SEC Regulation NMS (Reg NMS)
The United States Security and Exchange Commission (SEC) has established new rules governing financial market information,
commonly referred to as Regulation NMS (or Reg NMS). The Reg NMS regulations include requirements for the sychronization of clocks and maintaining related audit trail information.
The "Order Protection Rule" (rule 611) portion of the regulations
SEC's FAQ on Rule 611 and 610 of Regulation NMS (June 8, 2007) states that:
"In addition, a Firm should adopt reasonable policies and procedures for synchronizing its internal
clocks, to the extent that it uses different clocks to assign time-stamps to its order, trade, and
quotation data. For example, different trading desks or systems at a Firm potentially could use
different clocks to assign time-stamps to trades executed by such desks or systems, and these
clocks could be different from the clock that is used to assign time stamps to protected quotations
as they are received. The Firm should synchronize these internal clocks to enable the Firm to
reasonably determine through its compliance procedures that the trading desks and order
handling systems are executing trades and routing orders in compliance with Rule 611. "
FINRA (NASD) has well-established procedures and policies regarding time synchronization under it's OATS specifications that allow you
to address the Reg NMS requirement for "reasonable policies and procedures". We recommend you use our instructions on
configuring for compliance with FINRA (NASD) Order Audit Trail System (OATS) to ensure the
the clocks on your various systems are synchronized and generating correct time-stamps and are collecting the necessary
audit trail records to satisfy your data retention requirements.
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