OPRA -Auditing

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This document has been developed to serve as a guideline for market data vendors that are required to have an audit/review of their quote meter software.

An audit/review may be performed within the first 90 days of service by OPRA or an external audit firm acceptable to OPRA. Thereafter, an annual audit/review may be performed at the discretion of OPRA. Broker/dealers and banks may, with prior approval of OPRA, use internal audit departments to conduct their annual quote meter audit/review so long as both the audit/review scope and its findings are reported to OPRA and signed by the Chief Compliance Officer of the firm.

The audit/review should check that the quote meter is performing the following functions:

	Recognize and count a "quote-packet or options chain". A "quote packet" consists of last sale, bid/ask, and related market data for a single series or options or a related index. An "options chain" consists of last sale, bid/ask, and related market data for up to all series of put and call options on the same underlying security or index.
	Verify that metering of quote packets and options chains are being done for all metered services identified in Exhibit A. (For example, snap-quote, order entry, etc.) Additionally, ensure that non-metered services are being executed.
	Verify that "capping" of non-professionals at the non-professional rate is being metered properly, and that the "capped" accounts are being reported as non-professionals and their usage removed from the usage report.
	For data disseminated in respect of a list of issues in a portfolio format or set up as a market minder service, each quote packet for each issue is subject to the fee. (For example, a portfolio with five issues translates to 5 quote packets).
	Confirm that the quote meter is counting fee liable quotes (i.e., less than 15 minutes old) only during OPRA market hours, currently 8:30 a.m. through 3:30 p.m. CDT (excluding weekends and holidays).
	Validate that the quote counting software is able to generate monthly reports showing the total number of quotes accessed for each exchange, and that these report totals are consistent with the total number of quotes counted by the meter. The audit should also verify for any two months that the total quotes counted by the meter is the same count as reported to OPRA.

In the event that the audit is performed by an external firm or the customers internal audit department a report should be submitted to OPRA at the conclusion of the audit/review that summarizes the procedures performed and attests that the quote meter functions as described above.

Fifteen minute delayed data is not fee liable.

This fact sheet is a summary document intended to set forth the highlights of OPRA's policies and procedures. Questions and/or circumstances not covered in this document should be referred to OPRA for the determination of procedures.