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MiFID II, CAT, and the new reality of time

David Murray | December 4, 2017

The Markets in Financial Instruments Directive (MiFID), in its second iteration, kicks in January 3, 2018, across the European Union, but the effects will be felt worldwide. In the United States, the Security and Exchange Commission will begin to implement its Consolidated Audit Trail (CAT), which will make similar demands on the precision of timekeeping. The hope for both pieces of regulation is that major market-shaking events—or any market event of note—which may only last fractions of a second but may involve thousands or millions of transactions and hundreds of millions or billions in market value will be reconstructable with a high level of confidence and precision to see exactly what caused what.

For financiers, technologists, and any in the intersection of those two groups, this is no major plot twist. Anyone with eyes would have seen MiFID II and CAT coming for the almost completely digital world of finance. But MiFID II (specifically RTS 25) and CAT represent the...

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