Pillar 1 / Pre-Settlement / Capital Markets
Audit-defensible settlement attestation for broker-dealers and clearing firms.
Per-settlement-event evidence package admissible in any FINRA arbitration without a JIL fact witness. SEC Rule 204 (Reg SHO close-out) defensibility on every fail-to-deliver. Cryptographically signed and anchored on CourtChain, self-authenticating under FRE 902(14).
Fails are easy. The defensible record of why they happened is the hard part.
Every BD CCO has been here: a settlement fails, the customer reaches out, FINRA opens an inquiry, and the firm spends six weeks reconstructing an audit trail from order-management screenshots, end-of-day reports, and email threads. The trail is incomplete, the timestamps are best-effort, and the records-custodian deposition is a foregone conclusion. Pre-Settlement attaches a signed, jurisdictionally-anchored attestation to every settlement event in real time. The audit trail exists before the inquiry starts.
- SEC Rule 204 (Reg SHO close-out). FTDs over 13 settlement days trigger mandatory close-out. JIL emits a check per FTD event with a CREB® tying it to the underlying short-sale chain.
- FINRA Rule 4530 reporting. Customer complaint investigations require a defensible methodology. Per-event CREBs document the deterministic check that ran, the input data, and the verdict.
- SEC Rule 17a-5 (FOCUS reports). Net-capital-relevant settlement data needs auditable provenance. JIL anchors the source data hash on CourtChain at the moment of ingest.
- FINRA arbitration discovery. Demands typically run to 12-18 months of settlement records. JIL produces them in minutes, cryptographically authenticated, FRE 902(14) admissible.
It's not another fraud-screen vendor. It's the evidence layer underneath your existing surveillance.
| Your existing layer | JIL's role | What changes for you |
|---|---|---|
| Trade-surveillance (Nasdaq Smarts / Eventus / Trillium) | Settlement-event attestation alongside, not replacing | Surveillance still flags suspect activity; JIL ensures the underlying settlement record is admissible when the inquiry escalates |
| Order management (Bloomberg AIM / Charles River / Fidessa) | Reads the OMS event stream; emits a signed verdict per settlement | No change to OMS workflow; webhook adds the attestation tier |
| Clearing (DTCC NSCC, options OCC, ACATS) | Per-event attestation on close-out, ACATS partials, FTDs | Clearing house unchanged; firm-side attestation lets you defend against customer claims of bad allocation |
| Records management (EOS / Smarsh / Global Relay) | CREB® bundles archived alongside Rule 17a-4 records | Same SEC-compliant retention archive; attestations strengthen each record's admissibility |
Fail-to-deliver investigations High volume
Per-FTD check emits a CREB® bundling the original short-sale order, locate proof, settlement-fail event, and close-out outcome. Eliminates the records-reconstruction phase of Reg SHO 204 enforcement.
Trade allocation disputes High value
Per-allocation attestation timestamped to the second. When a customer alleges late or unfair allocation, the CREB® record is dispositive.
ACATS partial / rejected transfer Medium
Per-position attestation during ACATS partial. The firm has defensible evidence of which positions transferred when and why others didn't.
Options assignment disputes Medium
Per-assignment attestation tied to OCC random-allocation event. Eliminates the "why was I assigned" customer complaint loop.
Per-settlement-event pricing with three SLA tiers
| SLA tier | Price | Uptime / Latency | Per-event backing | Capital markets fit |
|---|---|---|---|---|
| Tier A - Standard | 35 bps min / $1 floor | 99.9% / 30s | $250K verdict / $5M annual | Boutique BD, single-BD clearing |
| Tier B - Institutional | 45-65 bps + 8-15% premium | 99.95% / 15s | $250K-$2M verdict / $25M annual | Mid-tier BD ($50M+ annual volume) |
| Tier C - Bespoke | Negotiated | 99.99% / 5s | Reinsured syndicate cap | Tier-1 BD, exchange, clearing firm |
Annual prepay reduces per-event rate 12-18%. Sandbox keys (10K events/mo, no SLA) free for evaluation. Pre-Clearance Tier-1 SLA financial backing applies; see /docs/strategy/preclearance/JIL_PreClearance_Section13_6_SLA_Financial_Backing.md.
Ready to see a live attestation against your own settlement stream?
We bring sandbox keys + a sample data set to a 30-min walkthrough. Bring your CCO, compliance counsel, and ops lead. We close with a written 90-day pilot proposal if there's interest.