On January 14, 2011, the SEC charged BNY Mellon Securities LLC, a formerly registered broker-dealer, for its failure to reasonably supervise the order desk manager on its institutional order desk and traders under his supervision from November 1999 through March 2008. During the relevant period, the institutional order desk executed orders to purchase and sell securities on behalf of a BNY Mellon affiliate, Mellon Investor Services LLC, an administrator for various employee stock purchase plans, employee stock option plans, direct stock purchase and sale plans and similar plans (the “plan customers”). According to the SEC, BNY Mellon’s order desk manager failed to meet his duty of best execution to certain plan customers by executing many of their orders at stale or inferior prices, which in many instances were outside of the national best bid and offer at the time of execution, in cross trades with a favored handful of accounts held by hedge funds and individuals and instructing traders under his supervision to do the same. BNY Mellon agreed to pay $19 million of disgorgement, plus prejudgment interest of approximately $4 million, and $1 million in civil penalties.