eDelta Trading Platform Marketing-2015

eDelta Consulting, Inc.
Trade Reporting Capabilities /Monitoring Requirements
Background
FINRA/NASDAQ Market Center (NMC):
According to FINRA, market participants need to comply with the requirement that Order Entry
Executing/Reporting Firms accept or decline trades in the NASDAQ Market Center (NMC) within 20
minutes of trade execution.
It provides information about the number of trades that compared in NMC within 20 minutes of executing
time and in increasing lengths of time later than 20 minutes after execution time, as well as the
percentage of those trades to total trades executed. (For trades marked with the .PRP modifier, the
report time instead of execution time should be used.)
FINRA Order Audit Trail System (OATS):
FINRA has established the Order Audit Trail System (OATS), as an integrated audit trail of order, quote,
and trade information for NASDAQ and OTC equity securities. FINRA uses this audit trail system to
recreate events in the life cycle of orders and more completely monitor the trading practices of member
firms.
Under FINRA Rules 7410 - 7470, FINRA member firms are required to develop a means for
electronically capturing and reporting to OATS specific data elements related to the handling or
execution of orders, including recording all times of these events in hours, minutes, and seconds and to
synchronize their business clocks (also covered by FINRA Rule-7430 – Clock Synchronization).
Each FINRA member is responsible for transmitting to OATs whenever an order is originated, received,
transmitted to another department within the member or to another member, modified, canceled, or
executed. Each report is required to be transmitted on the day such event occurred.
According to FINRA, OATs reporting compliance can be measured by the number and percentage of:
OATS late submissions;
Out-of-sequence events;
Unmatched execution reports;
Unmatched NASDAQ Execution System route reports;
Unmatched inter-firm route reports;
Unmatched inter-firm routes received; and,
Unrepaired repairable rejected order events.
Trace Reporting - NASD Introduced TRACE (Trade Reporting and Compliance Engine):
TRACE reporting came into effect in July 2002 in an effort to increase price transparency in the U.S.
corporate debt market. The system captures and disseminates consolidated information on secondary
market transactions in publicly traded TRACE-eligible securities (investment grade, high yield and
convertible corporate debt) - representing all over-the-counter market activity in these bonds.

According to FINRA, TRACE reporting compliance can be measured by the number of late trades that a
member firm reported to the Trade Reporting and Compliance Engine (TRACE).
Recent RegulatoryRule Changes
Proposed Rule Change Relating to the Expansion of TRACE to Include Asset-Backed Securities
Mortgage-Backed Securities and Other Similar Securities:
FINRA is filing with the Securities and Exchange Commission ("SEC" or "Commission") a proposed rule
change to amend the FINRA Rule 6700 Series (except for Rule 6740) and FINRA Rule 7730 to
designate asset-backed securities, mortgage-backed securities and other similar securities (collectively
defined hereinafter as "Asset-Backed Securities"), including TRACE-Eligible Securities, and to establish
reporting, fee and other requirements relating to such securities.
.
Trade Reporting Capabilities /Monitoring Requirements
Example of Our Audit Approach:
Our approach to reviewing controls over your trading environment would include:
Gaining an understanding of the type of equity and fixed income products currently traded and planned
to be traded in the near future by the Company.
Gaining a detailed understanding of the underlying systems and/or technologies that support the
Company’s order management, trade execution and trade reporting processes.
Reviewing the full “Equity” order flow from trade acceptance to trade execution and validating the
integrity (accuracy, completeness and timeliness) of trade data at each stage of transmission.
Reviewing the full “Fixed Income” order flow from trade acceptance to trade execution and validating the
integrity (accuracy, completeness and timeliness) of trade data at each stage of transmission.
Assessing existing trade reporting capabilities and controls to current trade reporting requirements and
Regulation NMS from a timeliness, accuracy and completeness perspective.
We will assess the controls in place within each system, interface, and/or reporting process to ensure
timely submission of trades, accurate submission of trade details in accordance with FINRA data
requirements and the complete submission of all trades executed including, but not limited to:
Logical Access / Security controls;
System Development / Change Management controls;
Operational controls including job and queue management;
Network integrity controls; and,
Application controls (including input, processing and output controls and data management controls).
Direct MarketAccess (DMA):An Update
Background:
Direct Market Access (DMA) tools permit buy-side traders to access liquidity pools and multiple
execution venues directly, without intervention from the sales side and/or Broker’s Desks. DMA has

