Minimizing Spend on MiFID II Compliance

April 28th 2016 · 2 min read · tco, mifidii, mifid2
By Victor Yodaiken

A customer recently pointed me at a series of blog posts about a project at a financial firm trying to comply with MiFID II clock regulations without TimeKeeper and “with minimum spend”. Reading the posts, it’s clear that costs are already well over what it would have cost them to buy TimeKeeper and they have a lot of work left. After at least six months of effort involving multiple engineers, the team recognizes that it’s a long way from roll out and lists unaddressed issues that include:

  1. Fault tolerance
  2. Monitoring
  3. Alerting

The plant looks quite small: back of the envelope estimating labor costs for the project so far would have put it all under TimeKeeper with money left over for a modern GPS clock, like a Velasync, to replace the end-of-lifed GPS clocks they are using as foundation; And they’d be done and working on other projects, not just starting to tackle fault-tolerance and multiple other hard problems. It looks like the next step will involve purchase of PTP aware network devices (which won’t solve their problems) even though PTP often works better without such devices and even NTP could have been used to meet MiFID II requirements.

The most remarkable aspect of this project, however, is that absence of instrumentation. The developers are relying completely on the software client estimate of accuracy. TimeKeeper’s multi-source capability is designed to solve both fault-tolerance and validation. There are also test devices from companies like Calnex. I wonder how many compliance groups would be happy with “we know it’s in compliance because the unsupported open source program we downloaded says so?” I wonder how customers would react. It’s also curious that a project of this importance that relies on open source projects downloaded from the Internet (which sometimes is a good idea) has been run without comprehensive use of source management tools (the author at one point can’t recall what configuration settings were on an earlier version of the system).

The Last Rose of Summer by William Michael Harnett Self-Operating Napkin by Rube Goldberg (Public Domain, Source)

Frankly, the whole thing is one of those salutary reminders that we (FSMLabs) need to do better market outreach. We have technology that would provide the minimal cost solution and would be reliable and far easier to sell to compliance, but we’re not marketing well enough to have attracted even a request for pricing from these guys. Ouch.

“We were reluctant to purchase TimeKeeper when we could download free software, but in the end the performance, reliability, and total cost of ownership advantages were too compelling to ignore. - Tamir Nitzan, Partner/Lead Technologist, Virtu Financial.