Question

Difficulty: MediumProhibited Market Manipulation and Fraudulent Practices

A compliance auditor is reviewing trading activity logs at a member broker-dealer to evaluate potential regulatory violations. Which of the following trading practices represent prohibited market manipulation or fraudulent conduct? (Select all that apply.)

  1. Entering non-bonafide buy orders with the intent to cancel them prior to execution to create a false impression of buying interest in a security.Answer
  2. Purchasing equity shares for a firm's proprietary account immediately prior to executing a large customer block buy order in the same stock.Answer
  3. C
    Matching a buyer and seller in a secondary market transaction as an agent and charging a disclosed commission on the trade.
  4. D
    Bringing criminal charges and imposing prison sentences on manipulative traders through SRO disciplinary proceedings.

Answer

The prohibited practices are entering non-bonafide orders intended for cancellation before execution (spoofing) and buying shares ahead of a client's block buy order (front-running).
Entering non-bonafide orders designed to be canceled before execution (spoofing) deceives market participants regarding genuine interest. Purchasing securities ahead of a client's institutional block order (front-running) takes unfair advantage of pending client orders. Both activities constitute illegal market manipulation and fraud.

Step-by-Step Solution

1
Analyze each trading activity to identify deceptive actions designed to mislead the market or exploit material non-public order information.
Entering fake orders to fabricate market depth (spoofing) and trading ahead of client block transactions (front-running) violate federal securities laws and FINRA ethical standards.
Both activities exploit order flow and artificially affect security prices to the detriment of public investors.
2
Differentiate lawful broker agency operations and SRO jurisdiction limits from manipulative trading.
Matching buyers and sellers for a commission is standard agency execution. SROs enforce membership rules through fines and suspensions, not criminal prosecution.
Standard agency transactions are legal, and criminal sanctions fall strictly under governmental jurisdiction.

Key Concept

Prohibited Market Manipulation and Fraudulent Practices
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