Order Granting Conditional Exemptive Relief, Pursuant to Section 36 of the Securities Exchange Act of 1934 (“Exchange Act”) and Rule 608(e) of Regulation NMS Under the Exchange Act to Rule 608(e) of Regulation NMS Under the Exchange Act, Relating to Granularity of Timestamps Specified in Section 6.8(b) and Appendix D, Section 3 of the National Market System Plan Governing the Consolidated Audit Trail, 20743-20745 [2020-07789]
Download as PDF
Federal Register / Vol. 85, No. 72 / Tuesday, April 14, 2020 / Notices
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change.
Persons submitting comments are
cautioned that we do not redact or edit
personal identifying information from
comment submissions. You should
submit only information that you wish
to make available publicly. All
submissions should refer to File
Number SR–NYSECHX–2020–12, and
should be submitted on or before May
5, 2020.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.11
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–07780 Filed 4–13–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–88608]
Order Granting Conditional Exemptive
Relief, Pursuant to Section 36 of the
Securities Exchange Act of 1934
(‘‘Exchange Act’’) and Rule 608(e) of
Regulation NMS Under the Exchange
Act to Rule 608(e) of Regulation NMS
Under the Exchange Act, Relating to
Granularity of Timestamps Specified in
Section 6.8(b) and Appendix D, Section
3 of the National Market System Plan
Governing the Consolidated Audit Trail
jbell on DSKJLSW7X2PROD with NOTICES
April 8, 2020.
I. Introduction
By letter dated February 3, 2020, BOX
Exchange LLC, Cboe BYX Exchange,
Inc., Cboe BZX Exchange, Inc., Cboe
EDGA Exchange, Inc., Cboe EDGX
Exchange, Inc., Cboe C2 Exchange, Inc.,
Cboe Exchange, Inc., Financial Industry
Regulatory Authority, Inc. (‘‘FINRA’’),
Investors Exchange LLC, Miami
International Securities Exchange LLC,
MIAX Emerald, LLC, MIAX PEARL,
LLC, NASDAQ BX, LLC, Nasdaq GEMX,
LLC, Nasdaq ISE, LLC, Nasdaq MRX,
LLC, NASDAQ PHLX LLC, The
NASDAQ Stock Market LLC, New York
Stock Exchange LLC, NYSE American
LLC, NYSE Arca, Inc., NYSE Chicago,
Inc., NYSE National, Inc., and Long
Term Stock Exchange, Inc. (collectively,
the ‘‘Participants’’) to the National
Market System Plan Governing the
Consolidated Audit Trail (‘‘CAT NMS
Plan’’),1 requested that the Securities
11 17
CFR 200.30–3(a)(12).
CAT NMS Plan was approved by the
Commission, as modified, on November 15, 2016.
See Securities Exchange Act Release No79318
1 The
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and Exchange Commission
(‘‘Commission’’ or ‘‘SEC’’) grant limited
exemptive relief to the Participants,
pursuant to its authority under Section
36 of the Securities Exchange Act of
1934 (‘‘Exchange Act’’) 2 and Rule 608(e)
of Regulation NMS under the Exchange
Act, from the timestamp granularity
requirements of Section 6.8(b) and
Section 3 of Appendix D of the CAT
NMS Plan.3
Section 36 of the Exchange Act grants
the Commission the authority, with
certain limitations, to ‘‘conditionally or
unconditionally exempt any person,
security, or transaction . . . from any
provision or provisions of [the Exchange
Act] or of any rule or regulation
thereunder, to the extent that such
exemption is necessary or appropriate
in the public interest, and is consistent
with the protection of investors.’’ 4
Under Rule 608(e) of Regulation NMS,
the Commission may ‘‘exempt from
[Rule 608], either unconditionally or on
specified terms and conditions, any selfregulatory organization, member
thereof, or specified security, if the
Commission determines that such
exemption is consistent with the public
interest, the protection of investors, the
maintenance of fair and orderly markets
and the removal of impediments to, and
perfection of the mechanism of, a
national market system.’’ 5
For the reasons set forth below, this
Order grants the Participants’ request for
an exemption from Section 6.8(b) and
Appendix D, Section 3 of the CAT NMS
Plan as set forth in the February 3, 2020
Exemption Request, subject to certain
conditions.6
II. Description
The CAT NMS Plan sets forth certain
requirements regarding the granularity
(November 15, 2016), 81 FR 84696 (November 23,
2016) (‘‘CAT NMS Plan Approval Order’’).
