Five Years. 21 Quarters. Zero Disclosures.

T3 Trading Group has been a FINRA-registered member firm since October 2019. The firm operates out of New York City, runs four branch offices, and employs approximately 200 registered representatives. Its core business is day trading and proprietary trading in exchange-listed stocks, equity options, and futures. Since January 2020, T3 has also operated a retail day-trading business, meaning everyday people trade through them.

Under federal law — specifically Rule 606(a) of Regulation NMS under the Securities Exchange Act of 1934 — every broker-dealer handling customer orders in National Market System (NMS) securities must publish a quarterly public report. That report must disclose where the firm routes customer orders, which venues get the most business, how much money the firm receives in payment for order flow, and whether any financial arrangements with those venues could influence routing decisions. The entire point is to let customers see whether their broker is routing their orders to get the best possible outcome for them, or the best possible outcome for the broker’s wallet.

T3 began accepting non-directed options orders from retail customers in January 2020, which triggered the Rule 606(a) reporting obligation immediately. The firm published no reports at all for the entire year of 2020. A FINRA examination eventually exposed what was happening, and the full timeline of concealment runs from April 2020 to April 2025: a five-year span covering 21 consecutive quarters without a single compliant disclosure.

They Didn’t Just Miss Deadlines. They Filed Blank Pages.

Starting in July 2021, T3 did begin publishing something every quarter. Regulators describe what those documents actually contained: blank versions of the sample reports available on the SEC’s own website. The firm downloaded templates from the government’s public resources, left them empty, slapped a “Rule 606” label on them, and called it compliance. This continued for years.

For five specific quarters — Q1 2022 through Q1 2023 — T3 also filed a second supplemental document that contained some actual data. But even those documents were missing the core required disclosures: order routing percentages, execution venue identification, payment-for-order-flow calculations, and any description of the firm’s financial relationships with the venues handling customer trades. Customers reading those reports would still have had no usable information about how their orders were handled.

The total damage: 21 quarters of required information withheld from the public. Five years of customers trading through T3 without the legally mandated right to know where their orders were going, who was getting paid to receive them, or whether those payments were influencing the quality of their executions.

What Was Actually Stolen From You

There is a reason this rule exists. Payment for order flow — the practice of brokerage firms receiving money from trading venues in exchange for routing customer orders to them — is one of the most quietly corrosive conflicts of interest in the retail investing world. When your broker gets paid by a venue to send your orders there, your broker has a financial incentive that has nothing to do with getting you the best price on your trade. Rule 606(a) was designed to drag that conflict into the open, to make firms publish exactly what they received and from whom, so customers could evaluate whether they were getting a fair shake.

T3’s retail customers, from January 2020 onward, had the legal right to that information every single quarter. They never got it. For an entire year — all four quarters of 2020 — the firm filed nothing. If a customer had gone looking for their quarterly disclosure during that period, they would have found a void. They could not evaluate their broker’s routing practices. They could not assess conflicts of interest. They could not make an informed decision about whether to stay with T3 or take their business elsewhere.

The Fake Compliance That’s Actually Worse Than Nothing

What T3 did starting in July 2021 is arguably more insulting than the initial blackout. The firm began downloading blank report templates from the SEC’s own public website and filing them as official disclosures. Imagine asking your bank how they’re investing your savings and being handed an empty form with your question printed at the top. That is precisely what T3 delivered to its customer base, quarter after quarter, for nearly four years. The performance of compliance while delivering none of the substance is a specific kind of contempt for the people you’re supposed to serve.

The firm’s own internal rulebook — the Written Supervisory Procedures that are supposed to be the backbone of a compliant brokerage operation — contained a claim that regulators found to be factually incorrect. T3’s procedures stated that all of the firm’s options orders were “directed” orders, meaning customers specifically chose the routing destination themselves. If that were true, the orders would be exempt from Rule 606(a) reporting. But the firm does handle non-directed orders, and regulators confirmed this. The false exemption claim sat in T3’s official policies from December 2021 until regulators forced a correction. It was the written justification the firm could point to if anyone came asking. It was a paper shield built on a factual lie.

The Supervisory System Was the Con, Not Just the Coverage

The deeper problem is structural. T3 did not simply forget to file reports. The firm operated, from January 2020 to the present, without any supervisory process designed to check whether its Rule 606(a) reports were complete or accurate. Even after the firm finally wrote down some WSP policies in December 2021, those procedures contained no guidance on reviewing the reports for completeness. Nobody at T3 was formally assigned to ask: “Is this right? Is this complete? Does this actually tell our customers what the law requires us to tell them?” That is a governance failure that runs straight to the top of the organization.

