Compliance Services


Licensing & Implementation

As the use of market data feed products and custom software applications consuming market data has increased, so has the need of consumer firms to control and report market data usage

Jordan & Jordan’s Market Data Services group provides industry-leading expertise to banks, brokers, investment managers and hedge funds consuming market data to help them fully understand how market data is used by their firms and their clients, and to be sure their market data usage is being properly reported by their organizations. Our compliance assessment team will provide:

  • Market Data Compliance Assessments
    • Review existing controls surrounding market data entitlement
    • Review and document applications consuming market data
    • Analyze existing inventory management and reporting processes
    • Identify potential reporting and other compliance gaps
    • Provide a potential exchange audit liability analysis
    • Recommend remediation steps to resolve potential compliance gaps based on industry best practices
  • Audit support and response
    • Assist firms in drafting audit responses

Exchange Agreements

Jordan & Jordan’s Market Data Services group specializes in Exchange Agreement interpretation and execution. We have analyzed market data policies relating to display, non-display, derived data creation, roles-based waivers, reporting, and audit provisions from over 70 exchanges worldwide, including:

  • Major Global Exchanges: CME Group, Deutsche Boerse AG, Euronext, Hong Kong Stock Exchange, Intercontinental Exchange, Korea Exchange, London Stock Exchange, New York Stock Exchange, Tokyo Stock Exchange
  • Regional Exchanges: Bolsa Mexicana de Valores, Milan Stock Exchange, Nagoya Stock Exchange, Philippine Stock Exchange, Moscow Exchange
  • Emerging and Frontier Market Exchanges: Bolsa de Valores de Caracas, Nigerian Stock Exchange

Services for Brokers, Investment Managers, Exchanges and Vendors

  • Consulting services for identifying agreement requirements
  • Agreement interpretation and execution
  • Assistance to exchanges and vendors in developing new policies and agreements

Relevant Engagements

Client Type: Global Investment Bank

Exchange Audit Preparation and Response

Assisted client with the management of an audit performed by a major European exchange.

  • Reviewed client market data desktop usage and reporting
  • Reviewed client applications sourcing exchange data
  • Created client analysis of the audit period
  • Reviewed official exchange audit report
  • Developed client's response to exchange audit findings
  • Assisted client in face-to-face meetings with exchange personnel and auditors

Client Type: Global Investment Bank

Market Data Spend Analysis and Reporting Improvements

  • Analyzed market data usage of over 200 applications in Europe, the Americas and the Pacific Rim
  • Identified under-reporting for 40 applications costing millions of dollars; recommended remediation activities reduced on-going liability by over 20%
  • Identified application users with access to unnecessary exchange market data. The termination of such access capability resulted in a further significant reduction in annual liability
  • Identified and quantified the annual financial liability associated with incomplete reporting of users permissioned through DACS
  • Identified application deployment and market data permissioning processes that increased compliance exposure and drafted appropriate workflows to ensure market data compliance
  • Integrated Jordan & Jordan's repository of exchanges' market data policies into its workflow
  • Assisted in developing a pro-active liability settlement strategy to approach exchanges, including development of an exchange-by-exchange risk rating analysis, identification of key exchange personnel and expected negotiation levers

 


NYSE Audits for Clients

Jordan & Jordan is a NYSE-approved audit service provider offering quality Quote Meter, Indirect Bill and Multiple Installations for Single User (MISU) audit services to investment banks, broker dealers, asset managers, hedge funds and vendors who seek assurance that they are compliant with NYSE's policies for market data distribution, usage and reporting.

Our audit methodologies follow the FISD Best Practice Recommendations on the Market Data Audit Process and have allowed us to conclude audits in a timely manner with good client communication and complete confidentiality.

Jordan & Jordan provides a proven process and experienced auditors with adequate backup personnel to handle the following NYSE audit services.

Quote Meter Audits

For a new quote meter vendor, the New York Stock Exchange (NYSE) requires an audit be performed within the first 90 days of service by an external auditing firm acceptable to NYSE. After that initial audit, next audit is due the following calendar year and every 2 years after that. The audit report is due to NYSE by December 31st of the year in which the audit is required.

Jordan & Jordan has been completing quote meter audits for our clients for over 15 years. Our process will verify that firms' quote metering systems are in compliance with the re-distribution, usage and reporting policies of the exchange. Our experience with metering systems enables us to meet the requirements of the exchange with minimal time commitment from the client.

Relevant Engagements

  • J&J completed a five system quote meter audit review for a large investment banking/brokerage firm.
  • J&J assisted an online brokerage firm in confirming that its quote metering system was in compliance with the per query distribution, usage and reporting policies.
  • J&J finalized a quote meter audit for a large global investment banking/brokerage firm in a three month timeframe.

 

Multiple Installations for Single Users (MISU) Audits

The New York Stock Exchange (NYSE) requires that an audit be conducted within the first ninety (90) days of the first issuance of MISU credits. Thereafter, an annual audit is required and must be submitted by December 31st of each year. . The audit is required in order to confirm that each phase of the MISU process is performed in compliance with NYSE guidelines.

J&J has been completing MISU Audits for over 9 years. We have designed our J&J audit procedures to meet the exchange requirements and provide confirmation that clients are in compliance with the exchanges’ reporting criteria. We work with our clients to complete the MISU audit in a timely and efficient manner.

Relevant Engagements

  • J&J confirmed that a global investment bank’s MISU reporting solution was compliant with the policies and procedures of a major US exchange.
  • J&J performed a MISU audit for a broker/dealer to confirm their MISU process was compliant with the exchange policies.

 

Indirect Bill Audits

NYSE requires that an audit be conducted within six months of vendor's eligibility for indirect bill model. Thereafter, an annual audit is required and must be submitted by December 31st of each year.

Our process will verify that firms' procedures for controlling entitlements, permissioning users and reporting are in compliance with the policies of the exchange.

Relevant Engagements

  • J&J assisted an online brokerage firm in confirming that its controls and reporting procedures were in compliance with the requirements of the NYSE Indirect Bill Guidelines.