This topic provides the CME Globex Front-End Audit Trail Requirements.
CME, CBOT, NYMEX, COMEX Rule 536.B.2. requires that the electronic audit trail associated with any system that accesses the CME Globex platform through the CME iLink gateway contain a complete and accurate record of all activity through that connection, and account for every electronic communication by the order routing or front-end system from the time such order routing or front-end system receives or generates an electronic communication until it is communicated to CME Globex. Further, the Rule requires that clearing members guaranteeing a connection to CME Globex are responsible for maintaining, or causing to be maintained, the electronic audit trail for a minimum of 5 years by the responsible party as set forth in the Rule.
Firms responsible for the order routing/front-end audit trail of a trading system that accesses CME Globex through the CME iLink gateway must have the ability to display data in the required format. Further, the connected entity must ensure that all trading functionality supported by the system is appropriately reflected in the audit trail.
For the convenience of those responsible for such order routing or front-end systems, the Exchanges have updated the data definitions, required format, and validation rules applied through the certification process of the minimum acceptable audit trail elements that such systems must capture.
Front End Audit Trail Tier 1 and Tier 2 Architecture
The following diagram depicts the scope of the audit trail responsibilities according to Tier 1 and Tier 2 architectural classifications.