What compliance failures did the SEC identify at OTC Link LLC?
The SEC identified failures tied to required written policies and procedures for OTC Link ATS.
The areas named in the SEC action
The supplied context says the settled order cited problems in these areas:
- System security
- Access control
- Application vulnerability management
- Testing
- Remediation
The SEC said OTC Link LLC did not establish, maintain, and enforce required written policies and procedures for OTC Link ATS during the relevant period.
What exam staff had flagged
The context also says SEC examination staff had flagged missing, draft, or unenforced policies and procedures several times during the period covered by the order.
The provided material does not include every detail of those examinations, so the SEC source should be checked for the official wording and any updates.
What period did the SEC say OTC Link LLC’s Regulation SCI violations covered?
The SEC said OTC Link LLC’s Regulation SCI violations covered the period from August 2016 to March 2025.
The period covered
The supplied context gives this timeline:
| Item | Detail |
|---|---|
| Start | August 2016 |
| End | March 2025 |
| Entity | OTC Link LLC |
| Platform referenced | OTC Link ATS |
| Issue | Required written policies and procedures |
During that period, the SEC said OTC Link LLC did not establish, maintain, and enforce required written policies and procedures for OTC Link ATS.
Why the long period matters
The context describes the violations as long-running and says SEC examination staff flagged policy and procedure issues several times during the period.
For the exact language of the settled order and any later updates, use the SEC announcement directly.
How much did OTC Link LLC have to pay in the SEC order?
OTC Link LLC was ordered to pay a $575,000 civil penalty.
The payment amount
The supplied context says the SEC censured the New York-based broker-dealer and ordered a $575,000 civil penalty.
That penalty was part of an action concerning Regulation Systems Compliance and Integrity, often referred to as Regulation SCI.
What the penalty was tied to
The order concerned failures involving required written policies and procedures for OTC Link ATS. The cited areas included system security, access control, application vulnerability management, testing, and remediation.
The context does not provide payment timing or other settlement mechanics. Check the SEC source for the official order language and current status.
What should broker-dealers operating ATS platforms review after this SEC action?
Broker-dealers operating ATS platforms can use the OTC Link action as a prompt to review the areas the SEC specifically cited.
Review areas named in the SEC action
The supplied context points to these practical areas:
- Written policies and procedures
- System security
- Access control
- Application vulnerability management
- Testing
- Remediation
For OTC Link ATS, the SEC said required written policies and procedures were not established, maintained, and enforced during the relevant period.
What this does not add
The provided material does not create a checklist for every broker-dealer, and it does not describe new requirements. It only identifies the areas cited in this SEC action.
Firms looking for current obligations should compare the SEC’s official wording with their own Regulation SCI procedures and any updated regulatory materials.
Sources / Learn more
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