The object is Knight Capital Americas LLC on the morning of 1 August 2012. The firm deployed new code in SMARS, its automated equity order router, so customers could use the New York Stock Exchange's Retail Liquidity Program that day. The new code reused a flag that had once turned on an unused function called Power Peg. On seven of eight servers the flag now meant RLP. On the eighth it still meant Power Peg. Power Peg's share-counting had been moved in 2005 and never retested, so that server sent child orders without regard to fills. Knight stayed connected to the markets for about forty-five minutes while staff tried to find the bug. There was no halt that would stop SMARS from sending without first knowing which server was wrong.
Domain: production deployment of a system that can send orders into a public market, and the difference between watching positions after they exist and stopping the next order from leaving.
If that reading is right, a flag that still calls unused code would not be reused for a new product. A router that can send child orders would have a stop that fires from its own output — child orders leaving versus parent orders that came in, or a firm-wide capital cap wired to order entry — without waiting for someone to name the defect. Uninstalling the new code from the servers that were working would not count as incident response.
Ostensive specimen: Securities and Exchange Commission, In the Matter of Knight Capital Americas LLC, Administrative Proceeding File No. 3-15570, Exchange Act Release No. 70694 (16 October 2013). Knight, without admitting or denying the findings, consented. The order is the public record of the flag, the eighth server, the missing halt, and the 45 minutes. https://www.sec.gov/litigation/admin/2013/34-70694.pdf Same file: https://www.sec.gov/files/litigation/admin/2013/34-70694.pdf Press release 2013-222: https://www.sec.gov/newsroom/press-releases/2013-222
What the order records, not recap. Beginning 27 July 2012, a technician copied the new RLP code onto SMARS servers on successive days and missed one of eight. No second technician reviewed the copy. Knight had no written procedure that required one. On 1 August the seven updated servers handled RLP orders. The eighth, still holding Power Peg, treated the reused flag as a call to that old function. For 212 incoming parent orders, SMARS sent millions of child orders, more than 4 million executions in 154 stocks, more than 397 million shares, in about 45 minutes. Knight ended with a net long of about $3.5 billion in 80 stocks and a net short of about $3.15 billion in 74. The Commission found a loss of more than $460 million on those positions.
The next-day number from the firm: Knight Capital Group, Inc., Form 8-K (2 August 2012), Exhibit 99.1. Realized pre-tax loss of approximately $440 million after trading out of the erroneous position. Software removed. Broker-dealer subsidiaries still in net-capital compliance. https://www.sec.gov/Archives/edgar/data/1060749/000119312512332176/d391111d8k.htm https://www.sec.gov/Archives/edgar/data/1060749/000119312512332176/d391111dex991.htm
The halt that was not there. Knight had controls before orders reached SMARS, and a 9.5 percent limit-price cap on parent orders that did not apply to these 212 pre-open orders and would not have stopped child orders while the quote moved less than 9.5 percent. It had no control that compared what left SMARS with what entered it, and no procedure to halt SMARS for its own aberrant output. The 33 Account, which held unmatched executions, had a $2 million gross position limit that was not linked to any automated firm-wide capital threshold that would stop order entry. PMON, the primary risk screen, was post-execution, human-watched, without automated alerts, and delayed in a high-volume event. One attempt to fix the live system uninstalled the new RLP code from the seven good servers and turned Power Peg on there too.
The signal that was not used as a stop. Starting about 8:01 a.m. ET, an internal system sent 97 automated "BNET reject" messages that named SMARS and the error "Power Peg disabled." They were not designed as system alerts and were not acted on before the open.
The rule already on the books: Exchange Act Rule 15c3-5, the market access rule, adopted November 2010, with an initial compliance date of 14 July 2011. Brokers with market access must have controls reasonably designed to prevent erroneous orders and orders that exceed pre-set capital thresholds, in the aggregate, for the firm. This was the Commission's first enforcement under that rule. https://www.sec.gov/files/rules/final/2010/34-63241.pdf
NYSE's RLP, the product the deploy was for: Exchange Act Release No. 34-67347 (3 July 2012), approving the 12-month pilot. https://www.sec.gov/files/rules/sro/nyse/2012/34-67347.pdf
Aftermath, not the object: on 6 August 2012 Knight sold $400 million of convertible preferred stock (about 73 percent of the common on an as-converted basis) under the NYSE's financial-viability exception to shareholder approval. https://www.sec.gov/Archives/edgar/data/1060749/000119312512338098/d392396dex992.htm