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FY2019 Annual Report · Nasdaq
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
_______________________________

FORM 10-K 

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2019

OR

TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from ________ to ________

Commission file number: 001-38855 
___________________________________
Nasdaq, Inc. 
(Exact name of registrant as specified in its charter)

Delaware
(State or Other Jurisdiction of Incorporation or Organization)

52-1165937
(I.R.S. Employer Identification No.)

151 W. 42nd Street, New York, New York

10036

(Address of Principal Executive Offices)

(Zip Code)

Securities registered pursuant to Section 12(b) of the Act:

Registrant’s telephone number, including area code: +1 212 401 8700 

Title of each class

Trading Symbol(s)

Name of each exchange on which registered

Common Stock, $0.01 par value per share

0.875% Senior Notes due 2030

1.75% Senior Notes due 2029

1.750% Senior Notes due 2023

3.875% Senior Notes due 2021

NDAQ

NDAQ30

NDAQ29

NDAQ23

NDAQ21

The Nasdaq Stock Market

The Nasdaq Stock Market

The Nasdaq Stock Market

The Nasdaq Stock Market

The Nasdaq Stock Market

Securities registered pursuant to Section 12(g) of the Act: None

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.   Yes  
Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Exchange Act.  Yes  
Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities 

    No  

   No  

Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has 
    No  
been subject to such filing requirements for the past 90 days.    Yes  

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to 
Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to 
submit such files).    Yes  

    No  

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting 

company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company” and 
“emerging growth company” in Rule 12b-2 of the Exchange Act.

Large accelerated filer
Non-accelerated filer
Emerging growth company

Accelerated filer
Smaller reporting company

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for 

complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. 

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).    Yes  

    No   

As of June 28, 2019, the aggregate market value of the registrant’s common stock held by non-affiliates of the registrant was 
approximately $11.1 billion (this amount represents approximately 115.5 million shares of Nasdaq, Inc.’s common stock based on the last reported 
sales price of $96.17 of the common stock on The Nasdaq Stock Market on such date).

Indicate the number of shares outstanding of each of the issuer’s classes of common stock, as of the latest practicable date.

Class
Common Stock, $0.01 par value per share

Outstanding at February 13, 2020
165,011,712 shares

Documents Incorporated by Reference: Certain portions of the Definitive Proxy Statement for the 2020 Annual Meeting of Stockholders are 
incorporated by reference into Part III of this Form 10-K. 

 
 
 
 
Nasdaq, Inc. 

Part I.

Item 1.

Business

Item 1A. Risk Factors

Item 1B. Unresolved Staff Comments

Item 2.

Properties

Item 3.

Legal Proceedings

Item 4. Mine Safety Disclosures

Part II.

Item 5. Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity 

Securities

Item 6.

Selected Financial Data

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Item 7A. Quantitative and Qualitative Disclosures About Market Risk

Item 8.

Financial Statements and Supplementary Data

Item 9.

Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

Item 9A. Controls and Procedures

Item 9B. Other Information

Part III.

Item 10. Directors, Executive Officers and Corporate Governance

Item 11. Executive Compensation

Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

Item 13. Certain Relationships and Related Transactions, and Director Independence

Item 14. Principal Accounting Fees and Services

Part IV.

Item 15. Exhibits, Financial Statement Schedules

Item 16. Form 10-K Summary

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Throughout this Form 10-K, unless otherwise specified:

About this Form 10-K

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“Nasdaq,” “we,” “us” and “our” refer to Nasdaq, Inc.

“Nasdaq Baltic” refers to collectively, Nasdaq Tallinn AS, Nasdaq Riga, AS, and AB Nasdaq Vilnius.

“Nasdaq BX” refers to the cash equity exchange operated by Nasdaq BX, Inc.

“Nasdaq BX Options” refers to the options exchange operated by Nasdaq BX, Inc.

“Nasdaq Clearing” refers to the clearing operations conducted by Nasdaq Clearing AB.

“Nasdaq First North” refers to our alternative marketplaces for smaller companies and growth companies in the Nordic and 
Baltic regions.

“Nasdaq GEMX” refers to the options exchange operated by Nasdaq GEMX, LLC.

“Nasdaq ISE” refers to the options exchange operated by Nasdaq ISE, LLC. 

“Nasdaq MRX” refers to the options exchange operated by Nasdaq MRX, LLC. 

“Nasdaq  Nordic”  refers  to  collectively,  Nasdaq  Clearing AB,  Nasdaq  Stockholm AB,  Nasdaq  Copenhagen A/S,  Nasdaq 
Helsinki Ltd, and Nasdaq Iceland hf.

“Nasdaq PHLX” refers to the options exchange operated by Nasdaq PHLX LLC.

“Nasdaq PSX” refers to the cash equity exchange operated by Nasdaq PHLX LLC.

“The Nasdaq Options Market” refers to the options exchange operated by The Nasdaq Stock Market LLC.

“The Nasdaq Stock Market” refers to the cash equity exchange and listing venue operated by The Nasdaq Stock Market LLC. 

Nasdaq also provides as a tool for the reader the following list of abbreviations and acronyms that are used throughout this 
Annual Report on Form 10-K.

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401(k) Plan: Voluntary Defined Contribution Savings Plan

ASU: Accounting Standards Update

2016 Credit Facility: $400 million senior unsecured term loan 

ATS: Alternative Trading System 

facility repaid in full and terminated in June 2019

2017  Credit  Facility:  $1  billion  senior  unsecured  revolving 

credit facility which matures on April 25, 2022

2019 Notes: $500 million aggregate principal amount of senior 
unsecured  floating  rate  notes  repaid  in  full  on  maturity  in 
March 2019

2020 Notes: $600 million aggregate principal amount of 5.55% 
senior unsecured notes repaid in full and terminated in May 
2019

2021  Notes:  €600  million  aggregate  principal  amount  of 

AUM: Assets Under Management

CAT: A market-wide consolidated audit trail established by 
Nasdaq and other exchanges under an SEC approved plan

CCP: Central Counterparty

CFTC: U.S. Commodity Futures Trading Commission

EMIR: European Market Infrastructure Regulation

Equity Plan: Nasdaq Equity Incentive Plan

ESPP: Nasdaq Employee Stock Purchase Plan

3.875% senior unsecured notes due June 7, 2021 

ETF: Exchange Traded Fund

2023 Notes: €600  million aggregate principal amount of 1.75% 

ETP: Exchange Traded Product

senior unsecured notes due May 19, 2023 

2024 Notes: $500 million aggregate principal amount of 4.25% 

senior unsecured notes due June 1, 2024

2026 Notes: $500 million aggregate principal amount of 3.85% 

Exchange Act: Securities Exchange Act of 1934, as amended

FASB: Financial Accounting Standards Board

FICC: Fixed Income and Commodities Trading and Clearing

senior unsecured notes due June 30, 2026

FINRA: Financial Industry Regulatory Authority

2029 Notes: €600  million aggregate principal amount of 1.75% 

IPO: Initial Public Offering

senior unsecured notes due March 28, 2029

2030  Notes:  €600  million  aggregate  principal  amount  of 

0.875% senior unsecured notes due February 13, 2030

LIBOR: London Interbank Offered Rate

MiFID  II:  Update  to  the  Markets  in  Financial  Instruments 
Directive

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MiFIR: Markets in Financial Instruments Regulation

SEC: U.S. Securities and Exchange Commission

MTF: Multilateral Trading Facility

SERP: Supplemental Executive Retirement Plan

NFF:  Nasdaq  Financial  Framework;  Nasdaq's  end-to-end 
technology solutions for market infrastructure operators, buy-
side firms, sell-side firms and other non-financial markets 

NFX: Nasdaq Futures, Inc.

NPM: The NASDAQ Private Market, LLC

NSCC: National Securities Clearing Corporation

OCC: The Options Clearing Corporation

OTC: Over-the-Counter

Proxy Statement: Nasdaq’s Definitive Proxy Statement for 
the 2020 Annual Meeting of Stockholders

PSU: Performance Share Unit

Regulation NMS: Regulation National Market System

Regulation SCI: Regulation Systems Compliance and 
Integrity

SaaS: Software as a Service

SFSA: Swedish Financial Supervisory Authority

SI: Systematic Internalizer

S&P: Standard & Poor’s

S&P 500: S&P 500 Stock Index

SRO: Self-regulatory Organization

SSMA: Swedish Securities Markets Act 2007:528

TSR: Total Shareholder Return 

U.S. GAAP: U.S. Generally Accepted Accounting Principles

UTP: Unlisted Trading Privileges

UTP  Plan:  Joint  SRO  Plan  Governing  the  Collection, 
Consolidation,  and  Dissemination  of  Quotation  and 
Transaction Information for Nasdaq-Listed Securities Traded 
on Exchanges on a UTP Basis

VAT: Value Added Tax

* * * * * *

NASDAQ, the NASDAQ logos, and other brand, service or product names or marks referred to in this report are trademarks or 
service marks, registered or otherwise, of Nasdaq, Inc. and/or its subsidiaries. FINRA and TRADE REPORTING FACILITY 
are registered trademarks of FINRA.

* * * * * *

This Annual Report on Form 10-K includes market share and industry data that we obtained from industry publications and surveys, 
reports  of  governmental  agencies  and  internal  company  surveys.  Industry  publications  and  surveys  generally  state  that  the 
information they contain has been obtained from sources believed to be reliable, but we cannot assure you that this information 
is accurate or complete. We have not independently verified any of the data from third-party sources nor have we ascertained the 
underlying economic assumptions relied upon therein. Statements as to our market position are based on the most currently available 
market data. For market comparison purposes, The Nasdaq Stock Market data in this Annual Report on Form 10-K for IPOs is 
based on data generated internally by us, which includes best efforts underwritings; therefore, the data may not be comparable to 
other publicly-available IPO data. Data in this Annual Report on Form 10-K for new listings of equity securities on The Nasdaq 
Stock Market is based on data generated internally by us, which includes best efforts underwritings, issuers that switched from 
other listing venues, closed-end funds and ETPs. Data in this Annual Report on Form 10-K for IPOs and new listings of equity 
securities on the Nasdaq Nordic and Nasdaq Baltic exchanges and Nasdaq First North also is based on data generated internally 
by us. IPOs and new listings data is presented as of period end. While we are not aware of any misstatements regarding industry 
data presented herein, our estimates involve risks and uncertainties and are subject to change based on various factors, including 
those discussed in “Item 1A. Risk Factors” in this Annual Report on Form 10-K.  

Nasdaq intends to use its website, ir.nasdaq.com, as a means for disclosing material non-public information and for complying 
with SEC Regulation FD and other disclosure obligations.  

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Forward-Looking Statements

The SEC encourages companies to disclose forward-looking information so that investors can better understand a company’s 
future prospects and make informed investment decisions. This Annual Report on Form 10-K contains these types of statements. 
Words such as “may,” “will,” “could,” “should,” “anticipates,” “envisions,” “estimates,” “expects,” “projects,” “intends,” 
“plans,” “believes” and words or terms of similar substance used in connection with any discussion of future expectations as to 
industry and regulatory developments or business initiatives and strategies, future operating results or financial performance, and 
other future developments are intended to identify forward-looking statements. These include, among others, statements relating 
to:

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our strategic direction;

the integration of acquired businesses, including accounting decisions relating thereto;

the  scope,  nature  or  impact  of  acquisitions,  divestitures,  investments,  joint  ventures  or  other  transactional 
activities;

the effective dates for, and expected benefits of, ongoing initiatives, including transactional activities and other 
strategic, restructuring, technology, de-leveraging and capital return initiatives;

our products, order backlog and services;

the impact of pricing changes;

tax matters;

the cost and availability of liquidity and capital; and

any litigation, or any regulatory or government investigation or action, to which we are or could become a 
party or which may affect us.

Forward-looking statements involve risks and uncertainties. Factors that could cause actual results to differ materially from those 
contemplated by the forward-looking statements include, among others, the following:

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our operating results may be lower than expected;

our ability to successfully integrate acquired businesses or divest sold businesses or assets, including the fact 
that any integration or transition may be more difficult, time consuming or costly than expected, and we may be 
unable to realize synergies from business combinations, acquisitions, divestitures or other transactional activities;

loss of significant trading and clearing volumes or values, fees, market share, listed companies, market data 
customers or other customers;

our ability to develop and grow our non-trading businesses, including our technology and analytics offerings;

our ability to keep up with rapid technological advances and adequately address cybersecurity risks;

economic, political and market conditions and fluctuations, including interest rate and foreign currency risk, 
inherent in U.S. and international operations;

the performance and reliability of our technology and technology of third parties on which we rely;

any significant error in our operational processes;

our ability to continue to generate cash and manage our indebtedness; and

adverse changes that may occur in the litigation or regulatory areas, or in the securities markets generally, or 
increased regulatory oversight domestically or internationally.

