Market Access Rule 15c3-5 Assessments
The Market Access Rule (Rule 15c3-5) remains on FINRA’s priority list – they provided guidance on the rule and initiated enforcement actions against firms struggling to adhere to it. Oyster Consulting often works with clients after the regulators have reviewed their Market Access programs and found them insufficient. It is in your firm’s best interest to take a proactive look at your Market Access program and get it in good order.
FINRA noted in its 2020 Risk Monitoring and Examination Priorities Letter that the continued growth of automated and high-speed trading increases potential risks to the financial condition of firms and the integrity the securities markets. As a result, FINRA stated it would assess firms’ compliance with SEC Rule 15c3-5 (Market Access Rule), focusing on issues relevant to firms’ business activities and associated risks. In recent enforcement cases, FINRA reminded its members that the Market Access Rule applies to fixed income trading in addition to automated, high-speed equity trading.
You can learn more about the Market Access Rule and what your firm should be doing by listening to the Oyster Stew podcast below:
The Oyster Difference
Oyster has done market access control reviews for some of the largest trading firms. In some instances, Oyster was the Independent Consultant retained as an undertaking of an enforcement action to review
a firm’s 15c3-5 controls across each of the technology frameworks. The review consisted of a review of schematics, written descriptions, WSPs related to 15c3-5 controls, 15c3-5 controls test plans, control inventories, test scripts, test results, SDLC practices, and documentation. At other firms, we have conducted higher level, less extensive reviews of those same controls and procedures.