Compliance Alert – CAT Clock Synchronization Certification Deadline

Understanding the Annual CAT Clock Synchronization Certification

The Annual Clock Synchronization Certification is a mandatory requirement for all CAT reporting Industry Members, including introducing brokers and clearing firms. Industry Members are required to complete the CAT Clock Synchronization Certification form by March 15th of each year. The certification confirms that all business clocks used for CAT reportable events are synchronized according to the required standards set by the CAT NMS Plan. The certification covers the period from January 1 to December 31st of the previous year. Firms that became CAT Reporters during the calendar year must also certify compliance from the date of their first CAT report submission to December 31^st.

The Annual Certification ensures that for electronic events, business clocks are synchronized to within fifty milliseconds of the NIST atomic clock, and for manual events, clocks used for manual order events are synchronized to within one second of the NIST atomic clock.

Who Must Submit the Certification Form?

All Industry Members who report to CAT, including:

• Introducing Brokers
• Clearing Firms
• Market Makers
• Proprietary Trading Firms

Each firm is individually responsible for certifying its compliance, regardless of whether a third-party vendor or clearing firm provides synchronization services.

Steps for CAT Reporters to Complete the Certification Process

Conduct an Internal Review

1. Verify that all business clocks were synchronized to the required accuracy for the entire calendar year to the compliance requirement of 50-millisecond for electronic orders and one-second for manual orders.
2. Review internal synchronization logs and any provided by external vendors for consistency and completeness.
3. Ensure clock drift corrections were applied promptly when necessary.
4. Validate that any drift outside of the standards was reported to FINRA CAT and evidenced within the Firm’s books and records.

Complete the Certification:

• Access the CAT Reporter Portal using your firm’s authorized credentials.
  • Navigate to the Forms Section on the CAT NMS site and complete Annual Clock Synchronization Certification Form (2025).
  • Complete and maintain the form as part of the firm’s books and records for at least five years.
  • Obtain, review, and evidence additional clock synchronization forms required for compliance from any other third-party vendor who are responsible for clock synchronization of the firm’s business clocks for reporting.

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