2 15 U.S.C. 78mm(a)(1).
3 See letter from the Participants to Vanessa
Countryman, Secretary, Commission, dated
February 3, 2020 (the ‘‘February 3, 2020 Exemption
Request’’). Unless otherwise noted, capitalized
terms are used as defined in the CAT NMS Plan.
4 15 U.S.C. 78mm(a)(1).
5 17 CFR 242.608(e).
6 The February 3, 2020 Exemption Request also
includes a separate request for exemptive relief
from Section 6.4(d)(ii)(C) of the CAT NMS Plan.
Specifically, in circumstances in which an Industry
Member uses an established trading relationship for
an individual Customer (rather than an account) on
the order reported to the CAT, the Participants
request an exemption from the requirement in
Section 6.4(d)(ii)(C) of the CAT NMS Plan for each
Participant to require, through its Compliance
Rules, its Industry Members to record and report to
the Central Repository the account number, the date
account opened and account type for the relevant
individual customer, subject to certain conditions.
The Commission is not addressing that request at
this time.
PO 00000
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Fmt 4703
Sfmt 4703
20743
of timestamps accepted by the CAT
system. Specifically, Section 6.8(b) of
the CAT NMS Plan states ‘‘[e]ach
Participant shall, and through its
Compliance Rule shall require its
Industry Members to, report information
required by SEC Rule 613 and this
Agreement to the Central Repository in
milliseconds,’’ but that ‘‘[t]o the extent
that any Participant’s order handling or
execution systems utilize timestamps in
increments finer than the minimum
required in this Agreement, such
Participant shall utilize such finer
increment when reporting CAT Data to
the Central Repository so that all
Reportable Events reported to the
Central Repository can be adequately
sequenced.’’ 7 Section 6.8(b) further
states that ‘‘each Participant shall,
through its Compliance Rule: (i) Require
that, to the extent that its Industry
Members utilize timestamps in
increments finer than the minimum
required in this Agreement in their
order handling or execution systems,
such Industry Members shall utilize
such finer increment when reporting
CAT Data to the Central Repository.’’ 8
In addition, Section 3 of Appendix D of
the CAT NMS Plan states that the
Central Repository must be able to
‘‘[a]ccept time stamps on order events
handled electronically to the finest level
of granularity captured by CAT
Reporters.’’
Section 6.8(c) of the CAT NMS Plan
imposes further requirements on
Participants regarding analysis of
timestamp granularity. Specifically,
Section 6.8(c) of the CAT NMS Plan
requires the Chief Compliance Officer
to, ‘‘[i]n conjunction with Participants’
and other appropriate Industry Member
advisory groups,’’ ‘‘annually evaluate
and make a recommendation to the
Operating Committee as to whether
industry standards have evolved such
that: . . . (ii) the required time stamp in
Section 6.8(b) should be in finer
increments.’’
III. Request for Relief
In the February 3, 2020 Exemption
Request, the Participants request that
the Commission exempt the Participants
from the requirement in Section 6.8(b)
of the CAT NMS Plan that Participants
reporting CAT Data to the Central
7 Notwithstanding other requirements of Section
6.8(b), the CAT NMS Plan provides that
Participants and Industry Members are permitted to
record and report Manual Order Events and the
time of allocation on Allocation Reports in
increments up to and including one second. See
CAT NMS Plan Section 6.8(b).
8 The CAT NMS Plan defines ‘‘Compliance Rule’’
to mean, ‘‘with respect to a Participant, the rule(s)
promulgated by such Participant as contemplated
by Section 3.11.’’ See CAT NMS Plan Section 1.1.
