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Epilogue
MYSTERY #2
Will regulators accept a skew-adjusted approach to application-timestamp error?
For simplicity, let’s assume for the moment that we only care about maximum divergence. I’ll extend the discussion to percentiles in a moment.
MYTH #5
If 99.x% of my timestamps fall within RTS 25, the odds that regulators will discover a timestamp that is out of compliance is very small.
MYSTERY #1
Will regulators be absolute in their focus on maximum divergence, or will they allow exceptions?
MYTH #4
There’s nothing to do about application-level error on a given server. It is what it is, and regulators will just have to accept that.
MYTH #3
Application-level error is so significant that no application- timestamping solutions can meet MiFID 2 requirements.
MYTH #2
Application-level error isn’t significant enough to matter. Look at how small my mean and standard deviation are.
MYTH #1
Application-level error doesn’t matter because it does not affect the sequence of reportable events.
Some people have argued as follows: