Time-Stamping Requirements

The whole topic hinges on one number: an order gets two time stamps, and a firm that captures only one has broken the rule.

Two Time Stamps: On Receipt and On Execution

The two stamps bracket the order's journey from the customer to the market.

• When a Futures Commission Merchant (FCM) or Introducing Broker (IB) receives a customer order, it must immediately prepare a written record of the order and time-stamp the date and time of receipt, to the nearest minute.
• The order is then time-stamped again to record the date and time it is transmitted for execution or reported as executed. The floor broker or executing party likewise records the date and time of execution.

Why Two Stamps: The Audit Trail

The pair of stamps exists to prove the order was handled cleanly.

• Together, the receipt-and-execution time stamps create an audit trail showing an order was handled in proper sequence and was not delayed, front-run, or reordered to a customer's disadvantage.
• Order records, like other required books and records, are retained for five years.

Think of it this way: the two stamps are like a package's "picked up" and "delivered" scans. One scan alone cannot prove the package moved on time. With both, anyone can see exactly when the order was received and when it went to market, so no one can quietly slip their own trade ahead of the customer's.

Exam Tip: Gotchas

• Orders get TWO time stamps, not one: on receipt and on execution. A firm that time-stamps only the fill, or only the receipt, breaks the audit trail the rule exists to create. A choice describing a single time stamp is wrong.
• The receipt stamp goes on immediately, to the nearest minute. The written order record is not prepared later from memory; it is created and stamped when the order comes in.