existed in different forms for many years, but has not been formally or specifically regulated by the
SEC and other governing bodies. The DMA industry has morphed into what is most commonly
referred to as High Frequency Trading. Platforms now possess the ability to initiate and send between
hundreds and thousands of orders per second. This ability, also allows the buy-side to trade at a lower
commission rate than traditional Program Trading which allows for block trading.
Basic Evolution of DMA:
As DMA has evolved over the last decade, there are two distinct, foundation classifications:
“Traditional Model”: requires the customer to transmit their order first to a clearing firm’s centralized
Order Rousting System which then delivers it to the designated exchange. This was the first step
where phone calls to the broker were eliminated.
“Pure Model”: Today, the DMA model often referred to as the Pure Model..
This has led to the birth of an entire New industry called High Frequency Trading. In this model, the
order bypasses the intermediary’s infrastructure completely and goes directly to the exchange’s
platform, thus reducing the amount of stops and overall latency.
This has led to the expanding concerns and attention of many regulatory bodies, most recently being the
SEC.
DMA Nicknames:
Broker Sponsored Access;
Naked Access;
High Frequency Trading;
Pure Trading;
“Black Box” trading strategies; and,
Unfiltered Access.
Governance and Regulatory Changes:
The impact is global in nature.
On October 27, 2009, SEC Chairman Mary Schapiro announced that she has initiated a program to
create and implement “Sponsored Access” specific rules.
The SEC Chairman also announced that the SEC has been working with NASDAQ to devise a broader
rule concerning DMA for over one year. Any rule adopted by NASDAQ would be implemented by
other exchanges and their associated markets to prevent varying treatment of DMA arrangements.
On October 19, 2009 NASDAQ submitted a 54 page amendment to it’s rule proposal.
NYSE Euronext has long held the position that their exchanges operate on an uneven playing field as
compared to ECN’s which don’t have to go through the same extensive filing process that is
required.
High Priority Risks:
This has existed for over seven years, but DMA is now officially under a microscope.
New regulatory rules and controls are in the process of being developed and will soon become
requirements that must be met.
Huge reputational risk exists with non compliance, which then could cause a negative fiduciary impact.
Just as the industry learned with Sarbanes Oxley, being proactive, creating and implementing a
compliance pro-gram, identifying your specific risk exposure, and implementing necessary mitigating
controls is imperative.

Professional Organization
Standards/Frameworks
1.Association of Certified Public Accountants
(AICPA)Institute of Internal Auditors (IIA)Committee
of Sponsoring Organizations (COSO)IT Governance
Institute (COBIT)
Regulatory Agencies
2. Public Accounting Oversight Board (PCAOB)
3. Security Exchange Commission (SEC)
4. Federal Reserve Bank (FED); and,
5.Various Others
There are many reasons to partner with an outside audit firm. Some companies simply need to expand their
internal audit or risk management infrastructure where others are experiencing rapid growth and need to
improve productivity and define flexible resources. We can help you assess your existing audit function and
provide practical service solutions to meet your specific needs.
Internal Audit provides management with an independent assessment of a company’s internal control
environment on critical business processes. eDelta supports the Internal Audit function in a variety of
ways, each focused on meeting the specific needs of the client.
For companies that are required to have an Internal Audit function but would prefer not to establish a
dedicated department, we provide a full outsourcing solution. For companies looking to complement their
existing team with specialized talent or temporarily enhance staffing, we offer staff augmentation and co-
sourcing solutions.
eDelta is a trusted Internal Audit partner to many of the Fortune 500 and Global 2000. We understand the
audit lifecycle (risk assessment, scheduling, planning, execution, reporting, risk re-assessment and
planning) and the importance of working closely with audit committees, corporate executives, internal
audit directors, external auditors and other key stakeholders.
Our on demand capabilities cross multiple industry segments and extend to all aspects of enterprise risk,
including financial, operational, technology and compliance. To fully support our clients, eDelta’s
methodologies comply with the auditing standards and frameworks of recognized professional
organizations and the requirements of regulatory agencies. Of course, we are realistic in our approach at
all times and flexible in designing programs to meet your needs.
eDelta is committed to integrity, objectivity, discipline and business insight in performing Internal Audit
services. Providing meaningful value to your organization through the Internal Audit function requires an
understanding of risk priorities and risk profile. We have extensive experience in evaluating and
assessing risks associated with:
Corporate governance;
Financial accounting and reporting;
Operational efficiency and effectiveness;
Information system integrity, availability, confidentiality (infrastructure and applications);
Compliance with policies, procedures, governmental regulations and laws; and,
Investigations of fraud, thefts, losses, or allegations.
Internal Audit Assistance
Offering FullOutsourcing and Co-sourcing Solutions
Additionally:

