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Is a CAT Reporter required to report two separate timestamps for Manual Order Events?

Is a CAT Reporter required to report two separate timestamps for Manual Order Events?

Yes, a CAT Reporter is required to report two separate timestamps for Manual Order Events that are entered into an electronic system. If an order is received manually and then later entered into an electronic system for further handling and execution, the CAT Reporter must report both the manual receipt time and the Electronic Capture Time. Specifically, CAT Reporters are required to record and report: (1) the time of a Manual Order Event in increments up to and including one second; and (2) the time when a Manual Order Event has been captured electronically in an order handling and execution system of the Participant or Industry Member ("Electronic Capture Time") in milliseconds. (See Section 6.8 of the CAT NMS Plan available at SEC Approved CAT NMS Plan (11/15/2016))