FinalSanctions: Restitution · Fine: $20,000 · Begun Feb 24, 2026 · Resolved Feb 24, 2026 · Consent · Docket SD 25-30751

   Excessive fees

8. Feb 20, 2026
   Regulatory Action: Mississippi FinalSanctions: Restitution; Administrative fine · Fine: $22,189 · Begun Jun 20, 2025 · Resolved Feb 20, 2026 · Consent · Docket LS-25-8156 HTTPS://WWW.SOS.MS.GOV/SECURITIES/SECURITIES-ENFORCEMENT-ACTIONS

   RBC charged unreasonable commissions on certain small principal equity transactions. The firm was ordered to pay restitution in the amount of $2,188.90 to Mississippi customers and an administrative penalty of $20,000.

9. Feb 5, 2026
   Regulatory Action: Pennsylvania Department of Banking and Securities: Contact Counsel Charles Vance 717-705-2298 FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution, censure, cease and desist, and undertakings · Fine: $20,000 · Begun Feb 5, 2026 · Resolved Feb 5, 2026 · Consent · Docket 260005

   RBC Capital Markets, LLC charged unreasonable commissions on certain equity transactions and did not reasonably surveil these transactions to ensure that respondents charged customers a reasonable commission and fee.

   Consent order issued to RBC Capital Markets, LLC.

10. Jan 21, 2026
    Regulatory Action: Missouri FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution; cease and desist; and undertakings · Fine: $25,000 · Begun Jan 21, 2026 · Resolved Jan 21, 2026 · Consent · Docket AP-25-06

    From May 16, 2020 to May 16, 2025, RBC Capital Markets, LLC allegedly charged unreasonable commissions in excess of 5% of the principal amount on certain small principal equity transactions and did not reasonably supervise transactions which applied the minimum equity commission charge to ensure that respondent charged customers a reasonable commission.

    RBC Capital Markets, LLC paid the administrative fine of $25,000 on 1/21/2026 and agrees to provide restitution within 120 days of the execution of this order.

11. Jan 15, 2026
    Regulatory Action: Utah FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $20,000 · Begun Jan 15, 2026 · Resolved Jan 15, 2026 · Stipulation and Consent · Docket SD-25-0030

    Respondent charged unreasonable commissions on certain low principal equity transactions and failed to reasonably supervise low principal equity transactions where the minimum commission was in excess of 5%.

12. Dec 19, 2025
    Regulatory Action: Texas FinalSanctions: Restitution; Reprimand · Fine: $25,000 · Begun Dec 19, 2025 · Resolved Dec 19, 2025 · Order · Docket LID-25-CAF-03

    From May 16, 2020, to May 16, 2025, RBC Capital Markets, LLC, allegedly charged unreasonable commissions (in excess of 5% of the principal amount) on certain low principal equity transactions. Respondent did not reasonably supervise transactions which applied the minimum equity commission charge to ensure that respondent charged customers a reasonable commission. Respondent has agreed to provide resitution to affected customers in the amount charged over 5% in addition to a fine by the TSSB. Respondent has also agreed to revisit respondent's policies and procedures to ensure that respondent include safeguards to prevent the charging of excessive fees in the future.

13. Nov 20, 2025
    Regulatory Action: Oregon Division of Financial Regulation FinalSanctions: Restitution; Civil penalties, agreement to cease and desist from future violations, censure · Fine: $20,000 · Begun May 28, 2025 · Resolved Nov 20, 2025 · Consent · Docket S-25-0035

    The division, in connection with a multistate task for coordinated among members of the north american securities administrators association, found that RBC charged unreasonable commissions to retail customers in excess of five percent of the principal amount.

14. Jun 4, 2025
    Regulatory Action: Office of Secretary of the Commonwealth of Massachusetts, Securities Division. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution; censure; cease and desist; and undertakings. · Fine: $25,000 · Begun Jun 4, 2025 · Resolved Jun 4, 2025 · Consent · Docket E-2025-0190

    RBC Capital Markets, LLC charged unreasonable commissions on certain equity transactions and did not reasonably surveil these transactions to ensure that respondent charged customers a reasonable commission and fee.

    RBC Capital Markets, LLC neither admitted nor denied the statement of facts and violation of G.L.C. 110a, SEC. 204(a)(2)(j).

15. Aug 14, 2024
    Regulatory Action: SEC FinalSanctions: Cease and Desist · Fine: $45.0M · Begun Aug 14, 2024 · Resolved Aug 14, 2024 · Order · Docket 3-22003

    The Securities and Exchange Commission deems it appropriate and in the public interest that public administrative and cease-and- desist proceedings be, and hereby are, instituted against RBC Capital Markets, LLC (RBC or respondent). In anticipation of the institution of these proceedings, respondent has submitted an offer of settlement that the commission has determined to accept. The commission finds that from at least June 2019 (the relevant period), RBC personnel sent and received off-channel communications that were records required to be maintained under Exchange Act rule 17A-4(b)(4) and/or Advisers Act rule 204- 2(a)(7). Respondent did not maintain or preserve the substantial majority of these written communications. Respondent's failures were firm-wide and involved personnel at various levels of authority throughout the organization. RBC's widespread failure to implement a system reasonably expected to determine whether personnel were following its policies and procedures that prohibit off-channel communications led to its failure to reasonably supervise its personnel within the meaning of section 15(b) (4)(e) of the Exchange Act and section 203(e)(6) of the Advisers Act. During the relevant period, RBC received and responded to commission subpoenas for documents and/or records requests in a number of commission investigations. As a result, RBC's recordkeeping failures likely impacted the commission's ability to carry out its regulatory functions and investigate violations of the federal securities laws across these investigations. Commission staff found RBC's misconduct after commencing a risk- based initiative to investigate the use of off-channel and unpreserved communications at investment advisers. RBC has initiated a review of its recordkeeping failures and begun a program of remediation. As a result of its conduct, RBC willfully violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder and failed reasonably to supervise its personnel, with a view to preventing or detecting certain of its supervised persons' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder.

16. Jul 2, 2024
    Regulatory Action: FINRA FinalFine: $75,000 · Begun Jul 2, 2024 · Resolved Jul 2, 2024 · Acceptance, Waiver & Consent(AWC) · Docket 2019063914601

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that its supervisory system did not provide certain customers with mutual fund sales charge waivers and fee rebates to which they were entitled through rights of reinstatement offered by mutual fund companies. The findings stated that the firm's oversightof discounts available through rights of reinstatement relied on an automated alert that was set to identify transactions in which a customer liquidates a position in a fund family and then purchases back into the same family at a later date. The alert was not designed to, and did not, capture all transactions eligible for reinstatement privileges. The firm also, at times, failed to reasonably review alerts that did trigger to ensure that eligible customers were credited with reinstatement privileges. As result, eligible customers paid $264,939.44 inexcess sales charges and fees.

17. Apr 29, 2024
    Regulatory Action: FINRA FinalFine: $375,000 · Begun Apr 29, 2024 · Resolved Apr 29, 2024 · Acceptance, Waiver & Consent(AWC) · Docket 2015046503001

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it sent trade confirmations to customers that contained inaccurate information. The findings stated that the firm sent its institutional customers confirmations for fixed income transactions, including certain municipal securities transactions, that inaccurately stated that the transactions were executed in an agency capacity, when they were executed in a principal capacity. The inaccuracies stemmed from coding errors in the electronic systems that the firm relied on for sending trade confirmations. The firm also sent its institutional customers trade confirmations that inaccurately stated that certain transactions that were solicited were unsolicited and vice versa. These inaccuracies resulted from the firm's coding of its fixed income trade order management system to automatically populate certain confirmations with a designation that the transactions were solicited, and others with a designation that the transactions were unsolicited. In addition, the firm failed to deliver trade confirmations to customers that had requested electronic delivery of trade confirmations. Furthermore, the firm failed to send trade confirmations for millions of dividend reinvestment program (DRIP) transactions. The firm did not provide customers with a detailed written description of the DRIP prior to enrollment containing certain disclosures, as required by a no-action letter that the SEC published. The firm instead confirmed automatic dividend reinvestments pursuant to a DRIP through monthly account statements rather than trade-by-trade confirmations. However, by failing to comply with the conditions of the no-action letter, the firm did not qualify for exemptive relief from rule 10B-10(a)'s trade-by-trade confirmation requirement. The findings also stated that the firm failed to establish, maintain, and enforce a supervisory system, including WSPS, reasonably designed to achieve compliance with trade confirmation requirements. The firm's WSPS failed to describe how supervisors should conduct periodic monitoring to confirm that internal firm systems and third-party vendor systems were working as intended to send customers trade confirmations when required and with accurate information. The firm also failed to conduct reasonable monitoring and periodic testing to confirm that the systems it relied upon for sending and generating accurate trade confirmations were working as intended. As a result, the firm did not timely detect multiple issues that impacted trade confirmations. The findings also included that the firm violated regulation t promulgated by the Board of Governors of the Federal Reserve system under section 7 of the Exchange Act by extending credit to certain customers of the firm and its introducing firms. Certain firm customers with cash accounts and certain customers of introducing brokers with cash accounts for which the firm was the clearing broker sold securities without previously paying for them in full. However, the firm failed to withdraw from those customers the privilege of delaying payment beyond the trade date for 90 calendar days following the date of sale of the security, as required by regulation t. As a result, the firm incorrectly executed hundreds of trades in those accounts and frequently sold the positions at issue to generate proceeds to cover the purchases. In connection with these transactions, customer accounts incurred commissions, markups, markdowns, and fees totaling $392,525.50, that they

18. Jan 19, 2024
    Regulatory Action: CME Group FinalSanctions: Other; Settlement · Fine: $25,000 · Begun Jan 19, 2024 · Resolved Jan 19, 2024 · Settled · Docket 23-CH-2313

    RBC Capital Markets, LLC violated CME rules 930.E.1. And 930.K.1.

19. Oct 13, 2023
    Regulatory Action: CME Group FinalSanctions: Other · Fine: $50,000 · Begun Oct 13, 2023 · Resolved Oct 13, 2023 · Settled · Docket 23-CH-2322

    RBC Capital Markets, LLC neither admitted nor denied violating exchange rules, found the firm guilty of violating CME rule 980.a.

20. Jul 11, 2023
    Regulatory Action: FINRA FinalSanctions: Other · Fine: $250,000 · Begun Jul 11, 2023 · Resolved Jul 11, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2021071191801

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it filed short interest reports that overreported the number of shares associated with short interest positions. The findings stated that the firm submitted short interest reports to FINRA that erroneously included short positions in accounts resulting from repurchase and pledge transactions and securities lending conducted by the firm or its affiliates, and syndicate activity of correspondent firms for which it clears securities transactions. Because these short positions did not result from "short sales" as defined in rule 200(a) of Regulation SHO and were not transactions that were marked long due to the firm's or the customer's net long position at the time of the transaction, they were not reportable under FINRA rule 4560. As a result, the firm overreported the number of shares associated with the short interest positions. The findings also stated that the firm failed to establish and maintain a supervisory system, including WSPS, reasonably designed to achieve compliance with short interest reporting requirements. Although the firm coded accounts as reportable or non-reportable for short interest reporting purposes, its supervisory system did not provide for testing of the coding of accounts on an ongoing basis. In addition, the firm relied on email notifications from the firm's correspondent business clearing line for reconciling the coding and inclusion or exclusion of syndicate accounts for short interest reporting purposes. However, the firm did not implement processes or procedures to monitor whether the notifications were timely received and reviewed. Subsequently, the firm amended its supervisory systems and procedures to include, among other things, additional reviews at the time of account creation and short interest reporting and a lookback review identifying changes in the last six report cycles.

21. Jun 12, 2023
    Regulatory Action: Nasdaq Stock Market FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $180,000 · Begun Jun 12, 2023 · Resolved Jun 12, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2021.05.0319

    The Nasdaq enforcement department (the "staff") reviewed the firm's compliance with Nasdaq rules requiring members to input the correct capacity codes on equity orders entered into exchange systems between August 28, 2015 and November 2, 2020. As a result of its review, the staff determined that the firm input the incorrect capacity code on hundreds of millions of equity orders it entered into multiple exchanges, including over 40,485,994 orders it input into the Nasdaq system with incorrect capacity codes.

22. Jun 12, 2023
    Regulatory Action: Nasdaq PHLX LLC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $45,000 · Begun Jun 12, 2023 · Resolved Jun 12, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2021.05.0319

    The PHLX enforcement department reviewed the firm's compliance with PHLX rules requiring members to input the correct capacity codes on equity orders entered into exchange systems between August 28, 2015 and November 2, 2020. The entry of inaccurate capacity codes causes the audit trail to be inaccurate, which can as a result of its review, the staff determined that the firm input the incorrect capacity code on hundreds of millions of equity orders it entered into multiple exchanges, including over 11,187,701 orders it input into the PSX system with incorrect capacity codes.

