Regulation NMS Due Diligence Services
Jordan & Jordan has been actively involved in Regulation NMS implementation and compliance at both the industry and firm level. We provided leadership and resources to the Joint SIFMA/FIF Regulation NMS Implementation Working Group made up of SROs, broker dealers, market data vendors and service bureaus. Additionally, for broker-dealer clients we have participated in Regulation NMS implementation efforts evaluating options for routing ISOs, crossing orders internally and vendor selection for Reg NMS services.With Reg NMS fully underway, Jordan & Jordan offers consulting, project management and compliance services which include:
Reg NMS Data Processing Review
The SEC recommends continued due diligence with respect to data handling in a Reg NMS environment.- Comparison of firm trade data to network quote data (CTA and UTP) based on time stamp to identify potential trade-through conditions
- Review of snapshot quotes and National Best Bid Offer (NBBO) when internalizing trades and generating Intermarket Sweep Orders (ISOs)
- Review and analyze snapshot quotes against network quote data to determine latency metrics
- Routing and execution venue performance analysis
- Assist in the development of action plans for the resolution of issues
Data Latency and Clock Synchronization Compliance Review
- Review the policies, procedures and tools used to monitor and manage end-to-end latency
- Confirm that all time stamp instrumentation systems provide synchronized time stamps from acceptable source(s) using acceptable method(s)
- Recommend appropriate technology upgrades and changes in policies and procedures, as required