by Adam W

On January 3rd 2018 the broadest piece of legislation affecting the financial markets, the Markets in Financial Instruments Directive came into effect - read this case to learn how Redcello and partners built a MIFID II compliant time service...



Case study: MIFiD II - Time Services



The Problem


One of the key MiFID II requirements is the need for verified and continuous synchronised time in order to achieve "trade reconstruction". Trading venues and the participants in the trade are required to time-stamp events and records that occur in the trading process with the time that is synchronised up to 100 microseconds depending on the type of trading venue from which they are operating i.e. HFT market participants need to reach the 100-microsecond standard. It is also necessary for trading venues to have a common reference time that allows operators of trading venues the ability to record the date and time based on the same time source, as well be able to distinguish between different reportable events. In order to respond to the need for a compliant and accurate time service, Redcello and our partner and Capital Markets customer CJC, set out to build a multi-source Grandmaster time service with a front end provision that would serve to achieve and maintain reports for MIFiD II compliance.

Is the time keeping requirement compliant with the MIFID II standard or better?

How can we ensure consistent time and monitor a number of sources?



Challenges


We understood that a number of challenges faced the build, for example, these are just a few:

Placement of Multiple GPS Devices - geographically based in the UK, accurate, agnostic capture of multiple time sources.

Custom built servers / enhanced quality hardware with opportunity for upgrades.

Low latency, highly available private connection services.

Finding the correct front end / customer client software - needs to have visualisation, dashboards, compliance / audit capabilities, the ability to manage, monitor and alert from one screen.

Finance grade time systems that are compliant and auditable with MiFID II accuracy SLA guarantee.

Timesources - multi sourced, NTP/PTP/PPS as a service.



The Solution


Keeping time can be messy, and can require detailed engineering - so simplicity was a key objective in the building of our solution. It was decided that our requirement would need us to build a custom Grandmaster, this should be done with enterprise quality hardware, and support a range of connection speeds up to 40Gbit and beyond, which appeared to be lacking in the current Time Server market. The Grandmaster also required accurate multi-source time - this would be done by installing multi-site GPS to grasp the most accurate time sources from disparate locations. The placement of the GPS had to be strategic in terms of not only the geographical location in relation to the time servers but also down a detailed placement path, that was protected from interference, the elements, and blockages in signal.



GPS


Installing GPS comes with a number of challenges, knowing the correct hardware to purchase and install is only half the battle, you also have to work around a number of operational processes in order to get an installation to take place, this can sometimes not happen quickly. Management of the networks, while installation took place on-site at the data-center, was also challenging.



Servers


As previously mentioned, we were keen to improve the quality of Timeserver hardware that was currently available on the market. This involved purchasing high-quality Dell servers custom made to our specifications that had the expansion capabilities we required. We also wanted to offer 25Gb/ 40GB NIC upgrades into our offering and our server build would have to accommodate this potential. GPS Clock Cards and PCIe cards were installed and a significant number of interoperability issues, incompatible driver updates were overcome - working alongside card manufacturers and partners alike to ensure we achieved a high-quality product and a generally enhanced offering suited to the demands of the Fintech market.



Network Connectivity


We decided that using several carriers would be the way forward in order to create a blended service, so that a service that was redundant and reliable was built. The connectivity between our sites would utilise Private Fibre connections, and high quality WAN connections made allowances in terms of expanding the service via the use of these connections.



Front End


Redcello became partner/ UK reseller for the Timekeeper Suite by FSMLabs. It was feature rich and satisfied the customer's original scope and requirements. The TimeKeeper client was able to support a number of different time sources, including NTP client, PTP Grandmaster, boundary clocks and PPS. The ability to be able to pull this time data into a time visualisation web-based front end would make it easy for customers to see the differing accuracy of all these time sources. Again in terms of the customer requirement for visibility, it was necessary that the software had extensive syslogs, messaging and notifications delivered as well as access to a REST API in order for customers to really customise their reporting. TimeKeeper client also had the ability to slew time, which is a must for leap second handling as well as the feature of time validation and the ability to clock adjust. So, all in all, Timekeeper software made it easy for us to deliver our Grandmaster time into a centralised management of time networks, with extensive compliance, regulatory reporting, and data governance all delivered via a GUI.


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