23. Jun 5, 2023
    Regulatory Action: NYSE American LLC FinalSanctions: Other · Fine: $10,000 · Begun Jun 5, 2023 · Resolved Jun 5, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2022-03-17-00037

    Without admitting or denying the findings, the firm ("RBCCM") consented to the sanctions and to the entry of findings that it violated: (I) NYSE American rule 7.33e by submitting over 151,000 principal orders incorrectly marked as agency orders to NYSE American from October 2019 through March 2020; and (II) NYSE American rules 3110(a) and 3110(b) by failing to have a reasonably designed supervisory system, including written supervisory procedures, to comply with its capacity code obligations during the period from August 2015 through November 2020. During the period from October 2019 through March 2020, the firm incorrectly entered over 151,000 orders into the NYSE American marketplace marked with the "agency" capacity code when the orders should have been marked with the "principal" capacity code due to a coding error impacting a firm trading platform (the "oms") that flipped the reported capacity from principal to agency. From August 2015 through November 2020, RBCCM did not have a supervisory system or written supervisory procedures in place that were reasonably designed to confirm that client orders were coded with accurate capacities and thus ensure compliance with NYSE American rules requiring that orders submitted to the exchange are marked with accurate agency or principal capacity codes. Specifically, during the period from October 2019 through March 2020, a field within the firm's surveillance report covering the oms was not correctly populated, resulting in "null" values that prevented the generation of alerts for incorrect capacity codes. The firm's surveillance review was therefore not functioning properly for a period of nearly six months. Additionally, from August 2015 through November 2020, the firm's surveillance review failed to include data from another of its trading platforms, resulting in a failure to detect ongoing capacity code violations that impacted this trading platform for a period of more than five years.

24. Jun 5, 2023
    Regulatory Action: NYSE Chicago, Inc. FinalSanctions: Other · Fine: $5,000 · Begun Jun 5, 2023 · Resolved Jun 5, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2022-03-17-00037

    Without admitting or denying the findings, the firm ("RBCCM") consented to the sanctions and to the entry of findings that during the period from October 2019 through March 2020, it incorrectly entered 2,384 orders into the NYSE Chicago marketplace marked with the "agency" capacity code when the orders should have been marked with the "principal" capacity code due to a coding error impacting a firm trading platform (the "oms") that flipped the reported capacity from principal to agency. The firm's surveillance review failed to detect that these orders were being entered with an incorrect capacity code because it was not functioning properly. Specifically, a field within the surveillance report covering the oms was not correctly populated, resulting in "null" values that prevented the generation of alerts for incorrect capacity codes. Additionally, from August 2015 through November 2020, the firm's surveillance review failed to include data from another of the firm's trading platforms, resulting in a failure to detect ongoing capacity code violations that impacted this trading platform for a period of more than five years. As discussed above, a coding error impacting the oms resulted in the firm incorrectly entering 2,384 orders into the NYSE Chicago marketplace marked with the "agency" capacity code when the orders should have been marked with the "principal" capacity code during the period from October 2019 through March 2020. Accordingly, the firm violated NYSE Chicago rule 7.33. From August 2015 through November 2020, RBCCM did not have a supervisory system or written supervisory procedures in place that were reasonably designed to confirm that client orders were coded with accurate capacities and thus ensure compliance with NYSE Chicago rules requiring that orders submitted to the exchange are marked with accurate capacity codes. The firm's supervisory review designed to ensure compliance with its order marking obligations was not functioning properly for a period of nearly six months from October 2019 through March 2020, resulting in a failure to detect that orders submitted to the exchange were being entered with incorrect capacity codes. Additionally, the firm's supervisory review failed to include data from another firm trading platform, resulting in a failure to detect ongoing capacity code violations that impacted this trading platform for a period of more than five years. Accordingly, the firm violated NYSE Chicago article 6, rules 5(a) and 5(c).

25. Jun 5, 2023
    Regulatory Action: NYSE ARCA, Inc. FinalSanctions: Other · Fine: $75,000 · Begun Jun 5, 2023 · Resolved Jun 5, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2022-03-17-00037

    Without admitting or denying the findings, the firm ("RBCCM") consented to the sanctions and to the entry of findings that during the period between August 2015 and November 2020 (the "relevant period"), it violated: (I) NYSE ARCA rule 7.33-E1 by submitting over 665,000 agency orders incorrectly marked as principal orders and over 12.1 million principal orders incorrectly marked as agency orders to NYSE ARCA; and (II) NYSE ARCA rules 11.18(b) and 11.18(c) by failing to have a reasonably designed supervisory system, including written supervisory procedures, to comply with its capacity code obligations. During the relevant period, two distinct issues involving two different firm trading platforms resulted in RBCCM incorrectly marking certain principal orders as agency and certain agency orders as principal. First, during the period from August 2015 through November 2020, a failure to update relevant account type code settings on a firm trading platform ("oms #1") resulted in the firm incorrectly entering: (I) over 11.7 million orders into the NYSE ARCA marketplace marked with the "agency" capacity code when the orders should have been marked with the "principal" capacity code; and (II) over 665,000 orders into the NYSE ARCA marketplace marked with the "principal" capacity code when the orders should have been marked with the "agency" capacity code. Second, during the period from October 2019 through March 2020, the firm incorrectly entered over 398,000 orders into the NYSE ARCA marketplace marked with the "agency" capacity code when the orders should have been marked with the "principal" capacity code due to a coding error impacting a different firm trading platform ("oms #2") that flipped the reported capacity from principal to agency. During the relevant period, RBCCM did not have a supervisory system or written supervisory procedures in place that were reasonably designed to confirm that client orders were coded with accurate capacities and thus ensure compliance with NYSE ARCA rules requiring that orders submitted to NYSE ARCA are marked with accurate agency or principal capacity codes. Specifically, the firm's surveillance review failed to include data from oms #1 during the entirety of the relevant period, resulting in a failure to detect the ongoing capacity code violations that impacted this trading platform for a period of more than five years. Additionally, during the period from October 2019 through March 2020, a field within the firm's surveillance report covering oms #2 was not correctly populated, resulting in "null" values that prevented the generation of alerts for incorrect capacity codes. The firm's surveillance review was therefore not functioning properly for a period of nearly six months.

26. Jun 5, 2023
    Regulatory Action: NYSE National, Inc. FinalSanctions: Other · Fine: $15,000 · Begun Jun 5, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2022-03-17-00037

    Without admitting or denying the findings, the firm ("RBCCM") consented to the sanctions and to the entry of findings that it violated: (I) NYSE National rule 7.33 by submitting over 401,000 principal orders incorrectly marked as agency orders to NYSE National from October 2019 through March 2020; and (II) NYSE National rules 11.3.2 and 11.5.1 by failing to have a reasonably designed supervisory system, including written supervisory procedures, to comply with its capacity code obligations during the period from May 2018 through November 2020. During the period from October 2019 through March 2020, the firm incorrectly entered over 401,000 orders into the NYSE National marketplace marked with the "agency" capacity code when the orders should have been marked with the "principal" capacity code due to a coding error impacting a firm trading platform (the "oms") that flipped the reported capacity from principal to agency. From May 2018 through November 2020, RBCCM did not have a supervisory system or written supervisory procedures in place that were reasonably designed to confirm that client orders were coded with accurate capacities and thus ensure compliance with NYSE american rules requiring that orders submitted to the exchange are marked with accurate agency or principal capacity codes. Specifically, during the period from October 2019 through March 2020, a field within the firm's surveillance report covering the oms was not correctly populated, resulting in "null" values that prevented the generation of alerts for incorrect capacity codes. The firm's surveillance review was therefore not functioning properly for a period of nearly six months. Additionally, from May 2018 through November 2020, the firm's surveillance review failed to include data from another of its trading platforms, resulting in a failure to detect ongoing capacity code violations that impacted this trading platform for a period of several years.

27. Jun 5, 2023
    Regulatory Action: New York Stock Exchange FinalSanctions: Other · Fine: $185,000 · Begun Jun 5, 2023 · Resolved Jun 5, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2022-03-17-00037

    Without admitting or denying the findings, the firm ("RBCCM") consented to the sanctions and to the entry of findings that during the period between August 2015 and November 2020 (the "relevant period"), it violated: (I) NYSE rule 132 (for certain orders sent before July 27, 2017) and (II) NYSE rule 7.33 (for certain orders sent on or after July 27, 2017) by submitting over 80.1 million agency orders incorrectly marked as principal orders and approximately 333,000 principal orders incorrectly marked as agency orders to the New York Stock Exchange LLC (the "NYSE" or the "exchange"); and (III) NYSE rules 3110(a) and 3110(b) by failing to have a reasonably designed supervisory system, including written supervisory procedures, to comply with its capacity code obligations. During the relevant period, two distinct issues involving two different firm trading platforms resulted in RBCCM incorrectly marking certain principal orders as agency and certain agency orders as principal. First, during the period from August 2015 through November 2020, a failure to update relevant account type code settings on a firm trading platform ("oms #1") resulted in the firm incorrectly entering: (I) over 88,000 orders into the NYSE marketplace marked with the "agency" capacity code when the orders should have been marked with the "principal" capacity code; and (II) over 80.1 million orders into the NYSE marketplace marked with the "principal" capacity code when the orders should have been marked with the "agency" capacity code. Second, during the period from October 2019 through March 2020, the firm incorrectly entered approximately 245,000 orders into the NYSE marketplace marked with the "agency" capacity code when the orders should have been marked with the "principal" capacity code due to a coding error impacting a different firm trading platform ("oms #2") that flipped the reported capacity from principal to agency. The findings also stated that during the relevant period, RBCCM did not have a supervisory system or written supervisory procedures in place that were reasonably designed to confirm that client orders were coded with accurate capacities and thus ensure compliance with NYSE rules requiring that orders submitted to the NYSE are marked with accurate agency or principal capacity codes. Specifically, the firm's surveillance review failed to include data from oms #1 during the entirety of the relevant period, resulting in a failure to detect the ongoing capacity code violations that impacted this trading platform for a period of more than five years. Additionally, during the period from October 2019 through March 2020, a field within the firm's surveillance report covering oms #2 was not correctly populated, resulting in "null" values that prevented the generation of alerts for incorrect capacity codes. The firm's surveillance review was therefore not functioning properly for a period of nearly six months.

28. Jun 5, 2023
    Regulatory Action: FINRA FinalSanctions: Other · Fine: $67,500 · Begun Jun 5, 2023 · Resolved Jun 5, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2020066722501

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it reported to FINRA orders with an inaccurate capacity code. The finding stated that the firm reported principal orders to trade reporting facilities from, among others, three internal accounts. However, the firm incorrectly marked the transactions from these accounts due to a coding error that flipped the reported capacity from principal to agency. As a result, the firm reported orders to the trade reporting facilities with an inaccurate capacity. In addition, the firm sent orders on its own behalf as well as on behalf of certain affiliates using one of its proprietary order management systems. Whether an order should be marked as principal or agency depends on the terms of the agreement between the market center to which the order is routed and the entity on whose behalf the order was being routed. At various times during this period, updates to the relevant agreements required the firm to change the capacity it reported for certain transactions. However, the firm failed to make corresponding updates to the order management system so that the correct capacity would be reported. Because the firm's reporting logic relied on these outdated settings, the firm reported orders to the trade reporting facilities with an inaccurate capacity. The findings stated that the firm had recordkeeping violations due to the order memoranda for the above-referenced transactions including the incorrect capacity. For example, at times the order memoranda indicated that it was a principal transaction when it was an agency transaction, or vice versa. The findings also included that the firm supervised for the accuracy of the order capacities it reported with two exception reports. However, these exception reports did not include transactions from the proprietary order management system the firm used to route orders with an inaccurate capacity. As a result, the firm failed to identify these inaccuracies. The firm has since remediated this supervisory failure.

29. Jun 5, 2023
    Regulatory Action: Investors' Exchange LLC FinalSanctions: Other · Fine: $675,000 · Begun Jun 5, 2023 · Resolved Jun 5, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2020066722502

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm routed orders to iex with an inaccurate capacity code as a result of two separate issues. The findings stated that the firm routed principal orders to iex from, among others, three internal accounts. However, the firm incorrectly marked the transactions from these three accounts due to a coding error that flipped the reported capacity from principal to agency. As a result, the firm routed orders to iex with an inaccurate capacity code. In addition, the firm sent orders on its own behalf as well as on behalf of certain affiliates using one of its proprietary order management systems. Whether an order should be marked as principal or agency depends on the terms of the agreement between the market center to which the order is routed and the entity on whose behalf the order was being routed. At various times during this period, updates to the relevant agreements required the firm to change the capacity it reported for certain transactions. The firm failed, however, to make corresponding updates to the order management system so that the correct capacity would be reported. Because the firm's reporting logic relied on these outdated settings, the firm routed orders to iex with an inaccurate capacity code. The findings also stated that the firm had recordkeeping violations due to the order memoranda for the above referenced transactions including the incorrect capacity code. For example, at times the order memoranda indicated that it was a principal transaction when it was an agency transaction, or vice versa. The findings also included that the firm supervised for the accuracy of the order capacities it reported with two exception reports. However, these exception reports did not include transactions from the order management system the firm used to route orders with an inaccurate capacity code. As a result, the firm failed to identify these inaccuracies. The firm has since remediated the supervisory failure.

30. May 6, 2023
    Regulatory Action: Virginia State Corporation Commission FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Penalty and cost of investigation · Fine: $10,000 · Begun May 26, 2023 · Resolved May 6, 2023 · Settled · Docket SEC-2023-00009

    Federallly covered investment advisor firm RBC Capital Markets, LLC allegedly employed an investment advisor representative in the commonwealth of Virginia without that person being duly registered with the division of securities and retail franchising of the state corporation commission of Virginia, in violation of § 13.1­504 c (II) of the Virginia Securities Act. The representative was registered in another state but moved offices with RBC.

