From March 2020 until August 2022, Virtu failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with the firm’s limit order display obligations. As a result, Virtu violated FINRA Rules 3110 and 2010. For these violations, Virtu is censured and fined $100,000, of which $20,000 shall be paid to FINRA.

From April 2021 through at least May 2025, Brown Associates failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with the firm’s obligations to conduct reasonable due diligence on private placement offerings sold by the firm to retail customers. During the same period, Brown Associates failed to identify and reasonably respond to material discrepancies that appeared in offering documents in several private placement offerings.