Regulation S-P (Privacy).
Financial Responsibility Rules (Net Capital Rule, Customer Protection, Books and Records, Risk
Assessment).
Electron Media and Signatures.
Anti-Money Laundering (See AML Offering).
Chief Compliance Officers/Compliance Rules (Rule 206(4)-7 under the Advisers Act and Rule 38a-1
under the Investment Company Act).
Business Continuity Planning.
NASD /NYSE Rules and Regulations.
eDelta’s practice serves multiple sectors of the industry, including, but not limited to, Banking, Investment
Management/Securities Processing and Broker Dealer.
Financial services companies are under continued pressure to meet customer demands for new services
and comply with the growing burden of regulation - adding to the challenge of remaining competitive
versus the cost of doing business. Our focus is to provide quality financial, operational and technology
audit and compliance services and solutions to the industry to efficiently and effectively address the
challenges presented by the market, its competitors, and enhanced governmental scrutiny. Some of the
key services eDelta provides to financial services companies include:
Financial, Operational and Technology Policies and Procedures Development.
Compliance Program Development, Management and Execution.
Regulatory Examination Preparation.
Internal Audit Outsourcing and/or Assistance (including Sarbanes Oxley).
Business Process Evaluation/Re-engineering.
Technology and Security Assessment.
Business Continuity Planning and Disaster Recovery.
Broker-Dealers
Like many other financial entities, broker-dealers are facing increased scrutiny and accountability from a
variety of sources. These firms must comply with a myriad of statutes, rules and regulations promulgated
and administered by the SEC, the NASD, the NYSE and SIPC. It is now more important than ever to
develop reliable and repeatable processes for managing compliance requirements and an overall
framework for controlling corporate risk.
eDelta consultants have expertise in several specialized areas relating to broker dealers, including:
SEC Rules and Regulations
Anti-Fraud Provisions (Fair Dealing, Best Execution, Confirmation Rule, Short Sales Insider Trading,
etc.).
Analysts and Regulation AC.
NASD requirements, including 3010, 3012 and 3013.
Sarbanes-Oxley.
Anti-Money Laundering (AML).

Bank Secrecy Act (BSA)
Specialized audits, such as XXXXXXXXXXXX
Software application assessments and certifications, including trading, accounting, performance, etc.
Focus Area: Broker Dealers
eDelta Combines Financial, Business & Technology Expertise to Provide an Integrated Audit Approach in Assessing Corporate
Risk and
Control Elements
Industry Expertise: Financial Services
ExpertKnowledge ofthe Broker Dealer Sector and itChallenges
Some of Our Key Clients
eDelta Consulting, Inc.: Corporate Profile
A Trusted Partner for Your Financial,Operationaland Technologyneeds
About eDelta
eDelta is a full-service accounting, consulting, technology and recruiting company maintaining extensive
and broad expertise across numerous industry sectors. Our team brings decades of experience from
major Accounting firms, Technology companies, Recruiting and Placement organizations, Fortune 500
and Government entities.
With more than 25 consultants, offices in New York and New England and a network of partners (both
domestically and internationally), eDelta consistently provides its clients with C-Level (CEO, CFO, CIO,
CTO) guidance and the highest level of management support.