31. Apr 14, 2023
    Regulatory Action: FINRA FinalFine: $300,000 · Begun Apr 14, 2023 · Resolved Apr 14, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2019061442501

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to achieve compliance with its suitability obligations in connection with syndicate preferred stock. The findings stated that while the firm's procedures called for supervisors to closely examine representatives' short-term trading of preferred stocks, the firm's electronic surveillance of short-term trading in preferred stock was unreasonably designed, and it failed to monitor for that activity. Although the surveillance system had certain alerts that specifically monitored for short-term trading in other products, such as closed-end funds, it did not have any alerts that specifically monitored for short-term trading in preferred stock. The firm also did not have any other alerts that flagged the purchase and sale within 180 days of syndicate preferred stock. Registered representatives at the firm recommended a number of the firm's retail customers purchase syndicate preferred stocks, and then sell the positions within 180 days, and the customers sustained losses on these transactions. The firm earned $653,313 in selling concessions from the syndicate purchases and $128,643 in sales commissions from the subsequent sales. The firm conducted a substantial syndicate preferred stock business yet did not maintain a reasonable supervisory system to monitor whether its representatives recommended short-term trading of syndicate preferred securities that was unsuitable, including for the purpose of capturing sales concessions and commissions. While the firm's procedures called for supervisors to closely examine whether brokers were engaging in short-term trading of preferred stocks, the firm did not implement a supervisory system reasonably designed to monitor for that trading activity. The firm used its automated surveillance system to monitor trading, but employed no alerts specific to preferred stocks, and its more general alerts were not sufficiently reasonably tailored to monitor for potentially unsuitable short-term trading of preferred stock.

32. Oct 31, 2022
    Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $360,000 · Begun Oct 31, 2022 · Resolved Oct 31, 2022 · Acceptance, Waiver & Consent(AWC) · Docket 2020067000501

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to have in place a supervisory system, including WSPS, reasonably designed to timely review paper statements from employees' outside brokerage accounts. The findings stated that the firm had no prescribed timeframe to track, reconcile, and review statements. Due to the manual nature of the paper statement review process, personnel turnover, and outdated technology systems, the firm had a backlog of approximately 8,950 unreviewed account statements. In addition, the firm manually tracked receipt of paper statements, had no system in place to notify the firm or employees that statements were missing, and had no procedure for following up on missing statements. In some instances, the firm did not receive paper statements for review. In addition, the firm's process to review paper statements was not reasonably designed. As a result, the firm failed to timely or reasonably monitor thousands of employee outside brokerage account statements for compliance with the firm's trading restrictions, including pre-clearance, holding period, and watch and restricted list policies.

33. Jun 7, 2022
    Regulatory Action: CBOE Exchange, Inc FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $90,000 · Begun Jun 7, 2022 · Resolved Jun 7, 2022 · Consent · Docket FILE NO. USRI-9504-01/URE-27-01/STAR NO. 20190639291-01

    RBC Capital Markets, LLC violated CBOE rules 4.1 and 6.9 in that the firm by and through its associated person entered an order in the same options class prior to the public disclosure of the original customer order's terms and conditions.

34. Feb 17, 2022
    Regulatory Action: CBOE BZX Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $25,500 · Begun Feb 17, 2022 · Resolved Feb 17, 2022 · Settled · Docket NO. USRI-9864-05

    From in or about August 2015 through November 2020 (the "review period"), the firm entered approximately 36,122,470 orders on BZX marked with the principal capacity code when they should have been marked with the agency 3 capacity code. Additionally, during the review period, the firm entered approximately 13,068,439 orders on BZX marked with the agency capacity code when they should have been marked with the principal capacity code. As a result, the firm's books and records contained inaccurate information as to the correct capacity on each order.

35. Feb 17, 2022
    Regulatory Action: CBOE Byx Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $8,500 · Begun Feb 17, 2022 · Resolved Feb 17, 2022 · Settled · Docket NO. USRI-9864-06

    From in or about August 2015 through November 2020 (the "review period"), the firm entered approximately 217,214 orders on byx marked with the agency capacity code when they should have been marked with the principal capacity code. As a result, the firm's books and records contained inaccurate information as to the correct capacity on each order.

36. Feb 17, 2022
    Regulatory Action: CBOE Edgx Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $25,500 · Begun Feb 17, 2022 · Resolved Feb 17, 2022 · Settled · Docket NO. USRI-9864-07

    From in or about aug 2015 thru nov 2020("review period"),the firm entered APPROX.35,507,601 orders on edgx marked with the prin capacity code when they should have been marked with the agency capacity code.additionally, during the review period,the firm entered APPROX.13,039,931 orders on edgx marked with the agency capacity code when they should have been marked with the prin capacity code.as a result,the firm's books and records contained inaccurate information as to the correct capacity on each order.

37. Feb 17, 2022
    Regulatory Action: CBOE Edga Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $25,500 · Begun Feb 17, 2022 · Resolved Feb 17, 2022 · Settled · Docket NO. USRI-9864-08

    From in or about aug 2015 - nov 2020(the "review period"),the firm entered approx 31,079,479 orders on edga marked with the prin capacity code when they should have been marked with the agency capacity code.additionally,during the review period, the firm entered approx 10,293,131 orders on edga marked with the agency capacity code when they should have been marked with the prin capacity code.as a result,the firm's books and records contained inaccurate information as to the correct capacity on each order.

38. Dec 31, 2021
    Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $2.6M · Begun Dec 29, 2021 · Resolved Dec 31, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2017054718901

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to report, and inaccurately reported, over-the-counter (OTC) options positions to the large options positions reporting system (LOPR). The findings stated that these violations were caused by errors in the reporting logic of the firm's internal risk system that it used to compile and submit OTC LOPR reports and it remained undetected for years. The findings also stated that the firm failed to establish and maintain a supervisory system reasonably designed to comply with its LOPR reporting obligations. The firm used supervisory systems to detect inaccurate LOPR reports. Those systems were not designed to detect, and in fact did not detect, instances where the firm failed to report OTC options positions to the LOPR. Further, the firm had no system to review whether contract quantities were reported accurately. In addition, the firm's WSPS identified firm principals who were responsible for conducting supervisory reviews of the firm's LOPR reports, but these procedures did not provide any guidance or set forth a process for how these principals should detect instances where the firm failed to report OTC options positions to the LOPR or to confirm the accuracy of reported contract quantities. Ultimately, the firm implemented multiple new surveillance reports and procedures to determine whether its reportable OTC positions had been reported and were accurate.

39. Dec 15, 2021
    Regulatory Action: FINRA FinalFine: $550,000 · Begun Dec 15, 2021 · Resolved Dec 15, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2017054432703

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPS), reasonably designed to achieve compliance with FINRA and municipal securities rulemaking board (MSRB) rules with respect to representatives' recommendations of high-yield corporate and municipal bonds. The findings stated that the firm's policies and procedures did not sufficiently address the suitability factors that representatives should consider before recommending high-yield bonds. The procedures did not include guidance as to how much of a customer's portfolio should be in vested in these products based on the customer's investor profile. The findings also stated that the firm used two automated alerts, a daily alert and a monthly alert, to identify potentially unsuitable concentrations of high-yield bonds in customer accounts, but neither alert functioned as intended. After the firm changed the tax coding of municipal bonds in its system, it inadvertently disabled the ability of the high-yield bond alerts to identify potential concentration issues for further assessment. The firm did not detect that these alerts were not working, in part, because the firm did not test its alerts. Once the firm first discovered that the alerts were defective, it did not fix the alerts until ten months later. During this ten-month period, the firm did not adopt alternative measures to identify potentially unsuitable concentrations in high-yield bonds. The firm also did not notify supervisors that the alerts were not working as intended and that they could not rely on the alerts for their review. As a result, the firm failed to review more than 100 customer accounts with conservative profiles for potentially unsuitable concentrations of high-yield bonds. In a number of those accounts, the holdings in high-yield bonds were more than six times the thresholds set by the firm.

40. Dec 10, 2021
    Regulatory Action: Louisiana Department of Insurance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $250 · Begun Dec 10, 2021 · Resolved Dec 10, 2021 · Settled · Docket N/A

    RBC Capital Markets, LLC. failed to timely report administrative actions in violation of l.a.r.s 22:1563(a).

    Form BD amendments which were submitted and on file with FINRA were not uploaded to insurance national insurance producer registry attachment wharehouse in a timely manner.

41. Oct 11, 2021
    Regulatory Action: NYSE American LLC FinalFine: $250,000 · Begun Oct 11, 2021 · Resolved Oct 11, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2020-01-00098

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to create, maintain, and preserve accurate records of manual customer orders routed to the NYSE American options floor (the "american options floor"). The findings stated that the firm failed to accurately make and keep current order memoranda reflecting the price and transmission times for institutional customer orders that it routed to the american options floor. These inaccuracies resulted from the fact that when routing orders to the american options floor, the firm's proprietary order management system transmitted as the price of the orders a snapshot of the market at the time, rather than the actual price at which the firm wanted to trade. Firm traders would then contact NYSE American floor brokers through communication channels (some but not all of which it has retained) with the true price once it had been agreed upon with its institutional customer. However, the firm did not make or keep current order memoranda of these true prices or the time at which it transmitted them to the american options floor for execution. Second, the electronic transmission times recorded by the firm and produced to NYSE regulation were inaccurate. Third, the firm routinely recorded manually received institutional customer options orders as having a price of MKT, for market order, despite the firm having agreed to a specific price with its institutional customer. The firm failed to make or keep current order memoranda reflecting this agreed-upon price. The findings also stated that the firm failed to establish and maintain a supervisory system reasonably designed to ensure compliance with its books and records obligations. Specifically, the firm failed to maintain a reasonably designed supervisory system to ensure the creation and retention of accurate records for manual options orders, including: (I) the prices of orders that it transmitted to the american options floor for execution; (II) the time at which it transmitted orders to the american options floor for execution; and (III) the prices of the orders it received from its institutional customers. The firm failed to remedy the books and records violations noted above despite, among other things, discussions with NYSE regulation identifying potential inaccuracies.

42. Sep 17, 2021
    Regulatory Action: SEC FinalSanctions: Cease and Desist · Fine: $150,000 · Begun Sep 17, 2021 · Resolved Sep 17, 2021 · Order · Docket 3-20568

    It is alleged that from 2014-2017, RBC Capital Markets LLC engaged in improper conduct in connection with the allocation, purchase and sale of certain new issue municipal bond offerings in violation of internal procedures, as well as MSRB and SEC rules.

    RBC submitted an offer of settlement, which the commission accepted and published on September 17, 2021. The SEC order found that as a result of the negligent conduct and its willful violations of MSRB rules G-11(k), G-17 and G-27, RBC willfully violated section 15b(c)(1) of the Exchange Act. The SEC order found that RBC also caused violations of section 15(a)(1) of the Exchange Act. The SEC ordered that the RBC cease and desist from committing or causing any violations and any future violations of sections 15(a)(1) and 15b(c)(1) of the Exchange Act; is censured; shall pay disgorgement of $552,440, prejudgment interest of $160,886.97 on disgorgement, and a civil money penalty of $150,000 to the commission. The payments were made by RBC on September 22, 2021.

43. Sep 8, 2021
    Regulatory Action: Virginia State Corporation Commission FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); $10,000 civil penalty · Fine: $10,000 · Begun Jun 4, 2021 · Resolved Sep 8, 2021 · Settled · Docket SEC-2021-00027

    The Virginia State Corporation Commission alleged that, from December 1, 2017 through November 27, 2020, RBC employed an investment advisor representative (IAR) who was registered in the District of Columbia but not Virginia and that RBC failed to enforce its written supervisory procedures regarding IAR registration.

    On September 8, 2021, RBC executed the settlement order which states that RBC neither admits nor denies the Virginia State Corporation Commission's allegations.

44. Jul 26, 2021
    Regulatory Action: New York Mercantile Exchange FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $45,000 · Begun Jul 26, 2021 · Resolved Jul 26, 2021 · Settled · Docket NYMEX 20-1311-BC

    A panel of the NYMEX business conduct committee ("BCC panel") found that on multiple occasions during March 2020, RBC submitted block trades in crude oil and natural gas futures to the exchange outside the reporting time requirements, submitted inaccurate block trade execution times to the exchange on one or more occasion, and also failed to properly advise and train its brokers as to relevant exchange rules and market regulation advisory notices ("MRANS") in a manner sufficient to ensure compliance with the exchange's block trade reporting rules.

45. Jul 6, 2021
    Regulatory Action: New York Stock Exchange FinalFine: $10,000 · Begun Jun 23, 2021 · Resolved Jul 6, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2020-04-00115

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it violated NYSE rule 3110(a) and (b) (supervision) by failing to establish and maintain a supervisory system and written supervisory procedures reasonably designed to detect and prevent errors in market on close (MOC) orders. The findings stated that on April 24, 2020, the firm entered a MOC basket order on behalf of its U.S. broker-dealer affiliate that mistakenly included approximately 300,000 shares across 476 exchange traded fund (ETF) component securities. The firm's affiliate broker-dealer utilizes the firm's NYSE membership and connectivity in order to gain access to the NYSE exchange. In connection with their ETF market making responsibilities, traders at the firm's affiliate may route MOC basket orders to hedge their existing exposure. On the review date, a trader mistakenly included an ETF that the firm did not need to hedge against when manually adding components into an excel macro script that is used to identify all underlying component securities that needed to be entered for that day's order. As a result, the firm routed to the NYSE a basket containing incorrect ETF component securities which the firm did not intend to execute during the closing auction. The desk responsible for generating the MOC basket did not recognize that the ETF component securities were erroneously included before entering the order and routing it to market. After the 3:50 PM cut-off time specified in NYSE rule 7.35b, but prior to the closing cross, the desk recognized its error and cancelled the basket. The firm failed to detect and prevent the error in the underlying MOC basket. Although the firm had the ability to review the components input into the firm's excel script and the generated MOC basket for errors before releasing it to market, they nonetheless were not able to catch this error in time, and there was no other check in place to alert the firm to the manual error. The firm also failed to maintain updated written supervisory procedures (WSPS) that accurately reflected the appropriate cut-off time of 3:50 PM for the cancellation of MOC orders; instead, the firm's WSPS reflected an outdated cut-off time of 3:45 PM. In addition, the firm failed to enable appropriate risk management controls to ensure against improper MOC order cancellations after the prescribed cut-off time. During the firm's migration to NYSE's pillar platform, its soft warning and hard block functionalities, which would alert the firm to potentially improper MOC order cancellations, became disabled for more than six months. Further, the firm failed to detect errors in its surveillance system that prevented the firm from being alerted to MOC orders canceled after the applicable cut-off time. Due to errors in an overlay file used to generate alerts for the firm's surveillance of MOC orders canceled after the applicable cut-off time, which was caused by an internal system update in October 2018, the firm's surveillance system was unable to generate alerts for potentially improper MOC cancellations until the error was discovered and corrected in July 2020, and the cancellation of the MOC basket was not identified as a potential exception for further review by supervision during the firm's t+1 review process.

