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Zorluk: Çok zorProhibited Market Manipulation and Fraudulent Practices

During an internal audit, a broker-dealer's compliance department uncovers two separate suspicious trading activities in a thinly traded over-the-counter (OTC) equity security: First, a trader enters a series of non-bona fide buy orders above the current national best bid to create a false appearance of buying interest, subsequently canceling them right before execution once other market participants raise their bids. Second, a registered representative executes pre-arranged matching buy and sell orders for a security between two customer accounts owned by the exact same legal entity, resulting in no actual change in beneficial ownership. Which of the following statements accurately classifies both prohibited market practices and correctly describes the regulatory enforcement jurisdiction over these violations?

  1. The first practice is spoofing and the second is wash trading; both FINRA and the SEC have regulatory jurisdiction to investigate and enforce sanctions for these fraudulent activities.Cevap
  2. B
    The first practice is wash trading and the second is spoofing; both FINRA and the SEC have regulatory jurisdiction to investigate and enforce sanctions for these fraudulent activities.
  3. C
    The first practice is spoofing and the second is wash trading; FINRA possesses exclusive authority to criminally prosecute the firm without SEC involvement because SROs hold sole jurisdiction over exchange trading rules.
  4. D
    The first practice is spoofing and the second is interpositioning; the second practice is permissible if the broker-dealer acts in a dealer capacity charging a mark-up rather than a broker capacity charging a commission.

Cevap

Entering non-bona fide orders intended for cancellation to manipulate prices is spoofing, while executing transactions with no change in beneficial ownership is wash trading. Both FINRA (an SRO) and the SEC (a federal agency) possess regulatory jurisdiction to investigate and penalize such fraudulent market manipulation.
The correct option accurately identifies the first scenario as spoofing (entering fake orders intended to be canceled to trick market participants) and the second scenario as wash trading (executing matched trades that result in no beneficial ownership change). Furthermore, it correctly states that both FINRA (the self-regulatory organization governing member firms) and the SEC (the federal regulator) have concurrent authority to investigate and discipline these fraudulent practices.

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1
Analyze the first trading activity pattern.
The practice of submitting non-bona fide quotes/orders higher than the current bid to simulate market demand and then canceling them before execution is classified as spoofing.
Spoofing aims to artificially move security prices or induce others to trade based on false liquidity signals.
2
Analyze the second trading activity pattern.
Executing offsetting buy and sell orders where accounts share the exact same beneficial owner results in no change of actual ownership, which defines wash trading.
Wash trading creates a misleading appearance of active trading volume and market interest without genuine financial risk.
3
Evaluate the regulatory enforcement jurisdiction.
Both the Securities and Exchange Commission (SEC) under federal securities laws (e.g., Securities Exchange Act of 1934 Section 10(b) / Rule 10b-5) and Self-Regulatory Organizations such as FINRA (under Rule 2010 and 2020) have jurisdiction to investigate and sanction member firms and associated persons.
FINRA enforces member ethical and trading standards, while the SEC enforces federal securities statutes and oversees SRO actions.

Anahtar Kavram

Prohibited Market Manipulation (Spoofing vs. Wash Trading) and Regulatory Authority Scope
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