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Federal Register / Vol. 85, No. 72 / Tuesday, April 14, 2020 / Notices
jbell on DSKJLSW7X2PROD with NOTICES
Repository utilize timestamps finer than
nanoseconds to the extent that the
Participant’s order handling or
execution systems utilize timestamps in
increments finer than nanoseconds. As
a condition to this exemption, if a
Participant captures timestamps in
increments more granular than
nanoseconds, such Participant would
truncate the timestamp after the
nanosecond level for submission to
CAT, not round up or down in such
circumstances. In addition, the
Participants request that the
Commission exempt the Participants
from the requirement in Section 6.8(b)
of the CAT NMS Plan for each
Participant, through its Compliance
Rule, to require that, to the extent that
its Industry Members utilize timestamps
in increments finer than nanoseconds in
their order handling or execution
systems, such Industry Members utilize
such finer increment when reporting
CAT Data to the Central Repository. As
a condition to this exemption, the
Participants, through their Compliance
Rules, will require Industry Members
that capture timestamps in increments
more granular than nanoseconds to
truncate the timestamps, after the
nanosecond level for submission to
CAT, not round up or down in such
circumstances.9 Lastly, the Participants
request that the Commission exempt the
Participants from the requirement in
Section 3 of Appendix D of the CAT
NMS Plan for the Central Repository to
be able to accept timestamps on order
events handled electronically to the
finest level of granularity captured by
CAT Reporters.
As a condition to this exemption, the
Participants state that the Central
Repository will be required to accept
timestamps on order events handled
electronically to a nanosecond
granularity. In addition, the Participants
request that the above timestamp
granularity exemptive relief remain in
effect for five years from the date that
the Commission grants the exemptive
relief. After five years, the timestamp
granularity exemptive relief would no
longer be in effect.
The Participants state that they, in
concert with the Plan Processor, have
determined that the cost of providing
the ability to utilize timestamps in the
CAT in a finer granularity than
9 Participants would require that electronic
timestamps submitted by Participants and Industry
Members be truncated by Participants and Industry
Members if they capture timestamps in increments
more granular than nanoseconds, believing that
rounding a timestamp would suggest an event
occurred later or earlier than it actually occurred,
while truncation treats all timestamps as if they
were provided with the same level of granularity.
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18:26 Apr 13, 2020
Jkt 250001
nanoseconds outweighs the benefits.
The Participants further state that, based
on discussions with the Plan Processor,
that Participants understand that
expanding the capture of timestamp
granularity to picoseconds by the Plan
Processor would take at least six months
at an estimated cost of approximately
$700,000, and that this effort would
include technical specification and
database modifications, modifying
query tools to support querying and
sequencing at a picosecond granularity.
The Participants also state that they
understand that exchanges currently
utilize timestamps only to the
nanosecond and do not utilize
timestamps to picoseconds or to finer
increments.
IV. Discussion
The Commission has carefully
considered the information provided by
the Participants in support of the
Participants’ exemption request from
Section 6.8(b) and Section 3 of
Appendix D of the CAT NMS Plan with
respect to timestamp granularity. Based
on the information provided by the
Participants in the February 3, 2020
Exemption Request, the Commission
believes that the exemptive relief would
provide cost savings and reduce build
time for the Plan Processor while not
negatively impacting the ability of
regulators to use CAT. As noted above,
the Participants state that it would take
at least six months and approximately
$700,000 to modify the Plan Processor
to accept picosecond timestamps. The
Participants state that, as described
above, Section 6.8(c) of the CAT NMS
Plan will require annual review of
timestamp granularity,10 and the
Participants have requested that such
exemptive relief expire in five years.
