Are US registered broker-dealers that operate in a foreign country required to comply with the CAT NMS Plan, including the clock synchronization requirements?
Yes. Any broker-dealer that is a member of a national securities exchange or FINRA and receives and/or handles orders in NMS Securities, which includes NMS stocks and Listed Options, and/or OTC Equity Securities – regardless of whether they operate in a foreign country — must report to CAT and satisfy clock synchronization requirements.