The Hong Kong Securities and Futures Commission fined BNP Paribas Securities (Asia) Limited HK $15 million (almost US $2 million) for alleged failures in its dark liquidity pool trading services known as the BNP Internal Exchange (BIX). Among other breakdowns, SFC claimed that, in promotional materials provided to clients, BNP represented that orders on BIX would be executed in accordance with order price priority, meaning that bids with higher prices would receive priority over bids with lower prices, and offers with lower prices would receive preference over offers with higher prices. However, said SFC, between November 2009 and April 2011, BIX treated all orders equally, and allocated executions pro rata, based on order size. In addition, after BNPP discovered the unintended order priority issues in April 2011, BNPP suspended BIX’s operations for 13 days, and then did not fully restore all services until December 2011. However, claimed SFC, the firm never disclosed this suspension to SFC despite being required to notify the regulator “about incidents of material service breakdown or disruption of the operations of the BIX affecting its users.” According to SFC, “given the use of dark liquidity pool for trading is on the rise in recent years, it is imperative that BNPP Securities Asia, as a dark liquidity pool trading service provider and operator, must ensure BIX users are provided with sufficient information to enable them to understand how their orders are handled and executed in the BIX.”