RES’ practices resulted in “less favorable overall execution prices,” which means “customers received worse prices.” Credit Suisse did not disclose those practices, which are contrary to its statements to customers. The company asserted that it avoids unfavorable market impact and executes customer orders at the most favorable terms reasonably available.
In addition, investigators found that RES generally failed to provide a better price to non-605 orders. On the other hand, Rule-605 orders frequently received price improvement. Credit Suisse also did not disclose this practice despite its claim that one of the core elements of RES’ approach to executing orders is providing opportunities for “robust” and “enhanced” price improvement.
In a statement, Underwood said, “Credit Suisse gamed its publicly-reported statistics and misled customers – and now they’re being held to account. Wall Street firms cannot offer misleading assurances about the execution quality they provide their customers while engaging in electronic trading strategies that undermine those promises.”