(Note: VERT is widely recognized by investors as a

(Note: VERT is widely recognized by investors as a market maker who abuses their market making obligations and manipulates stock prices for profit. They are the firm the less than reputable clients trade through when they want a “job done” and this enforcement case, despite the paltry fine, illustrates their willingness to avoid the rules.)

The Vertical Trading Group, LLC ( CRD #104353, NewYork, NewYork)

submitted a Letter of Acceptance, Waiver and Consent in which the firm was censured, fined $25,000 and required to revise its written supervisory procedures regarding the One Percent Rule; the dissemination of quotations to vendors; monthly order execution information; SEC Regulation SHO’s locate requirements; the acceptance of short sale orders for threshold securities; maintaining identical quotes; market order protection; best execution for block orders, not held orders and orders with special pricing terms or conditions; reporting the capacity in which trades are executed; ensuring the accuracy of trades reported on the member’s behalf; the tick test; and books and records. Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings that it failed to properly identify orders as short sale orders and, therefore, failed to report to the NNTRF the correct symbol indicating whether transactions were buy, sell, sell short, sell short exempt or cross for transactions in reportable securities, and to properly mark the orders as short. The findings stated that the firm’s supervisory system did not provide for supervision reasonably designed to achieve compliance with applicable laws, regulations and FINRA rules concerning the One Percent Rule; the dissemination of quotations to vendors; monthly order execution information; Regulation SHO’s locate requirements; the acceptance of short sale orders for threshold securities; maintaining identical quotes; market order protection; best execution for block orders, not held orders and orders with special pricing terms or conditions; reporting the capacity in which trades are executed; ensuring the accuracy of trades reported on the member’s behalf; the tick test; and books and records. The findings also stated that the firm failed to produce documentation that it enforced its written supervisory procedures concerning the marking of order tickets and locate requirements. The findings also included that the firm failed to report the correct symbol to the NNTRF or OTCRF indicating whether the firm executed transactions in reportable securities in a principal, "riskless" principal or agency capacity. (FINRA Case #2006004088101)