Most of these factors are difficult to predict accurately and are generally beyond our control. You should consider the uncertainty 
and any risk related to forward-looking statements that we make. These risk factors are discussed under the caption “Item 1A. 
Risk Factors,” in this Annual Report on Form 10-K. You are cautioned not to place undue reliance on these forward-looking 
statements, which speak only as of the date of this report. You should carefully read this entire Annual Report on Form 10-K, 
including “Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations” and the consolidated 
financial statements and the related notes. Except as required by the federal securities laws, we undertake no obligation to update 
any  forward-looking  statement,  release  publicly  any  revisions  to  any  forward-looking  statements  or  report  the  occurrence  of 
unanticipated events. For any forward-looking statements contained in any document, we claim the protection of the safe harbor 
for forward-looking statements contained in the Private Securities Litigation Reform Act of 1995.

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PART I

Item 1. Business

Overview

Nasdaq  is  a  global  technology  company  serving  the  capital 
markets  and  other  industries.  Our  diverse  offerings  of  data, 
analytics, software and services enables clients to optimize and 
execute their business vision with confidence.

We manage, operate and provide our products and services in 
four business segments: Market Services, Corporate Services, 
Information Services and Market Technology.

History

Nasdaq was founded in 1971 as a wholly-owned subsidiary of 
FINRA. Beginning in 2000, FINRA restructured and broadened 
ownership  in  Nasdaq  by  selling  shares  to  FINRA  members, 
investment companies and issuers listed on The Nasdaq Stock 
Market.  In  connection  with  this  restructuring,  FINRA  fully 
divested  its  ownership  of  Nasdaq  in  2006,  and  The  Nasdaq 
Stock  Market  became  fully  operational  as  an  independent 
registered  national  securities  exchange  in  2007.  In  2006, 
Nasdaq also reorganized its operations into a holding company 
structure.

In  February  2008,  Nasdaq  and  OMX  AB  combined  their 
businesses. This transformational combination resulted in the 
expansion of our business from a U.S.-based exchange operator 
to a global exchange company offering technology that powers 
our  own  exchanges  and  markets  as  well  as  many  other 
marketplaces  around  the  world.  In  connection  with  this 
acquisition, we changed our corporate name to The NASDAQ 
OMX  Group,  Inc.  We  operated  under  this  name  until  we 
rebranded our business as Nasdaq, Inc. in 2015. The chart below 
shows our historical evolution from 1971 through the present.

Growth Strategy

Since our transformative combination with OMX AB in 2008, 
we  have  grown  our  business  both  organically  and  through 
acquisitions  that  have  expanded  our  operations  globally  and 
increasingly diversified our product and service offerings. This 
evolution was driven by our ability to create opportunities in 
areas adjacent to our core businesses, many of which are non-
transaction based and rooted in innovative technology. To keep 

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pace with our understanding of future trends and to ensure our 
continued success in the evolving business  environment, we 
have focused on refining our vision, mission and strategy:

Our Vision: We reimagine markets to realize the potential of 
tomorrow.

Our  Mission:  We  bring  together  ingenuity,  integrity  and 
insights to deliver markets that accelerate economic progress 
and empower people to achieve their greatest ambitions.

Our  Strategy:  Our  strategic  direction  is  driven  by  our 
continuous examination of: (i) key macroeconomic, regulatory 
and technology trends, (ii) consultation with our clients about 
short-  and  long-term  trends  in  their  businesses  and  (iii)  the 
competitive landscape.

Under the strategic direction that we have been implementing 
over the past three years, we have focused on maximizing the 
resources, people and capital allocated to our largest growth 
opportunities,  particularly  in  our  Market  Technology  and 
Information Services segments. In addition, we are committed 
to  maintaining  and  enhancing  the  marketplace  platform 
businesses that are core to Nasdaq, and reducing capital and 
resources in areas that we believe are not as strategic to our 
clients and have less growth potential within Nasdaq.

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Increasing  Investment  in  Businesses  Where  We  See  the 
Highest  Growth  Opportunity.  We  have 
increased 
investment in areas that we believe help solve our clients’ 
biggest challenges and are likely to generate growth for 
our stockholders. These areas include: the data analytics 
business within our Information Services segment; NPM, 
within our Corporate Services segment; and our Market 
Technology segment (including our regulatory technology 
business). 

Consistent  with  this  objective,  in  2019  we  acquired 
Cinnober Financial Technology AB, or Cinnober, which is 
now part of our Market Technology segment. We also are 
continuing  to  invest  in  the  Market Technology  segment 
through the NFF and the expansion and enhancement of 
our  Nasdaq  Trade  Surveillance  offering,  including  the 
incorporation of machine intelligence capabilities.

Sustaining  Our  Foundation.  As  we  strive  to  grow  our 
business,  we  also  have  focused  on  enhancing  our 
leadership position in the marketplaces in which we operate 
as  we  continue  to  innovate  with  new  functionality  and 
strong market share in our core markets. For example, we 
expect  the  migration  of  Nasdaq  BX  Options  to  a  new 
trading platform that leverages the NFF to be completed 
during  the  third  quarter  of  this  year.  This  updated 
technology  will  drive  commonality  across  our  internal 
derivatives markets. 

•  Optimizing  Slower  Growth  Businesses.  We  continually 
review areas that are not critical to our core. In these areas, 
we expect to continue to target resiliency and efficiency 
versus  growth,  and  free  up  resources  when  possible  to 
redirect  toward  greater  opportunities.  We  completed 
several divestitures in 2019. In March 2019, we completed 

the  sale  of  our  BWise  enterprise  governance,  risk  and 
compliance  software  platform.  In  October  2019,  we 
completed the divestiture of the Nordic Fund Market, an 
electronic mutual fund service that was a smaller unit of 
our Broker Services business, in November 2019, we sold 
the core assets of our NFX business and in January 2020, 
management  commenced  an  orderly  wind-down  of  our 
broker services operations business.

Products and Services

We manage, operate and provide our products and services in 
four business segments: Market Services, Corporate Services, 
Information Services and Market Technology.

Collectively, the Nasdaq Nordic and Nasdaq Baltic exchanges 
offer  trading  in  cash  equities,  depository  receipts,  warrants, 
convertibles, rights, fund units and ETFs, as well as trading and 
clearing of derivatives and clearing of resale and repurchase 
agreements.  Our  platform  allows  the  exchanges  to  share  the 
same  trading  system,  which  enables  efficient  cross-border 
trading and settlement, cross membership and a single source 
for Nordic data products. Settlement and registration of cash 
equity trading takes place in Sweden, Finland, Denmark and 
Iceland via the local central securities depositories. In addition, 
Nasdaq owns two central securities depositories that provide 
notary, settlement, central maintenance and other services in 
the Baltic countries and Iceland.

Market Services

FICC

Our Market Services segment includes our Equity Derivative 
Trading and Clearing, Cash Equity Trading, FICC and Trade 
Management Services businesses.

Equity Derivative Trading and Clearing

We operate six electronic options exchanges in the U.S.: Nasdaq 
PHLX,  The  Nasdaq  Options  Market,  Nasdaq  BX  Options, 
Nasdaq  ISE,  Nasdaq  GEMX  and  Nasdaq  MRX.  These 
exchanges  facilitate  the  trading  of  equity,  ETF,  index  and 
foreign  currency  options.  Together,  our  combined  options 
market share in 2019 represented the largest share of the U.S. 
market for multiply-listed options on equities and ETFs. Our 
options trading platforms provide trading opportunities to both 
retail investors, algorithmic trading firms and market makers, 
who tend to prefer electronic trading, and institutional investors, 
who typically pursue more complex trading strategies and often 
trade on the floor. 

In Europe, Nasdaq offers trading in derivatives, such as stock 
options  and  futures  and  index  options  and  futures.  Nasdaq 
Clearing offers clearing services for fixed-income options and 
futures, stock options and futures, index options and futures, 
and interest rate swaps by serving as the CCP. Nasdaq Clearing 
also operates a clearing service for the resale and repurchase 
agreement market.

Cash Equity Trading

In the U.S., we operate three cash equity exchanges: The Nasdaq 
Stock  Market,  Nasdaq  BX  and  Nasdaq  PSX.  Our  U.S.  cash 
equity exchanges offer trading of both Nasdaq-listed and non-
Nasdaq-listed  securities.  The  Nasdaq  Stock  Market  is  the 
largest  single  venue  of  liquidity  for  trading  U.S.-listed  cash 
equities. Market participants include market makers, broker-
dealers, ATSs and registered securities exchanges.

In  Canada,  we  operate  an  exchange  with  three  independent 
markets,  Nasdaq  Canada  CXC,  Nasdaq  Canada  CX2  and 
Nasdaq  Canada  CXD,  for  the  trading  of  Canadian-listed 
securities.

In Europe, Nasdaq operates exchanges in Stockholm (Sweden), 
Copenhagen  (Denmark),  Helsinki  (Finland),  and  Reykjavik 
(Iceland). We also operate exchanges in Tallinn (Estonia), Riga 
(Latvia) and Vilnius (Lithuania).

Our FICC business includes the Nasdaq Fixed Income business 
and Nasdaq Commodities.

The U.S. portion of Nasdaq Fixed Income includes an electronic 
platform  for  trading  U.S.  Treasuries.  The  electronic  trading 
platform provides real-time institutional trading of benchmark 
U.S.  Treasury  securities.  Through  this  business,  we  provide 
trading access to the U.S. Treasury securities market with an 
array of trading instruments to meet various investment goals 
across the fixed income spectrum.

The European portion of Nasdaq Fixed Income provides a wide 
range of products and services, such as trading and clearing, for 
fixed income products in Sweden, Denmark, Finland, Iceland, 
Lithuania and Latvia. Nasdaq is the largest bond listing venue 
in  the  Nordics,  with  more  than  6,500  listed  retail  and 
institutional bonds. In addition, Nasdaq Nordic facilitates the 
trading and clearing of Nordic fixed income derivatives in a 
unique market structure. Buyers and sellers agree to trades in 
fixed income derivatives through bilateral negotiations and then 
report those trades to Nasdaq Clearing for CCP clearing. Nasdaq 
Clearing acts as the counterparty to both the buyer and seller.

and 

products 

Nasdaq Commodities is the brand name for Nasdaq’s European 
commodity-related 
services.  Nasdaq 
Commodities’ offerings include derivatives in power, natural 
gas  and  carbon  emission  markets,  seafood,  electricity 
certificates and clearing services. These products are listed on 
Nasdaq  Oslo  ASA,  except  for  seafood,  which  is  listed  on 
Fishpool, a third party platform.

Nasdaq  Oslo  ASA,  which  is  authorized  by  the  Norwegian 
Ministry of Finance and supervised by the Norwegian Financial 
Supervisory Authority, is the commodity derivatives exchange 
for European products. All trades with Nasdaq Oslo ASA are 
subject  to  clearing  with  Nasdaq  Clearing,  which  is  a  CCP 
authorized  under  EMIR  by  the SFSA  to  conduct  clearing 
operations.

Trade Management Services

We  provide  market  participants  with  a  wide  variety  of 
alternatives for connecting to and accessing our markets for a 
fee. Our marketplaces may be accessed via a number of different 
protocols  used  for  quoting,  order  entry,  trade  reporting  and 
connectivity to various data feeds. We also offer the Nasdaq 

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Workstation, a browser-based, front-end interface that allows 
market participants to view data and enter orders, quotes and 
trade  reports.  In  addition,  we  offer  a  variety  of  add-on 
compliance  tools  to  help  firms  comply  with  regulatory 
requirements.

We provide colocation services to market participants, whereby 
we  offer  firms  cabinet  space  and  power  to  house  their  own 
equipment and servers within our data centers. Additionally, we 
offer a number of wireless connectivity routes between select 
data centers using millimeter wave and microwave technology. 

Our  broker  services  operations  business  primarily  offers 
technology and customized securities administration solutions 
to financial participants in the Nordic market. Such services 
and solutions primarily consist of flexible back-office systems, 
which  allow  customers  to  efficiently  manage  safekeeping, 
settlement  and  corporate  actions  and  reporting,  and  include 
connectivity to exchanges and central securities depositories. 
In January 2020, we commenced an orderly wind-down of this 
broker services operations business. We expect this wind-down 
to continue through the second quarter of 2021.

Corporate Services

Our Corporate Services segment includes our Listing Services 
and Corporate Solutions businesses. These businesses deliver 
critical  capital  market  and  governance  solutions  across  the 
lifecycle of public and private companies. 

Listing Services

We operate a variety of listing platforms around the world to 
provide multiple global capital raising solutions for private and 
public companies. Companies listed on our markets represent 
a diverse array of industries including, among others, health 
care,  consumer  products, 
services, 
information  technology,  financial  services,  industrials  and 
energy. Our main listing markets are The Nasdaq Stock Market 
and the Nasdaq Nordic and Nasdaq Baltic exchanges.

telecommunication 

Companies  seeking  to  list  securities  on  The  Nasdaq  Stock 
Market  must  meet  minimum  listing  requirements,  including 
specified  financial  and  corporate  governance  criteria.  Once 
listed, companies must meet continued listing standards. The 
Nasdaq  Stock  Market  currently  has  three  listing  tiers:  The 
Nasdaq Global Select Market, The Nasdaq Global Market and 
The  Nasdaq  Capital  Market. All  three  market  tiers  maintain 
rigorous  listing  and  corporate  governance  standards  (both 
initial and ongoing).

