Between December 2021 and December 2024, ATMC failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with rules and laws prohibiting manipulative trading, including prearranged and coordinated trading, momentum ignition trading, layering and spoofing, and marking the close, in violation of FINRA Rules 3110(a) and (b) and 2010. For these violations, Respondent is censured and fined $12,500.

Between October 2021 and December 2024, FMS violated FINRA Rules 2121 and 2010 by charging unfair prices in 115 corporate bond transactions. During the same period, and continuing through the present, the firm failed to establish and maintain a supervisory system reasonably designed to achieve compliance with its fair pricing obligations relating to corporate bonds, in violation of FINRA Rules 3110 and 2010. For these violations, FMS is censured, fined $130,000, and required to certify that it has remediated the issues identified in this AWC.