Best Practices for Energy Price Indices © Copyright 2003, CCRO. All rights reserved. 7 III. DATA GATHERING AND SUBMISSION 3.1 Quality and Content of Submitted Data Opinions on what data should be submitted by data providers vary widely from index developer to index developer and between index developers and data providers. When determining the recommendations for the content of submitted data, the CCRO had to consider both the value of certain pieces of information for constructing an index as well as the operational, legal, and confidentiality considerations typical of highly competitive commodities markets. For example, providing counterparty name and buy/sell indicator for each transaction will improve index quality by allowing index developers to check for errors and to match transactions with a goal of eliminating double counting. However, such information is extremely sensitive from a commercial point of view and disclosure of such information outside of the index construction process could have severe negative consequences for a data provider. For this reason, best practice for a company submitting such information to an index developer creates an expectation of a strict standard of care on the part of the index developer. This strict standard of care requires both contractual protections and demonstrated business systems and processes to maintain the confidentiality of the data, to limit the use of the data, to control access to the data within the index developer, and to provide other relevant and appropriate safeguards to the data providers. In addition, best practice for some data providers and index developers may require the participation of an independent third party to receive, house, and maintain such data. The provision of such data may require amendments of underlying master agreements between counterparties to allow its release for the purpose of index construction. The CCRO recommends that data providers submit transactional information to index developers as set forth below. 3.1.1 Submit Only Raw Data on a Transaction-by-Transaction Basis Only raw transactional data should be provided, on a transaction-by-transaction basis. No mathematical calculations should be performed and included as data by the data providers the index developer(s) should perform all calculations (e.g., weighted averages, total counts, etc.). 3.1.2 Submit Data on All Applicable Transactions A data provider should submit data on all applicable transactions it completes unless currently existing contractual arrangements prevent it from doing so. A data provider should clearly state which of its legal entity or entities it represents in its submission. 3.1.3 Submit a Complete Set of Data A complete set of data should include all applicable transactions with all data elements/fields the data provider(s) and index developer agree are required for an index. The data should be submitted to index developers at a transactional level at the stipulated frequency for each index. Quantities should be presented in standard units. Commodity specifications from the data provider should be consistent with those of the index developer. In order to improve the accuracy and reliability of