FIA EPTA members are generally supportive of ESMA’s proposed changes to the RTS on synchronisation of business clocks. In relation to the proposed extension of the clock synchronisation requirements to new entities, in general, we agree with the proposed accuracy levels for APAs, SIs, DPEs and CTPs subject to one exception: we believe that the accuracy levels for SIs with a gateway-to-gateway latency less than one millisecond should be the same as that for trading venues and their participants with the same gateway-to-gateway latency. We see no reason why SIs using low latency gateways should have a less granular accuracy level and believe it would be more straightforward for all parties with this gateway-to-gateway latency to adhere to the same requirement.
