Regulation has become a huge part of the financial services ecosystem with an estimated spend of over $181 Billion a year which is the equivalent of about an 8% tax to individual firms!
And this doesn't even include the fines which in the US alone, is a total of $243 Billion since 2008!
This being said, Regulation isn't a simple problem you throw money at and hope it goes away. A lot of the time it involves expert resources, spending a lengthy amount of time building solutions or setting up processes to comply with the various regulations and more importantly, the reporting obligations that fall under them.
In this article, we are going to be looking at understanding some of the CAT NMS reporting obligations where it concerns clock synchronisation.
Before understanding how to report and the obligations associated with the financial industry that is caught under the US regulation, we need to understand what is required to comply with these in the first place.
Summary of the regulation (basic notes):
What are the CAT clock synchronization standards for CAT Reporters?
The CAT NMS Plan requires Industry Members to synchronize their Business Clocks at a minimum to within 50 milliseconds of the time maintained by the National Institute of Standards (NIST), with the exception of Business Clocks used solely for Manual Order Events or the time of allocation on Allocation Reports, which must be synchronized to within one second of the NIST clock.
The CAT NMS Plan requires Participants to synchronize their Business Clocks at a minimum to within 100 microseconds of the time maintained by the NIST, consistent with industry standards, with the exception of Business Clocks used solely for Manual Order Events, which must be synchronized to within one second of the NIST clock.
For an "industry member" this is referring to organisations that use the services of the participants (banks, hedge funds, etc.)
So what does this mean, in simple terms a trading venue or exchange "a participant" (or similar) is required to synchronise business clocks to less than 100 microseconds.
Where clock sync is concerned CAT NMS is not the most difficult regulation to achieve, of course, it still has the nuances of making sure the source of UTC is traceable but unlike other clock sync regulations, there is another more problematic rule. The main burden with these regulations is the reporting obligation, and that's why the Timebeat platform is there to make life simple.
The current obligations require reports to be submitted within 3 days of the following events (not long to gather all that information).
Large Drift from Clock Synchronization:
Twice the standard or 100 milliseconds for all systems other than those used for Manual Order Events and twice the standard or 2 seconds for systems that record Manual Order Events.
Persistent Drift from Clock Synchronization:
10 times in one rolling 24-hour period at any time when the system is recording a timestamp on data that is reportable to the CAT on a given device or server. (The 10 times standard also applies to systems that process Manual Order events.)
So what does this mean.....
This means that within 3 days of a trigger event a detailed report must be submitted to the regulators for all devices involved in the trigger event (this is likely more than 1).
below is an example of the report you need to send to the regulators (that Timebeat can automatically populate for you).
(By the time we are done, all you need to do Is Sign it) Timebeat makes this easy though, with our automated or one-click reports you can download clean, clear PDFs or CSV files for triggered events in seconds, making the 3 days challenge a breeze.
What is more though, we calibrate the triggers into the platform so that you will be alerted to make a report when the trigger condition is met.
In our experience, the challenge of regulation isn't the complexities of accurate sync but more the complexities in the ability to report. Just by having a solution such as ptp4l or sfptpd does not enable compliance and in fact, most people we speak to say it takes days of manpower to make credible reports in these circumstances and what we are saying is just click one button!
Reduce the complexity of your system and think about your sync ecosystem not just the function of accurate time, it's all about application over function, and that is why the Timebeat platform constantly evolves with our client's application requirements in mind to simplify their whole ecosystem and not just ensuring the time is delivered and synchronised to nanosecond accuracy.
If you want to find out more about the Timebeat platform or how it can fit in with your compliance get in touch. We can always create an automated report for you or a template for the regulators to make your life easy!