OUR VISION 

NASDAQ OMX has experience 

and expertise to assist with: 

• Collection and consolidation of 

data 

• Dissemination of data in a 

highly controlled environment to 

many customers or solely to 

regulators, as required 

NASDAq aMX·. 3 

Title VII of the Dodd-Frank Act takes important first steps in 

creating transparency for OTC derivatives trading. 

In particular, the creation of Swap Data Repositories creates a 

positive obligation on Swap Dealers and will encourage greater 

transparency. 

A truly transparent market for OTC derivatives will not only 

require that the information be reported to Swap Data 

Repositories, but also distributed widely throughout the industry 

in a manner that makes it easy to see and to understand. 

OTC derivatives are important to the industry and information 

about them should be as widespread as information for other 

asset classes. 
OUR VISION 

NASDAQ OMX's vision for OTC 

derivatives data is to increase 

transparency of market 

transparency by: 

NASDAqaMX 4 

Creating a simple and complete dissemination vehicle 

Utilizing NASDAQ OMX technology and management expertise 

Decreasing fragmentation within data repositories 

Mass distributing data throughout our global network of 1 ,500 

distributors including web portals, market data vendors, brokerdealers, independent software vendors, etc., as well as 

200,000+ subscribers 

PROPOSED SOLUTION 

REQUIREMENTS 

ASDAqaMX 6 

Harmonize and consolidate the data across many reporting 

parties 

Create a low cost real-time set of data feeds 

Keep the solution simple 

- Avoid unnecessary, distracting, expensive, delaying, and 

d ifficu It -to-replace solutions. 

- Avoid variety in the infrastructure which, over time, could 

escalate into a complex and expensive system, effectively 

establishing a barrier to broad-based distribution. 
PROPOSED SOLUTION 

REQUIREMENTS (CONT.) 

Sales 

Billing 

,If.';{ ... ~"' .• '-·' ":!;; 

': · M~nagement ~ ~ . ~ .... ' . 

j 

Administration 

NASDAqGMX 7 

Create a complete solution, including technology, management, 

and administrative components of distribution 

Operate at a high level of efficiency to provide maximum value to 

customers 

Facilitate repositories in fulfilling their obligation to provide 

information to regulators 

LEVERAGING OUR 

EXPERIENCE 

NASDAQ OMX's expertise in 

equities is transferrable to OTC 

Derivative data dissemination. 

NASDAq aMX·' 9 

• Consistent contact with vast majority of would-be customers 

of OTC data 

• Established contracts with terms and conditions governing 

data usage and distribution 

• Experience with consolidation of data and other technical 

expertise through the operation of the Tape C SIP and 

FINRAINASDAQ TRF 
EXPERIENCE: 

DATAFLOW 

Swap Data 

Repository 

Swap 

Execution 

Facility 

Swap Dealer 

Archive 

and 

Storage 

Real-time data 

Consolidator Feeds 

NASDAq aMX· 10 

Terminal Data 

lf Vendors 

~ 1 Online Portals 

I 

--l 

~ !: .-..j Broker/Dealers 

0 I. 1 Buy-Side Funds ::I 

'- Retail Online 

Brokers 
EXPERIENCE: 

GOVERNANCE 

Unified 

Plan 

Technical 

Committee 

Create a contractual unified plan giving participants ownership 

over direction 

Create a sub-committee (voted by plan participants) to vote on 

direction of plan 

•Include a representative from both the SEC and the CFTC. 

Create a technical committee to move quickly on technical 

changes 

Convene quarterly meetings to discuss outstanding items 
EXPERIENCE: 

GOVERNANCE 

NASDAq aMX 1

2 

Maintain external steering committee to help understand impact 

of direction 

Determine the outcome of votes by majority rather than 

unanimous outcome 

Draw heavily on the experience of the four US tape plans of 

which we are a member 
EXPERIENCE: 

TRANSPARENCY 

Real-time information is extremely 

important to data recipients. 

Delayed information does not help 

the industry with price discovery 

NASDAq GMX 3 

Real-time dissemination: 

Gives an indication of the price and size associated with 

instruments 

Allows users to be completely informed during the dissemination 

period 

Helps reduce confusion with fragmentation in the market 

Provides all information to customers at the same time - levels 

the playing field for all participants 
NASDAQ OMX 

GLOBAL DATA PRODUCTS 

NASDAq aMX~ 14 

• Experienced operator of consolidation services {Tape C 

Administrator, Tape C consolidator since 1990 with standard 

data feeds created in 2002) 

• Experienced participant and voting member of the Tape A, 

Tape B, Tape C and OPRA tape plans. 

• Provider of proven low latency technology 

• Huge economies of scale in technology, product 

management, customer administration, billing and customer 

support 

• Leader in innovative programs to ensure maximum uptake on 

products 

• Existing and recognized standards, connectivity, protocols 

and contacts 

• Established relationships ensures the fastest possible uptake 

by vendors and other market participants 
CONTACT US 

··:·;:·." . . : ... ~ 

' . '