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What is our obligation to ensure that the clocks a non-member uses for reports on our behalf are actually in synchronization?

April 26, 2017actually behalf clocks ensure non-member obligation reports synchronization uses

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What is our obligation to ensure that the clocks a non-member uses for reports on our behalf are actually in synchronization?

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You must obtain a current copy of the procedures used by the non-member entity. Your firm is ultimately responsible for compliance with the OATS Rules; therefore, if you have some indication that the non-member is not in compliance with the OATS Rules, you should contact the non-member entity and FINRA and, if the problem cannot be rectified, select another third party to record and report OATS data for you.