46. Mar 30, 2021
    Regulatory Action: CBOE Edgx Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $45,000 · Begun Feb 22, 2021 · Resolved Mar 30, 2021 · Consent · Docket STAR NO. 20170565048-04, FILE NO. USRI-7375-07

    RBC Capital Markets, LLC violated rule 15C3-5(b) and (c)(1)(II) and edgx rules 3.2 and 5.1 in that the firm's financial risk management controls and supervisory procedures were not reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or that indicate duplicative orders.

47. Mar 30, 2021
    Regulatory Action: CBOE Byx Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $70,000 · Begun Feb 22, 2021 · Resolved Mar 30, 2021 · Consent · Docket STAR NO. 20170565048-03, FILE NO. USRI-7375-06

    BC capital markets, LLC violated rule 15C3-5(b) and (c)(1)(II) and byx rules 3.2 and 5.1 in that the firm's financial risk management controls and supervisory procedures were not reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or that indicate duplicative orders.

48. Mar 30, 2021
    Regulatory Action: CBOE Edga Exchange, Inc. FinalFine: $45,000 · Begun Feb 22, 2021 · Resolved Mar 30, 2021 · Consent · Docket STAR NO. 20170565048-01, FILE NO. USRI-7375-08.

    RBC Capital Markets, LLC violated rule 15C3-5(b) and (c)(1)(II) and edga rules 3.2 and 5.1 in that the firm's financial risk management controls and supervisory procedures were not reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or that indicate duplicative orders.

49. Mar 30, 2021
    Regulatory Action: CBOE BZX Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $45,000 · Begun Feb 22, 2021 · Resolved Mar 30, 2021 · Consent · Docket STAR NO. 20170565048-02, FILE NO. USRI-7375-05

    RBC Capital Markets, LLC violated rule 15C3-5(b) and (c)(1)(II) and BZX rules 3.2 and 5.1 in that the firm's financial risk management controls and supervisory procedures were not reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or that indicate duplicative orders.

50. Mar 5, 2021
    Regulatory Action: Nasdaq Stock Market FinalFine: $145,000 · Begun Mar 5, 2021 · Resolved Mar 5, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2015045017001

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that its market access risk management controls and supervisory procedures were not reasonably designed to manage the financial and regulatory risks of the firm's market access business on the exchange. The findings stated that the firm failed to implement market access controls to its convertibles desk's order flow routed to the market. Therefore, the firm's financial and regulatory risk management controls and supervisory procedures for the convertibles desk were not reasonably designed to address the risks presented by the desk's market access business activity, in violation of Securities Exchange Act rule 15C3-5(b), (c)(1), and (c)(2). The findings also stated that the firm's financial risk management controls and supervisory procedures for its cash, electronic sales and trading, and exchange-traded fund lead market making desks were not reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or that indicate duplicative orders, in violation of rule 15C3-5(b) and (c)(1)(II). The findings also included that the firm's market access rule supervisory system and WSPS were unreasonable. As a result of the deficiencies described above, the firm violated Nasdaq rules 3010 and 2010a.

51. Feb 2, 2021
    Regulatory Action: Massachusetts Securities Division FinalSanctions: Restitution; Cease and desist, censure, review of supervisory procedures, engagement of independent compliance consultant, disgorgement, · Fine: $200,000 · Begun May 19, 2020 · Resolved Feb 2, 2021 · Consent · Docket E-2019-0117

    The division alleges that RBC failed to adequately supervise its representatives with respect to concentration and suitability of MLP and telecom positions in certain client accounts.

    RBCCM notes that in agreeing to the order RBCCM did not admit to any supervisory deficiencies and believe that the customers' account investments were appropriately supervised and were consistent with their stated investment goals and financial circumstances as well as RBCCM's policies. The customer accounts generated substantial income for the customers that exceed the commissions charged. After 50 years in the financial services industry, the registered representative voluntarily retired in 2020 having been the subject of only one customer complaint throughout his 50 year career, nor was he the subject of any prior regulatory discipline. RBCCM and the registered representative settled this matter in the interests of customer relations and to avoid the costs, uncertainties and distractions associated with litigation.

52. Dec 15, 2020
    Regulatory Action: FINRA FinalResolved Dec 15, 2020 · Acceptance, Waiver & Consent(AWC) · Docket 2016047696701

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to supervise representatives' recommendations to customers to purchase particular share classes of 529 college savings plans. The findings stated that the firm did not provide adequate guidance to representatives regarding the importance of considering share-class differences when recommending 529 plans. The firm had no procedures requiring supervisors to review 529 plan share-class recommendations for suitability. The firm updated its procedures to include such a requirement, but the updated procedures failed to adequately instruct supervisors to consider either the age of the beneficiary or the number of years until expected withdrawals, both critical factors in determining the suitability of the recommended share class. Also, the firm did not consistently provide supervisors with the information necessary to review the suitability of 529 plan share-class recommendations. Later, the firm issued a company-wide compliance alert that provided guidance to representatives regarding 529 plan share-class recommendations. The firm then updated its supervisory systems and procedures with respect to 529 share-class recommendations. Among other things, the firm instructed supervisors to consider the age of the beneficiary when assessing the suitability of a representative's 529 share- class recommendation. The firm has agreed to pay restitution and interest relating to the sale of class c shares to certain 529 plan customers in the estimated amount of $839,803.

53. Aug 21, 2020
    Regulatory Action: Chicago Mercantile Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $50,000 · Begun Jun 12, 2020 · Resolved Aug 21, 2020 · Decision & Order of Offer of Settlement

    The clearing house risk committee of the Chicago Mercantile Exchange alleged that the firm violated CME rule 971.A.1.

54. May 19, 2020
    Regulatory Action: Massachusetts Securities Division PendingSanctions: Restitution; Cease and desist, censure, review of supervisory procedures, engagement of independent compliance consultant, disgorgement, · Begun May 19, 2020 · Docket E-2019-0117

    The division alleges that RBC failed to adequately supervise its representatives with respect to concentration and suitability of MLP and telecom positions in certain client accounts.

55. Apr 24, 2020
    Regulatory Action: SEC FinalSanctions: Cease and Desist · Fine: $650,000 · Begun Apr 24, 2020 · Resolved Apr 24, 2020 · Order · Docket 3-19769

    The commission finds that from at least July 2012 through August 2017 (the "relevant period"), RBC disadvantaged certain retirement plan and charitable organization brokerage customers who maintained accounts at RBC ("eligible customers") by failing to ascertain that they were eligible for a less expensive share class, and recommending and selling them more expensive share classes in certain open-end registered investment companies ("mutual funds") when less expensive share classes were available. RBC did so without disclosing that it would receive greater compensation from the eligible customers' purchases of the more expensive share classes. Eligible customers did not have sufficient information to understand that RBC had a conflict of interest resulting from compensation it received for selling the more expensive share classes. Specifically, RBC recommended and sold these eligible customers class a shares with an up-front sales charge, or class b or class c shares with a back-end contingent deferred sales charge ("CDSC") (a deferred sales charge the purchaser pays if the purchaser sells the shares during a specified time period following the purchase) and higher ongoing fees and expenses, when these eligible customers were eligible to purchase load-waived class a and/or no-load class r shares. RBC omitted material information concerning its compensation when it recommended the more expensive share classes. RBC also did not disclose that the purchase of the more expensive share classes would negatively impact the overall return on the eligible customers' investments, in light of the different fee structures for the different fund share classes. In making those recommendations of more expensive share classes while omitting material facts, RBC violated sections 17(a)(2) and 17(a)(3) of the Securities Act. These provisions prohibit, respectively, in the offer or sale of securities, obtaining money or property by means of an omission to state a material fact necessary to make statements made not misleading, and engaging in a course of business which operates as a fraud or deceit on the purchaser. As a result of the conduct described above, RBC willfully violated sections 17(a)(2) and 17(a)(3) of the Securities Act.

    RBC has submitted an offer of settlement, which the commission has determined to accept. RBC willfully violated sections 17(a) (2) and 17(a)(3) of the Securities Act. Accordingly, it is ordered that respondent cease and desist from committing or causing any violations and any future violations of sections 17(a)(2) and 17(a)(3) of the Securities Act. Respondent is censured and shall pay disgorgement of $2,607,676 with prejudgment interest of $631,331, plus a civil monetary penalty of $650,000.

56. Dec 2, 2019
    Regulatory Action: NYSE ARCA, Inc. FinalSanctions: Other; N/a · Fine: $15,300 · Begun Dec 2, 2019 · Resolved Dec 2, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2016048771304

    Without admitting or denying the findings, RBC Capital Markets, LLC ("RBC", the "firm", or "respondent") consented to the sanctions and to the entry of findings that RBC failed to accurately record the order receipt and/or order transmission times of manual options orders it had routed to floor brokers at the exchange and various other national securities exchanges for execution. The findings stated that RBC's written supervisory procedures (WSPS)and supervisory system applicable to the handling of manual options orders by its global equity linked products desk (the gelp desk) and by its wealth management options desk (the WM desk) were not reasonably designed. That is, they were not reasonably designed to achieve compliance with, and to detect and prevent, insofar as practicable, violations of, the applicable recordkeeping provisions of the federal securities laws and the exchange rules.

57. Dec 2, 2019
    Regulatory Action: Nasdaq PHLX LLC FinalSanctions: Other; N/a · Fine: $15,300 · Begun Dec 2, 2019 · Resolved Dec 2, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2016048771301

    Without admitting or denying the findings, RBC Capital Markets, LLC ("RBC", the "firm", or "respondent") consented to the sanctions and to the entry of findings that RBC failed to accurately record the order receipt and/or order transmission times of manual options orders it had routed to floor brokers at the exchange and various other national securities exchanges for execution. The findings stated that RBC's written supervisory procedures (WSPS) and supervisory system applicable to the handling of manual options orders by its global equity linked products desk (the gelp desk) and by its wealth management options desk (the WM desk) were not reasonably designed. That is, they were not reasonably designed to achieve compliance with, and to detect and prevent, insofar as practicable, violations of, the applicable recordkeeping provisions of the federal securities laws and the exchange rules.

58. Dec 2, 2019
    Regulatory Action: Nasdaq Stock Market - the Nasdaq Options Market LLC FinalSanctions: Other; N/a · Fine: $15,300 · Resolved Dec 2, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2016048771302

    Without admitting or denying the findings, RBC Capital Markets, LLC ("RBC", the "firm", or "respondent") consented to the sanctions and to the entry of findings that RBC failed to accurately record the order receipt and/or order transmission times of manual options orders it had routed the Nasdaq options market and various other national securities exchanges for execution. The findings stated that RBC's written supervisory procedures (WSPS)and supervisory system applicable to the handling of manual options orders by its global equity linked products desk (the gelp desk) and by its wealth management options desk (the WM desk) were not reasonably designed. That is, they were not reasonably designed to achieve compliance with, and to detect and prevent violations of, the applicable recordkeeping provisions of the federal securities laws and the exchange rules.

59. Dec 2, 2019
    Regulatory Action: NYSE American LLC FinalSanctions: Other; N/a · Fine: $15,300 · Begun Dec 2, 2019 · Resolved Dec 2, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2016048771303

    Without admitting or denying the findings, RBC Capital Markets, LLC ("RBC", the "firm", or "respondent") consented to the sanctions and to the entry of findings that RBC failed to accurately record the order receipt and/or order transmission times of manual options orders it had routed to floor brokers at the exchange and various other national securities exchanges for execution. The findings stated that RBC's written supervisory procedures (WSPS)and supervisory system applicable to the handling of manual options orders by its global equity linked products desk (the gelp desk) and by its wealth management options desk (the WM desk) were not reasonably designed. That is, they were not reasonably designed to achieve compliance with, and to detect and prevent violations of, the applicable recordkeeping provisions of the federal securities laws and the exchange rules.

60. Oct 29, 2019
    Regulatory Action: Nasdaq Stock Market FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $37,500 · Begun Mar 31, 2019 · Resolved Oct 29, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2019.04.0041

    Without admitting or denying the findings, RBC Capital Markets, LLC (the "firm") consented to the sanctions and to the entry of findings that during the period February 14, 2017 through December 31, 2017, the firm violated Nasdaq rules 4613(a), 3010 and 2010a.