As  of  December 31,  2019,  a  total  of  3,140  companies  listed 
securities on The Nasdaq Stock Market, with 1,420 listings on 
The Nasdaq Global Select Market, 870 on The Nasdaq Global 
Market and 850 on The Nasdaq Capital Market.

We seek new listings, including from companies conducting 
IPOs as well as companies looking to switch from alternative 
exchanges. In 2019, The Nasdaq Stock Market attracted 313 
new  listings,  including  188  IPOs,  representing  78%  of  U.S. 
IPOs in 2019. The new listings were comprised of the following:

Switches from the New York Stock Exchange LLC,

or NYSE, NYSE American LLC, or NYSE
American, or IEX

IPOs
Upgrades from OTC
ETPs and Other Listings

 Total

16
188
31
78
313

During  2019,  we  had  16  new  listings  resulting  from  new 
companies  switching  their  listings  from  NYSE,  NYSE 
American or IEX to join Nasdaq, and combined with companies 
that transferred additional securities to Nasdaq during 2019, an 
aggregate of $230 billion in global equity market capitalization 
switched  to  Nasdaq.  Our  new  U.S.  corporate  bond  listing 
offering  won  11  new  issues  and  37  existing  bonds  that 
transferred  from  NYSE.  Notable  switches  in  2019  included 
Exelon Corporation, ViacomCBS Inc., and Noble Energy Inc.

We also offer listings on the exchanges that comprise Nasdaq 
Nordic and Nasdaq Baltic. For smaller companies and growth 
companies, we offer access to the financial markets through the 
Nasdaq  First  North  alternative  marketplaces.  As  of 
December 31, 2019, a total of 1,040 companies listed securities 
on our Nordic and Baltic exchanges and Nasdaq First North.

Our European listing customers include companies, funds and 
governments. Customers issue securities in the form of cash 
equities,  depository  receipts,  warrants,  ETPs,  convertibles, 
rights,  options,  bonds  or  fixed-income  related  products.  In 
2019, a total of 53 new companies listed on our Nordic and 
Baltic  exchanges  and  Nasdaq  First  North.  In  addition,  10 
companies upgraded their listings from Nasdaq First North to 
the Nordic and Baltic exchanges.

Our  Listing  Services  business  also  includes  NPM,  which 
provides liquidity solutions for private companies and private 
funds. NPM’s platform helps employees, investors, companies, 
funds and institutions execute transactions, whether for private 
companies,  private  investment  funds,  or  other  private  asset 
classes.  In  2019,  NPM  announced  an  agreement  with  a 
secondary  fund  advisor  to  provide  enhanced  execution 
capabilities  for  general  partner,  or  GP,  sponsored  secondary 
transactions using our platform. We believe that the combined 
offering can bring greater standardization and efficiency to this 
market  while  appealing  to  the  broader  ecosystem  of  GPs, 
limited partners and secondary investors. 

We are continuing to grow our recently launched U.S. Corporate 
Bond exchange for the listing and trading of corporate bonds. 
This exchange operates pursuant to The Nasdaq Stock Market 
exchange license and is powered by the NFF. Surveillance is 
conducted  by  the  Nasdaq  regulatory  team,  assisted  by  our 
Nasdaq Trade Surveillance solution. As of December 31, 2019, 
58 corporate bonds traded on the Corporate Bond exchange.

Corporate Solutions

Our Corporate Solutions business serves both public and private 
companies and organizations. Our public company clients can 
be companies listed on our exchanges or other U.S. and global 
exchanges.  We  help  organizations  enhance  their  ability  to 

4

understand  and  expand  their  global  shareholder  base,  and 
improve corporate governance through our suite of advanced 
technology, analytics, and consultative services.

As of December 31, 2019, we provided Corporate Solutions 
products and services in the following key areas:

• 

Investor Relations Intelligence. We offer a global team of 
that  deliver  advisory  services 
consultative  experts 
including  Strategic  Capital  Intelligence,  Shareholder 
Identification  and  Perception  Studies  as  well  as  an 
industry-leading platform, Nasdaq IR Insight®, to investor 
relations  professionals.  These  solutions  allow  investor 
relations officers to better manage their investor relations 
programs,  understand  their  investor  base,  target  new 
investors,  manage  meetings  and  consume  key  data 
elements such as equity research, consensus estimates and 
news.

•  Governance  Solutions.  We  provide  a  global  technology 
offering that streamlines the meeting process for board of 
directors and executive leadership teams and helps them 
accelerate  decision  making  and  strengthen  governance. 
Our  solutions  protect  sensitive  data  and  facilitate 
productive collaboration, so board members and teams can 
work faster and more effectively. 

In October 2019, Nasdaq acquired the Center for Board 
Excellence, or CBE, a provider of corporate governance 
and compliance solutions for boards of directors, CEOs, 
corporate secretaries and general counsels.

Information Services

Our  Information  Services  business  provides  the  global 
investing  community  with  access  to  the  financial  markets 
together with strong investment insights. 

Our  Information  Services  segment  is  organized  into  the 
following businesses:

•  Market Data;

• 

• 

Index; and

Investment Data & Analytics.

For  both  institutional  and  retail  investors,  our  market  and 
alternative  data  enhances  transparency  and  access  to  the 
markets we operate, and we help guide investment decisions 
around  the  globe  through  our  proprietary  indexes  and 
investment data and analytics.

Market Data

Our Market Data business sells and distributes historical and 
real-time market data to the sell-side, the buy-side, retail online 
brokers,  proprietary  trading  shops,  other  venues,  internet 
portals and data distributors. 

Our  market  data  products  enhance  transparency  of  market 
activity within our exchanges and provide critical information 
to  professional  and  non-professional  investors  globally.  We 
collect, process and create information and earn revenues as a 
distributor of our own, as well as select third-party content. We 

5

provide varying levels of quote and trade information to our 
customers  who 
this 
information. Our systems enable distributors to gain access to 
our  market  depth,  mutual  fund  valuation,  order  imbalances, 
market sentiment and other analytical data.

in  turn  provide  subscriptions  for 

We  distribute  this  proprietary  market  information  to  both 
market participants and non-participants through a number of 
proprietary products, including Nasdaq TotalView, our flagship 
market  depth  quote  product.  TotalView  shows  subscribers 
quotes, orders and total anonymous interest at every displayed 
price  level  in  The  Nasdaq  Stock  Market  for  Nasdaq-listed 
securities and critical data for the opening, closing, halt and IPO 
crosses. We also offer TotalView products for our Nasdaq BX, 
Nasdaq PSX, Nasdaq Fixed Income and other Nordic markets.

We operate several other proprietary services and data products 
to provide market information, including Nasdaq Basic, a low 
cost alternative to the industry Level 1 feed and Nasdaq Canada 
Basic, a low cost alternative to other high priced data feeds. We 
also provide various other data, including data relating to our 
six U.S. options exchanges, Nordic and U.S. futures, Nordic 
commodities, and U.S. Treasuries.

Our  Market  Data  business  also  includes  revenues  from  U.S. 
tape plans. The plan administrators sell quotation and last sale 
information  for  all  transactions  in  Nasdaq-listed  securities, 
whether  traded  on  The  Nasdaq  Stock  Market  or  other 
exchanges, to market participants and to data distributors, who
then  provide  the  information  to  subscribers. After  deducting 
costs, the plan administrators distribute the tape revenues to the 
respective  plan  participants  based  on  a  formula  required  by 
Regulation  NMS  that  takes  into  account  both  trading  and 
quoting activity.

The Nasdaq Nordic and Nasdaq Baltic exchanges, as well as 
Nasdaq  Commodities,  also  offer  data  products  and  services. 
These  data  products  and  services  provide  critical  market 
transparency  to  professional  and  non-professional  investors 
who participate in European marketplaces and, at the same time, 
give investors greater insight into these markets.

Much  like  the  U.S.  products,  European  data  products  and 
services  are  based  on  trading  information  from  the  Nasdaq 
Nordic  and  Nasdaq  Baltic  exchanges,  as  well  as  Nasdaq 
Commodities, for the following classes of assets: cash equities, 
bonds, derivatives and commodities. We provide varying levels 
of quote and trade information to market participants and to 
data  distributors,  who  in  turn  provide  subscriptions  for  this 
information.  Significant  European  data  products  include 
Nordic  Equity TotalView,  Nordic  Derivative TotalView,  and 
Nordic Fixed Income TotalView, Level 2 and Analytics.

Index 

Our  Index  business  develops  and  licenses  Nasdaq-branded 
indexes, associated derivatives, and financial products and also 
provides  custom  calculation  services  for  third-party  clients. 
License fees for our trademark licenses vary by product based 
on a percentage of underlying assets, dollar value of a product 
issuance, number of products or number of contracts traded. 
We  also  license  cash-settled  options,  futures  and  options  on 

futures on our indexes.

in  AUM.  This 

for  $233  billion 

As of December 31, 2019, 332 ETPs listed in 20 countries and 
on  24  different  exchanges  tracked  a  Nasdaq  index  and 
accounted 
includes 
approximately $100 billion in ETP AUM that tracked our smart 
beta indexes during this same time period, which accounted for 
approximately 43% of the total ETP AUM tracking Nasdaq's 
indexes. Our flagship index, the Nasdaq-100 Index, includes 
the top 100 non-financial securities listed on The Nasdaq Stock 
Market. 

We provide index data products based on Nasdaq indexes. Index 
data products include our Global Index Data Service, which 
delivers real-time index values throughout the trading day, and 
Global Index Watch/Global Index File Delivery Service, which 
delivers daily as well as historical weightings and components 
data, corporate actions and a breadth of additional data for our 
more than 30,000 indexes that we operate. 

Nasdaq Dorsey Wright, or NDW, provides passive indexing and 
the  financial  advisor 
to  support 
smart  beta  strategies 
community, as well as Systematic Relative Strength strategies 
to  manage  separately  and  unified  managed  accounts. NDW 
strengthens  Nasdaq’s  position  as  a  leading  smart  beta  index 
provider in the U.S. 

Investment Data & Analytics

Our  Investment  Data  &  Analytics  business  provides  asset 
managers,  investment  consultants  and  asset  owners  with 
information  and  analytics  to  facilitate  better  investment 
decisions. Through eVestment, we provide a flexible suite of 
cloud-based  solutions  to  help  the  institutional  investing 
community identify and capitalize on global investment trends 
and to select and monitor investment managers. eVestment’s 
products  also  enable  asset  managers  to  market  their  funds 
worldwide. Nasdaq Fund Network and Quandl are additional 
components  in  our  suite  of  investment  data  and  analytics 
offerings. Nasdaq Fund Network gathers and distributes daily 
net  asset  values  from  approximately  35,000  funds  and  other 
investment vehicles across North America. We have extended 
Nasdaq Fund Network to support the distribution of collective 
investment  trusts,  hedge  funds,  managed  accounts,  separate 
accounts and demand deposit accounts. Quandl strengthens our 
position  as  a  leading  source  for  financial,  economic,  and 
alternative  datasets.  For  hedge  funds,  investment  banks  and 
other asset managers, we provide predictive insights to inform 
investment decisions from discovered data. 

Market Technology

Powering over 100 market infrastructure operators in more than 
50  countries,  our  Market  Technology  business  is  a  leading 
global technology solutions provider and partner to exchanges, 
clearing  organizations,  central 
securities  depositories, 
regulators,  banks,  brokers,  buy-side  firms  and  corporate 
businesses.  Our  solutions  can  handle  a  wide  array  of  assets, 
including but not limited to cash equities, equity derivatives, 
currencies,  various  interest-bearing  securities,  commodities, 
energy products and digital currencies. Our solutions can also 
be used in the creation of new asset classes, and non-capital 

6

markets  customers,  including  those  in  insurance  liabilities 
securitization and digital advertising futures trading.

Nasdaq’s market technology is utilized by leading markets in 
the U.S., Europe and Asia as well as emerging markets in the 
Middle  East,  Latin America,  and Africa. Additionally,  more 
than  160  market  participants  leverage  our  surveillance 
technology globally to manage their integrity obligations and 
assist  them  in  complying  with  market  rules,  regulations  and 
internal market surveillance policies.

In January 2019, we bolstered our Market Technology business 
by acquiring Cinnober, a major Swedish financial technology 
provider to brokers, exchanges and clearinghouses worldwide 
that provides technology solutions similar and complimentary 
to  our  Market  Technology  business.  This  acquisition 
strengthened  our  position  as  a  leading  market  infrastructure 
technology provider.

Market  Infrastructure  Operators  (MIO)  &  New  Markets 
Portfolio

For  MIOs,  we  provide  and  deliver  mission-critical  solutions 
across the trade lifecycle via the NFF, which is our flexible and 
modular  architecture  and  technology  that  provides  next 
generation  capital  markets  capabilities  in  an  open  and  agile 
environment. The  NFF  is  designed  to  cover  all  aspects  of  a 
market  operator’s  needs,  from  trading  and  clearing  to  risk 
management,  market  surveillance,  index  development,  data, 
management, testing, and quality assurance. During 2019, we 
continued  to  invest  in  the  NFF  by  enabling  emerging 
technologies, including integrating technology for issuance and 
settlement of securities, cloud-enabled trading and clearing, and 
machine learning applications.

