At the beginning of 2018 in Europe, and before the end of 2017 in the US, new time-stamping requirements will come into force, under European MiFID II regulation and the US SEC’s Consolidated Audit Trail (CAT) project. The RTS 25 provision of MiFID II sets exact millisecond and microsecond levels for time-stamp accuracy depending on whether the party involved is a trading venue, high-frequency trader, algorithmic trader or manual, human trader. CAT will require self-regulatory organizations to report time-stamped information at a certain standard as well. Both the European and US time-stamping rules will affect how trades and orders may be tracked.
For trade reporting operations, what burdens do MiFID II’s RTS 25 standards create, particularly for time-stamping and tracking orders?
Is MiFID II too reliant on accurate time-stamps? Is the emphasis on time-stamp accuracy justified and helpful?
Are the provisions of MiFID II and CAT concerning time-stamping very similar or very different?
Can SROs adequately address industry standards for clock synchronization, or do so better than the industry as a whole? Is MiFID II’s approach to clock synchronization better than a SRO-led approach?
How reasonable is CAT’s clock synchronization standard of within 100 microseconds of the time maintained by the National Institute of Standards and Technology?
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