The Commission has previously
stated that regulators need sufficiently
granular timestamps to sequence events
across orders and within order
lifecycles, and that a lack of uniform
and granular timestamps can limit the
ability of regulators to sequence events
accurately and link data with
10 In the February 3, 2020 Exemption Request, the
Participants state that an analysis of the timestamp
granularity would be required as part of the annual
evaluation required to be performed by the Chief
Compliance Officer pursuant to Section 6.8(c) of the
CAT NMS Plan. If the Operating Committee
determines that this analysis concludes that the
benefit of the CAT Reporters reporting, and the
Central Repository providing the ability to accept,
timestamps in finer granularity than nanoseconds
outweighs the burdens, then the timestamp
exemption could be terminated or be revised to
reflect more granular timestamps than nanoseconds
in accordance with the analysis. See February 3,
2020 Exemption Request, supra note 2, at 4.
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Frm 00083
Fmt 4703
Sfmt 4703
information from other data sources.11
Many public data sources report time in
seconds or milliseconds, and some,
including direct data feeds, report time
in microseconds or nanoseconds.12 The
Participants state that the exchanges
currently utilize timestamps only to the
nanosecond and do not utilize
timestamps to picoseconds or to finer
increments.13 Nanoseconds are smaller
than milliseconds or microseconds and
so the Participants’ proposal would
result in the collection of information
that is at least as granular as existing
data sources, and more granular than
FINRA’s Order Audit Trail System
which requires timestamps in
milliseconds for firms that capture time
in milliseconds but does not require
members to capture time in
milliseconds.14 The Participants also
believe that CAT Reportable Events can
be adequately sequenced in the CAT
without requiring timestamps in a finer
granularity than nanoseconds, and the
Participants believe that the requested
relief would serve to maintain and
enhance the reliability and accuracy of
the data reported to the Central
Repository.15
The proposed approach described in
the February 3, 2020 Exemption Request
would require both Participants and
Industry Members to truncate
timestamps in increments more granular
than nanoseconds to nanoseconds for
submission to the CAT, and the Central
Repository will be required to accept
timestamps on order events handled
electronically to a nanosecond
granularity. Based on the foregoing, the
Commission believes that, pursuant to
Section 36 of the Exchange Act, this
exemption is appropriate in the public
interest and consistent with the
protection of investors, and that
pursuant to Rule 608(e), this exemption
is consistent with the public interest,
the protection of investors, the
maintenance of fair and orderly markets
and the removal of impediments to, and
the perfection of a national market
system to exempt the SROs from Section
6.8(b) and Section 3 of Appendix D of
the CAT NMS Plan with respect to
11 See
CAT NMS Plan Approval Order, supra note
1.
12 Id. at 84813. For example, Options Price
Reporting Authority allows for timestamps in
nanoseconds, while other registered Securities
Information Processors require timestamps in
microseconds for equity trades and quotes. Id. at
84813–14.
13 See February 3, 2020 Exemption Request, supra
note 2, at 3.
14 See CAT NMS Plan Approval Order, supra note
1, at 84813–14.
15 See February 3, 2020 Exemption Request, supra
note 2, at 2 and 3.
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Federal Register / Vol. 85, No. 72 / Tuesday, April 14, 2020 / Notices
timestamp granularity for a period of
five years.
Accordingly, it is hereby ordered,
pursuant to Section 36(a)(1) of the
Exchange Act,16 and Rule 608(e) of the
Exchange Act 17 and with respect to the
proposed approaches specifically
described above, that the Participants
are granted a five-year exemption from
the timestamp granularity requirement
set forth in Section 6.8(b) and Section 3
of Appendix D of the CAT NMS Plan of
the CAT NMS Plan, subject to the
conditions described above.
By the Commission.
Vanessa A. Countryman,
Secretary.
[FR Doc. 2020–07789 Filed 4–13–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–88600; File No. SR–FINRA–
2020–011]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of a
Proposed Rule Change To Address
Brokers With a Significant History of
Misconduct
April 8, 2020.
jbell on DSKJLSW7X2PROD with NOTICES
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on April 3,
2020, Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’) filed with the
Securities and Exchange Commission
(‘‘SEC’’ or ‘‘Commission’’) the proposed
rule change as described in Items I, II,
and III below, which Items have been
prepared by FINRA. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
FINRA is proposing to (1) amend the
FINRA Rule 9200 Series (Disciplinary
Proceedings) and the 9300 Series
(Review of Disciplinary Proceeding by
National Adjudicatory Council and
FINRA Board; Application for SEC
Review) to allow a Hearing Officer to
impose conditions or restrictions on the
activities of a respondent member firm
or respondent broker, and require a
respondent broker’s member firm to
adopt heightened supervisory
16 15
U.S.C. 78mm(a)(1).
CFR 242.608(e).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
17 17
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18:26 Apr 13, 2020
Jkt 250001
procedures for such broker, when a
disciplinary matter is appealed to the
National Adjudicatory Council (‘‘NAC’’)
or called for NAC review; (2) amend the
FINRA Rule 9520 Series (Eligibility
Proceedings) to require member firms to
adopt heightened supervisory
procedures for statutorily disqualified
brokers during the period a statutory
disqualification eligibility request is
under review by FINRA; (3) amend
FINRA Rule 8312 (FINRA BrokerCheck
Disclosure) to allow the disclosure
through FINRA BrokerCheck of the
status of a member firm as a ‘‘taping
firm’’ under FINRA Rule 3170 (Tape
Recording of Registered Persons by
Certain Firms); and (4) amend the
FINRA Rule 1000 Series (Member
Application and Associated Person
Registration) to require a member firm
to submit a written request to FINRA’s
Department of Member Regulation
(‘‘Member Regulation’’), through the
Membership Application Group (‘‘MAP
Group’’), seeking a materiality
consultation and approval of a
continuing membership application, if
required, when a natural person that
has, in the prior five years, one or more
‘‘final criminal matters’’ or two or more
‘‘specified risk events’’ 3 seeks to
become an owner, control person,
principal or registered person of the
member firm.
