2024-2025 Regulatory Shift

The compliance landscape has fundamentally changed. New SEC requirements specifically target private equity firms and alternative investment managers, while major vendors have increased audit activity by 40% year-over-year.

The Compliance Crisis

Market data compliance has evolved from a back-office concern to a C-suite risk. Vendor audits are increasing in frequency and sophistication, regulatory requirements are expanding, and the financial consequences of non-compliance have never been higher.

$2-5M Average audit settlement for mid-sized firms
40% Increase in vendor audits (2024 vs 2023)
18-24 Months of back-fees typically assessed

What Changed in 2024-2025

Private equity under the microscope. For the first time, PE firms face explicit market data reporting requirements under new SEC rules. Many firms have never properly inventoried their market data usage and are unprepared for compliance reviews.

Alternative data creates new exposure. The explosion of alternative datasets—from satellite imagery to credit card transactions—has created licensing complexity that most compliance teams don't understand.

Remote work amplifies risk. Post-pandemic hybrid work models have created new distribution patterns that many firms haven't properly licensed, creating significant audit exposure.

Financial Risk

Back-fees, penalties, and legal costs can reach $10M+ for large institutions. Even mid-sized firms regularly settle for $2-5M.

Operational Risk

Vendors can terminate services immediately upon finding violations, potentially shutting down trading operations.

Reputational Risk

Major audits become industry knowledge, affecting client perception and LP confidence.

Regulatory Risk

SEC violations can trigger broader regulatory reviews and enforcement actions beyond market data.

Our Compliance Framework

We've been on both sides of vendor audits—as buy-side market data managers defending our firms and as industry experts advising on audit strategy. We know exactly what vendors look for and how to address gaps before they become million-dollar problems.

1

Comprehensive Risk Assessment

We conduct a thorough evaluation of your current compliance posture:

  • Complete inventory of all market data sources and usage
  • Contract review to identify all compliance obligations
  • Gap analysis between current usage and licensed entitlements
  • Audit probability assessment by vendor
  • Estimated exposure calculation
2

Pre-Audit Remediation

If we identify compliance gaps, we help you address them proactively:

  • Prioritized remediation roadmap based on risk and cost
  • Licensing amendments and true-ups with vendors
  • Usage policy development and enforcement
  • Distribution controls implementation
  • Documentation of compliance procedures for audit defense
3

Audit Response Management

When you receive an audit notice, we serve as your advocate:

  • Audit notice analysis and response strategy
  • Data gathering and documentation preparation
  • Direct representation in vendor discussions
  • Settlement negotiation and fee mitigation
  • Legal coordination if disputes escalate
4

Ongoing Compliance Program

Compliance is not a one-time project—it requires ongoing vigilance:

  • Quarterly compliance reviews and reporting
  • New hire/termination controls to maintain licensing accuracy
  • Contract amendment tracking and renewal management
  • Regulatory monitoring and updates
  • Annual audit preparedness testing

Who Should Prioritize Compliance Now

Private Equity & Alternative Investment Managers

The 2024-2025 regulatory changes make you a priority target. If you haven't conducted a comprehensive audit of your market data usage, you're exposed. Many PE firms have grown through acquisition without harmonizing market data licensing—creating massive compliance gaps.

Rapidly Growing Asset Managers

Growth creates compliance risk. When your user count doubles but your licensing processes haven't evolved, you're vulnerable. We've seen numerous cases where firms discover 30-50% of users are improperly licensed during internal audits.

Firms Using Alternative Data

Alternative data providers have different—and often stricter—licensing terms than traditional market data vendors. Social media data, satellite imagery, and transaction data all come with unique redistribution restrictions that most compliance teams don't understand.

Post-Merger Integration

M&A creates instant compliance exposure when you inherit another firm's licensing relationships, usage patterns, and potential violations. We help clean up these situations before vendors discover them.

Typical Outcomes

Pre-Audit Clients

Firms that engage us proactively before receiving audit notices typically achieve:

Audit Response Clients

When we represent firms already under audit, we typically achieve:

Don't Wait for an Audit Notice

Schedule a confidential compliance assessment. We'll identify your exposure and provide a clear remediation roadmap.

Schedule Compliance Assessment