TD Securities (USA) LLC, as successor to Cowen & Company LLC, has agreed to pay a fine of $85,000 as a part of a settlement with Nasdaq Texas LLC.

Cowen and TD Securities USA became members of Nasdaq Texas in January 2009 and December 2024, respectively. Effective December 9, 2024, Cowen merged into TD Securities USA, whose registration on Nasdaq Texas remains in effect.

TD Securities USA is a broker-dealer whose business includes making inter-dealer markets in debt and equity products. Neither Cowen nor TD Securities USA has a relevant disciplinary history.

During the period from at least November 2, 2021, through April 12, 2026 (the “Relevant Period”), Cowen’s and later TD Securities USA’s pre-trade controls and supervisory system were not reasonably designed in multiple respects to prevent erroneous orders.

First, the Firm’s Average Daily Volume (ADV) control was set too high to effectively complement the firm’s single-order volume and notional value controls. Also, the firm’s Price Away control exceeded the Exchange’s numerical guidelines for erroneous transactions in certain circumstances.

Additionally, the firm sent orders to the Exchange in several specific circumstances without pre-trade controls reasonably designed to prevent erroneous orders.

Finally, until July 2025, the firm lacked a supervisory system, including Written Supervisory Procedures (WSPs), reasonably designed to document and review traders’ overrides of soft blocks triggered by the firm’s pre-trade controls.

Based on the conduct described in the settlement, the firm violated Securities Exchange Act Rules 15c3-5(b) and 15c3-5(c)(1)(ii) and NTX General 9, Sections 20(a) and 1(a).

The firm has agreed to a censure in addition to the $85,000 fine.