Our New Markets initiative is focused on extending the NFF’s 
capabilities and our expertise as a market operator outside of 
capital markets. Market Technology currently offers its services 
to  several  digital  assets  exchanges,  a  commercial  real  estate 
market, the reinsurance market, an airline derivatives market, 
and several sports wagering operators. 

Many  MIO  and  New  Markets  projects  involve  complex 
delivery  management  and  systems  integration.  Through  our 
integration services, we can assume responsibility for projects 
that involve migration to a new system and the establishment 
of  entirely  new  marketplaces.  We  also  offer  operation  and 
support for the applications, systems platforms, networks and 
other  components  included  in  an  information  technology 
solution, as well as advisory services.

Buy- and Sell-side Portfolio

We continue to expand the NFF offering to the global bank and 
broker  community.  Regulatory  pressure  across  multiple 
jurisdictions has made outsourcing of front-office infrastructure 
an attractive option for sell-side organizations and, as a result, 
we offer trading and execution infrastructure for SIs, single-
dealer platforms and both multi-lateral and organized trading 
facilities.  Our  execution  platform  business  added  four  new 
banks in 2019, in addition to the two global investment banks 
that have been working with us since 2017. 

We also continue to gain market share for our Nasdaq Trade 
Surveillance solution, which is a managed service designed for 
brokers  and  other  market  participants  to  assist  them  in 
complying with market rules, regulations and internal market 
surveillance policies. In addition, our products include Nasdaq 
Risk, which is a suite of products that offer a real-time, multi-
tiered  risk  solution  that  integrates  pre-,  at-  and  on-trade  risk 
management, including margining.

Technology

Technology plays a key role in ensuring the growth, reliability 
and  regulation  of  financial  markets.  We  have  established  a 
technology risk program to evaluate the resiliency of critical 
systems,  including  risks  associated  with  cybersecurity.  This 
program is focused on (i) identifying areas for improvement in 
systems  and  (ii)  implementing  changes  and  upgrades  to 
technology  and  processes  to  minimize  future  risk.  We  have 
continued our focus on improving the security of our technology 
with  an  emphasis  on  employee  awareness  through  training, 
targeted phishing campaigns, and new tool deployment for our 
securities operations team. See “Item 1A. Risk Factors,” in this 
Annual Report on Form 10-K for further discussion.

Core Technology. The NFF is Nasdaq’s approach to delivering 
end-to-end solutions for market infrastructure operators, buy-
side firms, sell-side firms and other non-financial markets. The 
framework consists of a single operational core platform that 
ties together Nasdaq’s portfolio of functionality across the trade 
in  an  open  framework  whereby  exchanges, 
lifecycle, 
clearinghouses,  central  securities  depositories,  and  other 
entities can easily integrate Nasdaq’s business applications with 
each other, as well as other third-party solutions. In addition to 
being able to integrate a broad range of business functions, the 
NFF  enables  end  users  to  leverage  recent  technology 
developments. 

Competitive Strengths

We  are  a  global  technology  company  that  in  recent  years, 
through building on capital markets experience, technological 
expertise, and a clear understanding of our clients’ needs, has 
diversified its product and service offerings.

A Unique Value Proposition

We operate a diverse and resilient capital markets franchise with 
a  marketplace  core.  Our  businesses  provide  capital-markets 
infrastructure services to industry players, allowing us to:

•  Develop  efficient  and  reliable  technologies  to  facilitate 

capital markets activity;

•  Manage the complexities and costs of business on a global 

scale; and 

• 

Provide data, tools and insights that drive sound decision 
making.

Technological Strength

We are living through a time where innovative technologies are 
transforming financial services. We have come a long way in 
trading  since  Nasdaq  launched  the  first  fully  electronic 
exchange in 1971 and we see forces accelerating that will bring 
major  changes  to  the  capital  markets.  The  strength  and 
resiliency  of  our  technology,  enhanced  by  our  Market 
Technology business, in meeting the advancing demands of our 
global customer base is vital to the continued success of our 
business and distinguishes us from our competitors.  

A Focus on Client Needs Throughout the Marketplace

We strive to serve a diverse range of clients by:

•  Brokers  and  Traders  -  Helping  brokers  and  traders  to 
confidently  plan,  optimize  and  execute  their  business 
vision.

•  Market  Participants  -  Enabling  market  participants  to 
monitor and capitalize on real-time market changes.

• 

Investors and Asset Managers - Offering products and 
services  to  assist  investors  and  asset  managers  in 
optimizing their portfolios and offerings.

•  Listed Companies - Promoting the capital health of our 

listed companies.

•  Private Companies - Working with private companies to 
meet liquidity needs, manage relationships with long-term 
institutional  investors  and  oversee  their  entire  equity 
program.

•  Market  Infrastructure  Players  -  Assisting  market 
regulators, 
infrastructure 
clearinghouses,  and  central  securities  depositories)  in 
increasing  efficiency,  meeting  customer  needs  and 
growing revenue. 

(exchanges, 

players 

•  Capital-Markets  -  Delivering  efficiencies 

through 
economies  of  scale  (cost,  speed,  connectivity)  to  all 
members of the capital-markets ecosystem.

Competition

Market Services

We face intense competition in North America and Europe in 
businesses that comprise our Market Services segment. We seek 

7

to  provide  market  participants  with  greater  functionality, 
trading  system  stability,  speed  of  execution,  high  levels  of 
customer service, and efficient pricing. In both North America 
and Europe, our competitors include other exchange operators, 
operators  of  non-exchange  trading  systems  and  banks  and 
brokerages  that  operate  their  own  internal  trading  pools  and 
platforms.

In  the  U.S.,  our  options  markets  compete  with  exchanges 
operated  by  Cboe  Global  Markets,  Inc.,  or  Cboe,  Miami 
International  Holdings,  Inc.,  or  Miami,  and  Intercontinental 
Exchange, Inc., or ICE. In cash equities in the U.S., we compete 
with exchanges operated by Cboe and ICE. New exchanges in 
the U.S. have recently been launched or announced, including 
one to be established by a group of our customers. We also face 
competition from ATSs, known as “dark pools,” and other less-
heavily regulated broker-owned trade facilitation systems, as 
well as from other types of OTC trading. In Canada, our cash 
equities exchange competes with exchanges such as the Toronto 
Stock Exchange, or TSX, and other marketplaces.

In Europe, our cash equities markets compete with exchanges 
such as Cboe, Euronext N.V., Deutsche Börse A.G. and London 
Stock Exchange Group plc, or LSE, and many MTFs such as 
Turquoise.  Our  competitors  in  the  trading  and  clearing  of 
options  and  futures  on  European  equities  include  the  Eurex 
Group companies, or Eurex, Cboe, ICE Futures Europe and the 
MTFs. In addition, in equities in Europe we face competition 
from other broker-owned systems, dark pools, SIs, and other 
types  of  OTC  trading.  Competition  among  exchanges  for 
trading European equity derivatives tends to occur where there 
is  competition  in  the  trading  of  the  underlying  equities.  In 
addition to exchange-based competition, we face competition 
from OTC derivative markets.

The  implementation  of  MiFID  II  and  MiFIR  has  resulted  in 
further competitive pressure on our European trading business. 
MTFs  and  SIs  are  already  attracting  a  significant  share  of 
electronically  matched  volume.  With 
regulatory 
environment likely to stay more favorable to alternative trading 
venues, we expect such venues to compete aggressively for the 
trading  of  equity  securities  listed  on  our  Nordic  exchanges. 
Different bilateral trading systems pursuing block business also 
remain  active  in  Europe. As  part  of  this,  trading  on  SIs  has 
increased markedly as volumes migrate from more transparent 
types of trading venues. 

the 

Our FICC business also operates in an intensely competitive 
environment. Our  trading  platform  for  benchmark  U.S. 
treasuries  faces  competition  from  both  long-established 
competitors, such as CME Group Inc. (which recently acquired 
BrokerTec)  and  newly  emerging  electronic  and  voice 
brokerages, and the operating environment remains extremely 
challenging.  Our  European  fixed  income  and  commodities 
products and  services  are  subject  to  relentless  competitive 
pressure from European exchanges and clearinghouses. 

Our Trade Management Services business competes with other 
exchange  operators,  extranet  providers,  and  data  center 
providers.

Corporate Services

Our  Listing  Services  business  in  both  the  U.S.  and  Europe 
provides  a  means  of  facilitating  capital  formation  through 
public  capital  markets. There  are  competing  ways  of  raising 
capital, and we seek to demonstrate the benefits of listing shares 
on an exchange. Our primary competitor for larger company 
stock  share  listings  in  the  U.S.  is  NYSE. The  Nasdaq  Stock 
Market competes with local and international markets located 
outside the U.S. for listings of equity securities of both U.S. and 
non-U.S. companies that choose to list (or dual-list) outside of 
their home country. For example, The Nasdaq Stock Market 
competes for listings with exchanges in Europe and Asia, such 
as LSE and The Stock Exchange of Hong Kong Limited.

The Listings Services business in Europe is characterized by a 
large number of exchanges competing for new or secondary 
listings.  Each  country  has  one  or  more  national  exchanges, 
which are often the first choice of companies in each respective 
country.  For  those  considering  an  alternative,  competing 
European exchanges that frequently attract many listings from 
outside their respective home countries include LSE, Euronext 
N.V.  and  Deutsche  Börse  A.G.  In  addition  to  the  larger 
exchanges, companies seeking capital or liquidity from public 
capital  markets  are  able  to  raise  capital  without  a  regulated 
market listing and can consider trading their shares on smaller 
markets and quoting facilities.

In our Corporate Solutions business, competition is varied and 
can  be  fragmented.  For  our  Investor  Relations  Intelligence 
business,  there are  many regional competitors and relatively 
few global providers. Other exchange operators are partnering 
with  firms  that  have  capabilities  in  this  area  and  seeking  to 
acquire  relevant  assets  in  order  to  provide  investor  relations 
services 
listing  services.  The 
competitive landscape for our Governance Solutions business 
varies  by  customer  sector  and  geography.  Most  participants 
offer SaaS solutions that are supported by a data center strategy. 
Some  firms  offer  specialized  services  that  focus  on  a  single 
niche sector. The larger players often offer additional services. 
Customers frequently seek single-source providers that are able 
to address a broad range of needs within a single platform.

to  customers  alongside 

Information Services

Our Market Data business in the U.S. includes both proprietary 
and consolidated data products. Proprietary data products are 
made  up  exclusively  of  data  derived  from  each  exchange’s 
systems. Consolidated data products are distributed by SEC-
mandated  consolidators  (one  for  Nasdaq-listed  stocks  and 
another for NYSE and other-listed stocks) that share the revenue 
among the exchanges that contribute data. In Europe, all data 
products are proprietary, as there is no official data consolidator. 
Competition in the data business is intense and is influenced by 
rapidly changing technology and the creation of new product 
and service offerings.

The sale of our proprietary data products in both the U.S. and 
Europe is under competitive threat from alternative exchanges 
and trading venues that offer similar products. Our data business 
competes  with  other  exchanges  and  third  party  vendors  to 

8

provide information to market participants. Examples of our 
competitors in proprietary data products are ICE, Cboe, TSX, 
and Dow Jones & Company.

The consolidated data business is under competitive pressure 
from  other  securities  exchanges  that  trade  Nasdaq-listed 
securities.  In  addition,  The  Nasdaq  Stock  Market  similarly 
competes  for  the  tape  fees  from  the  sale  of  information  on 
securities listed on other markets.

Our Index business faces competition from providers of various 
competing financial indexes. For example, there are a number 
of indexes that aim to track the technology sector and thereby 
compete with the Nasdaq-100 Index and the Nasdaq Composite 
Index. We face competition from investment banks, dedicated 
index providers, markets and other product developers.

Our Investment Data & Analytics business faces competition 
from  a  broad  array  of  data  and  analytics  suppliers,  both 
established firms and small start-ups. Our primary competitors 
are Morningstar, Factset, Mercer and any number of smaller 
and 
start-up 
firms 
aggregators. Additionally, other large providers to the financial 
services industry, such as Bloomberg and Refinitiv, are believed 
to be interested in pursuing certain aspects of the services we 
provide.

along  with 

providers 

data 

Market Technology

Traditionally,  exchanges  and  exchange-related  businesses 
technology,  sometimes  aided  by 
internally  developed 
consultants.  However,  over  time  this  model  has  changed  as 
many operators have recognized the cost-savings made possible 
by buying technology from third parties. As a result, two types 
of  competitors  have  emerged  in  our  Market  Technology 
segment:  exchange  operators  and  technology  providers 
unaffiliated  with  exchanges.  These  organizations  make 
available a range of off-the-shelf technology, including trading, 
clearing,  market  surveillance,  settlement,  depository  and 
information  dissemination,  and  offer  customization  and 
operation expertise. Market conditions in Market Technology 
are evolving rapidly, which makes continuous investment and 
innovation a necessity.

