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Credit Suisse pays $4.25 million for ‘blue sheet’ compliance gaps

Credit Suisse Securities (USA) LLC agreed Monday to pay $4.25 million for submitting deficient information to the SEC over a two-year period about trades by customers, commonly referred to as “blue sheet data.”

The New York-headquartered firm admitted violating the recordkeeping and reporting provisions of the federal securities laws.

The SEC settled the enforcement action with an internal administrative order and didn't go to court.

The SEC's order said broker-dealers like Credit Suisse are required when asked to electronically provide the SEC with blue sheet data. The SEC uses it to identify and analyze trades during investigations and other work. 

The term “blue sheet” comes from the color of the forms originally mailed to broker-dealers to complete and return to the SEC. The process shifted to an electronic format in the 1980s.

Credit Suisse admitted that during 2012 and 2013, it made at least 593 deficient blue sheet submissions to the SEC, omitting more than 553,400 reportable trades representing 1.3 billion shares. 

The broker identified "certain technological and human errors as the root cause of the deficient blue sheet submissions," the SEC said. 

Credit Suisse later made changes to ensure the accuracy of its blue sheets, "including measures to prevent, detect, and correct blue sheet data errors."

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The SEC's Securities Exchange Act of 1934 Release No. 75992 and Admininstrative Proceeding File No. 3-16835 In the Matter of Credit Suisse Securities (USA) LLC (both dated September 28, 2015) are here (pdf).


Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.