More exchanges are demanding granular reporting, audits are tougher and more frequent and the scope of what counts as ‘chargeable data’ continues to expand.
In TRG Screen’s latest webinar, Eimear Keane, Senior Manager of Market Data Compliance, joined Julian Morris, Senior Sales Executive, to unpack the fast-changing landscape and share practical steps firms can take to stay ahead of the next audit.
The compliance environment is shifting on multiple fronts. Exchanges are auditing more often, asking for greater detail in reports, and applying new fees to delayed or historical data.
“Where exchanges once overlooked delayed or stored data, many are now charging for it,” Eimear explained. “We’re also seeing new audits from venues that previously didn’t perform them.”
Among the trends highlighted during the discussion:
The result: rising pressure on teams to prove compliance under rules that change faster than their internal systems.
Audits aren’t just an administrative afterthought; they can expose serious financial and operational risk. Interest penalties alone have, in some cases, exceeded the original liability, leaving firms with unexpected exposure.
They’re also taking longer. Remote audits have removed the old face-to-face urgency to close quickly, any many now stretch for six months to a year or more.
“Certain exchanges apply compound interest month on month for the entire audit period… for some firms, the interest amount is actually greater than the underlying liability,” Eimear noted.
The challenges run deeper than timing. A lack of transparency around vendor netting, entitlement mismatches and outdated permissioning can trigger costly discrepancies. And when it comes to data access, auditors take a strict view.
“If an application had the potential to access data – even if it didn’t – they’ll assume a charge,” Eimear warned. “Potential consumption counts.”
The best defense is preparation: define the audit scope early, confirm which systems and users fall within it, and maintain complete, auditable permissioning records. With the right controls in place, firms can reduce the duration and the cost of an audit.
Exchange agreements are becoming increasingly intricate. From affiliate ownership thresholds to cloud-based delivery models and derived data, the definitions that determine compliance are nuanced and open to interpretation.
Non-display usage – once largely confined to algorithmic trading – now covers a much broader range of functions including risk management, portfolio valuation and quantitative analytics. Each may require separate licenses or attestations.
“Even determining whether an affiliate is covered under a parent license can be a challenge,” Eimear noted. “You have to understand the precise language of each agreement.”
Not all the news is bad. Several exchanges are offering netting and savings programs that can offset costs; if managed correctly and if firms meet the reporting demands.
A live poll during the session showed a near-even split between firms managing exchange declarations entirely in-house and those outsourcing some or all of the process.
Eimear’s advice: there’s no universal answer. What matters is control, consistency and transparency.
Teams should focus on:
“The firms that stay audit-ready all year round, not just when the notice arrives, are the ones avoiding unnecessary cost and disruption,” Eimear concluded.
For more information on how TRG Screen helps firms simplify exchange compliance and reduce audit exposure through automation and expert guidance, get in touch with our team. We’d love to help you feel more confident about exchange compliance and your readiness to face audits.