Nasdaq Texas (NTX Options )has posted a notice of disciplinary action against Susquehanna Securities, LLC.

In 48 separate instances on 46 unique trade dates between August 14, 2023, and March 31, 2025, the firm, while acting as a Market Maker or Lead Market Maker, failed to provide two-sided quotations in 60% or 90% of the cumulative number of seconds for which the firm’s assigned options series were open for trading.

The violations were caused primarily by confusion regarding the methodology the Exchange uses to calculate firms’ compliance with continuous quoting obligations.

The conduct constitutes violations of NTX Options Rule Options 2, Sections 4(j) and 5(d)(1).

During the Review Period, the firm’s written supervisory procedures (WSPs) and supervisory system were not reasonably designed to achieve compliance with NTX Options Rule Options 2, Sections 4(j) and 5(d)(l).

Specifically, although the firm utilized a live monitoring tool to assess its aggregate quoting performance in real-time, the system did not generate alerts or exceptions for the firm to review, and did not differentiate between the firm’s various market making obligations. As a result, the firm unreasonably relied on reports provided by the Exchange to monitor its continuous quoting compliance.

Additionally, the firm’s WSPs did not sufficiently explain the supervisory steps and reviews to be taken by compliance personnel during their review of the firm’s internal heat map. Specifically, although the WSPs direct compliance personnel to review certain reports, they do not inform compliance personnel of the Firm’s various continuous quoting obligations, the firm’s market maker designation, or the Exchange’s calculation methodology.

The conduct constitutes a violation of Nasdaq Texas Rule General 9, Sections 20(a) and 1(a).

The firm has agreed to the imposition of the following sanctions:

1. A censure;
2. A fine in the amount of $180,000, of which $39,600 will be paid to Nasdaq Texas, and
3. An undertaking to provide a certification that the firm has (a) remedied the issues and (b) revised its WSPs and surveillance system.