We consider it critically important that regulated buyers monitor their data vendors on an ongoing basis. Anecdotally we have heard that the SEC takes this view, particularly with respect to tracking vendor litigation. Recently, a member of the SEC Examinations team expressed a similar opinion at Neudata’s Winter Summit. We believe that a shift to events-based diligence, rather than diligence solely around contract signatures and renewals, is necessary to mitigate risk in the current environment.

We were comforted to hear a perspective that we consider consistent with the buy-side community’s long-standing diligence and contracting practices for onboarding alternative data.