A wide range of providers compete with us in surveillance. In 
surveillance, standardization of products and budget pressures 
drive customers to focus on pricing. 

Intellectual Property

We believe that our intellectual property assets are important 
for maintaining the competitive differentiation of our products, 
systems, software and services, enhancing our ability to access 
technology  of  third  parties  and  maximizing  our  return  on 
research and development investments.

To  support  our  business  objectives  and  benefit  from  our 
investments in research and development, we actively create 
and  maintain  a  wide  array  of  intellectual  property  assets, 
including  patents  and  patent  applications  related  to  our 
innovations, products and services; trademarks related to our 
brands,  products  and  services;  copyrights  in  software  and 
creative content; trade secrets; and through other intellectual 

9

property  rights,  licenses  of  various  kinds  and  contractual 
provisions.  We  enter  into  confidentiality  and  invention 
assignment  agreements  with  our  employees  and  contractors, 
and utilize non-disclosure agreements with third parties with 
whom we conduct business in order to secure and protect our 
proprietary rights and to limit access to, and disclosure of, our 
proprietary information.

We own, or have licensed, rights to trade names, trademarks, 
domain names and service marks that we use in conjunction 
with our operations and services. We have registered many of 
our  most  important  trademarks  in  the  U.S.  and  in  foreign 
countries.  For  example,  our  primary  “Nasdaq”  mark  is  a 
registered trademark that we actively seek to protect in the U.S. 
and in over 50 other countries worldwide.

Over time, we have accumulated a robust portfolio of issued 
patents in the U.S. and in many other jurisdictions across the 
world. We currently hold rights to patents relating to certain 
aspects of our products, systems, software and services, but we 
primarily rely on the innovative skills, technical competence 
and marketing abilities of our personnel. No single patent is in 
itself core to the operations of Nasdaq or any of its principal 
business areas.

Corporate Venture Practice

We  operate  a  corporate  venture  program  to  make  minority 
investments primarily in emerging growth financial technology 
companies that are strategically relevant to, and aligned with, 
Nasdaq. Investments are made through the venture program to 
further  our  organic  research  and  development  efforts  and 
accelerate  the  path  to  commercial  viability.  We  expect  that 
capital invested will continue to be modest and will not have a 
material  impact  on  our  consolidated  financial  statements, 
existing  capital  return  or  deployment  priorities.  Since  its 
inception  in  2017,  our  venture  program  has  grown,  with 
aggregate initial and follow-on investments of approximately 
$42 million in ten companies in various sectors, including data 
and  analytics,  digital  assets,  market  infrastructure,  machine 
intelligence and regulatory technology.

Environmental, Social and Governance Matters

Nasdaq is committed to long-term environmental, social and 
governance, or ESG, advocacy, oversight, and philanthropy to 
engage  with  stakeholders  at  all  levels.  During  2019,  we 
broadened our corporate and community ESG efforts, including 
expanding ESG oversight of our own operations and furthering 
our commitment to greater sustainability. We also expanded our 
ESG services and solutions with new offerings for our clients, 
including  our  Nasdaq  Sustainable  Bond  Network,  which 
provides access to detailed information on sustainable, green 
and  social  bonds  and  allows  investors  to  obtain  detailed 
information  on  sustainable  bonds  for  product  due  diligence, 
selection and monitoring.

For more information regarding our ESG efforts, both internally 
and externally, please see our Proxy Statement.

Regulation

We are subject to extensive regulation in the U.S., Canada and 
Europe.

U.S. Regulation

U.S. federal securities laws establish a system of cooperative 
regulation of securities markets, market participants and listed 
companies. SROs conduct the day-to-day administration and 
regulation  of  the  nation’s  securities  markets  under  the  close 
supervision of, and subject to extensive regulation, oversight 
and enforcement by, the SEC. SROs, such as national securities 
exchanges, are registered with the SEC.

This regulatory framework applies to our U.S. business in the 
following ways:

• 

• 

regulation of our registered national securities exchanges; 
and

regulation  of  our  U.S.  broker-dealer  and  investment 
advisor subsidiaries.

National Securities Exchanges. SROs in the securities industry 
are  an  essential  component  of  the  regulatory  scheme  of  the 
Exchange  Act  for  providing  fair  and  orderly  markets  and 
protecting  investors.  The  Exchange  Act  and  the  rules 
thereunder,  as  well  as  each  SRO’s  own  rules,  impose  many 
regulatory and operational responsibilities on SROs, including 
the  day-to-day  responsibilities  for  market  and  broker-dealer 
oversight.  Moreover,  an  SRO  is  responsible  for  enforcing 
compliance  by  its  members,  and  persons  associated  with  its 
members, with the provisions of the Exchange Act, the rules 
and regulations thereunder, and the rules of the SRO, including 
rules  and  regulations  governing  the  business  conduct  of  its 
members.

Nasdaq currently operates three cash equity, six options markets 
and  one  corporate  bond  market  in  the  U.S.  We  operate The 
Nasdaq  Stock  Market,  The  Nasdaq  Options  Market  and  the 
Corporate Bond Market pursuant to The Nasdaq Stock Market’s 
SRO license; Nasdaq BX and Nasdaq BX Options pursuant to 
Nasdaq  BX’s  SRO  license;  Nasdaq  PSX  and  Nasdaq  PHLX 
pursuant  to  Nasdaq  PHLX’s  SRO  license;  and  Nasdaq  ISE, 
Nasdaq GEMX and Nasdaq MRX, each of which operates an 
options market under its own SRO license. As SROs, each entity 
has separate rules pertaining to its broker-dealer members and 
listed  companies.  Broker-dealers  that  choose  to  become 
members  of  our  exchanges  are  subject  to  the  rules  of  those 
exchanges.

All of our U.S. national securities exchanges are subject to SEC 
oversight,  as  prescribed  by  the  Exchange  Act,  including 
periodic and special examinations by the SEC. Our exchanges 
also are potentially subject to regulatory or legal action by the 
SEC  at  any  time  in  connection  with  alleged  regulatory 
violations. We have been subject to a number of routine reviews 
and inspections by the SEC or external auditors in the ordinary 
course, and we have been and may in the future be subject to 
SEC enforcement proceedings. To the extent such actions or 
reviews and inspections result in regulatory or other changes, 

we may be required to modify the manner in which we conduct 
our business, which may adversely affect our business.

Section 19 of the Exchange Act provides that our exchanges 
must submit to the SEC proposed changes to any of the SROs’ 
rules,  practices  and  procedures,  including  revisions  to 
provisions of our certificate of incorporation and by-laws that 
constitute  SRO  rules.  The  SEC  will  typically  publish  such 
proposed  changes  for  public  comment,  following  which  the 
SEC  may  approve  or  disapprove  the  proposal,  as  it  deems 
appropriate. SEC approval requires a finding by the SEC that 
the proposal is consistent with the requirements of the Exchange 
Act and the rules and regulations thereunder. Pursuant to the 
requirements of the Exchange Act, our exchanges must file with 
the  SEC,  among  other  things,  all  proposals  to  change  their 
pricing structure.

Nasdaq conducts real-time market monitoring, certain equity 
surveillance not involving cross-market activity, most options 
surveillance,  rulemaking  and  membership  functions  through 
our  Nasdaq  Regulation  department.  We  review  suspicious 
trading  behavior  discovered  by  our  regulatory  staff,  and 
depending on the nature of the activity, may refer the activity 
to  FINRA  for  further  investigation.  Pursuant  to  regulatory 
services agreements between FINRA and our SROs, FINRA 
provides certain regulatory services to our markets, including 
some  regulation  of  trading  activity  and  surveillance  and 
investigative  functions.  Our  SROs  retain  ultimate  regulatory 
responsibility  for  all  regulatory  activities  performed  under 
regulatory  agreements  by  FINRA,  and  for  fulfilling  all 
regulatory  obligations  for  which  FINRA  does  not  have 
responsibility under the regulatory services agreements.

In addition to its other SRO responsibilities, The Nasdaq Stock 
Market, as a listing market, also is responsible for overseeing 
each  listed  company’s  compliance  with  The  Nasdaq  Stock 
Market’s  financial  and  corporate  governance  standards.  Our 
listing  qualifications  department  evaluates  applications 
submitted by issuers interested in listing their securities on The 
Nasdaq Stock Market to determine whether the quantitative and 
qualitative listing standards have been satisfied. Once securities 
are listed, the listing qualifications department monitors each 
issuer’s on-going compliance with The Nasdaq Stock Market’s 
continued listing standards.

Broker-dealer regulation. Nasdaq’s broker-dealer subsidiaries 
are subject to regulation by the SEC, the SROs and various state 
securities  regulators.  Nasdaq  operates  five  broker-dealers: 
Nasdaq  Execution  Services,  LLC,  Execution  Access,  LLC, 
NPM  Securities,  SMTX,  LLC,  and  Nasdaq  Capital  Markets 
Advisory LLC. Each broker-dealer is registered with the SEC, 
a  member  of  FINRA  and  registered  in  the  U.S.  states  and 
territories required by the operation of its business.

Nasdaq Execution Services operates as our routing broker for 
sending  orders  from  Nasdaq's  U.S.  cash  equity  and  options 
exchanges  to  other  venues  for  execution.  SMTX  acts  as  an 
intermediary to facilitate closings of, and introduce prospective 
accredited  investors  in  connection  with,  private  non-capital 
raising transactions. Nasdaq Capital Markets Advisory acts as 

10

a  third-party  advisor  to  privately-held  or  publicly-traded 
companies during IPOs and various other offerings.

Two of our broker-dealers also are registered with the SEC as 
an ATS. Execution Access operates as the broker-dealer for our 
fixed  income  business,  including  as  Nasdaq  Fixed  Income’s 
registered ATS  for  U.S. Treasury  securities.  NPM  Securities 
operates  an  ATS  that  facilitates  the  purchase  and  sale  of 
ownership interests in primary and secondary transactions in 
certain  funds  (both  registered  or  not  registered  under  the 
Investment  Company  Act  of  1940),  business  development 
companies,  certain  closed  end  funds  and  private  real  estate 
investment funds.

The SEC, FINRA and the exchanges adopt rules and examine 
broker-dealers and require strict compliance with their rules and 
regulations. The SEC, SROs and state securities commissions 
may  conduct  administrative  proceedings  which  can  result  in 
censures, fines, the issuance of cease-and-desist orders or the 
suspension  or  expulsion  of  a  broker-dealer,  its  officers  or 
employees.  The  SEC  and  state  regulators  may  also  institute 
proceedings  against  broker-dealers  seeking  an  injunction  or 
other sanction. All broker-dealers have an SRO that is assigned 
by  the  SEC  as  the  broker-dealer’s  Designated  Examining 
Authority. The Designated Examining Authority is responsible 
for examining a broker-dealer for compliance with the SEC’s 
financial responsibility rules. FINRA is the current Designated 
Examining Authority for each of our broker-dealer subsidiaries.

Our  registered  broker-dealers  are  subject  to  regulatory 
requirements  intended  to  ensure  their  general  financial 
soundness and liquidity, which require that they comply with 
certain  minimum  capital  requirements. As  of  December 31, 
2019, each of our broker-dealers were in compliance with all 
of the applicable capital requirements. 

Regulatory contractual relationships with FINRA. Our SROs 
have signed a series of regulatory service agreements covering 
the services FINRA provides to the respective SROs. Under 
these  agreements,  FINRA  personnel  act  as  our  agents  in 
performing the regulatory functions outlined above, and FINRA 
bills us a fee for these services. These agreements have enabled 
us to reduce our headcount while ensuring that the markets for 
which we are responsible are properly regulated. However, we 
have reduced the scope of services provided by FINRA under 
these regulatory services agreements and are performing certain 
of those regulatory functions directly. In addition, our SROs 
retain  ultimate  regulatory  responsibility  for  all  regulatory 
activities performed under these agreements by FINRA.

Exchange  Act  Rule  17d-2  permits  SROs  to  enter  into 
agreements,  commonly  called  Rule  17d-2  agreements, 
approved by the SEC with respect to enforcement of common 
rules  relating  to  common  members.  Our  SROs  have  entered 
into  several  such  agreements  under  which  FINRA  assumes 
the 
regulatory  responsibility  for  specifics  covered  by 
agreement, including:

• 

agreements  with  FINRA  covering  the  enforcement  of 
common  rules,  the  majority  of  which  relate  to  the 
regulation of common members of our SROs and FINRA;

• 

• 

• 

industry  agreements  with  FINRA  covering 

joint 
responsibility for enforcement of insider trading rules;

industry  agreement  with  FINRA  covering 
joint 
enforcement of rules related to cash equity sales practices 
and certain other non-market related rules; and

joint  industry  agreement  covering  enforcement  of  rules 
related to options sales practices.

