Between September 2021 and June 2022, Benchmark failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to prevent prohibited trade-throughs of protected quotations in National Market System securities. Benchmark additionally failed to take reasonable steps to establish that the intermarket sweep orders (ISOs) it routed to certain market centers met the requirements for an ISO. As a result, Benchmark violated Rules 611(a) and (c) of Regulation NMS of the Securities Exchange Act of 1934 and FINRA Rules 3110 and 2010.