61. Oct 23, 2019
    Regulatory Action: CBOE BZX Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $9,000 · Begun Oct 23, 2019 · Resolved Oct 23, 2019 · Consent · Docket STAR NO. 20160487713, FILE NO. USE-1710

    Without admitting or denying the findings, RBC Capital Markets, LLC ("RBC", the "firm", or "respondent") consented to the sanctions and to the entry of findings that RBC failed to accurately record the order receipt and/or order transmission times of manual options orders it had routed to floor brokers at the exchange and various other national securities exchanges for execution. The findings stated that RBC's written supervisory procedures (WSPS)and supervisory system applicable to the handling of manual options orders by its global equity linked products desk (the gelp desk) and by its wealth management options desk (the WM desk) were not reasonably designed. That is, they were not reasonably designed to achieve compliance with, and to detect and prevent violations of, the applicable recordkeeping provisions of the federal securities laws and the exchange rules.

62. Oct 18, 2019
    Regulatory Action: CBOE Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $27,000 · Begun Oct 18, 2019 · Resolved Oct 18, 2019 · Consent · Docket USE-1710 / STAR NO. 20160487713

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm (I) failed to record accurate order receipt times for ten of the twenty sampled manual customer option orders reviewed that were routed to and executed on CBOE; (II) failed to record accurate order transmission times for eight of the twenty sampled manual customer options orders reviewed that were routed to and executed on CBOE; (III) failed to record an accurate order receipt time for one of twenty-one sampled manual customer option orders that were routed to and executed (or partially executed) on CBOE; and (IV) failed to establish, maintain and enforce written supervisory procedures, and a system for applying such procedures, reasonably designed to prevent and detect violations of CBOE rule 15.1; and section 17(a) of the Exchange Act and rule 17A-3 thereunder, in connection with the conduct described. Violation of exchange rules 4.2, 4.24 and 15.1; section 17(a) of the Securities Exchange Act of 1934, as amended and rule 17A-3, thereunder. Sanction: a censure and a monetary fine of $27,000.

63. Oct 17, 2019
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.9M · Begun Oct 17, 2019 · Resolved Oct 17, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2015046652401

    Without admitting or denying the findings, the firm entered into a letter of acceptance, waiver and consent with FINRA that found that from March 2008 to June 2016, the firm failed to deliver prospectuses to customers in connection with approximately 165,000 ETF and etn purchases and at least hundreds of thousands of mutual fund purchases. The AWC also found that the firm failed to design, implement, and enforce a reasonable supervisory system, controls and procedures to comply with the prospectus delivery rules for ETFS, etns and mutual funds. RBC failed to have in place a system to supervise its manual coding of software to trigger the delivery of an ETF or etn prospectus. Although the firm instituted a surveillance procedure to identify prospectus delivery coding issues after discovering certain coding errors, RBC failed to properly implement that process. With respect to mutual funds, RBC relied upon third-party software to automatically code mutual fund purchases for prospectus delivery. Due to a design flaw, the software did not code certain mutual fund purchases for prospectus delivery as required. RBC's supervisory system included a written procedure to designate an employee to conduct periodic supervisory reviews to determine whether mutual funds were properly coded for prospectus delivery. The firm did not assign these supervisory duties. Therefore, these duties were not performed during the relevant period. As a result, issues with the coding was not discovered until FINRA's investigation in this matter. RBC failed to perform an audit, review or other testing to verify that it was delivering prospectuses. The firm also did not test the system modifications and surveillance procedures put in place to address the ETF and etn coding errors it had previously discovered. In determining the appropriate sanction in this matter, FINRA took into account (I) the firm's prior disciplinary history; (II) the more than eight years over which the violations occurred; (III) the extent of the supervisory deficiencies; (IV) the lack of supervisory controls and testing; (v) that the firm voluntarily undertook a comprehensive review of its ETF and etn prospectus delivery processes upon discovery of the issues and disclosed its findings from that exercise to FINRA; (VI) the firm's extensive testing of its non-ETF/etn prospectus delivery processes to assist FINRA in understanding the scope of the issue; and (VII) certain firm corrective actions cited in the settlement.

64. Oct 2, 2019
    Regulatory Action: Nasdaq PHLX LLC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $7,138 · Begun Oct 2, 2019 · Resolved Oct 2, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2016050933606

    Without admitting or denying the findings, RBC capital makets, LLC ("RBC" or the "firm") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.

65. Oct 2, 2019
    Regulatory Action: Nasdaq Stock Market -The Nasdaq Options Market FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5,687 · Begun Oct 2, 2019 · Resolved Oct 2, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2016050933605

    Without admitting or denying the findings, RBC capital makets, LLC ("RBC" or the "firm") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.

66. Oct 2, 2019
    Regulatory Action: Nasdaq Ise, LLC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $6,721 · Begun Oct 2, 2019 · Resolved Oct 2, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2016050933604

    Without admitting or denying the findings, RBC capital makets, LLC ("RBC" or the "firm") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.

67. Oct 2, 2019
    Regulatory Action: CBOE BZX Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $28,271 · Begun Oct 2, 2019 · Resolved Oct 2, 2019 · Consent · Docket USRI-7935: STAR NO. 20160509336

    Without admitting or denying the findings, RBC capital makets, LLC ("RBC" or the "firm") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.

68. Sep 30, 2019
    Regulatory Action: CFTC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.0M · Begun Sep 30, 2019 · Resolved Sep 30, 2019 · Order · Docket 19-47

    It is alleged that the firm engaged in at least 385 non-competitive, fictitious wash exchange-for-physical transactions. It is further alleged that the firm failed to meet supervisory obligations, resulting in additional violations include failures to prepare and timely file quarterly risk exposure reports, failures to disclose material non-compliance issues, and failures to maintain and timely produce required records.

69. Sep 30, 2019
    Regulatory Action: NYSE ARCA, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5,509 · Begun Sep 30, 2019 · Resolved Sep 30, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2016050933608

    Without admitting or denying the findings, RBC capital makets, LLC ("RBC" or the "firm") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.

70. Sep 30, 2019
    Regulatory Action: NYSE American LLC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $4,098 · Begun Sep 30, 2019 · Resolved Sep 30, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2016050933607

    Without admitting or denying the findings, RBC capital makets, LLC ("RBC" or the "firm") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.

71. Aug 28, 2019
    Regulatory Action: CBOE Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $36,592 · Begun Aug 22, 2019 · Resolved Aug 28, 2019 · Consent · Docket USRI-7935 / STAR NO. 20160509336

    Without admitting or denying the findings, RBC capital makets, LLC ("RBC" or the "firm") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.

72. Aug 28, 2019
    Regulatory Action: CBOE C2 Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5,984 · Begun Aug 22, 2019 · Resolved Aug 28, 2019 · Consent · Docket USRI-7935 / STAR NO. 20160509336

    Without admitting or denying the findings, RBC capital makets, LLC ("RBC" or the "firm") consented to the sanctions and to the entry of findings that the firm entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of the firm. The findings stated that the firm ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In additon to the foregoing, for the calendar year 2018, RBC conducted eleven of twelve monthly origin code reviews late. RBC failed to enforce its procedures requiring timely origin code reviews.

73. May 7, 2019
    Regulatory Action: CBOE Edga Exchange, Inc. FinalFine: $3,000 · Begun Apr 8, 2019 · Resolved May 7, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2017055792103

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take reasonable steps to establish that certain of the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in Exchange Act rule 600(b)(30) leading to conduct in violation of rule 611(c). The findings state that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the exchange, concerning ISOS that complied with the SEC's regulation NMS.

74. May 7, 2019
    Regulatory Action: CBOE BZX Exchange, Inc FinalFine: $15,000 · Begun Apr 8, 2019 · Resolved May 7, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2017055792102

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take reasonable steps to establish that certain of the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in Exchange Act rule 600(b)(30) leading to conduct in violation of rule 611(c). The findings state that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the exchange, concerning ISOS that complied with the SEC's regulation NMS.

75. May 7, 2019
    Regulatory Action: CBOE Edgx Exchange, Inc. FinalFine: $12,000 · Begun Apr 8, 2019 · Resolved May 7, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2017055792101

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take reasonable steps to establish that certain of the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in Exchange Act rule 600(b)(30) leading to conduct in violation of rule 611(c). The findings state that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the exchange, concerning ISOS that complied with the SEC's regulation NMS.

76. Mar 11, 2019
    Regulatory Action: SEC FinalSanctions: Other; N/a · Begun Mar 11, 2019 · Resolved Mar 11, 2019 · Order · Docket 3-19101

    The SEC alleged that RBCCM, during the period January 1, 2014 through March 27, 2017, failed to make adequate disclosures, in its form ADV or otherwise, regarding its mutual fund share class selection practices, and the 12B-1 fees it received, in connection with advisory account transactions. Specifically, at times during the relevant period, RBCCM purchased, recommended or held in advisory accounts mutual fund share classes that charged 12B-1 fees instead of lower-cost share classes in the same fund. The SEC alleged that RBCCM failed to adequately disclose the receipt of the 12B-1 fees and the conflict created thereby, thereby allegedly willfully violating sections 206(2) and 207 of the Investment Advisers Act.

    The firm has submitted an offer of settlement which the commission has determined to accept. In view of the foregoing, the commission deems it appropriate in the public interest to impose the sanctions agreed to in the respondent's offer. Respondent self-reported to the commission the violations discussed in this order pursuant to the division of enforcement's share class selection disclosure initiative ("SCSD initiative"). Accordingly, this order and respondent's offer are based on the information self-reported by respondent.

77. Nov 8, 2018
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $215,000 · Begun Nov 8, 2018 · Resolved Nov 8, 2018 · Acceptance, Waiver & Consent(AWC) · Docket 2013039211801

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that during the period of January 1, 2014 through April 5, 2016, the firm's supervisory system was not reasonably designed to account for the multi-day approach, which is utilized to calculate credit toward the firm's close-out and delivery obligations. The firm's deficient supervisory system allowed numerous violations of rule 204 of Regulation SHO to go undetected. The findings also provided that the firm failed to close out the fail-to-deliver positions in accordance with rule 204 of Regulation SHO during the periods of June 1, 2013 through September 30, 2013, October 1, 2014 through December 31, 2014, and January 1, 2016 through June 2, 2016. Third, the findings provided that the firm had a fail-to-deliver position at a registered clearing agency in an equity security and did not close out the fail-to-deliver positions by purchasing or borrowing securities of like kind and quantity within the time prescribed by rule 204(a) of Regulation SHO, and FINRA rule 2010. The department of enforcement found that the firm violated NASD rule 3010 (for conduct prior to December 1, 2014) and FINRA rule 3110 (for conduct on or after December 1, 2014), rule 204(a) of Regulation SHO of the Exchange Act, and FINRA rule 2010.

78. Aug 30, 2018
    Regulatory Action: Chicago Board Options Exchange, Incorporated FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $75,000 · Begun Jun 21, 2018 · Resolved Aug 30, 2018 · Consent · Docket 18-0012/20160498080

    It was alleged that on two settlement dates the firm entered sell-side orders prior to the cut-off time for participation in the special opening quotation and subsequently changed its orders through submission of buy-side orders after the cut-off time which is violation of CBOE rule 6.2b. It was further alleged that the firm violated CBOE rule 4.2 for failing to supervise its associated persons to assure compliance with exchange rule 6.2b for failing to establish and maintain adequate supervisory procedures for compliance with exchange rule 6.2b.

79. Jun 29, 2018
    Regulatory Action: Chicago Mercantile Exchange FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $50,000 · Begun Jun 29, 2018 · Resolved Jun 29, 2018 · Settled · Docket 18-CH-1804

    The clearing house risk committee of the Chicago merchantile exchange alleged that the firm violated CME rule 971.A.1.

80. Jun 13, 2018
    Regulatory Action: CBOE Futures Exchange, LLC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $50,000 · Begun Jun 13, 2018 · Resolved Jun 13, 2018 · Consent · Docket 18-0002

    Without admitting or denying the findings, it was alleged that the firm violated cfe rules 401a, 412b(a) and 609. On numerous dates from May 2016 through May 2017, due to a third party service provider programming error and a failure to follow its own written procedures, the firm reported inaccurate open interest in various VX weekly contracts, resulting in overstatements of overall exchange open interest. In addition, on numerous dates between December 2016 and August 2017, due to a third party service provider inputting incorrect reportable levels and a failure to follow its own written procedures, the firm failed to report large trader positions in various VX weekly contracts.

81. May 25, 2018
    Regulatory Action: NYSE ARCA, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure and undertaking · Fine: $25,000 · Begun May 25, 2018 · Resolved May 25, 2018 · Decision & Order of Offer of Settlement · Docket 2016-10-00034

    The firm violated Securities Exchange Act of 1934 rule 15C3-5(c)(1)(II) (market access rule) by failing to establish, document, and maintain risk management controls and supervisory procedures that were reasonably designed to prevent the entry of erroneous orders, by rejecting orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time; and NYSE ARCA equities rules 6.18(b) and (c), by failing to establish and maintain adequate supervisory systems and written procedures that were reasonably designed to ensure compliance with rule 15C3-5.

    In determining to resolve this matter on the basis set forth herein, enforcement took into consideration that the firm cooperated in NYSE regulation's investigation and modified controls relating to the entry of erroneous orders, including pre- market orders, and modified its process for handling the submission of requests for review pursuant to NYSE ARCA rule 7.10-e during pre-market hours. The firm has undertaken to address any remaining deficiencies.