Key Services Provided
Why We Are Different
eDelta maintains the philosophy that every client and every project requires a specialized approach to
guarantee success. eDelta provides highly skilled and experienced professionals and matches the right
resources to each task every time. Our clients enjoy the benefit of working with true professionals who
understand the meaning of value in a relationship, and the importance of quality of service.
A key differentiator of our company is our total commitment to service. We maintain the highest level of
customer satisfaction, and proudly supply executive and board level references from some of the world’s
most recognized brands.
Our Experience
eDelta was founded by former senior professionals from the Big 4 who have been serving fortune 500
clients since 2000. Our partial client list below demonstrates our ability to understand and successfully
address the needs of even the most complex corporations.
Industries Served
eDelta provides professional services in the following industries:
Financial Services (Domestic/Foreign Banking, Asset Management, Mutual/Hedge Funds, Brokerage,
Exchanges);
Insurance and Re-insurance;
Retail and Manufacturing;
Pharmaceuticals, Hospital, Health Care, Medical Device and Information Services;
Media Technology and Internet;
Not-for Profit/Government;
Business and Software Services;
Diversified Electronics; and,
Delivery and Freight Services.
Direct MarketAccess (DMA):Example ofServices Provided
Algorithmic Trading and DMAin Financial Services
Scope Example:
The below is a brief example of the scope of a recent review of the Algorithmic Trading environment and
infrastructure of a
Financial Services client.
For a financial holding company who operates several registered broker-dealers and a designated
market maker in equity securities and rights listed on the New York Stock Exchange, we performed a
comprehensive assessment of all algorithmic or programmatic trading applications with direct market
access to various electronic exchanges including but not limited to NYSE Arca, Chicago Board of
Options Exchange, etc. The Company provides securities execution and brokerage services to
institutional investors and professional traders and operates as a market maker in over-the-counter,
bulletin board, and pink sheet securities. The company also operates as a:
Specialist in options, futures, and exchange-traded funds (ETFs) on various exchanges;

Market-maker in options, ETFs, and futures on various exchanges;
Market-maker for ETFs traded on the London Stock Exchange, the Euroex and Euronext exchanges;
and,
Broker-dealer in the United Kingdom.
The scope of the assessment included but was not limited to:
Ensuring that all Direct Market Access (DMA) is covered by a signed and authorized agreement.
Determining whether DMA access is limited to the list of authorized individuals provided by the Customer
and that the Customer has implemented reasonable precautions to prevent unauthorized access.
This would include a review of network, operating system and application security controls to
ensure only authorized trading activities are sent through its DMA connections.
Determine whether DMA access is appropriately monitored by both the Customer and the Company.
Ensure that trading activities are within appropriate limits and/or authorized trading products.
Ensure that program controls and adequate systems development/change controls exist within the
Company’s and selected Customer’s trading applications that reduce the risk of erroneous trading
activities.
Determine that systemic controls and policies and procedures exist that ensure compliance with rules
relating to short selling; trading halts; proper uses of order types; proper use of Inter-market Sweep
Orders; trading ahead of customer limit orders; prohibitions against manipulative trading practices,
including wash sales and marking the close; restricted lists of securities for purposes of SEC Rule
10b-18; and applicable margin rules.
Ensure the policies and procedures exist around trade confirmation and affirmation assuring timely
delivery of DVP trades.
A review of operational controls to ensure that the DMA systems and infrastructure remain available and
ensure integrity.
Direct MarketAccess (DMA):Example of Services Provided
Market Data and Exchange Review for Financial Services
Introduction:
eDelta was requested to assist a global investment firm with 250 employees with a market data services
review, to assess the clients its use and distribution of market data across the enterprise in addition to
assessing the accuracy of the market data provider invoices. Proprietary tools and spreadsheets were
developed and deployed to aggregate market data use and billing information. Through detailed
interviews with users, and detailed analytics of invoices and usage statistics, the accuracy of invoicing
was assessed.
Our client had very large fees associated relating to market data and exchanges. The goal was to
ensure that each market data provisioning was limited to what was essential to a users job responsibility.
Our review included the following:
Accuracy of Exchange fees;
Identification of duplicate charges;
Unused and/or unnecessary market data services;
User employee status changes; and,

