Trading Time Precision

Qomply has seen high percentage of on-venue transactions reported with the inappropriate level of time precision for the type of trading being conducted.

It would not be considered material if a small percentage of transactions were reported without the required milliseconds or microseconds reflected in the trading date and time. However, if a fair number of transactions are reported without the required trading time precision, it could signal an issue in the front office trade capture systems or downstream systems. It may also lead to issues within the firm’s market surveillance or downstream market oversight conducted by the regulators.

Some general points to remember:

When activity is generated by a firm using a high-frequency algorithmic trading technique and executed on a Trading Venue, then the firm should report the transaction using microsecond granularity or better.

If activity was not generated by a high-frequency trading technique and traded on a trading venue, the trading date and time should be recorded using millisecond granularity or better for the transaction report showing the market execution.

For a chain with an end execution on a Trading Venue only the entity facing the market on the Trading Venue needs to be reported with the granularity.

For Off-Venue Transactions, firms should populate the trading date and time on its transaction report to second granularity or better.