Regulation NMS and Options Intermarket Linkage Plan. We 
are subject to Regulation NMS for our cash equity markets, and 
our  options  markets  have  joined  the  Options  Intermarket 
Linkage Plan. These are designed to facilitate the routing of 
orders among exchanges to create a national market system as 
mandated by the Exchange Act. One of the principal purposes 
of a national market system is to assure that brokers may execute 
investors’ orders at the best market price. Both Regulation NMS 
and  the  Options  Intermarket  Linkage  Plan  require  that 
exchanges avoid trade-throughs, locking or crossing of markets 
and provide market participants with electronic access to the 
best prices among the markets for the applicable cash equity or 
options order.

In  addition,  Regulation  NMS  requires  that  every  national 
securities exchange on which an NMS stock is traded and every 
national  securities  association  act  jointly  pursuant  to  one  or 
more national market system plans to disseminate consolidated 
information,  including  a  national  best  bid  and  national  best 
offer, on quotations for transactions in NMS stocks, and that 
such  plan  or  plans  provide  for  the  dissemination  of  all 
consolidated information for an individual NMS stock through 
a single plan processor.

The UTP Plan was filed with and approved by the SEC as a 
national market system plan in accordance with the Exchange 
Act  and  Regulation  NMS  to  provide  for  the  collection,
consolidation  and  dissemination  of  such  information  for 
Nasdaq-listed securities. The Nasdaq Stock Market serves as 
the processor for the UTP Plan pursuant to a contract that was 
extended for a five-year term beginning in October 2015. The 
Nasdaq Stock Market also serves as the administrator for the 
UTP Plan. To fulfill its obligations as the processor, The Nasdaq 
Stock  Market  has  designed,  implemented,  maintained,  and 
operated  a  data  processing  and  communications  system, 
hardware,  software  and  communications  infrastructure  to 
provide processing for the UTP Plan. As the administrator, The 
Nasdaq Stock Market manages the distribution of market data, 
the  collection  of  the  resulting  market  data  revenue,  and  the 
dissemination of that revenue to plan members in accordance 
with the terms of the UTP Plan and of Regulation NMS.

Regulation SCI. Regulation SCI is a set of rules designed to 
strengthen the technology infrastructure of the U.S. securities 
markets.  Regulation  SCI  applies  to  national  securities 
exchanges, operators of certain ATSs, market data information 
providers  and  clearing  agencies,  subjecting  these  entities  to 
extensive  new  compliance  obligations,  with  the  goals  of 
reducing  the  occurrence  of  technical  issues  that  disrupt  the 
securities  markets  and  improving  recovery  time  when 
disruptions  occur.  We  implemented  an  inter-disciplinary 

11

program to ensure compliance with Regulation SCI. Regulation 
SCI policies and procedures were created, internal policies and 
procedures  were  updated,  and  an  information  technology 
governance program was developed to ensure compliance.

Regulation of Registered Investment Advisor Subsidiary. Our 
subsidiary NDW is an investment advisor registered with the 
SEC  under  the  Investment  Advisors  Act  of  1940.  In  this 
capacity, NDW is subject to oversight and inspections by the 
SEC. Among other things, registered investment advisors like 
NDW  must  comply  with  certain  disclosure  obligations, 
advertising  and  fee  restrictions  and  requirements  relating  to 
client suitability and custody of funds and securities. Registered 
investment  advisors  are  also  subject  to  anti-fraud  provisions 
under both federal and state law.

CFTC Regulation. We also operate NFX, a designated contract 
market under the Commodity Exchange Act that is subject to 
regulatory oversight by the CFTC, an independent agency with 
the mandate to regulate commodity futures and options markets 
in the U.S.

As a designated contract market, NFX is required to comply 
with  23  Core  Principles  as  set  forth  in  Section  5(d)  of  the 
Commodity  Exchange Act  and  with  Part  38  of  the  CFTC’s 
regulations. NFX is also subject to the requirements of Part 40 
of the CFTC’s regulations with respect to the adoption of new 
rules or rule amendments and the listing of new products. 

In November 2019, we entered into an agreement to sell the 
core assets of our NFX platform to a third-party. 

The Dodd-Frank Wall Street Reform and Consumer Protection 
Act also has resulted in increased CFTC regulation of our use 
of  certain  regulated  derivatives  products,  as  well  as  the 
operations of some of our subsidiaries outside the U.S. and their 
customers.

Canadian Regulation

Regulation of Nasdaq Canada is performed by the Canadian 
Securities  Administrators,  an  umbrella  organization  of 
Canada’s provincial and territorial securities regulators. As a 
recognized exchange in Ontario, Nasdaq Canada must comply 
with the terms and conditions of its exchange recognition order. 
While exempt from exchange recognition in each jurisdiction 
in Canada other than Ontario where Nasdaq Canada carries on 
business, Nasdaq must comply with the terms and conditions 
of  an  exemption  order  granted  by  the  other  jurisdictions. 
Oversight of the exchange is performed by Nasdaq Canada’s 
lead 
the  Ontario  Securities  Commission. 
Additionally,  Nasdaq  Fixed  Income  provides  access  to 
Canadian-based “Permitted Clients” for trading non-Canadian 
fixed income securities and is subject to Canadian securities 
regulations in connection with providing these services.

regulator, 

Nasdaq  Canada  is  subject  to  several  national  marketplace 
related instruments which set out requirements for marketplace 
operations, trading rules and managing electronic trading risk. 
Exchange terms and conditions include but are not limited to, 
requirements for, governance, regulation, rules and rulemaking, 
fair access, conflict management and financial viability.

European Regulation

Regulation  of  our  markets  in  the  European  Union  and  the 
European  Economic  Area  focuses  on  matters  relating  to 
financial services, listing and trading of securities, clearing and 
settlement  of  securities  and  commodities  as  well  as  issues 
related to market abuse.

In July 2016, the European Union’s Market Abuse Regulation, 
which is intended to prevent market abuse, entered into force. 
MiFID II and MiFIR entered into force in January 2018 and 
primarily affect our European trading businesses. Many of the 
provisions of MiFID II and MiFIR are implemented through 
technical  standards  drafted  by  the  European  Securities  and 
Markets Authority and approved by the European Commission. 
In addition, in 2016, the European Union adopted legislation 
on  governance  and  control  of  the  production  and  use  of 
benchmark indexes. The Benchmark Regulation applies in the 
European Union from early 2018. However, due to transitional 
clauses in the Benchmark Regulation, Nasdaq as a benchmark 
provider, did not need to be in compliance with the Benchmark 
Regulation  until  January  1,  2020  in  relation  to  benchmarks 
provided by Nasdaq’s European subsidiaries, or until January 
1, 2022, in relation to benchmarks provided by non-European 
Nasdaq  entities. As  the  regulatory  environment  continues  to 
evolve and related opportunities arise, we intend to continue 
developing  our  products  and  services  to  ensure  that  the 
exchanges  and  clearinghouses  that  comprise  Nasdaq  Nordic 
and Nasdaq Baltic maintain favorable liquidity and offer fair 
and efficient trading.

The entities that operate trading venues in the Nordic and Baltic 
countries are each subject to local regulations. As a result, we 
have a strong local presence in each jurisdiction in which we 
operate  regulated  businesses.  The  regulated  entities  have 
decision-making power and can adopt policies and procedures 
and retain resources to manage all operations subject to their 
license.  In  Sweden,  general  supervision  of  the  Nasdaq 
Stockholm exchange is carried out by the SFSA, while Nasdaq 
Clearing’s  role  as  CCP  in  the  clearing  of  derivatives  is 
supervised by the SFSA and overseen by the Swedish central 
bank (Riksbanken). Additionally, as a function of the Swedish 
two-tier supervisory model, certain surveillance in relation to 
the exchange market is carried out by the Nasdaq Stockholm 
exchange, through its surveillance function.

Nasdaq  Stockholm’s  exchange  activities  are  regulated 
primarily  by  the  SSMA,  which  implements  MiFID  II  into 
Swedish law and which sets up basic requirements regarding 
the board of the exchange and its share capital, and which also 
outlines the conditions on which exchange licenses are issued. 
The SSMA also provides that any changes to the exchange’s 
articles  of  association  following  initial  registration  must  be 
approved by the SFSA. Nasdaq Clearing holds the license as a 
CCP under EMIR.

With  respect  to  ongoing  operations,  the  SSMA  requires 
exchanges  to  conduct  their  activities  in  an  honest,  fair  and 
professional manner, and in such a way as to maintain public 
confidence  in  the  securities  markets.  When  operating  a 
regulated market, an exchange must apply the principles of free 

12

access  (i.e.,  that  each  person  which  meets  the  requirements 
established  by  law  and  by  the  exchange  may  participate  in 
trading),  neutrality  (i.e.,  that  the  exchange’s  rules  for  the 
regulated market are applied in a consistent manner to all those 
who  participate  in  trading)  and  transparency  (i.e.,  that  the 
participants  must  be  given  speedy,  simultaneous  and  correct 
information concerning trading and that the general public must 
be  given  the  opportunity  to  access  this  information). 
Additionally, the exchange operator must identify and manage 
the risks that may arise in its operations, use secure technical 
systems and identify and handle the conflicts of interest that 
may arise between the exchange or its owners’ interests and the 
interest in safeguarding effective risk management and secure 
technical systems. Similar requirements are set up by EMIR in 
relation to clearing operations.

The SSMA also contains the framework for both the SFSA’s 
supervisory work in relation to exchanges and clearinghouses 
and  the  surveillance  to  be  carried  out  by  the  exchanges 
themselves.  The  latter  includes  the  requirement  that  an 
exchange should have “an independent surveillance function 
with sufficient resources and powers to meet the exchange’s 
obligations.” That requires the exchange to, among other things, 
supervise trading and price information, compliance with laws, 
regulations and good market practice, participant compliance 
with 
instrument 
compliance with relevant listing rules and the extent to which 
issuers  meet  their  obligation  to  submit  regular  financial 
information to relevant authorities.

trading  participation 

financial 

rules, 

The  regulatory  environment  in  the  other  Nordic  and  Baltic 
countries in which a Nasdaq entity has a trading venue is broadly 
similar to the regulatory environment in Sweden. Since 2005, 
there has been cooperation between the supervisory authorities 
in  Sweden,  Iceland,  Denmark  and  Finland,  which  looks  to 
safeguard  effective  and  comprehensive  supervision  of  the 
exchanges comprising Nasdaq Nordic and the systems operated 
by it, and to ensure a common supervisory approach. In 2019, 
the supervisory authority in Norway joined this cooperation.

We operate a licensed exchange, Nasdaq Oslo ASA, in Norway 
that trades and lists commodity derivatives. Although Norway 
is not a member of the EU, as a result of the European Economic 
Area, or EEA, agreement (agreement on the EEA entered into 
between  the  EU  and  European  Free  Trade Association)  the 
regulatory environment is broadly similar to what applies in EU 
member  states.  In  addition,  in  January  2019  new  legislation 
entered into force in Norway mirroring the provisions of MiFID 
II  and  MIFIR.  As  a  result,  the  regulatory  environment  in 
Norway is similar to Sweden. The Norwegian FSA supervises 
the  Norwegian  exchange  on  an  autonomous  basis  and  the 
Norwegian  exchange  has  a  separate  market  surveillance 
function overseen by the Norwegian FSA.

Confidence  in  capital  markets  is  paramount  for  trading  to 
function  properly.  Nasdaq  Nordic  carries  out  market 
surveillance through an independent unit that is separate from 
the business operations. The surveillance work is conceptually 
organized into two functions: one for the review and admission 
of  listing  applications  and  surveillance  activities  related  to 

13

issuers (issuer surveillance) and one for surveillance of trading 
(trading surveillance). The real-time trading surveillance for the 
Finnish,  Icelandic,  Danish  and  Swedish  markets  has  been 
centralized  to  Stockholm.  In  addition,  there  are  special 
personnel who carry out surveillance activities at Nasdaq Oslo 
and each of the three Baltic exchanges. In Finland and Sweden, 
decisions to list new companies on the main market are made 
by listing committees that have external members in addition 
to  members  from  each  respective  exchange  and  in  the  other 
countries the decision is made by the respective president of 
the exchange.

If there is suspicion that a listed company or member has acted 
in breach of exchange regulations, the matter is handled by the 
respective  surveillance  department.  Serious  breaches  are 
considered  by  the  respective  disciplinary  committee  in 
Denmark,  Finland,  Iceland  and  Sweden.  Suspected  insider 
trading  is  reported  to  the  appropriate  authorities  in  the 
respective country.

In the United Kingdom, The Nasdaq Stock Market and Nasdaq 
Oslo  ASA  are  each  subject  to  regulation  by  the  Financial 
Conduct  Authority  as  “Recognised  Overseas  Investment 
Exchanges.” Nasdaq Clearing is registered as a recognized third 
country CCP with the Bank of England under the temporary 
recognition regime. The registration will come into effect on 
December 31, 2020, at the end of the Brexit implementation 
period  and  last  for  three  years.  We  will  be  applying  for 
permanent  recognition  within  six  months  of  the  end  of  this 
implementation period.

Employees

As of December 31, 2019, Nasdaq had 4,361 employees.

