What clock synchronization procedures are we required to have in order to comply with the OATS Rules?
In order to comply with the requirements of NASD Rule 7430, member firms must have written procedures in effect describing their clock synchronization process. The procedures must be thorough and include the method of synchronizing computer system and mechanical clocks used for recording the times of market events. The synchronization process must take place every business day before market open, and it must include checks of synchronization at pre-determined intervals throughout the business day, to ensure that the clocks maintain synchronization. In addition, all member firms with clock synchronization requirements should have written supervisory procedures that describe the methods they use to ensure that the synchronization process is being followed. Firms should be able to demonstrate their supervision of the synchronization process.
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