R. Clock Synchronization
This topic includes information related to the requirements for synchronization of business clocks.
- CAT AlertCAT Alert 2020-02 - Standards for Self Reporting Deviations of Clock Synchronization Standards to FINRA CAT
On January 28, 2020, the CAT NMS Plan Operating Committee approved parameters for when a CAT Reporter is required to self-report to the CAT Plan Processor, FINRA CAT, deviations of clock synchronizations standards required under SRO Rules and the CAT NMS Plan. FINRA CAT will use this information to evaluate the impact of the reported incident(s) on the quality of the CAT Data and to provide notice to the Regulatory Users of reported incident(s) that may impact their analysis of CAT Data.
On Wednesday, June 10, 2020 at 3:30 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar focusing on how and when to use and submit the self reporting clock synchronization deviations and erroneous data forms.Audio file
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- Reference Material
As previously communicated, Industry Members must complete an annual certification for Business Clock Synchronization by March 15th of each year.
UPDATED A copy of the certification form is available here .
On Wednesday, January 8, 2020, at 2 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host a CAT 101 Industry Webinar. This Webinar is designed for Industry Members that may be new to, or less familiar with, CAT and will provide an introduction to the reporting requirements, timelines and mechanics of the Consolidated Audit Trail. The event will be held at 2 pm ET.Audio file
Yes. Firms required to synchronize their clocks according to the CAT NMS Plan should keep a log of the times when they synchronize their clocks and the results of the synchronization process. This log should include notice of any time the clock drifts more than allowed by the CAT NMS Plan.
- FAQR2. If I am an agency broker-dealer and I send my orders through a third-party service provider’s system (e.g., Bloomberg), what clock synchronization compliance obligations do I have with regard to the third-party service provider’s clocks and my own clocks? Do I need to do anything with regard to the internal systems (e.g., internal PCs or servers) or clocks within my own firm to satisfy the clock synchronization requirements?
An Industry Member must satisfy the CAT clock synchronization requirements for all of its Business Clocks. Business Clocks are defined as clocks used to record the date and time of any Reportable Event required to be reported under SEC Rule 613.
All Industry Members that have Business Clocks that are subject to the clock synchronization requirements must document and maintain their synchronization procedures and keep a log of the times when they synchronize their Business Clocks and the results of the synchronization process. The Participants expect that each Industry Member will synchronize its Business Clocks every business day before market open, and check synchronization at pre-determined intervals throughout the business day, to reasonably ensure that Business Clocks maintain synchronization.