Best Practices for Energy Price Indices © Copyright 2003, CCRO. All rights reserved. 8 price indices, a data provider should submit additional data elements, such as counterparty name and buy-sell indication, only if it determines it is contractually or otherwise permitted to do so and has adequate assurance from an index developer that the data will be protected from improper release or misuse. Contractual confidentiality obligations and demonstrated protection by the index developer with less sensitive data elements may not be sufficient protection for sensitive data and accordingly some data providers and index developers may require the participation of an independent third party. 3.1.4 Submit Annotations for Transactions on Trading Platforms and Clearinghouses The data submitted by energy market participants should include transactions executed on electronic trading platforms and over-the-counter clearinghouses. Since an energy market participant and the platform or clearinghouse may submit the same data to the index developer, energy market participants should include the platform or clearinghouse name in their data set. This allows index developers to eliminate duplications from the data sets submitted by energy market participants on one hand and trading platforms and clearinghouses on the other. All such annotations and submissions should be governed by the contractual (confidentiality) arrangements between the data providers and the trading platforms and the clearinghouses. 3.1.5 Exclude Intracompany Transactions Intracompany transactions (transactions executed with affiliate companies or trading desks within the same company) should not be included in the data provided. 3.1.6 Exclude Nonstandard Transactions Structured transactions (i.e., negotiated transactions that are composed of a combination of standard products such as forwards, futures, and options) should not be included in the data provided. 3.2 Data Provider Processes and Controls The CCRO recommends the following processes and controls for data gathering and data submission for use by energy merchant companies and other entities active in the wholesale energy commodities markets that choose to provide data. Although the guidelines may reference terminology and organization structures most frequently associated with energy merchant companies, each recommendation is intended to be applicable to all market participants that choose to submit data, such as independent producers, consumers, brokerage firms, exchanges, and clearinghouses. For each index, an index developer should define a time horizon for trades to be included in the index, a deadline for data submission, and error resolution, error revision, and challenge processes that include appropriate deadlines. These deadlines should be consistent for all data providers to that index and should take into consideration the time required for the data providers to verify the accuracy and completeness of the data. To illustrate these steps, Exhibit A (appended) lays out an example of a timeline for all the elements of data submission and index publication, including the error resolution, error revision and challenge processes. Actual timelines should be determined by
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