Contract review.
Additionally, eDelta reviewed theby which market data provider responded to changes and whether
those changes were duly reflected within the invoices.
Our assessment identified gaps and provided cost-effective ways to save on market data fees,
recommendations to implement improved user on-boarding and termination procedures, and improved
market data use monitoring. We also recommended and implemented software to track and monitor
market data expenses. The review resulted in a savings of over $600,000.
Electronic Trading &MarketData
Overview
Trading firms should have written procedures in place to cover ETS day-to-day operations.
Tasks may include confirmation of market connectivity, verification of start-of-day and end-of day
positions and other critical system or business related tasks relevant to correct operation of electronic
trading platforms.
Access & Oversight
Firms must ensure their ETSs are supervised at all times while operating in the markets. Staff must have
training, experience and tools that enable them to monitor and control the trading systems and
troubleshoot and respond to operational issues in a timely and appropriate manner. Firms should have
processes to ensure trading operations staff is trained on the expected operating parameters of any ETS
for which they are responsible. For example, staff may need to know the expected number of orders per
second, maximum position, and maximum open order quantities of an algorithm.
Firms should have policies and procedures for ensuring that appropriate staff involved in supporting
electronic trading operations have the necessary authorizations with relevant exchanges, brokers or
clearing firms to inquire about order status, manage orders, execute trades by voice or screen, and
invoke exchange error trade policies. Firms should have procedures for tracking and updating such
authorizations with relevant business partners.
Each ETS should have a management console to display information about the actions and market
exposure. This management console should also provide the trader with the capability to control the
ETS.
Firms should have policies and processes for setting, modifying and tracking changes to pre and post-
trade risk checks. Policies should specify who is authorized to enter, view and modify pre- and post-trade
checks, which checks are enforced, and in what manner.
Firms should consider how responsibilities are assigned for managing pre- and post-trade checks,
inputting settings and operating other parts of the ETS and should strive to minimize potential
opportunities for unauthorized trading.

Key Controls Assessed
Change Management & Testing:
Firms should have processes in place to allow representatives from trading, risk, and software
management to approve changes and verify internal testing before a new trading system can be enabled
in production.
Conformance Testing:
Trading firms are required to pass conformance testing with the party providing access when
implementing a new direct access system or when the exchange deems it necessary because of a
fundamental change in exchange functionality. The onus is on the trading firm to determine when it must
recertify due to a change in logic within their system.
Error Control:
Trading firms should have documented procedures that direct the actions of traders, ETS trading
monitors and support staff in the event of a trading system error. The procedures should be aimed at
evaluating, managing and mitigating market disruption and firm risk and should specify people to be
notified in the event of an error resulting in violations of risk profile, or potential violations of exchange
rules.
Pre-Trade Risk Management (KeyControls)
In addition to pre-trade risk controls at the exchange and clearing firm levels, trading firms should set risk
controls at the trading firm level. We will assess the following:
Pre-Trade Risk Limits:
Trading firms should establish and automatically enforce pre-trade risk limits that are appropriate for the
firms’ capital base, clearing arrangements, trading style, experience, and risk tolerance. These risk limits
can include a variety of hard limits, such as position size and order size. Depending on the trading
strategy, these limits may be set at several levels of aggregation. These risk limits should be
implemented in multiple independent pre-trade components of a trading system.
Price Collars:
Trading systems should have upper and lower limits on the price of the orders they can send,
configurable by product. They should prevent any order for a price outside of the “price collar” from
leaving the system.
Volatility Awareness:
Trading systems should take a specified action (have an alert, pause, or automatically disable) if an
unusual price move or volume spike occurs during a specified timeframe.
Fat-Finger Quantity Limits:
Trading systems should have upper limits on the size of the orders they can send, configurable by
product. They should prevent any order for a quantity larger than the fat-finger limit from leaving the
system.
Repeated Automated Execution Throttle:

Automated trading systems should have functionality in place that monitors the number of times a
strategy is filled and then re-enters the market without human intervention. After a configurable number
of repeated executions the system should be disabled until a human re-enables it.
Outbound Message Rate:
Trading firms should limit the number of order messages their trading systems can send to the exchange
in a short period of time. These limits should be in line with exchange rules and the trading firm risk
tolerance.
Market Data Reasonability:
Trading systems should have “reasonability checks” on incoming market data as well as on generated
values.
Kill Button:
Trading systems should have a manual “kill button” that, when activated, disables the system’s ability to
trade and cancels all resting orders.
Market Maker Protections:
Firms acting as designated market makers should be aware of and, when appropriate, utilize exchange-
provided market maker protections.
Trading Interruptions:
Heartbeats Among System Components—Electronic trading systems should monitor “heartbeats” among
their various components as well as with the exchange to identify when connectivity to any system
component or the exchange has been lost. If connectivity is lost, the ETS should be disabled and
working orders cancelled by the system or through exchange provided “cancel-on-disconnect”
functionality.
Emergency Notification Procedures:
Trading operations staff should have contact details for incident response personnel responsible for
network connectivity, software development, and third-party vendors as well as market operations staff at
relevant exchanges.
Back-Up Execution Facilities:
Trading firms should have alternate execution platforms available to their traders and trading monitors in
the event that their primary systems or direct market access fail. Options include exchange, clearing firm
or ISV-provided execution platforms. In addition, firms should have documented procedures for
alternative trade execution methods (including trading desk phone numbers, account numbers, clearing
information as applicable).
Post-Execution and Back Office:
All firms should strive to maintain timely and accurate trade and account information by reconciling as
soon as practicable their own electronic trading logs with records provided by their brokers, clearing
firms, or other business partners. In satisfying this objective, firms should consider segregating trading
and back office roles and responsibilities in such a way that an

