Order Entry, Routing, and Execution

Quick Answer

A firm controls trading through written trader mandates and Reg SHO aggregation units, then makes markets under two-sided continuous quotation standards. Reg SHO governs short-sale marking, locate, and close-out. Regulation NMS and best execution govern routing and protected quotations. The market access rule, Limit Up-Limit Down (LULD), and circuit breakers cap risk; supervisors detect and escalate violations.

The whole trading-desk supervision unit on one sheet: the structural controls, the marketplace rules, the volatility pauses, and the prohibited conduct the exam pairs together.


Structural Controls: Mandates and Aggregation Units

  • A trader mandate grants written authority: products, position limits, loss limits, counterparties, trading hours, prohibited strategies; it must be in writing AND enforced.
  • An aggregation unit under Regulation SHO nets long/short positions separately at the desk level, not firm-wide, for short-sale marking; the net long call sits at this level: long and short desks in the same security mark independently.
  • Independent netting needs four conditions: a written plan identifying each unit, its objectives, and its independence; a net position at each sale; independent strategies; and one unit per trader at a time.

Market Making and Quoting

  • Market makers must post two-sided continuous quotations within the Designated Percentage of the National Best Bid/Offer (NBBO) to bar stub quotes, during normal hours (9:30 a.m.-4:00 p.m. ET); intermittent quoting violates the standard.
  • An unexcused withdrawal can cost the firm registration in that security; a voluntarily terminated market maker may not re-register for 20 business days (equipment failure excuses it, trading losses don't).
  • A passive market maker under Regulation M may match, not exceed, the highest independent bid, capped at the greater of 30% ADTV (average daily trading volume) or 200 shares (2x minimum quotation size). Payments for market making are a bright-line ban: no issuer, promoter, or affiliate may pay for quoting or market making.

The One-Liners That Win Points

  • A short sale is marked long, short, or short exempt at order entry: "short exempt" means exempt from the alternative uptick test, though locate/close-out still apply. The locate must be documented before order entry, not before settlement; bona fide market making is exempt.
  • The order protection rule bars trade-throughs of automated, top-of-book protected quotations at the NBBO (not manual/depth-of-book quotes). Execution-quality reports are the market center's monthly duty; order-routing reports, the broker-dealer's quarterly duty, disclose payment for order flow.
  • The market access rule bars unfiltered (naked) sponsored access: every order clears the broker-dealer's pre-trade controls. The Manning rule bars trading ahead of an unfilled customer order at a fillable price.

Numbers to Lock In

ItemValue
Voluntary-termination bar20 business days
Passive market maker capgreater of 30% ADTV or 200 shares
Short-sale fail close-outstart of trading, T+1
Long-sale fail close-outstart of trading, T+3
Threshold securityfail-to-deliver 5+ consecutive settlement days, 10,000+ shares AND 0.5%+ shares outstanding
Uptick-rule trigger10% intraday decline from prior close
Uptick-rule durationrest of trigger day + next trading day
Best-execution regular/rigorous reviewat least quarterly, security-by-security AND order-type
Sub-penny increment$0.01 at $1.00+; $0.0001 below $1.00
Market access controlsreviewed & CEO-certified annually
LULD Tier 1 (S&P 500, Russell 1000)5%, doubles to 10% final 25 min, no opening doubling
LULD Tier 2 (other NMS)10%, no doubling at/above $3.00; only Tier 1 & sub-$3.00 stocks double, final 25 min
LULD mechanic15-second band breach triggers 5-minute pause
Circuit breaker Level 17% S&P 500 drop, 15-minute halt
Circuit breaker Level 213% S&P 500 drop, 15-minute halt
Circuit breaker Level 320% S&P 500 drop, halt for the day
Levels 1/2 cutoffonly before 3:25 p.m. ET
OTC piggyback quotingno gap over 4 business days

Memory Aid: Below-Market Orders Adjust Down

Memory Aid: Buy limit and Sell stop adjust DOWN for cash dividends; "BLISS" is a false trap. Sell limit and buy stop, above market, don't adjust.

Top Gotchas

  • Locate is BEFORE order entry; close-out is AFTER a settlement-date fail. A locate is not a borrow; pre-borrow needs a borrow or a bona fide arrangement to borrow.
  • A Level 1/2 circuit breaker at or after 3:25 p.m. ET does NOT halt trading; the close runs. Only Level 3 (20%) halts late, ending trading, not pausing 15 minutes. Percentages use the prior day's closing S&P 500; Levels 1/2 trigger only once per day.
  • LULD is single-stock; circuit breakers are market-wide, and LULD's reopening auction runs at the primary listing market. A trader who flips between aggregation units to mark a covered short as long commits a Regulation SHO sham-aggregation violation.
  • A failure to escalate is itself a supervisory-system failure, separate from the violation; on manipulation/front-running, the supervisor must freeze trading, preserve records immediately.

One-Breath Recap

A firm constrains trading with written, enforced trader mandates and Regulation SHO aggregation units that net long/short separately at the desk level, making markets with two-sided quotes inside the Designated Percentage, under a 20-business-day withdrawal suspension. Regulation SHO marks every sale long, short, or short exempt; demands a documented locate before order entry; closes out short fails T+1, long T+3; and imposes the alternative uptick rule on a 10% intraday drop. Regulation NMS and best execution govern routing, protected quotations, and market-center/broker-dealer reports. The market access rule blocks naked sponsored access via CEO-certified annual controls; LULD (15-second breach, 5-minute pause) and circuit breakers (7%, 13%, 20%) cap volatility; and the supervisor must detect/escalate prohibited conduct or own the supervisory-system failure.


Need more than the recap? Read the full Order Entry, Routing, and Execution unit.