Susan Merrill Quotations

A broker-dealer cannot place the financial markets, and its customers, at risk by its own inadequacies, especially in the areas of anti-money laundering and customer accounts.

This case is a stern reminder that firms must have adequate procedures to supervise and control transfers of assets from customer accounts. It goes to the heart of customers' expectations that their money is safe.

Blue sheets are an essential component of NYSE investigations into insider trading, market manipulation and other potential violations. Firms must get their operations in order, then periodically test their internal systems to be sure this vital information is accurate. We cannot allow the failure of firms to respond accurately and completely to regulatory requests for information to impede our investigations.

It is vital for firms to carefully supervise trades relating to business strategies pegged to the closing price to protect customers and the market from excess volatility.