82. May 9, 2018
    Regulatory Action: Nasdaq Stock Market FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $13,500 · Begun May 9, 2018 · Resolved May 9, 2018 · Acceptance, Waiver & Consent(AWC) · Docket 2016049343501

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it did not follow up on position limit overages and failed to promptly take the action necessary to bring a position into compliance. The findings stated that a correspondent firm, a client of the firm, effected opening transactions for the account of its customer that exceeded the applicable position limit on the bullish side of the market in a security, which was 50,000 contracts, by 5,676 contracts. The next day, the correspondent firm executed an additional 500 contracts in the security for the same customer while the customer's position in the security had already exceeded the position limit on the previous trading day, which further caused the applicable position limit to be exceeded by a total of 6,176 contracts. The findings also stated that the firm maintained and cleared the options positions in the security for the correspondent firm. During a bi-monthly surveillance review of options positions that the firm conducted, it identified the positions in the security. However, the firm mistook the 5,000,000 shares position limit, which it had obtained from the website of the options clearing corporation, as contracts. The 5,000,000 shares position limit is equivalent to the 50,000 contracts position limit since the shares deliverable of an options contract is 100 shares. As such, the firm considered the subject options position to be within the position limit. As a result, the firm did not follow up on these position limit overages and failed to promptly take the action necessary to bring the position into compliance. Further, the correspondent firm also failed to bring its customer's position in the security into compliance with the applicable position limit. The position limit in a security was exceeded for a total 16 consecutive trading days, which ranged from approximately 11 percent to 12 percent over the applicable limit for the security. On March 18, 2016, a position limit increase was published by the options clearing corporation that increased the limit from 50,000 contracts to 75,000 contracts, which brought the customer's positions in compliance. The firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the Nasdaq options market LLC (NOM), concerning position limits. Specifically, the firm only conducted a bi-monthly surveillance review of options positions to determine compliance with position limits, and it failed to detect the position limit overages in the security when they were reviewed.

    On May 2, 2016, the firm modified its supervisory systems and procedures to provide for a daily review of options positions to determine compliance with position limits for securities in RBC wealth management, a division of the firm.

83. Apr 13, 2018
    Regulatory Action: Box Options Exchange LLC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $150,000 · Begun Apr 13, 2018 · Resolved Apr 13, 2018 · Consent · Docket 2014043230901

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it inappropriately used options clearing corporation (OCC) adjustments to create a position without trading on an exchange and subsequently inappropriately used OCC adjustments to close out a position without trading on an exchange. The findings stated that further, it was determined that the firm through 273 internal entries triggered OCC adjustments in a total of 107 symbols for a total of 203,478 contracts, which created long and short positions at the OCC without trading on an exchange, and resulted in inflated open interest. The findings also stated that the firm failed to follow its written supervisory procedures related to the proper use of OCC adjustments. The firm further failed to establish and maintain a supervisory system that was reasonably designed to achieve compliance with the applicable securities laws and regulations, and box rules, concerning OCC adjustments, as the firm did not have any procedures in place to verify that OCC adjustments were not associated with internal entries.

84. Dec 29, 2017
    Regulatory Action: Chicago Board Options Exchange, Incorporated FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure and disgorgement · Fine: $20,000 · Begun Nov 7, 2017 · Resolved Dec 29, 2017 · Stipulation and Consent · Docket 11-0052/20160501553

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to enforce written supervisory procedures, designed to prevent and detect violations of Exchange Act rule 14E-4 relating to its tender of 32,567 shares into the baxter international ("BAX") partial tender offer on May 18, 2016 in excess of its net long position.

    A summary of this action is set forth in the letter of consent, which is publicly available via the CBOE.

85. Oct 18, 2017
    Regulatory Action: Bats BZX Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $10,500 · Begun Sep 20, 2017 · Resolved Oct 18, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2014041635007

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take reasonable steps to establish that certain of the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in rule 600(b)(30) of regulation NMS. The findings stated that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the exchange, concerning ISOS that complied with the SEC's regulation NMS. Specifically, the firm's supervisory system did not include written supervisory procedures that would enable it in certain instances to promptly identify issues with the firm's access to timely and accurate market data.

    Action number 20140416350 includes 20150441761 and 20160512855

86. Oct 18, 2017
    Regulatory Action: Bats Edgx Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $21,000 · Begun Sep 20, 2017 · Resolved Oct 18, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2014041635006

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take reasonable steps to establish that certain of the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in rule 600(b)(30) of regulation NMS. The findings stated that on the review date, the firm failed to take reasonable steps to avoid displaying, and engaged in a pattern or practice of displaying, quotations that locked or crossed a protected quotation, without simultaneously routing an iso to execute against the full displayed size of any protected quotation that was a locking quotation or crossing quotation. The findings also stated that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the exchange, concerning ISOS that complied with the SEC's regulation NMS. Specifically, the firm's supervisory system did not include written supervisory procedures that would enable it in certain instances to promptly identify issues with the firm's access to timely and accurate market data. The firm's regulation NMS compliance iso exception reports, which were reviewed by firm personnel, did not identify that the firm had locked or crossed a protected quotation on the review date.

    Action number 20140416350 includes 20150441761 and 20160512855

87. Oct 18, 2017
    Regulatory Action: Bats Byx Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $10,500 · Begun Sep 20, 2017 · Resolved Oct 18, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2014041635008

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take reasonable steps to establish that certain of the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in rule 600(b)(30) of regulation NMS. The findings stated that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the exchange, concerning ISOS that complied with the SEC's regulation NMS. Specifically, the firm's supervisory system did not include written supervisory procedures that would enable it in certain instances to promptly identify issues with the firm's access to timely and accurate market data.

    Action number 20140416350 includes 20150441761 and 20160512855

88. Oct 18, 2017
    Regulatory Action: Bats Edga Exchange, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $10,500 · Begun Sep 20, 2017 · Resolved Oct 18, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2014041635005

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take reasonable steps to establish that certain of the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in rule 600(b)(30) of regulation NMS. The findings stated that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the exchange, concerning ISOS that complied with the SEC's regulation NMS. Specifically, the firm's supervisory system did not include written supervisory procedures that would enable it in certain instances to promptly identify issues with the firm's access to timely and accurate market data.

    Action number 20140416350 includes 20150441761 and 20160512855

89. Sep 20, 2017
    Regulatory Action: Nasdaq BX, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $10,500 · Begun Sep 20, 2017 · Resolved Sep 20, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2014041635004

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take reasonable steps to establish that certain of the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in rule 600(b)(30) of regulation NMS. The findings stated that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the exchange, concerning ISOS that complied with the SEC's regulation NMS. Specifically, the firm's supervisory system did not include written supervisory procedures that would enable it in certain instances to promptly identify issues with the firm's access to timely and accurate market data.

    Action number 20140416350 includes 20150441761 and 20160512855

90. Sep 20, 2017
    Regulatory Action: Nasdaq Stock Market FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $10,500 · Begun Sep 20, 2017 · Resolved Sep 20, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2014041635003

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take reasonable steps to establish that certain of the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in rule 600(b)(30) of regulation NMS. The findings stated that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the exchange, concerning ISOS that complied with the SEC's regulation NMS. Specifically, the firm's supervisory system did not include written supervisory procedures that would enable it in certain instances to promptly identify issues with the firm's access to timely and accurate market data.

    Action number 20140416350 includes 20150441761 and 20160512855

91. Sep 19, 2017
    Regulatory Action: NYSE ARCA, Inc. FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $10,500 · Begun Sep 19, 2017 · Resolved Sep 19, 2017 · Decision & Order of Offer of Settlement · Docket 2014041635001

    The firm entered into an offer of settlement and consent for the sole purpose of settling this disciplinary proceeding, without adjudication of any issues of law or fact, and without admitting or denying any allegations or findings referred to in the offer of settlement. The firm failed to take reasonable steps to establish that certain of the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in rule 600(b)(30) of regulation NMS. The findings stated that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the exchange, concerning ISOS that complied with the SEC's regulation NMS. Specifically, the firm's supervisory system did not include written supervisory procedures that would enable it in certain instances to promptly identify issues with the firm's access to timely and accurate market data.

    Action number 20140416350 includes 20150441761 and 20160512855

92. Sep 18, 2017
    Regulatory Action: New York Stock Exchange FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $10,500 · Begun Aug 24, 2017 · Resolved Sep 18, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2014041635002

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to take reasonable steps to establish that certain of the intermarket sweep orders (ISOS) it routed met the definitional requirements set forth in rule 600(b)(30) of regulation NMS. The findings stated that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of the exchange, concerning ISOS that complied with the SEC's regulation NMS. Specifically, the firm's supervisory system did not include written supervisory procedures that would enable it in certain instances to promptly identify issues with the firm's access to timely and accurate market data.

    Action number 20140416350 includes 20150441761 and 20160512855

93. Sep 13, 2017
    Regulatory Action: Box Options Exchange LLC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure & disgorgement · Fine: $45,000 · Begun Sep 13, 2017 · Resolved Sep 13, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2015046552701

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that on one trade, it had modified an expiring exercise declaration (EED) submission after the 5:30 P.M. (ET) cut-off time, without an allowable exception and based on after-hours trading information, in violation of box rule 9000, and also had related supervisory deficiencies. The findings stated that this cut-off time was established to prevent option holders from waiting for material information to determine if the underlying price will vary substantially from the closing price on expiration, unfairly disadvantaging the short option holders. The findings also stated that the firm failed to ensure that any exercise instructions submitted after the applicable cut-off time are the result of a good faith error or other applicable exception, and are not based on material information, including after-hours trading activity, released after the cut-off time. As a result, a firm trader submitted this particular modified EED to the firm's operations department based on after-hours trading after the 5:30 P.M. Cut- off time, and the operations staff submitted the modified EED to the firm's clearing firm without completely understanding the rules governing EED submissions. In addition, the firm failed to have adequate supervisory policies and systems, including written supervisory procedures ("WSPS"), reasonably designed to achieve compliance with box rules relating to the obligations of a box participant when exercising options contracts. Specifically, the firm's WSPS lacked references to the identity of the individual responsible for supervision; the supervisory steps and reviews to be taken by the designated supervisor; the frequency of such reviews; and how such reviews should be documented.

94. Aug 28, 2017
    Regulatory Action: State of North Carolina FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $77,145 · Begun Aug 28, 2017 · Resolved Aug 28, 2017 · Order · Docket 13 SEC 088

    It is highly likely that the firm accepted orders for transactions in securities through certain employees who were not appropriately licensed in accordance with applicable state laws, constituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

    As part of a multistate settlement, the firm entered into an agreement individually with each state in the aggregate amount of $2.8 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with the applicable state laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

95. May 3, 2017
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure and untertaking · Fine: $225,000 · Begun May 3, 2017 · Resolved May 3, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 20150464695-01

    It is alleged that the firm transmitted to the order audit trail system (OATS) reports in which the special handling code field was not populated to indicate whether the orders were "held" or "not held." The findings alleged that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of FINRA, concerning transmitting accurate information to OATS. Specifically, the firm's supervisory system did not include written supervisory procedures (WSPS) providing for a review of the firm's OATS reports that was representative of the types of business in which the firm engaged to ensure its submissions were accurate. The findings also alleged that the firm failed to report to the trade reporting and compliance engine (TRACE) transactions in TRACE eligible corporate debt securities that it was required to report. In these instances, the firm reported block transactions that were to be allocated to separate managed accounts as a single block instead of reporting the allocations as individual transactions, as required. The findings also alleged that the firm effected customer transactions in a municipal security in an amount lower than the minimum denomination of the issue, which were not subject to an exception under the applicable municipal securities rulemaking board (MSRB) rule. FINRA alleged that the firm also failed to disclose all material facts concerning municipal securities transactions at or prior to the time of trade. Specifically, the firm failed to inform its customer that the municipal securities transaction was in an amount below the minimum denomination of the issue. FINRA also alleged that the firm failed to report information regarding 18,634 purchase and sale transactions effected in municipal securities to the realtime transaction reporting system (RTRS). For approximately 1,500 of these instances, the firm reported block transactions that were to be allocated to separate managed accounts as a single block instead of reporting the allocations as individual transactions, as required.

    FINRA case number 20150464695 includes case numbers 20150465800, 20160492672, 20160494357, and 2016052372

96. Dec 21, 2016
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure and undertaking · Fine: $3.5M · Begun Dec 21, 2016 · Resolved Dec 21, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2016049821601

    It is alleged that RBC Capital Markets, LLC and RBC Capital Markets arbitrage, S.A. (Both noted together as "RBC" hereafter) failed to retain electronic records in worm ("write once, read many") format. RBC is also alleged to have failed to implement an audit system regarding the inputting of records in electronic storage media. RBC is alleged to have failed to obtain an attestation from their third party vendor. RBC's supervisory system was allegedly not reasonably designed to enforce specific procedures concerning storage of electronic broker-dealer records in worm format.

97. Oct 19, 2016
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure and undertaking · Fine: $22,500 · Begun Oct 19, 2016 · Resolved Oct 19, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 20150442305-01

    It is alleged that the firm failed to transmit reportable order events (ROES) to the order audit trail system (OATS). It is also alleged that the firms supervisory system did not provide for supervision reasonably calculated to comply with applicable rules regarding transmitting orders that took place outside of the firm's omss to OATS. Specifically, the firm's supervisory system did not include written supervisory procedures providing for the identification of the person(s) responsible for supervision with respect to the applicable rules; a statement of the supervisory step(s) to be taken by the identified person(s); a statement as to how often such person(s) should take such step(s); and a statement as to how the completion of the step(s) included in the written supervisory procedures should be documented.

