Introduction

Due to the sensitive and highly regulated nature of stock trading, SnapTrade needs to ensure that applications on its platform adhere to a consistent compliance policy. This is intended to reduce the risk associated with operating and consuming the SnapTrade API, so that all parties can benefit safely and confidently.

The four parties involved in the SnapTrade API are:

• Financial institutions
• SnapTrade
• Investing applications
• End users

Application Permission Levels

SnapTrade categorizes applications based on the permissions they require in order to deliver their service. The two supported permission levels are read-enabled and trade-enabled. Depending on which group is assigned or chosen by the application, SnapTrade will apply an appropriate compliance policy to ensure safe and compliant use of SnapTrade’s API.

All applications on SnapTrade platform require at least read-enabled permissions and therefore must adhere to the compliance policy for read-enabled applications. Some applications will also require trade-enabled permissions, and will be subject to an additional compliance policy to ensure that the sensitive nature of trading integrations is handled appropriately.

Guiding Principles for Permission Levels

At a high level, SnapTrade’s policy aims to adhere to specific guiding principles as a function of the permission level.

Read-enabled

• The user owns their account data and can choose with whom and how to share it.
• Any market data passed through the API is not considered user data and must be used only for the user that was licensed to receive the data.
• Applications must be clear and truthful to users in describing a) how their application works, b) how user data is used or shared, and c) what services users can expect to receive.
• Any functionality that provides trade suggestions, signals, or portfolio analysis must be “pull-based”, meaning that the user requests the analysis which causes the results to be communicated.
• Applications must not claim endorsement by financial institutions unless there is a bona fide agreement in place that permits the endorsement.
• Applications must comply with all applicable laws and regulations for each jurisdiction in which they operate.

Trade-enabled

• The user must understand and consent to all orders placed in their account.
• All applicable regulatory disclosures must be presented to the account owner at the point in time where they issue instructions that may result in orders being placed in their trading account. If exact fees or execution price are not known at the time of disclosure, this should be clearly explained and the user must consent to proceed without such information.
• Orders that receive explicit confirmation from the account owner at placement time are generally acceptable.
• Automated orders are acceptable as long as they are managed by a rules-based and non-stochastic approach that the user consents to.
• Automated orders are not acceptable if it appears to be a blanket grant of trading authority without further input from the account owner, unless the application is registered with the appropriate regulatory authorities to do so.
• Fully managed services may be deemed acceptable if the application is a registered investment advisor or a discretionary portfolio manager in the jurisdiction of the account holder.

Prior to launching in production, all applications must ensure that they are in compliance with our policies particularly concerning adherence to relevant regulations, use of any market data, and protection of end-user data and interests.

Once launched and your app is made available for public use, SnapTrade will periodically monitor your application to ensure compliance with SnapTrade’s policies. Upon request, application developers will be expected to provide SnapTrade with unrestricted access to their application to aid with our review. There may be instances where you are asked to provide SnapTrade with additional documentation.

The policies set forth in this document will be updated as the regulatory landscape changes. However, it is your responsibility to ensure that your application continues to meet any updates to regulatory requirements. SnapTrade does not assume liability for failure in adhering to regulatory requirements and SnapTrade reserves the right to shut off access to the API for non-compliance. 

We reserve the right to update our policies at any time.