The Financial Industry Regulatory Authority (FINRA), the largest independent regulator for all securities firms ‎doing business in the United States, today fined Virtu Americas LLC (formerly KCG Americas LLC) for a handful of violations and failures.

The core allegations are centered around the broker’s methodology governing the  Execution  Execution Execution is the process during which a client submits an order to the brokerage, which consequently executes it resulting in an open position in a given asset. The execution of the order occurs only when it is filled. There is typically a time delay between the placement of the order and the execution which is called latency.In the retail FX space, reliable brokers always strive to deliver best execution to their clients in order to maintain a solid business relationship with them. This is a common marketing point of emphasis by brokers, whose action execution varies considerably from company to company. When execution prices are not matching the submitted price the client is charged or credited the difference resulting from the negative or positive slippage.Slippage is a very contentious issue among retail traders, which can lead to issues. Many traders view levels of slippage at brokers as a key determinant for their business. Best Execution a Legal ObligationBrokers are required by law to diver to their clients the best execution possible. Some regulators are requiring brokers to submit execution stats in order to assess the quality of their services. Other brokers are regularly posting execution statistics in order to boost the confidence of their clients in the best execution commitment of the company.Best execution has been a point of emphasis in recent years from both retail and institutional players in the FX industry. Negotiating and executing transactions in order to promote a robust, fair, open, liquid and appropriately transparent FX market is identified as one of the six main principles outlined in the FX Global Code of Conduct, which came into effect in 2018. Execution is the process during which a client submits an order to the brokerage, which consequently executes it resulting in an open position in a given asset. The execution of the order occurs only when it is filled. There is typically a time delay between the placement of the order and the execution which is called latency.In the retail FX space, reliable brokers always strive to deliver best execution to their clients in order to maintain a solid business relationship with them. This is a common marketing point of emphasis by brokers, whose action execution varies considerably from company to company. When execution prices are not matching the submitted price the client is charged or credited the difference resulting from the negative or positive slippage.Slippage is a very contentious issue among retail traders, which can lead to issues. Many traders view levels of slippage at brokers as a key determinant for their business. Best Execution a Legal ObligationBrokers are required by law to diver to their clients the best execution possible. Some regulators are requiring brokers to submit execution stats in order to assess the quality of their services. Other brokers are regularly posting execution statistics in order to boost the confidence of their clients in the best execution commitment of the company.Best execution has been a point of emphasis in recent years from both retail and institutional players in the FX industry. Negotiating and executing transactions in order to promote a robust, fair, open, liquid and appropriately transparent FX market is identified as one of the six main principles outlined in the FX Global Code of Conduct, which came into effect in 2018. Read this Term and priority of pending orders from May 2013 to September 2019. In particular, Virtu did not have a written execution methodology for OTC equity securities that were handled manually and executed outside of the firm's automated Manning system.

For instance, Wall Street’s industry-funded watchdog found that the firm executed 35 percent of its OTC orders manually outside of its Manning system, while it did not have a written document addressing priority requirements for such orders. Given the firm's size in the OTC market, the failure to have a written methodology document for manually executed orders created a substantial risk.

A disruption to market trading standards

In addition to violating these rules, FINRA found that certain order types for NMS securities, such as stop orders and certain orders in Nasdaq-listed securities, were also handled manually prior to market open. This act may provide an advantageous trading price to the market maker while inhibiting the fair price for its clients.

Overall, regardless of the motivation, Finra considered these violations a disruption to market trading standards, which regulators seek to uphold for all investing participants. Making it worse, Virtu was described by the Finra as "one of the largest OTC  Market Makers  Market Makers Market makers or called dealing desk brokers represent a type of broker that internalize flows and are taking the opposite side of a transaction submitted by their clients. The market making broker is only quoting a feed of prices to its clients. These feeds may or may not be the exact same as the prices quoted on the interbank market.Any order a client enters is processed internally and never goes out to the market, except in rare cases where a market making brokerage identifies a client as a very high risk and chooses to route the flow to another liquidity provider.Such brokers are typically providing very quick execution, however an inherent conflict of interest is possible due to the fact that the brokers is making the bulk of its profits from client losses.Role of Market Makers in FX IndustryIn the FX space, a market maker quotes two-way prices for tradable currency pairs. In doing so these market makers quite literally make the market. In particular, a forex market maker performs three specific tasks.This includes setting bid and offer prices within a given currency pair, committing to accepting deals at these prices within certain constraints, and taking the resulting exposure on to their own book.In terms of accounting for this exposure onto their book, market makers can opt to hedge the exposure with another bank, pending favorable rates. How quickly or slowly, or how much risk they lay off will be at their own discretion.Market makers can make profit through several techniques. If these entities identify enough flow at both sides of their quote, they can simply collect the bid offer spread.Consequently, market makers can net off their exposure. Presently, large banks see huge flows of foreign currency transactions from their operations around the world in a multi trillion-dollar-a-day industry. Market makers or called dealing desk brokers represent a type of broker that internalize flows and are taking the opposite side of a transaction submitted by their clients. The market making broker is only quoting a feed of prices to its clients. These feeds may or may not be the exact same as the prices quoted on the interbank market.Any order a client enters is processed internally and never goes out to the market, except in rare cases where a market making brokerage identifies a client as a very high risk and chooses to route the flow to another liquidity provider.Such brokers are typically providing very quick execution, however an inherent conflict of interest is possible due to the fact that the brokers is making the bulk of its profits from client losses.Role of Market Makers in FX IndustryIn the FX space, a market maker quotes two-way prices for tradable currency pairs. In doing so these market makers quite literally make the market. In particular, a forex market maker performs three specific tasks.This includes setting bid and offer prices within a given currency pair, committing to accepting deals at these prices within certain constraints, and taking the resulting exposure on to their own book.In terms of accounting for this exposure onto their book, market makers can opt to hedge the exposure with another bank, pending favorable rates. How quickly or slowly, or how much risk they lay off will be at their own discretion.Market makers can make profit through several techniques. If these entities identify enough flow at both sides of their quote, they can simply collect the bid offer spread.Consequently, market makers can net off their exposure. Presently, large banks see huge flows of foreign currency transactions from their operations around the world in a multi trillion-dollar-a-day industry. Read this Term in terms of dollar, trade, and share volume" as it was the wholesale market maker for 10,000 OTC securities with a trading desk of 25 staff.

Virtu makes markets over 25,000 financial instruments, at over 235 venues, in 36 countries worldwide, continuously quoting buy and sell prices for others to trade against, profiting off the bid-offer spread, using high-frequency trading (HFT) strategies.

In 2017, Virtu Financial acquired rival KCG Holdings Inc. for $1.4 billion in cash, as tough market conditions forced high-frequency traders to consolidate and rethink business strategies. The combined entity created a giant HFT firm responsible for around 20 percent of the volume in US equities.