The text of the proposed rule change
is available on FINRA’s website at
https://www.finra.org, at the principal
office of FINRA and at the
Commission’s Public Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
FINRA included statements concerning
the purpose of and basis for the
proposed rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item IV below. FINRA has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of such statements.
3 As explained more below, the proposed
definitions of ‘‘final criminal matter’’ and
‘‘specified risk event’’ generally include final,
adjudicated disclosure events disclosed on a
person’s or firm’s Uniform Registration Forms. For
purposes of the proposed rule change, Uniform
Registration Forms for firms and brokers refer to,
and would be defined as, the Uniform Application
for Broker-Dealer Registration (Form BD), the
Uniform Application for Securities Industry
Registration or Transfer (Form U4), the Uniform
Termination Notice for Securities Industry
Registration (Form U5) and the Uniform
Disciplinary Action Reporting Form (Form U6), as
such may be amended or any successor(s) thereto.
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Frm 00084
Fmt 4703
Sfmt 4703
20745
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
Overview
FINRA uses a combination of tools to
reduce the risk of harm to investors
from member firms and the brokers they
hire that have a history of misconduct.
These tools include assessments of
applications filed by member firms to
retain or employ an individual subject
to a statutory disqualification, reviews
of membership and continuing
membership applications (‘‘CMAs’’),
disclosure of brokers’ regulatory
backgrounds, supervision requirements,
focused examinations, risk monitoring
and disciplinary actions. These tools,
among others, have been useful in
identifying and addressing a range of
misconduct and serve to further the
Exchange Act goals, reflected in
FINRA’s mission, of investor protection
and market integrity.
In addition, FINRA Rule 3110
(Supervision) requires member firms to
establish and maintain a system to
supervise the activities of each
associated person that is reasonably
designed to achieve compliance with
applicable securities laws and FINRA
rules. The rule also requires member
firms to establish, maintain and enforce
written procedures to supervise the
types of business in which they engage
and the activities of their associated
persons that are reasonably designed to
achieve compliance with applicable
securities laws and FINRA rules.4
Despite these requirements and
FINRA’s ongoing efforts to strengthen
protections for investors and the
markets through its oversight of member
firms and the brokers they employ,
persistent compliance issues continue to
arise in some member firms. Recent
studies, for example, find that some
firms persistently employ brokers who
engage in misconduct, which results in
higher levels of misconduct by these
firms. These studies also provide
evidence that past disciplinary and
other regulatory events associated with
a member firm or individual can be
predictive of similar future events, such
as repeated disciplinary actions,
arbitrations and complaints.5 This risk
4 See
Rule 3110(a) and (b).
example, in 2015 FINRA’s Office of the
Chief Economist (OCE) published a study that
examined the predictability of disciplinary and
other disclosure events associated with investor
harm based on past similar events. The OCE study
showed that past disclosure events, including
regulatory actions, customer arbitrations and
5 For
E:\FR\FM\14APN1.SGM
Continued
14APN1
Agencies
[Federal Register Volume 85, Number 72 (Tuesday, April 14, 2020)]
[Notices]
[Pages 20743-20745]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-07789]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-88608]
Order Granting Conditional Exemptive Relief, Pursuant to Section
36 of the Securities Exchange Act of 1934 (``Exchange Act'') and Rule
608(e) of Regulation NMS Under the Exchange Act to Rule 608(e) of
Regulation NMS Under the Exchange Act, Relating to Granularity of
Timestamps Specified in Section 6.8(b) and Appendix D, Section 3 of the
National Market System Plan Governing the Consolidated Audit Trail
April 8, 2020.