Straight From the Document. No Spin.

These are direct, verbatim passages from the official FINRA enforcement document. T3 agreed to these factual findings. The firm signed this.

Why This Isn’t Just a “Compliance Paperwork” Problem

Professional traders and institutional investors have always had access to information that retail investors do not. Rule 606(a) was a rare attempt to close one specific corner of that gap. It forced brokerage firms to publish, in plain terms, the financial arrangements that influence where your order goes after you click “buy.” Payment for order flow, venue rebates, profit-sharing relationships with execution venues: these are practices that can quietly erode the quality of trade executions for retail customers while generating revenue for the firms handling their orders.

T3 serves approximately 200 registered representatives and runs a retail day-trading business line that launched in January 2020. Retail day traders are, by definition, people who are actively trying to build wealth through frequent trading. The quality of order execution on each individual trade matters to them in a direct and concrete way. Across five years and 21 quarters, T3’s retail customers placed trades without the ability to evaluate whether the firm’s routing practices served their financial interests or the firm’s. That is the definition of an information-based power imbalance, and it falls hardest on the people with the least margin for error.

The irony is structural: the customers who most needed this information — active retail traders trying to compete in a market dominated by professionals — were the exact customers T3 kept in the dark. The firm’s retail day-trading business line was new. Those customers chose T3 without the ability to compare its routing practices against competitors using disclosed data, because T3 never provided that data. Informed consumer choice, the cornerstone of a functioning market, was made impossible by the firm’s silence.

FINRA fined T3 $175,000 ($175,000 is roughly equivalent to the annual salary of one mid-level compliance officer — the exact type of professional whose job T3 refused to fund or empower). This is the financial consequence for five years of systematic non-disclosure affecting customers across four branch offices and a 200-person firm. The fine covers a period during which T3 operated its retail business, collected commissions and fees, and received whatever payment-for-order-flow arrangements it maintained with execution venues — none of which it disclosed.

There is a clear asymmetry in who bears the cost of enforcement at this scale. FINRA staff spent time and resources conducting the examination that uncovered these violations. The regulatory infrastructure that protects retail investors costs money to operate. T3 paid $175,000 ($175,000 is roughly what the average American household would need to save for nearly three years at the current national median savings rate) to close out five years of violations. The fine does not include any restitution to customers. There is no compensation mechanism in this settlement for people who traded through T3 during the blackout period and may have received inferior order execution they had no way to detect or challenge.

The Price Tag on Five Years of Silence

Who’s Responsible, Who’s Watching, and What You Can Do

The Firm’s Leadership

The AWC was signed on behalf of T3 Trading Group, LLC by Garret Marquis, Chief Executive Officer, on August 15, 2025. FINRA’s enforcement counsel Becket Marum accepted the settlement on August 21, 2025. The AWC becomes part of T3’s permanent disciplinary record. Per the settlement terms, a senior management principal must certify in writing within 90 days that the firm has corrected its supervisory systems. That certification goes directly to FINRA’s enforcement team.

The Watchlist: Who Regulates This Space

• FINRA (Financial Industry Regulatory Authority): The self-regulatory body that brought this action. You can check any broker’s disciplinary history at BrokerCheck: finra.org/brokercheck
• SEC (Securities and Exchange Commission): Rule 606(a) is an SEC rule. The SEC oversees Regulation NMS and the broader framework of retail investor protection in equity markets.
• CFPB (Consumer Financial Protection Bureau): Monitors financial products that harm everyday consumers, including retail investment products.
• Your state securities regulator: Every state has a securities division. They can investigate broker misconduct independently of federal bodies and sometimes move faster.

The Undertaking: T3’s Obligations Going Forward

T3 is required by the settlement to implement a compliant supervisory system, produce accurate Rule 606(a) reports, and have a registered principal certify the remediation in writing within 90 days of the AWC’s acceptance. FINRA staff retains the right to request further evidence of that remediation. This agreement becomes part of the firm’s permanent record and can be used in any future regulatory action. If T3 violates Rule 606(a) again, regulators will have this history on file.

What You Can Do Right Now

If you traded through T3 between January 2020 and April 2025, you can file a complaint with FINRA at finra.org/investors/have-problem. You can check T3’s full regulatory history on BrokerCheck. You can share this article with anyone in your life who uses a retail brokerage, because this enforcement action is a reminder that the disclosures these firms are legally required to publish exist for a reason, and firms routinely test whether anyone is paying attention.

The single most powerful thing retail investors can do is read the disclosures that brokers file and demand answers when those disclosures are missing, vague, or late. Enforcement only catches what gets examined. You are the first line of detection.