Nasdaq Website and Availability of SEC Filings

We file periodic reports, proxy statements and other information 
with  the  SEC.  The  SEC  maintains  a  website  that  contains 
information  statements,  and  other 
reports,  proxy  and 
information regarding issuers that file electronically with the 
SEC. The address of that site is http://www.sec.gov.

Our website is http://ir.nasdaq.com. Information on our website 
is not a part of this Form 10-K. We make available free of charge 
on our website, or provide a link to, our Forms 10-K, Forms 
10-Q and Forms 8-K and any amendments to these documents, 
that are filed or furnished pursuant to Section 13(a) or 15(d) of 
the Exchange Act as soon as reasonably practicable after we 
electronically file such material with, or furnish it to, the SEC. 
To access these filings, go to Nasdaq’s website and click on 
“Financials” then click on “SEC Filings.”

Item 1A. Risk Factors

The risks and uncertainties described below are not the only 
ones facing us. Additional risks and uncertainties not presently 
known to us or that we currently believe to be immaterial may 
also adversely affect our business. If any of the following risks 
actually occur, our business, financial condition, or operating 
results could be adversely affected.

RISKS RELATED TO OUR BUSINESS AND INDUSTRY

The industries we operate in are highly competitive.

Economic conditions and market factors, which are beyond 
our control, may adversely affect our business and financial 
condition.

Our business performance is impacted by a number of factors, 
including  general  economic  conditions,  market  volatility, 
changes in investment patterns and priorities, and other factors 
that are generally beyond our control. To the extent that global 
or national economic conditions weaken and result in slower 
growth  or  recessions,  our  business  is  likely  to  be  negatively 
impacted. Adverse market conditions could reduce customer 
demand for our services and the ability of our customers, lenders 
and other counterparties to meet their obligations to us. Poor 
economic conditions may result in a reduction in the demand 
for our products and services, including our market technology, 
data,  indexes  and  corporate  solutions,  a  decline  in  trading 
volumes or values and deterioration of the economic welfare 
of our listed companies. 

Trading volumes and values are driven primarily by general 
market conditions and declines in trading volumes or values 
may affect our market share and impact our pricing. In addition, 
our  Market  Services  businesses  receive  revenues  from  a 
relatively  small  number  of  customers  concentrated  in  the 
financial  industry,  so  any  event  that  impacts  one  or  more 
customers or the financial industry in general could impact our 
revenues.

The number of listings on our markets is primarily influenced 
by  factors  such  as  investor  demand,  the  global  economy, 
available sources of financing, and tax and regulatory policies. 
Adverse  conditions  may  jeopardize  the  ability  of  our  listed 
companies to comply with the continued listing requirements 
of our exchanges, or reduce the number of issuers launching 
IPOs.

Information Services revenues may be significantly affected by 
global economic conditions. Professional subscriptions to our 
data products are at risk if staff reductions occur in financial 
services  companies  or  if  our  customers  consolidate,  which 
could result in significant reductions in our professional user 
revenue or expose us to increased risks relating to dependence 
on a smaller number of customers. In addition, adverse market 
conditions  may  cause  reductions  in  the  number  of  non-
professional investors with investments in the market and in 
ETP AUM tracking Nasdaq indexes.

There  may  be  less  demand  for  our  Corporate  Solutions  or 
Market Technology products if global economic conditions are 
weak. Our customers historically cut back on purchases of new 
services  and  technology  when  growth  rates  decline,  thereby 
reducing our opportunities to sell new products and services or 
upgrade existing products and services.

A  reduction  in  trading  volumes  or  values,  market  share  of 
trading,  the  number  of  our  listed  companies,  or  demand  for 
Information  Services,  Market  Technology  or  Corporate 
Services products and services due to economic conditions or 
other  market  factors  could  adversely  affect  our  business, 
financial condition and operating results.

We  face  significant  competition  in  our  Market  Technology, 
Information Services and Corporate Services businesses from 
other  market  participants. We  face  intense  competition  from 
other exchanges and markets for market share of trading activity 
and listings. This competition includes both product and price 
competition.

The  liberalization  and  globalization  of  world  markets  has 
resulted  in  greater  mobility  of  capital,  greater  international 
participation in local markets and more competition. As a result, 
both in the U.S. and in other countries, the competition among 
exchanges  and  other  execution  venues  has  become  more 
intense. Marketplaces in both Europe and the U.S. have also 
merged to achieve greater economies of scale and scope.

Regulatory  changes  also  have  facilitated  the  entry  of  new 
participants  in  the  European  Union  that  compete  with  our 
European  markets.  The  regulatory  environment,  both  in  the 
U.S. and in Europe, is structured to maintain this environment 
of  intense  competition.  In  addition,  a  high  proportion  of 
business in the securities markets is becoming concentrated in 
a smaller number of institutions and our revenue may therefore 
become concentrated in a smaller number of customers.

We also compete globally with other regulated exchanges and 
markets, ATSs, MTFs and other traditional and non-traditional 
execution  venues.  Some  of  these  competitors  also  are  our 
customers. In addition, competitors recently have launched, or 
announced  a  plan  to  launch,  new  exchanges  in  the  U.S., 
including an exchange established by a group of our customers. 
Competitors  may  develop  market  trading  platforms  that  are 
more  competitive  than  ours.  Competitors  may  leverage  data 
more effectively or enter into strategic partnerships, mergers or 
acquisitions  that  could  make  their  trading,  listings,  clearing, 
data or technology businesses more competitive than ours.

We face intense price competition in all areas of our business. 
In  particular,  the  trading  industry  is  characterized  by  price 
competition. We have in the past lowered prices, and in the U.S., 
increased  rebates  for  trade  executions  to  attempt  to  gain  or 
maintain market share. These strategies have not always been 
successful  and  have  at  times  hurt  operating  performance. 
Additionally,  we  have  also  been,  and  may  once  again  be, 
required to adjust pricing to respond to actions by competitors 
and  new  entrants,  which  could  adversely  impact  operating 
results. We  also  compete  with respect  to  the  pricing  of  data 
products and with respect to products for pre-trade book data 
and  for  post-trade  last  sale  data.  In  addition,  pricing  in  our 
Corporate Services, Indexes and Market Technology businesses 
is subject to competitive pressures.

If we are unable to compete successfully in the industries in 
which  we  do  business,  our  business,  financial condition and 
operating results will be adversely affected.

System limitations or failures could harm our business.

Our businesses depend on the integrity and performance of the 
technology, computer and communications systems supporting 
them. If new systems fail to operate as intended or our existing 

14

systems  cannot  expand  to  cope  with  increased  demand  or 
otherwise fail to perform, we could experience unanticipated 
disruptions in service, slower response times and delays in the 
introduction of new products and services. These consequences 
could result in service outages, lower trading volumes or values, 
financial losses, decreased customer satisfaction and regulatory 
sanctions.  Our  markets  and  the  markets  that  rely  on  our 
technology have experienced systems failures and delays in the 
past and could experience future systems failures and delays.

Although we currently maintain and expect to maintain multiple 
computer facilities that are designed to provide redundancy and 
back-up  to  reduce  the  risk  of  system  disruptions  and  have 
facilities in place that are expected to maintain service during 
a  system  disruption,  such  systems  and  facilities  may  prove 
inadequate. If trading volumes increase unexpectedly or other 
unanticipated events occur, we may need to expand and upgrade 
our  technology,  transaction  processing  systems  and  network 
infrastructure.  We  do  not  know  whether  we  will  be  able  to 
accurately  project  the  rate,  timing  or  cost  of  any  volume 
increases, or expand and upgrade our systems and infrastructure 
to accommodate any increases in a timely manner.

While we have programs in place to identify and minimize our 
exposure to vulnerabilities and work in collaboration with the 
technology  industry  to  share  corrective  measures  with  our 
business partners, we cannot guarantee that such events will not 
occur in the future. Any system issue that causes an interruption 
in  services,  decreases  the  responsiveness  of  our  services  or 
otherwise  affects  our  services  could  impair  our  reputation, 
damage our brand name and negatively impact our business, 
financial condition and operating results.

We must continue to introduce new products, initiatives and 
enhancements to maintain our competitive position.

We intend to launch new products and initiatives and continue 
to explore and pursue opportunities to strengthen our business 
and  grow  our  company. We  may  spend  substantial  time  and 
money developing new products, initiatives and enhancements 
to existing products. If these products and initiatives are not 
successful, we may not be able to offset their costs, which could 
have an adverse effect on our business, financial condition and 
operating results.

In  our  technology  operations,  we  have  invested  substantial 
amounts in the development of system platforms, the rollout of 
our platforms and the adoption of new technologies. Although 
investments are carefully planned, there can be no assurance 
that the demand for such platforms or technologies will justify 
the related investments. If we fail to generate adequate revenue 
from  planned  system  platforms  or  the  adoption  of  new 
technologies,  or  if  we  fail  to  do  so  within  the  envisioned 
timeframe,  it  could  have  an  adverse  effect  on  our  results  of 
operations  and  financial  condition.  In  addition,  clients  may 
in  anticipation  of  new  products  or 
delay  purchases 
enhancements. Additionally,  it  is  also  possible  that  we  may 
allocate  significant  amounts  of  cash  and  other  resources  to 
product  technologies  or  business  models  for  which  market 
demand is lower than anticipated. In addition, the introduction 
of new products by competitors, the emergence of new industry 

15

standards or the development of entirely new technologies to 
replace existing product offerings could render our existing or 
future products obsolete.

A decline in trading and clearing volumes or values or market 
share will decrease our trading and clearing revenues.

Trading and clearing volumes and values are directly affected 
by economic, political and market conditions, broad trends in 
business  and  finance,  unforeseen  market  closures  or  other 
disruptions in trading, the level and volatility of interest rates, 
inflation, changes in price levels of securities and the overall 
level  of  investor  confidence.  In  recent  years,  trading  and 
clearing volumes and values across our markets have fluctuated 
significantly depending on market conditions and other factors 
beyond  our  control.  Current  initiatives  being  considered  by 
regulators and governments could have a material adverse effect 
on overall trading and clearing volumes or values. Because a 
significant  percentage  of  our  revenues  is  tied  directly  to  the 
volume or value of securities traded and cleared on our markets, 
it is likely that a general decline in trading and clearing volumes 
or values would lower revenues and may adversely affect our 
operating results if we are unable to offset falling volumes or 
values through pricing changes. Declines in trading and clearing 
volumes or values may also impact our market share or pricing 
structures  and  adversely  affect  our  business  and  financial 
condition.

If our total market share in securities decreases relative to our 
competitors,  our  venues  may  be  viewed  as  less  attractive 
sources of liquidity. If our exchanges are perceived to be less 
liquid,  then  our  business,  financial  condition  and  operating 
results could be adversely affected.

Since some of our exchanges offer clearing services in addition 
to trading services, a decline in market share of trading could 
lead to a decline in clearing revenues. Declines in market share 
also could result in issuers viewing the value of a listing on our 
exchanges  as  less  attractive,  thereby  adversely  affecting  our 
listing business. Finally, declines in market share of Nasdaq-
listed securities, or new SEC rules and regulations, could lower 
The Nasdaq Stock Market’s share of tape pool revenues under 
the consolidated data plans, thereby reducing the revenues of 
our Market Data business.

Our role in the global marketplace may place us at greater 
risk for a cyberattack.

Our  systems  and  operations  are  vulnerable  to  damage  or 
interruption  from  security  breaches.  Some  of  these  threats 
include attacks from foreign governments, hacktivists, insiders 
and criminal organizations. Foreign governments may seek to 
obtain a foothold in U.S. critical infrastructure, hacktivists may
seek to deploy denial of service attacks to bring attention to 
their cause, insiders may pose a risk by human error or malicious 
activity  and  criminal  organizations  may  seek  to  profit  from 
stolen data. Computer viruses and worms also continue to be a 
threat with ransomware increasingly being used by criminals 
to  extort  money.  Given  our  position  in  the  global  securities 
industry, we may be more likely than other companies to be a 
direct target, or an indirect casualty, of such events.

While we continue to employ resources to monitor our systems 
and  protect  our  infrastructure,  these  measures  may  prove 
insufficient  depending  upon  the  attack  or  threat  posed. Any 
system  issue,  whether  as  a  result  of  an  intentional  breach, 
collateral  damage  from  a  new  virus  or  a  non-malicious  act, 
could damage our reputation and cause us to lose customers, 
experience lower trading volumes or values, incur significant 
liabilities or otherwise have a negative impact on our business, 
financial condition and operating results. Any system breach 
may  go  undetected  for  an  extended  period  of  time.  As 
cybersecurity  threats  continue  to  increase  in  frequency  and 
sophistication, and as the domestic and international regulatory 
and compliance structure related to information security, data 
privacy  and  data  usage  becomes  increasingly  complex  and 
exacting, we may be required to devote significant additional 
resources to strengthen our cybersecurity capabilities, and to 
identify and remediate any security vulnerabilities, which could 
adversely  impact  our  business,  financial  condition  and 
operating results.