98. Oct 18, 2016
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $975,000 · Begun Oct 18, 2016 · Resolved Oct 18, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 20140413771-01

    It is alleged that during the periods of April 2011 through April 2014 and November 2002 through December 29, 2014, the firm experienced systems issues during the review periods that resulted in violation of NASD rules 2110 (for conduct prior to December 15, 2008), 3010 (for conduct prior to December 1, 2014), and 3310 (for conduct prior to February 15, 2010), and FINRA rules 2010 (for conduct on and after December 15, 2008), 3110 (for conduct on and after December 1, 2014), and 5210 (for conduct on and after February 15, 2010). The firm is alleged to have overstated its advertised trade volume due to a computer coding error. Due to a separate computer coding error, it is alleged that the advertised trade volume from the firm's electronic trading desk was reported with the wrong execution date. Additionally, the firm is alleged to have failed to establish and maintain a supervisory system that was reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and NASD and FINRA rules, concerning advertised trade volume. The firm's supervisory system allegedly did not include sufficient written supervisory procedures providing for: (1) the identification of the person(s) responsible for supervision with respect to the applicable rules; (2) a statement of the supervisory step(s) to be taken by the identified person(s); (3) a statement as to how often such person(s) should take such step(s); and (4) a statement as to how the completion of the step(s) included in the written supervisory procedures should be documented.

99. Aug 31, 2016
    Regulatory Action: SEC FinalSanctions: Other; N/a · Fine: $2.0M · Begun Aug 31, 2016 · Resolved Aug 31, 2016 · Order · Docket 317520

    SEC admin release 3478735, August 31, 2016: the Securities and Exchange Commission ("commission") deems it appropriate that cease and desist proceedings be, and hereby are, instituted pursuant to section 21c of the Securities Exchange Act of 1934 ("Exchange Act"), against RBC Capital Markets, LLC ("RBC" or "respondent"). It is alleged that RBC caused RURAL/metro corporation's violations of the proxy statement provisions of the federal securities laws in connection with the sale of RURAL/metro corporation ("RURAL") in 2011 to a private equity firm. RBC, which served as RURAL's lead financial adviser for the sale, allegedly rendered a fairness opinion to RURAL's board of directors that contained materially false and misleading information concerning RBC's valuation analysis. RBC allegedly caused that information to be included in the proxy statement that RURAL filed to solicit VS hareholder approval for the sale. As a result, RBC allegedly caused RURAL to violate section 14(a) of the Exchange Act and rule 14A9 thereunder, which prohibits solicitation by means of a proxy statement that contains any materially false or misleading statement.

100. Jul 29, 2016
     Regulatory Action: Chicago Baord of Trade FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $30,000 · Begun Jul 29, 2016 · Resolved Jul 29, 2016 · Settled · Docket CBOT 149940BC

     It is alleged that on January 13, 2014, RBC Capital Markets, LLC ("RBCCM") executed a block trade in the March 2014 5year note contract that was not reported to the exchange within the applicable time limit following execution, and that RBCCM reported an inaccurate time of execution of the block trade. Additionally, it is alleged the RBCCM agreed to sell to the customer at one price, but reported that the block trade was executed at a different price to the exchange. This conduct allegedly violated CBOT rule 526.f.

101. Jul 22, 2016
     Regulatory Action: State of Louisiana FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $41,040 · Begun Jul 22, 2016 · Resolved Jul 22, 2016 · Order · Docket OFI2016004

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who were not appropriately licensed in accordance with applicable state laws, constituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multistate settlement, the firm entered into an agreement individually with each state in the aggregate amount of $2.8 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with the applicable state laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

102. Jun 10, 2016
     Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $125,000 · Begun Jun 10, 2016 · Resolved Jun 10, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2014043628201

     It is alleged that RBC Capital Markets, LLC violated FINRA rule 2010 and 2081 when mediating a dispute with a claimant on October, 2014 by including a "a term or condition" that "claimants will not oppose expungement" on a settlement agreement. Additionally, it is alleged that the firm violated NASD rule 3010(a) and FINRA rules 3110(a) and 2010 by failing to establish and maintain a supervisory system, including written procedures, reasonably designed to ensure compliance with FINRA rule 2081. The firm is also alleged to have failed to establish, maintain and enforce written supervisory procedures (WSPS) which should have included a designated supervisor responsible for conducting supervision regarding compliance with rule 2081, a description of the review process that such supervisor would take to review for compliance, the frequency of such review, how such reviews should be documented, as well as what the firm should do when deficiencies in compliance are identified, leading to a violation of FINRA rules 3110(b) and 2010.

103. May 4, 2016
     Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $15,000 · Begun May 4, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2014043005601

     It is alleged that RBC capital markest, LLC transmitted execution or combined order/execution reports to the order audit trail system (OATS) that contained inaccurate, incomplete, or improperly formatted data which prevented the OATS system from matching the reports to the related trade report in a FINRA trade reporting facility (TRF). The findings also alleged that the firm transmitted to OATS execution or combined order/execution reports that it was not required to report.

     Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it transmitted execution or combined order/execution reports to the order audit trail system (OATS) that contained inaccurate, incomplete, or improperly formatted data which prevented the OATS system from matching the reports to the related trade report in a FINRA trade reporting facility (TRF). The firm also consented to the entry of findings that the firm transmitted to OATS execution or combined order/execution reports that it was not required to report.

104. Apr 11, 2016
     Regulatory Action: Chicago Board Options Exchange, Incorporated ("CBOE") FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $75,000 · Begun Nov 11, 2015 · Resolved Apr 11, 2016 · Decision & Order of Offer of Settlement · Docket 15-0093/20150459684

     From in or about December 2011 through in or about March 2012, RBC Capital Markets, LLC ("RBCCM") is alleged to have failed to properly close out a fail-to-deliver position in seven sampled equity securities. From in or about December 2011 through in or about March 2012, RBCCM is alleged to have increased its short position when a fail-to-deliver position had not been properly closed out without demonstrating that it made arrangements for pre-borrowing in specific equity securities. From in or about December 2011 through in or about March 2012, RBCCM is alleged to have failed to supervise its associated persons to assure compliance with Regulation SHO rule 204 in that it: (1) failed to assure that numerous fail-to-deliver positions were closed out on a timely basis; and (2) improperly asserted reliance on certain exemptions under reg. Sho rule 204 without undertaking sufficient due diligence to ascertain and document that specific requirements thereunder were met.

     Without admitting or denying the violations, the firm consented to the described sanctions and entry of findings, therefore the firm is censured and agreed to pay a fine of $75,000.

105. Apr 4, 2016
     Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $225,000 · Begun Apr 4, 2016 · Resolved Apr 4, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2014042542901

     The firm is alleged to have failed to identify and apply sales charge discounts to certain customers' eligible purchases of unit investment trusts (UITS). The findings stated that specifically, the firm failed to apply sales charge discounts to 4,399 eligible uit purchases resulting in customers paying excessive sales charges of approximately $502,088.88. The findings also stated that the firm failed to establish, maintain and enforce a supervisory system and WSPS reasonably designed to ensure customers received sales charge discounts on all eligible uit purchases. Although the firm had WSPS related to uit sales charge discounts, the firm failed to effectively inform and train registered representatives and supervisors to ensure that representatives followed these procedures and identified and applied all applicable discounts.

     Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to identify and apply sales charge discounts to certain customers' eligible purchases of unit investment trusts (UITS).

106. Mar 31, 2016
     Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $40,000 · Begun Mar 31, 2016 · Resolved Mar 31, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2014041197401

     It is alleged that the firm failed to report to the trade reporting and compliance engine (TRACE) S1 transactions in TRACE-eligible corporate debt securities within the time required by FINRA rule 6730 and failed to report to TRACE transactions in TRACE-eligible securitized products and TRACE-eligible agency debt securities within the time required by FINRA rule 6730.

     Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to report to the trade reporting and compliance engine (TRACE) S1 transactions in TRACE-eligible corporate debt securities within the time required by FINRA rule 6730 and failed to report TRACE transactions in TRACE-eligible securitized products and TRACE- eligible agency debt securities within the time required by FINRA rule 6730.

107. Mar 17, 2016
     Regulatory Action: State of Oklahoma Department of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $41,520 · Begun Mar 17, 2016 · Resolved Mar 17, 2016 · Order · Docket 14-078

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who where not appropriately licensed in accordance with applicable state laws, constituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multi-state settlement, the firm entered into an agreement individually with each state in the aggregate amount of $2.8 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with applicable state laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

108. Mar 1, 2016
     Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $300,000 · Begun Mar 1, 2016 · Resolved Mar 1, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2013039474902

     It is alleged that RBC Capital Markets, LLC ("the firm") failed to amend, or timely amend, the forms U4 for registered representatives to report unsatisfied tax liens and civil judgments. The findings state that the firm received wage garnishment orders from courts and tax authorities (including the IRS) resulting from tax levies, civil judgments, and similar actions, for registered representatives. The firm however is alleged to have failed to consistently conduct a sufficient inquiry to determine if the underlying event triggering each garnishment order involved an event that should have been reported on the affected individual's Form U4. The findings also alleged that the firm failed to establish and maintain a supervisory system and WSPS reasonably designed to ensure that it disclosed reportable unsatisfied liens and judgments of registered representatives on forms U4, in instances in which a garnishment notice was sent to the firm.

     Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to amend, or timely amend, the forms U4 for registered representatives to report unsatisfied tax liens and civil judgments between januart 1, 2013 through June 30, 2015.

109. Aug 28, 2015
     Regulatory Action: NYSE MKT LLC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $80,000 · Begun Aug 28, 2015 · Resolved Aug 28, 2015 · Acceptance, Waiver & Consent(AWC) · Docket 2013039452701

     Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that on 13 occasions, the firm violated NYSE rule 92(a) by entering a proprietary order to buy or sell an NYSE-listed security while knowingly in possession of a customer order to buy or sell such security that could be executed at the same price, and which proprietary order then traded along with, or ahead of, the customer order, or traded outside of the customer's consent parameters. The findings stated that on two occasions, the firm violated NYSE rule 2010 by failing to document customer consent to the allocation split as required by NYSE rule 92(b). The findings also stated that the firm violated NYSE rule 342 in that it failed to reasonably supervise and implement adequate controls, including a separate system of follow-up and review, reasonably designed to achieve compliance with certain NYSE rules and policies, including with respect to transmitting and executing proprietary and agency trades on the NYSE.

110. Jul 27, 2015
     Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $450,000 · Begun Jul 27, 2015 · Resolved Jul 27, 2015 · Acceptance, Waiver & Consent(AWC) · Docket 20130377846-01

     The firm self-reported an order audit trail system ("OATS") reporting system logic change implemented in January 2012 may have caused the firm's system to cease reporting reportable order events ("ROES"), which affected approximately 500 million ROES, therefore potentially violating NASD rule 3010, FINRA rule 2010, and FINRA rule 7450. After implementing a system fix, the firm engaged an external consulting firm to assess and evaluate the efficacy of its corrective actions. Additional OATS reporting issues were identified and submitted via self-report in March 2014.

     Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm failed to transmit to OATS 1,183,844,292 roes over a period constituting approximately 28 months, therefore violating FINRA rule 7450, FINRA rule 2010, and NASD rule 3010.

111. Jun 18, 2015
     Regulatory Action: SEC FinalSanctions: Cease and Desist; Monetary penalty · Fine: $500,000 · Begun Jun 18, 2015 · Resolved Jun 18, 2015 · Order · Docket 3-16632

     SEC admin releases 339839;3475233,June 18, 2015: the Securities and Exchange Commission deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted against RBC capital markers, LLC ("the firm"). The firm willfully violated section 17(a)(2) of the Securities Act. This matter involves violations of an antifraud provision of the federal securities laws in connection with the firm's underwriting of certain municipal securities offerings. The firm, a registered broker dealer, conducted inadequate due diligence in certain offerings and as a result, failed to form a reasonable basis for believing the truthfulness of certain material representations in official statements issued in connection with those offerings. This resulted in the firm offering and selling municipal securities on the basis of materially misleading disclosure documents. The violations were self-reported by the firm to the commission pursuant to the division of enforcement's (the "division") municipalities continuing disclosure cooperation (MCDC) initiative.

     In anticipation of the institution of these proceedings, RBC Capital Markets, LLC ("the firm") has submitted an offer of settlement (the "offer") which the commission has determined to accept. Solely for the purpose of these proceedings and any other proceedings brought by or on behalf of the commission, or to which the commission is a party, and without admitting or denying the findings, except as to the commission's jurisdiction over the firm and the subject matter of these proceedings, which are admitted, the firm consentsto the entry of this order instituting administrative and cease-and-desist proceedings pursuant to section 8a of the Securities Act of 1933 and section 15(b) of the Securities Exchange Act of 1934, making findings, and imposing remedial sanctions and a cease-and-desist order. In view of the foregoing, the commission deems it appropriate and in the public interest to impose the sanctions agreed to in the firm's offer. The firm shall cease and desist from committing or causing any violations and any future violations of 17(a)(2)of the Securities Act; within ten (10) days of the entry of this order, pay a civil money penalty in the amount of $500,000 to the Securities and Exchange Commission; and retain an independent consultant to conduct a review of policies and procedures as they relate to municipal securities underwriting due diligence.

112. Apr 23, 2015
     Regulatory Action: FINRA FinalSanctions: Censure; Fine and restitution · Fine: $1.0M · Resolved Apr 23, 2015 · Acceptance, Waiver & Consent(AWC) · Docket 2010022918701

     It is alleged that between 2008 and 2012, the firm failed to have in place supervisory systems and procedures reasonably designed to ensure compliance with applicable securities laws and regulations and its internal guidelines concerning the suitability of reverse convertibles therefore violating NASD rules 3010(a), 2310, 2110, and FINRA rule 2010.