I. Introduction
By letter dated February 3, 2020, BOX Exchange LLC, Cboe BYX
Exchange, Inc., Cboe BZX Exchange, Inc., Cboe EDGA Exchange, Inc., Cboe
EDGX Exchange, Inc., Cboe C2 Exchange, Inc., Cboe Exchange, Inc.,
Financial Industry Regulatory Authority, Inc. (``FINRA''), Investors
Exchange LLC, Miami International Securities Exchange LLC, MIAX
Emerald, LLC, MIAX PEARL, LLC, NASDAQ BX, LLC, Nasdaq GEMX, LLC, Nasdaq
ISE, LLC, Nasdaq MRX, LLC, NASDAQ PHLX LLC, The NASDAQ Stock Market
LLC, New York Stock Exchange LLC, NYSE American LLC, NYSE Arca, Inc.,
NYSE Chicago, Inc., NYSE National, Inc., and Long Term Stock Exchange,
Inc. (collectively, the ``Participants'') to the National Market System
Plan Governing the Consolidated Audit Trail (``CAT NMS Plan''),\1\
requested that the Securities and Exchange Commission (``Commission''
or ``SEC'') grant limited exemptive relief to the Participants,
pursuant to its authority under Section 36 of the Securities Exchange
Act of 1934 (``Exchange Act'') \2\ and Rule 608(e) of Regulation NMS
under the Exchange Act, from the timestamp granularity requirements of
Section 6.8(b) and Section 3 of Appendix D of the CAT NMS Plan.\3\
---------------------------------------------------------------------------
\1\ The CAT NMS Plan was approved by the Commission, as
modified, on November 15, 2016. See Securities Exchange Act Release
No79318 (November 15, 2016), 81 FR 84696 (November 23, 2016) (``CAT
NMS Plan Approval Order'').
\2\ 15 U.S.C. 78mm(a)(1).
\3\ See letter from the Participants to Vanessa Countryman,
Secretary, Commission, dated February 3, 2020 (the ``February 3,
2020 Exemption Request''). Unless otherwise noted, capitalized terms
are used as defined in the CAT NMS Plan.
---------------------------------------------------------------------------
Section 36 of the Exchange Act grants the Commission the authority,
with certain limitations, to ``conditionally or unconditionally exempt
any person, security, or transaction . . . from any provision or
provisions of [the Exchange Act] or of any rule or regulation
thereunder, to the extent that such exemption is necessary or
appropriate in the public interest, and is consistent with the
protection of investors.'' \4\ Under Rule 608(e) of Regulation NMS, the
Commission may ``exempt from [Rule 608], either unconditionally or on
specified terms and conditions, any self-regulatory organization,
member thereof, or specified security, if the Commission determines
that such exemption is consistent with the public interest, the
protection of investors, the maintenance of fair and orderly markets
and the removal of impediments to, and perfection of the mechanism of,
a national market system.'' \5\
---------------------------------------------------------------------------
\4\ 15 U.S.C. 78mm(a)(1).
\5\ 17 CFR 242.608(e).
---------------------------------------------------------------------------
For the reasons set forth below, this Order grants the
Participants' request for an exemption from Section 6.8(b) and Appendix
D, Section 3 of the CAT NMS Plan as set forth in the February 3, 2020
Exemption Request, subject to certain conditions.\6\
---------------------------------------------------------------------------
\6\ The February 3, 2020 Exemption Request also includes a
separate request for exemptive relief from Section 6.4(d)(ii)(C) of
the CAT NMS Plan. Specifically, in circumstances in which an
Industry Member uses an established trading relationship for an
individual Customer (rather than an account) on the order reported
to the CAT, the Participants request an exemption from the
requirement in Section 6.4(d)(ii)(C) of the CAT NMS Plan for each
Participant to require, through its Compliance Rules, its Industry
Members to record and report to the Central Repository the account
number, the date account opened and account type for the relevant
individual customer, subject to certain conditions. The Commission
is not addressing that request at this time.
---------------------------------------------------------------------------
II. Description
The CAT NMS Plan sets forth certain requirements regarding the
granularity of timestamps accepted by the CAT system. Specifically,
Section 6.8(b) of the CAT NMS Plan states ``[e]ach Participant shall,
and through its Compliance Rule shall require its Industry Members to,
report information required by SEC Rule 613 and this Agreement to the
Central Repository in milliseconds,'' but that ``[t]o the extent that
any Participant's order handling or execution systems utilize
timestamps in increments finer than the minimum required in this
Agreement, such Participant shall utilize such finer increment when
reporting CAT Data to the Central Repository so that all Reportable
Events reported to the Central Repository can be adequately
sequenced.'' \7\ Section 6.8(b) further states that ``each Participant
shall, through its Compliance Rule: (i) Require that, to the extent
that its Industry Members utilize timestamps in increments finer than
the minimum required in this Agreement in their order handling or
execution systems, such Industry Members shall utilize such finer
increment when reporting CAT Data to the Central Repository.'' \8\ In
addition, Section 3 of Appendix D of the CAT NMS Plan states that the
Central Repository must be able to ``[a]ccept time stamps on order
events handled electronically to the finest level of granularity
captured by CAT Reporters.''
