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Technical Notice

Weekend Testing Opportunity – Long Term Stock Exchange – August 15, 2020

August 14, 2020

The Long Term Stock Exchange (“LTSE”) is providing a testing opportunity this weekend in preparation for their future launch.  Firms participating in the August 15, 2020 test may send OATS data related to those orders to the OATS Certification Testing environment before the following Monday's OATS reporting deadline. OATS will then attempt to match to LTSE test data. Matching statistics for the weekend test will be provided to firms upon request and will not be published to OATS CT Website.

2019061507001 Luke C. Nelson CRD 6217103 AWC va (2020-1599959128446).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019061507001 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Luke C. Nelson, Respondent Former Registered Representative CRD No. 6217103 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Luke C. Nelson submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2020065385101 Andrew M. Arthur CRD 1864083 AWC va (2020-1599959128594).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2020065385101 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Andrew M. Arthur, Respondent General Securities Representative CRD No. 1864083 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Andrew M. Arthur submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2020066424801 Michael Erwin CRD 6774571 AWC sl (2020-1599959128402).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2020066424801 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Michael Erwin, Respondent General Securities Representative CRD No. 6774571 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Michael Erwin submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below. This AWC is submitted on the

Regulatory Notice 20-29

Summary

FINRA requests comment on the practice of internalizing customer trades in the corporate bond market after obtaining auction responses, commonly known as “pennying.” In particular, pennying involves a dealer, after receiving a customer order, initiating a bid or offer wanted auction process on behalf of a customer, reviewing the auction responses, and then executing the customer order itself at a price that either matches or slightly improves the best priced auction response.

2017055128201 BGC Financial, L.P. CRD 19801 AWC sl (2020-1599959128680).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2017055128201 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: BGC Financial, L.P., Respondent Member Firm CRD No. 19801 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent BGC Financial, L.P. (“BGC Financial” or the “firm”) submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2019063061701 Richard Denecker CRD 1065784 AWC sl (2020-1599959128647).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019063061701 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Richard Denecker, Respondent General Securities Representative CRD No. 1065784 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Richard Denecker submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below. This AWC is submitted on the