Regulatory Notice 4.13.1 — Audit Trails and Records
1.1 In accordance with Rule 4.13.1, a Trading Member and its Trading Representative must maintain proper, complete and accurate records and audit trails, including a complete audit trail of transactions, whether entered into for itself or the Trading Member's customers, from the receipt of an order to its settlement, to evidence compliance with the Rules.
2. Storage of Audit Trail Data
2.1 In accordance with Rule 4.13.2, the Trading Member must keep data and records such that they are easily retrievable by authorised personnel and are stored securely such that no tampering occurs. Backups of records must be kept at a location separate from the original records.
2.2 The Trading Member must also check data and records for quality and accuracy on an on-going basis and correct any quality or accuracy defects detected.
2.3 The following are examples of proper procedures in maintaining records and audit trails:
(a) for electronic storage of audit trail data:
(i) the Trading Member is able to store or download the data in text delimited or ASCII format or such other format that is readable by SGX-ST;
(ii) the Trading Member is able to print out the data in hard copies;
(iii) the Trading Member has proper back-up controls for its data and records;
(iv) the order management system 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 Trading 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 Trading Member must produce to SGX-ST, if asked, a complete audit trail of transactions, whether entered into for itself or its customers, from the receipt of an order to its settlement. Unless otherwise required by SGX-ST, for trades and orders that occurred within the six-month period immediately before the request, the records must be provided to SGX-ST immediately, and for trades and orders that occurred more than six months prior to the request, the records must be provided to SGX-ST no later than two business days from the date of request.
3.2 For a complete audit trail of transactions, a Trading Member must ensure that the following records are captured, where applicable:
Record of all Fields Relating to Order Entry
Record of all Fields Relating to Order Entry
|2.||Trader ID and name|
|3.||Client ID and name — from customer account carried on the books of the Trading Member|
|4.||Trading Account code|
|5.||Position Account code|
|6.||User ID and name — used to log into Trading Member's systems|
|7.||Order ID — assigned by the Trading System|
|8.||Order type — e.g. good-till-cancelled order, all-or-none order, etc|
|10.||Counter name and quantity to be bought/sold|
|11.||Order price — including original trigger price for stop orders|
|12.||Settlement instructions — e.g. settlement with CPF funds, contra etc|
|13.||Force Key usage|
|14.||Flow of order — if order passes through multiple systems prior to reaching the market|
|15.||Identity of order reviewer — if any|
Description of amendments made — if any
Date and time of order entry, and of any actions taken relating to the order—including transmission, rejection, amending, routing, filtering, execution, withdrawal, etc and should include orders that are progressively released.
|18.||Error messages and subsequent actions taken by the user, reviewer or system|
|19.||Status of order — such as the order being partially filled, fulfilled, unfilled, withdrawn, amended, rejected, etc|
|20.||Executed order number — assigned by the Trading System|
|21.||Traded price — for executed orders|
|22.||Counter name and quantity bought/sold — for executed orders|
|23.||Counterparty Trading Member identity — for executed orders|
|24.||Orders and trades in Trading Member records not stored electronically — to be referenced to Order ID and executed order numbers assigned by the Trading System|
|25.||Any other relevant records/instructions|
3.3 For record of times required under the Rules, the Trading Member must ensure that:
(a) 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;
(b) the times captured must not use a clock that can be modified by the person entering the order; and
(c) the time in the order management system should be synchronised with the GPS time adopted by SGX-ST. If it is not feasible to synchronise the times, the Trading Member must maintain on record the time difference at the start of each Trading Day so as to facilitate the reconciliation of audit trail logs during audit and security incident investigations.