---------------------------------------------------------------------------
\7\ Notwithstanding other requirements of Section 6.8(b), the
CAT NMS Plan provides that Participants and Industry Members are
permitted to record and report Manual Order Events and the time of
allocation on Allocation Reports in increments up to and including
one second. See CAT NMS Plan Section 6.8(b).
\8\ The CAT NMS Plan defines ``Compliance Rule'' to mean, ``with
respect to a Participant, the rule(s) promulgated by such
Participant as contemplated by Section 3.11.'' See CAT NMS Plan
Section 1.1.
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Section 6.8(c) of the CAT NMS Plan imposes further requirements on
Participants regarding analysis of timestamp granularity. Specifically,
Section 6.8(c) of the CAT NMS Plan requires the Chief Compliance
Officer to, ``[i]n conjunction with Participants' and other appropriate
Industry Member advisory groups,'' ``annually evaluate and make a
recommendation to the Operating Committee as to whether industry
standards have evolved such that: . . . (ii) the required time stamp in
Section 6.8(b) should be in finer increments.''
III. Request for Relief
In the February 3, 2020 Exemption Request, the Participants request
that the Commission exempt the Participants from the requirement in
Section 6.8(b) of the CAT NMS Plan that Participants reporting CAT Data
to the Central
[[Page 20744]]
Repository utilize timestamps finer than nanoseconds to the extent that
the Participant's order handling or execution systems utilize
timestamps in increments finer than nanoseconds. As a condition to this
exemption, if a Participant captures timestamps in increments more
granular than nanoseconds, such Participant would truncate the
timestamp after the nanosecond level for submission to CAT, not round
up or down in such circumstances. In addition, the Participants request
that the Commission exempt the Participants from the requirement in
Section 6.8(b) of the CAT NMS Plan for each Participant, through its
Compliance Rule, to require that, to the extent that its Industry
Members utilize timestamps in increments finer than nanoseconds in
their order handling or execution systems, such Industry Members
utilize such finer increment when reporting CAT Data to the Central
Repository. As a condition to this exemption, the Participants, through
their Compliance Rules, will require Industry Members that capture
timestamps in increments more granular than nanoseconds to truncate the
timestamps, after the nanosecond level for submission to CAT, not round
up or down in such circumstances.\9\ Lastly, the Participants request
that the Commission exempt the Participants from the requirement in
Section 3 of Appendix D of the CAT NMS Plan for the Central Repository
to be able to accept timestamps on order events handled electronically
to the finest level of granularity captured by CAT Reporters.
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\9\ Participants would require that electronic timestamps
submitted by Participants and Industry Members be truncated by
Participants and Industry Members if they capture timestamps in
increments more granular than nanoseconds, believing that rounding a
timestamp would suggest an event occurred later or earlier than it
actually occurred, while truncation treats all timestamps as if they
were provided with the same level of granularity.
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As a condition to this exemption, the Participants state that the
Central Repository will be required to accept timestamps on order
events handled electronically to a nanosecond granularity. In addition,
the Participants request that the above timestamp granularity exemptive
relief remain in effect for five years from the date that the
Commission grants the exemptive relief. After five years, the timestamp
granularity exemptive relief would no longer be in effect.
The Participants state that they, in concert with the Plan
Processor, have determined that the cost of providing the ability to
utilize timestamps in the CAT in a finer granularity than nanoseconds
outweighs the benefits. The Participants further state that, based on
discussions with the Plan Processor, that Participants understand that
expanding the capture of timestamp granularity to picoseconds by the
Plan Processor would take at least six months at an estimated cost of
approximately $700,000, and that this effort would include technical
specification and database modifications, modifying query tools to
support querying and sequencing at a picosecond granularity. The
Participants also state that they understand that exchanges currently
utilize timestamps only to the nanosecond and do not utilize timestamps
to picoseconds or to finer increments.