individual cannot conceal unauthorized trading activity.
Post-Trade Limits:
Trading firms can also establish and automatically enforce post-trade risk limits that are appropriate for
the firms’ capital base, clearing arrangements, trading style, experience, and risk tolerance. For example,
a trading firm can set daily loss-limits by instrument, asset class, and strategy and automatically close
out or reduce positions if those limits are breached.
Order Fill Validity:
Trading firms can monitor order fill messages they receive from the exchange in order to confirm they
are valid. Validity can be determined by a number of trade specific factors including fill price, fill quantity,
order ownership, or aggregate measures such as net positions and fill frequencies. Should an order fail
these checks, action should be taken to investigate the discrepancy.
Near Real-Time Reconciliation:
ETSs should have functionality to accept drop-copies from exchanges and clearing firms. Drop copies
are duplicate copies of orders that allow a firm to compare the exchange or clearing firm view of trades
and positions with the systems’ internal view. This helps to assure that all systems are performing as
expected and maintaining accurate and consistent views of trades and positions. The drop-copy data
may also be used by risk managers to view their firm’s risk exposure independently of the trading
system.
Information TechnologyRelated Controls
Physical Security:
Firms should consider physical security at their place (s) of business, co-location and/ or proximity sites
and be aware of the risk of access to their business infrastructure by unauthorized personnel.
Electronic Security:
Firms should consider the security of their trading and business networks and be aware of the risk of
access to their network infrastructure by unauthorized personnel. In particular, firms with direct access to
exchange matching engines should be aware of the potential, once compromised, for intruders to use
their network infrastructure to launch attacks against exchange networks or others or potentially engage
in unauthorized trading, and firms must take steps to mitigate such risk.
Business Continuity:
Firms should consider the necessity of a comprehensive disaster response plan in the context of their
business. Such plans should designate disaster response personnel with all necessary contact details.
eDelta Consulting:ClientReference Listing
Experienced, Certified Professionals:
Conducting successful audits requires a variety of specialized skill sets and relevant, real world

experience. eDelta’s team of experts have earned numerous professional designations and
certifications, demonstrating our commitment to service quality.
Some of the credentials among our team include: Certified Public Accountant (CPA), Certified Bank
Auditor (CBA), Certified Financial Services Auditor (CFSA), Certified Information Systems Auditor
(CISA), Certified Internal Auditor (CIA), Certified Information Security Manager (CISM) and Certified
Information Systems Security Professional (CISSP).
Partial Client Listing:
Below is a partial listing of eDelta clients. This shows our diverse experience in the FSI.
Alliance Bernstein (Internal Audit Assistance)
Broadridge Financial (Internal Audit Assistance)
Cenlar Bank (ERM Risk Assessment)
Fiduciary Trust Company (Internal Audit/Sarbanes Oxley Assistance)
Franklin Templeton Investments (Internal Audit / Sarbanes Oxley Assistance)
Jefferies & Company (Sarbanes Oxley Assistance)
Gabelli Asset Management (Sarbanes Oxley Assistance)
ING Bank (Sarbanes Oxley Assistance)
Instinet (Sarbanes Oxley Assistance)
LaBranche (Sarbanes Oxley Assistance)
LandesBank (Internal Audit Assistance)
Assistance)
Mizuho Capital Markets (Internal Audit Assistance)
Ridgewood Savings Bank

eDelta Trading Platform Marketing-2015

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