Goldman to Pay SEC $6 Million in Penalties for Providing Deficient Blue Sheet Data

The Securities and Exchange Commission (SEC) has made an official announcement regarding the resolved charges against Goldman Sachs & Co. LLC. These charges pertain to the firm’s failure to provide complete and accurate securities trading data, commonly referred to as “blue sheet data,” to the SEC. As part of the resolution, Goldman has agreed to pay a penalty of $6 million to settle the SEC’s allegations.

According to the SEC’s order, spanning approximately ten years, Goldman submitted more than 22,000 blue sheet reports to the SEC that were found to be deficient. These submissions contained a staggering 43 different types of errors, leading to missing or inaccurate trade data for a minimum of 163 million transactions. Furthermore, the order highlights Goldman’s lack of adequate processes to verify the accuracy of the electronic blue sheet submissions.

Thomas P. Smith Jr., Associate Regional Director in the New York Regional Office, emphasized the importance of providing complete and accurate blue sheet data, stating, “Firms must provide complete and accurate blue sheet data in response to our requests. Blue sheet data is vital to the Commission’s ability to carry out its enforcement and regulatory functions and to protect investors and maintain market integrity.”

The SEC’s order unequivocally states that Goldman willfully violated the broker-dealer recordkeeping and reporting provisions established by federal securities laws. Goldman has admitted to these findings as outlined in the SEC’s order, and as part of the settlement, they have agreed to censure and to pay the $6 million penalty. Additionally, the order acknowledges that Goldman has embarked on remedial actions aimed at addressing and enhancing its blue sheet reporting systems and controls. These efforts included conducting a comprehensive review of its reporting program, leading to the self-reporting of 29 of the 43 error types cited in the order, along with significant enhancements in supervisory controls.

It is also worth noting that the Financial Industry Regulatory Authority (FINRA) separately reached a settlement with Goldman related to the same conduct.