IV. Discussion
The Commission has carefully considered the information provided by
the Participants in support of the Participants' exemption request from
Section 6.8(b) and Section 3 of Appendix D of the CAT NMS Plan with
respect to timestamp granularity. Based on the information provided by
the Participants in the February 3, 2020 Exemption Request, the
Commission believes that the exemptive relief would provide cost
savings and reduce build time for the Plan Processor while not
negatively impacting the ability of regulators to use CAT. As noted
above, the Participants state that it would take at least six months
and approximately $700,000 to modify the Plan Processor to accept
picosecond timestamps. The Participants state that, as described above,
Section 6.8(c) of the CAT NMS Plan will require annual review of
timestamp granularity,\10\ and the Participants have requested that
such exemptive relief expire in five years.
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\10\ In the February 3, 2020 Exemption Request, the Participants
state that an analysis of the timestamp granularity would be
required as part of the annual evaluation required to be performed
by the Chief Compliance Officer pursuant to Section 6.8(c) of the
CAT NMS Plan. If the Operating Committee determines that this
analysis concludes that the benefit of the CAT Reporters reporting,
and the Central Repository providing the ability to accept,
timestamps in finer granularity than nanoseconds outweighs the
burdens, then the timestamp exemption could be terminated or be
revised to reflect more granular timestamps than nanoseconds in
accordance with the analysis. See February 3, 2020 Exemption
Request, supra note 2, at 4.
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The Commission has previously stated that regulators need
sufficiently granular timestamps to sequence events across orders and
within order lifecycles, and that a lack of uniform and granular
timestamps can limit the ability of regulators to sequence events
accurately and link data with information from other data sources.\11\
Many public data sources report time in seconds or milliseconds, and
some, including direct data feeds, report time in microseconds or
nanoseconds.\12\ The Participants state that the exchanges currently
utilize timestamps only to the nanosecond and do not utilize timestamps
to picoseconds or to finer increments.\13\ Nanoseconds are smaller than
milliseconds or microseconds and so the Participants' proposal would
result in the collection of information that is at least as granular as
existing data sources, and more granular than FINRA's Order Audit Trail
System which requires timestamps in milliseconds for firms that capture
time in milliseconds but does not require members to capture time in
milliseconds.\14\ The Participants also believe that CAT Reportable
Events can be adequately sequenced in the CAT without requiring
timestamps in a finer granularity than nanoseconds, and the
Participants believe that the requested relief would serve to maintain
and enhance the reliability and accuracy of the data reported to the
Central Repository.\15\
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\11\ See CAT NMS Plan Approval Order, supra note 1.
\12\ Id. at 84813. For example, Options Price Reporting
Authority allows for timestamps in nanoseconds, while other
registered Securities Information Processors require timestamps in
microseconds for equity trades and quotes. Id. at 84813-14.
\13\ See February 3, 2020 Exemption Request, supra note 2, at 3.
\14\ See CAT NMS Plan Approval Order, supra note 1, at 84813-14.
\15\ See February 3, 2020 Exemption Request, supra note 2, at 2
and 3.
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The proposed approach described in the February 3, 2020 Exemption
Request would require both Participants and Industry Members to
truncate timestamps in increments more granular than nanoseconds to
nanoseconds for submission to the CAT, and the Central Repository will
be required to accept timestamps on order events handled electronically
to a nanosecond granularity. Based on the foregoing, the Commission
believes that, pursuant to Section 36 of the Exchange Act, this
exemption is appropriate in the public interest and consistent with the
protection of investors, and that pursuant to Rule 608(e), this
exemption is consistent with the public interest, the protection of
investors, the maintenance of fair and orderly markets and the removal
of impediments to, and the perfection of a national market system to
exempt the SROs from Section 6.8(b) and Section 3 of Appendix D of the
CAT NMS Plan with respect to
[[Page 20745]]
timestamp granularity for a period of five years.
Accordingly, it is hereby ordered, pursuant to Section 36(a)(1) of
the Exchange Act,\16\ and Rule 608(e) of the Exchange Act \17\ and with
respect to the proposed approaches specifically described above, that
the Participants are granted a five-year exemption from the timestamp
granularity requirement set forth in Section 6.8(b) and Section 3 of
Appendix D of the CAT NMS Plan of the CAT NMS Plan, subject to the
conditions described above.
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\16\ 15 U.S.C. 78mm(a)(1).
\17\ 17 CFR 242.608(e).
By the Commission.
Vanessa A. Countryman,
Secretary.
[FR Doc. 2020-07789 Filed 4-13-20; 8:45 am]
BILLING CODE 8011-01-P