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 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:

  • Audit support and response
  • Application Compliance Assessments
    • Analyze existing inventory management and reporting processes
    • Review and document applications consuming market data
    • Identify reporting gaps and potential compliance issues
    • Recommend remediation steps to resolve potential compliance issues

Exchange Agreements

Jordan & Jordan’s Market Data group specializes in Exchange Agreement interpretation and execution. We have analyzed, interpreted, and executed agreements from over 70 exchanges worldwide, including:

  • Major Global Exchanges: Deutsche Boerse AG, Euronext, Hong Kong Stock 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, Russian Trading System
  • 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


Market Data Usage Audits

Jordan & Jordan’s Audit Practice provides audit services to investment banks, broker dealers, asset managers, hedge funds and vendors who seek assurance that they are compliant with policies for market data distribution, usage and reporting. Our Audit Practice focuses on providing quality Quote Meter Audits and Multiple Installations for Single User (MISU) Audits for our clients.

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, time saving tools and experienced auditors to handle the following audit services.

Quote Meter Audits

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, a quote meter audit must be performed every 2 years and is due to NYSE by December 31st.

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 Installation for Single Users (MISU) Audit

The New York Stock Exchange (NYSE) requires an annual audit for firms submitting MISU reports. 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 since 2008. 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.