I received an interesting response from an exchange official when I queried him why a substantial, top-tier privately held proprietary trading group would have a very modest broker/dealer filing with the SEC and FINRA. His response made sense. His explanation was that if a firm's trader required a broker/dealer status in order to accomplish some sort of equities-related arbitrage spread, that the firm would typically set up a broker/dealer subsidiary and only fund it to the extent that the particular trader required in order to execute his trade.
For example, DRW Trading Group is a privately held proprietary trading firm based out of Chicago that has four offices and five hundred employees. And they are definitely a top-tier proprietary trading group - no reasonable person could argue the point. http://drw.com/about-us/
Yet, in 2012, DRW was fined by the CBOE for operating as a broker-dealer under SEC Rules and allowing their minimum net capital to fall below $250K.
http://www.cboe.com/publish/DisDecision/11-0042.pdf
So this entire notion that a public filing like a SEC broker/dealer filing will define the relative size of a privately-held, upper tier proprietary trading firm just does not hold water.
Same thing with setting up a shell subsidiary to trade power in an ISO like PJM. The margin capital that a proprietary trading firm's power trading subsidiary company reports to the ISO does not necessarily reflect the size of the parent firm. If you will recall, there were a few prominent HF's that had limited financial liability regarding PJM power trading losses because of their subsidiary's limited capitalization and that is another great case study regarding this.
For example, DRW Trading Group is a privately held proprietary trading firm based out of Chicago that has four offices and five hundred employees. And they are definitely a top-tier proprietary trading group - no reasonable person could argue the point. http://drw.com/about-us/
Yet, in 2012, DRW was fined by the CBOE for operating as a broker-dealer under SEC Rules and allowing their minimum net capital to fall below $250K.
http://www.cboe.com/publish/DisDecision/11-0042.pdf
So this entire notion that a public filing like a SEC broker/dealer filing will define the relative size of a privately-held, upper tier proprietary trading firm just does not hold water.
Same thing with setting up a shell subsidiary to trade power in an ISO like PJM. The margin capital that a proprietary trading firm's power trading subsidiary company reports to the ISO does not necessarily reflect the size of the parent firm. If you will recall, there were a few prominent HF's that had limited financial liability regarding PJM power trading losses because of their subsidiary's limited capitalization and that is another great case study regarding this.
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