Charles Fraud hereby recognizes MarketAxess Corporation for their "pattern and practice" of misreporting trade execution times to the Real-time Transaction Reporting System (RTRS) due to the firm's "incorrect interpretation of the time of trade" and, additionally, for similar issues due to "technological errors" that caused inaccurate and untimely transaction reporting to the Trade Reporting and Compliance Engine (TRACE).  The majority of the misreported transactions were inaccurate by only one second - which may not seem particularly severe, but there are several issues that make this "Disciplinary Action" stand out, and a deeper dive confirms that it is genuinely worthy of the DISSY award.   
 
"MarketAxess reported 57,340 [municipal securities] transactions to the RTRS with an inaccurate time of trade due to the firm’s incorrect interpretation of time of trade. For a majority of these transactions, the execution time was inaccurate by one second." MarketAxess A.W.C. FINRA NO. 2020065254901, p.3. 

Also, 51,252 corporate bond transactions and 2,446 U.S. Treasury transactions were reported to TRACE with inaccurate transaction times. "For about half of these transactions, the time of execution was inaccurate by one second... These inaccurate and late reports occurred due to a technological error..."  MarketAxess A.W.C., p.3. 

While a one second deviation may seem insignificant, that is more than enough time to exploit and conceal manipulative and abusive trading.  Generally, in electronic trading (and especially in the context of high-frequency algorithmic trading), where many strategies rely on quick responses to real‑time data, even a one‑second deviation can be exploited into an unfair advantage, including Shadow Front Running of Customer Orders and/or concealing Matched-Book or Wash Trades - more on that below.  To be fair, nothing of this sort is reported in this A.W.C., but there is nothing to suggest that any serious inquiry was made by FINRA in this regard, either.  

The deciding factor for awarding this Dissy was that, even after new measures were implemented "to ensure that accurate execution times were reported to TRACE and RTRS", THE PROBLEMS CONTINUED, AND THERE IS NO MENTION OF THE ISSUE EVER BEING RESOLVED.  Astoundingly, the inaccurate times continued to be attributed to the firm's "incorrect interpretation of the meaning of time of trade." p.4  

From FINRA MarketAxess A.W.C. NO. 2020065254901 - page 4 (literally as a footnote):
"After January 2022 when the firm began performing automated surveillance and manual reviews of surveillance alerts, the firm continued to report certain municipal bond transactions to RTRS with inaccurate times of trade due to its incorrect interpretation of the meaning of time of trade."

But since this is now a settled matter, and so long as MarketAxess "accepts and consents to the findings without admitting or denying them" and pays the $180,000 fine, the firm may now exempt from further action regarding this matter... even for problems that continued after remedial measures were taken and which may still be unresolved because, of course, this A.W.C. contains the standard boilerplate verbiage:​ 

"FINRA will not bring any future actions against Respondent alleging violations based on the same factual findings described in this AWC." p.1​

So, perhaps MarketAxess continues to operate with an "incorrect interpretation of the meaning of time of trade" and...
NO FURTHER ACTION CAN BE TAKEN REGARDING THIS MATTER. 
Congratulations!  That is an impressive feat well-deserving of a DISSY!