Compliance

Understanding vendors’ and exchanges’ data policies and tracking data usage belong to the biggest challenges of user firms.

Data Policies & Audits

In 2006, an article in Inside Market Data (IMD), covering a story about an audit by London Stock Exchange (LSE), marked the start of a new era. Since then, a growing group of exchanges and data providers have adopted the means of an audit - to verify that past and current data usage is compliant with contract obligations and policies.
This has proven to be so successful – for the auditors – that this has developed as a business-in-the-business.

Simultaneously, despite the efforts of industry groups, data contracts and data policies still lack standardisation and appear to get more and more complex. Today, over 100 global exchanges offer information products. Even though this data may be carried by a third party data vendor, e.g. Refinitiv, Bloomberg, etc., its use remains subject to the individual policies of the respective exchanges. User firms are required to ensure that data usage and the associated reporting of licenses is compliant with these policies.

An audit may easily result in an unpleasant surprise for the user firm, e.g. through unexpected corrective invoices due to under-reporting, penalties, as well as a significant increase of the future spend.

 

 

Compliance assessment

Market data audits ususally result in findings, caused by reporting discrepancies as a result of an unintentional misinterpretation of the reporting rules as laid down in agreements and policies. The financial impact can be huge. To ensure that you are compliant and to avoid any negative effects of an audit, we offer to conduct a compliance assessment.

Thanks to our deep knowledge of market data agreements and exchanges’ data policies, our open communication lines with vendors and exchanges, as well as many years of experience with managing audits, we are in a unique position to quickly and efficiently assess your firms’s state of compliance with contractual obligations. It includes an assessment of specific requirements which the user firm must meet, e.g. the setup and use of (an) entitlements system(s), technical measures preventing users from accessing data via more than one device simultaneously, the registration of non-professional subscribers, the use of trademarks in client reports containing benchmark data, etc. We'll  ensure as well that you benefit from favourable policies where applicable.

The assessment ensures a correct and unambiguous interpretation of:

In the event the assessment points out that data usage is not compliant with certain agreements or data policies, we'll ensure that the necessary steps will be determined and corrective actions will be taken. 

We cannot prevent vendors and exchanges to carry out audits, but a compliance assessment will prevent you from unexpected and unpleasant surprises from audits.

 

Audit management

In case the firm is faced with an audit, it is important to have the right combination of skills on board, capable to efficiently and effectively follow up on the vendor's requirements.  If not, the chances are high that, despite the efforts of your staff,  the audit will result in a financial drama, including potential reputational consequences. In case the firm is faced with an audit, we can partner with you to manage the audit. We'll unburden your staff from the audit activities, such as the retrieval of all information, e.g. historical entitlements reports, as well as the proper reporting to the auditor and any follow-up actions. The expert knows the pitfalls of the data policies and speaks the language of the vendors and the exchanges. We ensure that the impact remains as limited as possible.

 

Declaration service

The Declaration Service is a unique service which helps you to ensure that your data access declarations are compliant with vendor agreements and exchanges' data policies. There is no need to hire expensive market data specialists for declaring data accesses; we'll do the work for you.

We process the exports from your inventory and entitlements systems, to produce accurate and compliant declarations in accordance with vendor agreements and exchange data policies.

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