Directive No. 4 — Audit Trails and Records

1. Introduction

1.1 In accordance with Rule 12.1.1, a Trading Member must maintain proper records and audit trails to evidence compliance with the Rules, and in accordance with the requirements in the Securities and Futures Act, Securities and Futures Regulations, and the Rules.

2. Storage of Audit Trail Data

2.1 The Trading Member must keep data and records such that they are easily retrievable by authorised personnel and are stored securely such that no tampering occurs. Backups of records must be kept at a location separate from the original records.
2.2 The Trading Member must check data and records for quality and accuracy on an on-going basis and correct any quality or accuracy defects detected.
2.3 The following are examples of proper procedures in maintaining records and audit trails:—
(a) for electronic storage of audit trail data :
(i) the Trading Member is able to store or download the data in text delimited or ASCII format or such other format that is readable by SGX-ST;
(ii) the Trading Member is able to print out the data in hard copies;
(iii) the Trading Member has proper back-up controls for its data and records;
(iv) the order management system has dated and clocked all data files placed on storage media to reflect the computer run time of the file; and
(b) for non-electronic storage of audit trail data, the Trading Member has paper records showing all the actions of an order (from the point the order is entered) and the respective times and dates, and there are paper records to reflect the print time and date.

3. Audit Trail of Transactions

3.1 A Trading Member must produce to SGX-ST, if asked, a complete audit trail of transactions, from the receipt of an order to its settlement. Unless otherwise required by SGX-ST, for trades and orders which occurred within the 6 month period immediately before the request, the records must be provided to SGX-ST immediately, and for trades and orders which occurred more than 6 months prior to the request, the records must be provided to SGX-ST no later than two business days from the date of request.
3.2 For a complete audit trail of transactions, a Trading Member must ensure that the following records are captured, where applicable:

Record of all Fields Relating To Order Entry

1. SGXAccess Connection ID
2. Trader ID and name
3. Client ID and name — from customer account carried on the books of the Trading Member
3A. Trading Account code
3B. Position Account code
4. User ID and name — used to log into Trading Member's systems
5. Order ID — assigned by the Trading System
6. Order type — eg good-till-cancelled order, all-or-none order, etc
7. Buy/sell
8. Counter name and quantity to be bought/sold
9. Order price — including original trigger price for stop orders
10. Settlement instructions — eg settlement with CPF funds, contra etc
11. Forced key usage
12. Flow of order — if order passes through multiple systems prior to reaching the market
13. Identity of order reviewer — if any
14. Description of amendments made — if any
15. Date and time of order entry, and of any actions taken relating to the order — including transmission, rejection, amending, routing, filtering, execution, withdrawal, etc ,and should include orders that are progressively released.
16. Error messages and subsequent actions taken by the user, reviewer or system
17. Status of order — such as the order being partially filled, fulfilled, unfilled, withdrawn, amended, rejected, etc
18. Executed order number — assigned by the Trading System
19. Traded price — for executed orders
20. Counter name and quantity bought/sold — for executed orders
21. Counterparty Trading Member identity — for executed orders
22. Orders and trades in Trading Member records not stored electronically — to be referenced to Order ID and executed order numbers assigned by the Trading System
23. Any other relevant records/instructions
3.3 For record of times required under the Rules, the Trading Member must ensure that:—
(a) the record of times should be to the highest level of precision achievable by the operating system and such record must be accurate at least to the second;
(b) the times captured must not use a clock that can be modified by the person entering the order; and
(c) the time in the order management system should be synchronized with the GPS time adopted by SGX-ST. If it is not feasible to synchronize the times, the Trading Member must maintain on record the time difference at the start of each Trading Day so as to facilitate the reconciliation of audit trail logs during audit and security incident investigations.

Added on 18 September 201218 September 2012 and amended on 15 March 201315 March 2013 and 1 July 20161 July 2016.