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R. Clock Synchronization
This topic includes information related to the requirements for synchronization of business clocks.
- EventAudio file
- 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 .
- CAT AlertCAT Alert 2020-02 - Standards for Self Reporting Deviations of Clock Synchronization Standards to FINRA CAT
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.
Computer system and mechanical clocks must be synchronized every business day before market open. To maintain clock synchronization, clocks should be checked against the NIST atomic clock and re-synchronized, if necessary, throughout the day. Industry Members must document and maintain their clock synchronization procedures.
- FAQR3. Does the CAT NMS Plan allow Industry Members to continue to write the time on order tickets or are Industry Members required to purchase mechanical time clocks?
The CAT NMS Plan does not disallow the use of manually written timestamps provided the clock referenced is synchronized properly.