Market Access Rule 15c3-5 Assessments

assessmentsThe Market Access Rule (SEC Rule 15c3-5) requires broker-dealers with market access to establish, document and maintain a system of risk management controls and supervision processes to limit financial exposure and ensure compliance with all regulatory requirements. 15c3-5 controls are ideally built into business processes, and are supported by systematic and operational controls with real-time alerts & monitoring.

Oyster can provide your firm with a 15c3-5 audit and assessment. Our services include comprehensive reviews of:

  • Supervisory and monitoring processes, procedures, tools, interactions and accountability
  • Compliance and governance processes
  • Risk management culture, processes, procedures and controls
  • Written Supervisory Procedures regarding 15c3-5 controls, Software Development Life Cycle (“SDLC”) processes, trading and market surveillance
  • Internal audit and/or internal controls assurance functions
  • Systems, architectural design and market access gateways
  • Kill switch procedures to test, execute and manage an incident
  • SDLC policies, procedures, tools and controls
  • Internal Controls review of:
    • Pre-order compliance configurations
    • Trade reporting functionality
    • Operational risk mitigation
    • Counterparty risk process
    • Surveillance and monitoring capabilities
    • Record keeping practices
    • Supervisory controls
    • System implementation controls
    • QA/Testing – automation, scope, regression, defects and approvals
    • Financial controls and reporting
    • Information security/privacy
    • Compliance with FINRA and SEC regulations

The Oyster Difference

Oyster offers practical advice that only comes from experience and industry expertise. Oyster consultants have held senior positions (CEO, COO, CCO and Head of Trading) for trading companies and broker-dealers, and know what it’s like to sit in your seat. Oyster has provided consulting services to well-known and respected High Frequency Traders and automated trading firms. We have experience with high profile 15c3-5 assessments, certifications, and independent consultant engagements on both FINRA and SEC matters. Oyster can perform a comprehensive assessment of your 15c3-5 compliance program, your technology platform, risk management and supervisory practices.