     Without admitting or denying the findings, the firm consented to the sanctions and the to the entry of findings that between 2008 and 2012, the firm failed to have in place supervisory systems and procedures reasonably designed to ensure compliance with applicable securities laws and regulations and its internal guidelines concerning the suitability of reverse convertibles therefore violating NASD rules 3010(a), 2310, 2110, and FINRA rule 2010.

113. Mar 18, 2015
     Regulatory Action: State of Maryland Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $48,580 · Begun Mar 18, 2015 · Resolved Mar 18, 2015 · Order · Docket 2014-0094

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who were not appropriately licensed in accordance with applicable state laws, constituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multi-state settlement, the firm entered into an agreement individually with each state in the aggregate amount of $2.8 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with the applicable state laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

114. Jan 23, 2015
     Regulatory Action: State of Maryland Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $15,000 · Begun Jan 23, 2015 · Resolved Jan 23, 2015 · Consent · Docket 2014-0458

     RBC Capital Markets, LLC is alleged to have violated section 11-402 of the Maryland Securities Act by failing to register an individual appropriately as an investment adviser representative between August 3, 2011 and June 2, 2014.

115. Dec 1, 2014
     Regulatory Action: Chicago Board Options Exchange FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $40,000 · Begun Oct 2, 2014 · Resolved Dec 1, 2014 · Settled · Docket 14-0143

     It is alleged that RBC Capital Markets, LLC (RBCCM) failed to register seventeen associated persons as proprietary traders with the Chicago Board Options Exchange (CBOE) on various dates between on or about November 5, 2011 through on or about April 29, 2013. It is also alleged that RBCCM failed to register one associated person with CBOE from on or about December 18, 2012 through on or about May 13, 2013 as a proprietary trading principal. In addition, from on or about April 1, 2012 through on or about April 19, 2013, it is alleged that RBCCM failed to register one associated person with CBOE as a proprietary trader principal. It is also alleged that RBCCM failed to register its chief compliance officer as a proprietary trader compliance officer with CBOE by November 5, 2011 pursuant to exchange rule 3.6a.

116. Nov 5, 2014
     Regulatory Action: CBOE Futures Exchange, LLC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $25,000 · Begun Oct 1, 2014 · Resolved Nov 5, 2014 · Decision & Order of Offer of Settlement · Docket CFE-14-0003

     It is alleged that during the approximate period from in or about May 2012 through in or about April 2013, on numerous dates, RBC Capital Markets, LLC failed to submit order entry operator ids pursuant to cfe rule 303a with numerous orders sent to cfe.

117. Sep 16, 2014
     Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution · Fine: $5,000 · Begun Sep 16, 2014 · Resolved Sep 16, 2014 · Acceptance, Waiver & Consent(AWC) · Docket 20120317576-01

     Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to contemporaneously or partially execute 27 customer limit orders in 15 over-the-counter (OTC) securities after it traded each subject security for its own market-making account at a price that would have satisfied each customer's limit order.

118. Jul 2, 2014
     Regulatory Action: Missouri Office of Secretary of State FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $50,220 · Begun Jul 2, 2014 · Resolved Jul 2, 2014 · Order · Docket AP-14-11

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who were not appropriately licensed in accordance with applicable state laws, constituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multi-state settlement, the firm entered into an agreement individually with each state in the aggregate amount of $.28 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with applicable state laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

119. Jun 27, 2014
     Regulatory Action: FINRA FinalSanctions: Censure · Fine: $12,500 · Begun Jun 27, 2014 · Resolved Jun 27, 2014 · Acceptance, Waiver & Consent(AWC) · Docket 20130358260-01

     It is alleged that the firm transmitted to order audit trail system ("OATS") 174 reports for which it did not have an OATS reporting responsibility.

120. Jun 20, 2014
     Regulatory Action: New York Office of the Attorney General FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $65,370 · Begun Jun 20, 2014 · Resolved Jun 20, 2014 · Order · Docket AOD NO. 14-126

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who were not appropriately licensed in accordance with applicable state laws, constituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multi-state settlement, the firm entered into an agreement individually with each state in the aggregate amount of $.28 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with applicable state laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

121. Jun 16, 2014
     Regulatory Action: Nebraska Department of Banking & Finance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $35,240 · Begun Jun 16, 2014 · Resolved Jun 16, 2014 · Order · Docket N/A

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who were not appropriately licensed in accordance with applicable state laws, constituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multi-state settlement, the firm entered into an agreement individually with each state in the aggregate amount of $.28 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with applicable state laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

122. Apr 21, 2014
     Regulatory Action: Commonwealth of Kentucky Department of Financial Institutions FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $38,020 · Resolved Apr 21, 2014 · Order · Docket 2014-AH-0021

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who where not appropriately licensed in accordance with applicable state laws, constituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multi-state settlement, the firm entered into an agreement individually with each state in the aggregate amount of $2.8 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with applicable state laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

123. Mar 26, 2014
     Regulatory Action: State of Florida Office of Financial Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $71,380 · Begun Mar 26, 2014 · Resolved Mar 26, 2014 · Order · Docket 0273-SR-07/13

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who where not appropriately licensed in accordance with applicable state laws, consituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multi-state settlement, the firm entered into an agreement individually with each state in the aggregate amount of $2.8 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with applicable state laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

124. Mar 21, 2014
     Regulatory Action: State of South Dakota Division of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $46,470 · Begun Mar 21, 2014 · Resolved Mar 21, 2014 · Order · Docket N/A

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who where not appropriately licensed in accordance with applicable state laws, constituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multi-state settlement, the firm entered into an agreement individually with each state in the aggregate amount of $2.8 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with applicable state laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

125. Jan 17, 2014
     Regulatory Action: Idaho Department of Finance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $45,770 · Begun Jan 17, 2014 · Resolved Jan 17, 2014 · Order · Docket 2013-7-10

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who were not appropriately licensed in accordance with applicable state laws, constituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multi-state settlement, the firm entered into an agreement individually with each state in the aggregate amount of $2.8 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with applicable satte laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

126. Jan 10, 2014
     Regulatory Action: District of Columbia Department of Insurance, Securities and Banking FinalSanctions: Undertaking · Fine: $38,925 · Begun Jan 10, 2014 · Resolved Jan 10, 2014 · Order · Docket SB-CO-12-13

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who where not appropriately licensed in accordance with applicable state laws, consituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multi-state settlement, the firm entered into an agreement individually with each state in the aggregate amount of $2.8 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with applicable satte laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures, and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

127. Oct 31, 2013
     Regulatory Action: Office of the Mississippi Secretary of State Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $34,070 · Resolved Oct 31, 2013 · Order · Docket LS-13-0732

     It is highly likely that the firm accepted orders for transactions in securities through certain employees who where not appropriately licensed in accordance with applicable state laws, consituting failure by the firm to establish and enforce an adequate system to monitor the licensing status of such employees.

     As part of a multi-state settlement, the firm entered into an agreement individually with each state in the aggregate amount of $2.8 million. This resulted from allegations that client associates who were not appropriately licensed in accordance with applicable state laws accepted orders for transactions in securities; and the firm failed to establish and enforce an adequate system to monitor the licensing status of such employees. In addition to the aggregate fine, the firm undertakes to establish and maintain policies, procedures and systems that reasonably supervise the trade process so that the firm can only accept client orders that originate from jurisdictions where the employee who accepts the order is appropriately licensed.

Actions about affiliates (7)

1. Mar 28, 2024
   Regulatory Action: CBOE Futures Exchange, LLC FinalAbout an affiliate: RBC Dominion SecuritiesSanctions: Other; Settlement · Fine: $30,000 · Begun Mar 28, 2024 · Resolved Mar 28, 2024 · Settled · Docket URE-298-09

   RBC Dominion Securities, inc. violated CBOE exchange rules 412b(b) for alleged failure to submit timely large trader reports for a single customer.

2. Nov 2, 2023
   Regulatory Action: SEC FinalAbout an affiliate: Royal Bank of CanadaSanctions: Civil and Administrative Penalt(ies) /Fine(s); It was ordered that the firm cease and desist from committing or causing any violations and any future violations of sections · Fine: $6.0M · Begun Nov 2, 2023 · Resolved Nov 2, 2023 · Decision & Order of Offer of Settlement · Docket ADMINISTRATIVE PROCEEDING FILE NO. 3-21792

   Failure to make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the issuer. Failure to devise and maintain a system of internal account controls sufficient to provide reasonable assurance that transactions are recorded to permit preparation of financial statements in conformity with generally accepted accounting principles.

   Without admitting or denying the findings, the firm consented to the entry of the order instituting cease-and-desist proceedings and imposing a cease-and-desist order.

3. Nov 2, 2023
   Regulatory Action: ( g g g y y ) FinalAbout an affiliate: Royal Bank of CanadaSanctions: Civil and Administrative Penalt(ies) /Fine(s); It was ordered that the firm cease and desist from committing or causing any violations and any future violations of sections · Fine: $6.0M · Begun Nov 2, 2023 · Resolved Nov 2, 2023 · Decision & Order of Offer of Settlement · Docket ADMINISTRATIVE PROCEEDING FILE NO. 3-21792

   Failure to make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the issuer. Failure to devise and maintain a system of internal account controls sufficient to provide reasonable assurance that transactions are recorded to permit preparation of financial statements in conformity with generally accepted accounting principles.

4. Apr 24, 2020
   Regulatory Action FinalAbout an affiliate: RBC Capital Markets, LLC; the full record is on the affiliate's own Form ADVSanctions: Cease and Desist · Fine: $650,000 · Begun Apr 24, 2020 · Resolved Apr 24, 2020 · Order · Docket 3-19769

   The commission finds that from at least July 2012 through August 2017 (the "relevant period"), RBC disadvantaged certain retirement plan and charitable organization brokerage customers who maintained accounts at RBC ("eligible customers") by failing to ascertain that they were eligible for a less expensive share class, and recommending and selling them more expensive share classes in certain open-end registered investment companies ("mutual funds") when less expensive share classes were available. RBC did so without disclosing that it would receive greater compensation from the eligible customers' purchases of the more expensive share classes. Eligible customers did not have sufficient information to understand that RBC had a conflict of interest resulting from compensation it received for selling the more expensive share classes. Specifically, RBC recommended and sold these eligible customers class a shares with an up-front sales charge, or class b or class c shares with a back-end contingent deferred sales charge ("CDSC") (a deferred sales charge the purchaser pays if the purchaser sells the shares during a specified time period following the purchase) and higher ongoing fees and expenses, when these eligible customers were eligible to purchase loadwaived class a and/or no-load class r shares. RBC omitted material information concerning its compensation when it recommended the more expensive share classes. RBC also did not disclose that the purchase of the more expensive share classes would negatively impact the overall return on the eligible customers' investments, in light of the different fee structures for the different fund share classes. In making those recommendations of more expensive share classes while omitting material facts, RBC violated sections 17(a)(2) and 17(a) (3) of the Securities Act. These provisions prohibit, respectively, in the offer or sale of securities, obtaining money or property by means of an omission to state a material fact necessary to make statements made not misleading, and engaging in a course of business which operates as a fraud or deceit on the purchaser. As a result of the conduct described above, RBC willfully violated sections 17(a)(2) and 17(a)(3) of the Securities Act.

   RBC has submitted an offer of settlement, which the commission has determined to accept. RBC willfully violated sections 17(a) (2) and 17(a)(3) of the Securities Act. Accordingly, it is ordered that respondent cease and desist from committing or causing any violations and any future violations of sections 17(a)(2) and 17(a)(3) of the Securities Act. Respondent is censured and shall pay disgorgement of $2,607,676 with prejudgment interest of $631,331, plus a civil monetary penalty of $650,000.

5. Aug 30, 2019
   Regulatory Action: Ontario Securities Commission FinalAbout an affiliate: Royal Bank of CanadaSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $10.3M · Begun Aug 23, 2019 · Resolved Aug 30, 2019 · Decision & Order of Offer of Settlement

   Failure to have sufficient supervision and controls in its FX trading business.

6. Dec 19, 2016
   Regulatory Action: CFTC FinalAbout an affiliate: Convergent Wealth; the full record is on the affiliate's own Form ADVSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $800,000 · Begun Dec 19, 2016 · Resolved Dec 19, 2016 · Settled · Docket CFTC DOCKET NO. 17-02

   On December 19, 2016 Convergent Wealth advisors, LLC agreed to a civil monetary penalty without admitting or denying the findings and conclusions in the order of settlement of $800,000 issued by the U.S. Commodity Futures Trading Commission arising out of with the fraudulent omissions and false statements of an employee related to the employee's outside business activities. The employee is no longer with Convergent Wealth advisors, LLC.

7. Dec 18, 2014
   Regulatory Action: CFTC FinalAbout an affiliate: Royal Bank of CanadaSanctions: Civil and Administrative Penalt(ies) /Fine(s); Injunction · Fine: $35.0M · Begun Apr 2, 2012 · Resolved Dec 18, 2014 · Consent · Docket 12-CV-2497 (AKH/KNF)

   Royal Bank of Canada is alleged to have violated section 4c(a) of the Commodity Exchange Act, and commission regulation 1.38(a), by knowingly entering into purchases and sales of single stock futures and narrow-based index futures contracts opposite its subsidiaries with the express or implied understanding that the position would be offset or delivered opposite each other.

Disclosures filed elsewhere

The firm's Form ADV names these and the kind of action only; the details are on the named firm's own filing.

• 1 regulatory action disclosure about City National Rochdale

Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.