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Regulatory Notice 2.6.4 — Audit Trails and Records
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Regulatory Notice 2.6.4 — Audit Trails and Records

Past version: effective up to May 1 2011.
To view other versions open the versions tab on the right.

Issue Date Cross Reference Enquiries
Added on
22 September 2006.
Rule 2.6.4 Please contact Member Supervision:

Facsimile No : 6538 8273
E-Mail Address: membersup@sgx.com

1. Introduction

1.1 This Regulatory Notice explains the circumstances, conditions and operational procedures pursuant to the requirement under Rule 2.6.4 that a corporate Member maintains proper records and audit trails that evidence compliance with this Rules.

2. Storage of Audit Trail Data

2.1 The Member should keep data and records such that they are easily retrievable by authorised personnel and are stored securely such that no tampering occurs.
2.2 The following are examples of proper procedures in maintaining records and audit trails:—
(a) for electronic storage of audit trail data :
(i) the Member is able to store or download the data in text delimited or ASCII format or such other format that is readable by the Exchange;
(ii) the Member is able to print out the data in hard copies;
(iii) the Member has proper back-up controls for its data and records; and
(iv) the OMS has dated and clocked all data files placed on storage media to reflect the computer run time of the file;
and
(b) for non-electronic storage of audit trail data, the Member has paper records showing all the actions of an order (from the point the order is entered) and the respective times and dates, and there are paper records to reflect the print time and date.

3. Audit Trail of Transactions

3.1 A corporate Member shall produce to the Exchange, if asked, a complete audit trail of transactions, from the receipt of an order to its settlement. For this purpose, a Clearing Member's Customers include those Members that it sponsors. The Clearing Member should arrange for a Customer granted Bypass Privileges to provide to the Clearing Member details of that Customer's trades, and where necessary, the daily orders.
3.2 For a complete audit trail of transactions, a corporate Member must ensure that the following records are captured, where applicable:
3.2.1 Record of all Fields Relating To Order Entry

(details of an order)

1. Order date — date order is entered into the OMS
2. Trade date — date order is executed in QUEST
3. Commodity
4. Commodity month
5. Commodity year
6. Call/ put
7. Strike price
8. Traded premium
9. Original quantity — original order size
10. Transmitted quantity — actual size transmitted to QUEST or an accessible foreign market
11. Traded quantity — actual size of order filled
12. Original order price — price at which order is to be executed
13. Original trigger price (for stop orders)
14. Traded price — actual price at which order is executed
15. Trade type (e.g. outright order, spread order)
16. Approved Trader/ User id — unique identifier for each user of the OMS. In the case of Direct Market Access, Member should be able to identify where the order is coming from
17. Order number — unique number assigned to each order sequentially
18. Clearing Member code
19. Account number
20. Status of order at all stages (e.g. original order, amended, filled, unfilled, withdrawn or cancelled, rejected, re-routed for review)
21. Order type (e.g. Market Order, Limit Order, Stop Order)
22. Combined order type (e.g. Market — If — Touched order, Market — On — Close order, One — Cancels — the — Other Order)
23. Order qualifier (e.g. day order, fill or kill, good — till — cancelled, good — till — date, good — till — session)
24. Buy/ Sell
25. Time of entry through all processors in the OMS (e.g. time at which order entered into the OMS , time at which order reached the Member's network, time at which order reached QUEST)
26. Time of execution
27. Origin (Customer or House Trade)
28. Timestamp for changes made to audit trail records (e.g. to record the time at which the account number, price or quantity of a filled trade in the audit trail file/ record is changed)
3.2.2 Record of amendment of orders
1. Details of the change that is made (the newly amended order should be easily traced to the original order)
2. Time of amendment
3. User id of the Approved Trader who enters the original order into the OMS
4. User id of the Approved Trader who amends the order (if the order is amended by another user)
3.2.3 Record of Withdrawal of Orders
1. Details of the order
2. Time of withdrawal
3. User id of the Approved Trader who enters the original order into the OMS
4. User id of the Approved Trader who withdraws the order (if the order is withdrawn by another user)
3.2.4 Record of Orders Rejected
1. Details of the order
2. Time at which order was rejected by the OMS
3. Time at which order was rejected by QUEST
4. Reasons for the rejection of order
3.2.5 Record of Orders Entered into the Local Order Pad of the OMS

(where orders that are not released to QUEST are stored)

1. Details of the order (as described in paragraph 3.2.1, wherever applicable)
2. Time at which order was entered into, amended and/or withdrawn from the local order pad
3. Time at which order was released to QUEST
4. Time at which order in the queue was moved back to the local order pad
3.2.6 Record of Customers' Orders Deferred/ Re-routed to the Member

(if the OMS allows interception of Customers' orders before releasing the orders to QUEST)

1. Details of the order (as described in paragraph 3.2.1, wherever applicable)
2. Time at which order was intercepted by the Member
3. Time and details of any subsequent amendment/ withdrawal of the intercepted order
4. Time at which order was released to QUEST
5. User id of the Member's employee who handled the intercepted order
3.2.7 A "Relative" Key
1. A unique identifier that will tie together all actions relating to a specific order. This identifier will remain unchanged throughout the lifespan of the order and should be able to link the order to the trade number assigned by QUEST.
3.3 For record of times required under this Rules, the Member must ensure that:

1. the record of times should be to the highest level of precision achievable by the operating system and such record must be accurate at least to the second;
2. the times captured must not use a clock that can be modified by the person entering the order; and
3. the time in the OMS should be synchronized with the GPS time adopted by the Exchange. If it is not feasible to synchronize the times, the Member must maintain on record the time difference at the start of each Business Day so as to facilitate the reconciliation of audit trail logs during audit investigation.