The success of our business depends on our ability to keep up 
with  rapid  technological  and  other  competitive  changes 
affecting  our  industry.  Specifically,  we  must  complete 
development  of,  successfully  implement  and  maintain 
platforms that have the functionality, performance, capacity, 
reliability  and  speed  required  by  our  business  and  our 
regulators, as well as by our customers.

technology,  evolving 

The markets in which we compete are characterized by rapidly 
industry  and  regulatory 
changing 
standards,  frequent  enhancements  to  existing  products  and 
services,  the  adoption  of  new  services  and  products  and 
changing customer demands. We may not be able to keep up 
with  rapid  technological  and  other  competitive  changes 
affecting  our  industry.  For  example,  we  must  continue  to 
enhance  our  platforms  to  remain  competitive  as  well  as  to 
address our regulatory responsibilities, and our business will 
be  negatively  affected  if  our  platforms  or  the  technology 
solutions we sell to our customers fail to function as expected. 
If  we  are  unable  to  develop  our  platforms  to  include  other 
products  and  markets,  or  if  our  platforms  do  not  have  the 
required  functionality,  performance,  capacity,  reliability  and 
speed required by our business and our regulators, as well as 
by our customers, we may not be able to compete successfully. 
Further,  our  failure  to  anticipate  or  respond  adequately  to 
changes  in  technology  and  customer  preferences  or  any 
significant delays in product development efforts, could have 
a material adverse effect on our business, financial condition 
and operating results.

Our clearinghouse operations expose us to risks, including 
credit or liquidity risks that may include defaults by clearing 
members, or insufficiencies in margins or default funds.

We  are  subject  to  risks  relating  to  our  operation  of  a 
clearinghouse, including counterparty and liquidity risks, risk 
of  defaults  by  clearing  members  and  risks  associated  with 
adequacy  of  the  customer  margin  and  of  default  funds.  Our 
clearinghouse  operations  expose  us  to  counterparties  with 
differing risk profiles. We may be adversely impacted by the 

financial distress or failure of a clearing member, which may 
cause  us  negative  financial  impact,  reputational  harm  or 
regulatory  consequences,  including  litigation  or  regulatory 
enforcement actions.

In  September  2018,  a  member  of  the  Nasdaq  Clearing 
commodities  market  defaulted  due  to  an  inability  to  post 
sufficient collateral to cover increased margin requirements for 
the positions of the relevant member. For further discussion of 
the default, see Note 16, “Clearing Operations.” There are no 
assurances  that  similar  defaults  will  not  occur  again,  which 
could  result  in  substantial  expenses.  To  the  extent  that  our 
regulatory  capital  and  risk  management  policies  are  not 
adequate to manage future financial and operational risks in our 
clearinghouse, we may experience adverse consequences to our 
operating results or ability to conduct our business.

We  are  exposed  to  credit  risk  from  third  parties,  including 
customers, counterparties and clearing agents.

We  are  exposed  to  credit  risk  from  third  parties,  including 
customers,  counterparties  and  clearing  agents.  These  parties 
may default on their obligations to us due to bankruptcy, lack 
of liquidity, operational failure or other reasons.

We  clear  or  stand  as  riskless  principal  to  a  range  of  equity-
related  and 
fixed-income-related  derivative  products, 
commodities and resale and repurchase agreements. We assume 
the counterparty risk for all transactions that are cleared through 
our markets and guarantee that our cleared contracts will be 
honored.  We  enforce  minimum  financial  and  operational 
criteria  for  membership  eligibility,  require  members  and 
investors to provide collateral, and maintain established risk 
policies and procedures to ensure that the counterparty risks are 
properly monitored and proactively managed; however, none 
of  these  measures  provides  absolute  assurance  against 
experiencing 
from  defaults  by  our 
losses 
counterparties on their obligations. No guarantee can be given 
that  the  collateral  provided  will  at  all  times  be  sufficient. 
Although we maintain clearing capital resources to serve as an 
additional layer of protection to help ensure that we are able to 
meet our obligations, these resources may not be sufficient.

financial 

In addition, one of our broker-dealer subsidiaries, Execution 
Access,  has  a  clearing  arrangement  with  the  Industrial  and 
Commercial Bank of China Financial Services LLC, or ICBC. 
As of December 31, 2019, we have contributed $15 million of 
clearing  deposits  to  ICBC  in  connection  with  this  clearing 
arrangement. Some of the trading activity in Execution Access 
is  cleared  by  ICBC  through  the  Fixed  Income  Clearing 
Corporation. Execution Access assumes the counterparty risk 
of clients that do not clear through the Fixed Income Clearing 
Corporation. Counterparty risk of clients exists for Execution 
Access  between  the  trade  date  and  settlement  date  of  the 
individual transactions, which is at least one business day (or 
more,  if  specified  by  the  U.S.  Treasury  issuance  calendar). 
Counterparties  that  do  not  clear  through  the  Fixed  Income 
Clearing  Corporation  are  subject  to  a  credit  due  diligence 
process and may be required to post collateral, provide principal 
letters,  or  provide  other  forms  of  credit  enhancement  to 
Execution Access for the purpose of mitigating counterparty 

16

risk. Daily position trading limits are also enforced for such 
counterparties. Although we believe that the potential for us to 
be  required  to  make  payments  under  these  arrangements  is 
mitigated  through  the  pledged  collateral  and  our  risk 
management policies, no guarantee can be provided that these 
arrangements will at all times be sufficient.

We also have credit risk related to transaction and subscription-
based revenues that are billed to customers on a monthly or 
quarterly basis, in arrears.

Credit  losses  such  as  those  described  above  could  adversely 
affect  our  consolidated  financial  position  and  results  of 
operations.

Technology issues relating to our role as exclusive processor 
for Nasdaq-listed stocks could affect our business.

Nasdaq,  as  technology  provider  to  the  UTP  Operating 
Committee,  has  implemented  measures  to  enhance  the 
resiliency of the existing processor system. Nasdaq transferred 
the processor technology platform to our INET platform and 
this migration further enhanced the resiliency of the processor 
systems. We further improved the systems' resiliency by adding 
the  UTP  SnapShot  service.  However,  if  despite  these 
improvement measures, future outages occur or the processor 
systems fail to function properly while we  are operating the 
systems,  it  could  have  an  adverse  effect  on  our  business, 
reputation and financial condition.

Stagnation  or  decline  in  the  listings  market  could  have  an 
adverse effect on our revenues.

The  market  for  listings  is  dependent  on  the  prosperity  of 
companies and the availability of risk capital. A stagnation or 
decline  in  the  number  of  new  listings  on The  Nasdaq  Stock 
Market and the Nasdaq Nordic and Nasdaq Baltic exchanges 
could  cause  a  decrease  in  revenues  for  future  years. 
Furthermore, a prolonged decrease in the number of listings 
could  negatively  impact  the  growth  of  our  transactions 
revenues. Our Corporate Solutions business is also impacted 
by declines in the listings market or increases in acquisitions 
activity as there will be fewer publicly-traded customers that 
need our products.

RISKS RELATED TO TRANSACTIONAL ACTIVITIES 
AND STRATEGIC RELATIONSHIPS 

We  may  not  be  able  to  successfully  integrate  acquired 
businesses,  which  may  result  in  an  inability  to  realize  the 
anticipated benefits of our acquisitions.

We must rationalize, coordinate and integrate the operations of 
our  acquired  businesses.  This  process  involves  complex 
technological,  operational  and  personnel-related  challenges, 
which are time-consuming and expensive and may disrupt our 
business.  The  difficulties,  costs  and  delays  that  could  be 
encountered may include:

• 

difficulties,  costs  or  complications  in  combining  the 
companies’  operations,  including  technology  platforms, 
which  could  lead  to  us  not  achieving  the  synergies  we 

anticipate or customers not renewing their contracts with 
us as we migrate platforms;

incompatibility of systems and operating methods;

reliance on, or provision of, transition services;

inability  to  use  capital  assets  efficiently  to  develop  the 
business of the combined company;

difficulties  of  complying  with  government-imposed 
regulations  in  the  U.S.  and  abroad,  which  may  be 
conflicting;

resolving possible inconsistencies in standards, controls, 
procedures 
and 
compensation structures;

and  policies,  business 

cultures 

the  diversion  of  management’s  attention  from  ongoing 
business concerns and other strategic opportunities;

difficulties in operating businesses we have not operated 
before;

difficulties  of  integrating  multiple  acquired  businesses 
simultaneously;

the retention of key employees and management;

the implementation of disclosure controls, internal controls 
and financial reporting systems at non-U.S. subsidiaries to 
enable us to comply with U.S. GAAP and U.S. securities 
laws and regulations, including the Sarbanes Oxley Act of 
2002,  required  as  a  result  of  our  status  as  a  reporting 
company under the Exchange Act;

the coordination of geographically separate organizations;

the coordination and consolidation of ongoing and future 
research and development efforts;

possible  tax  costs  or  inefficiencies  associated  with 
integrating the operations of a combined company;

pre-tax restructuring and revenue investment costs;

the  retention  of  strategic  partners  and  attracting  new 
strategic partners; and

negative impacts on employee morale and performance as 
a result of job changes and reassignments.

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Foreign  acquisitions  involve  risks  in  addition  to  those 
mentioned  above,  including  those  related  to  integration  of 
operations across different cultures and languages, our ability 
to enforce contracts in various jurisdictions, currency risks and 
the  particular  economic,  political  and  regulatory  risks 
associated  with  specific  countries.  We  may  not  be  able  to 
address  these  risks  successfully,  or  at  all,  without  incurring 
significant costs, delays or other operating problems that could 
disrupt our business and have a material adverse effect on our 
financial condition.  

For these reasons, we may not achieve the anticipated financial 
and  strategic  benefits  from  our  acquisitions  and  strategic 
initiatives. Any actual cost savings and synergies may be lower 
than we expect and may take a longer time to achieve than we 

17

anticipate, and we may fail to realize the anticipated benefits 
of acquisitions.

We may be required to recognize impairments of our goodwill, 
intangible assets or other long-lived assets in the future.

Our business acquisitions typically result in the recording of 
goodwill and intangible assets, and the recorded values of those 
assets may become impaired in the future. As of December 31, 
2019, goodwill totaled $6.4 billion and intangible assets, net of 
accumulated  amortization, 
totaled  $2.2  billion.  The 
determination  of  the  value  of  such  goodwill  and  intangible 
assets requires management to make estimates and assumptions 
that affect our consolidated financial statements.

We assess goodwill and intangible assets, as well as other long-
lived  assets,  including  equity  method  investments,  equity 
securities,  and  property  and  equipment,  for  potential 
impairment on an annual basis or more frequently if indicators 
of impairment arise. We estimate the fair value of such assets 
by  assessing  many  factors,  including  historical  performance 
and projected cash flows. Considerable management judgment 
is necessary to project future cash flows and evaluate the impact 
of  expected  operating  and  macroeconomic  changes  on  these 
cash flows. The estimates and assumptions we use are consistent 
with our internal planning process. However, there are inherent 
uncertainties in these estimates.

There  was  no  impairment  of  goodwill  for  the  years  ended 
December 31,  2019,  2018  and  2017,  and  there  were  no 
indefinite-lived intangible asset impairment charges in 2019, 
2018 and 2017. 

We  may  experience  future  events  that  may  result  in  asset 
impairments.  Future  disruptions  to  our  business,  prolonged 
economic weakness or significant declines in operating results 
at  any  of  our  reporting  units  or  businesses,  may  result  in 
impairment charges to goodwill, intangible assets or other long-
lived assets. A significant impairment charge in the future could 
have a material adverse effect on our operating results.

For  additional  discussion  of  our  goodwill,  indefinite-lived 
intangible assets and other long-lived assets, including related 
Impairment,” 
see “Goodwill  and  Related 
impairment, 
“Indefinite-Lived Intangible Assets and Related Impairment,” 
and  “Other  Long-Lived Assets  and  Related  Impairment,”  of 
“Critical  Accounting  Policies  and  Estimates,”  of  Item 7. 
“Management’s  Discussion  and  Analysis  of  Financial 
Condition  and  Results  of  Operations,”  and  “Goodwill  and 
Indefinite-Lived Intangible Assets,” and “Valuation of Other 
Long-Lived  Assets,”  of  Note  2,  “Summary  of  Significant 
Accounting  Policies,”  Note  6,  “Goodwill  and  Acquired 
Intangible  Assets,”  Note  7,  “Investments,”  and  Note  8, 
“Property and Equipment, net,” to the consolidated financial 
statements.

Acquisitions,  dispositions,  investments,  joint  ventures  and 
other 
transactional  activities  may  require  significant 
resources  and/or  result  in  significant  unanticipated  losses, 
costs or liabilities.

Over the past several years, acquisitions have been significant 
factors in our growth. We also may divest additional businesses 
or  assets  in  the  future.  Although  we  cannot  predict  our 
transactional activities with complete accuracy, we believe that 
additional  acquisitions,  divestments, 
joint 
ventures and other transactional activities will be important to 
our  strategy.  Such  transactions  may  be  material  in  size  and 
scope. Many of the other potential purchasers of assets in our 
industry  have  greater  financial  resources  than  we  have. 
Therefore, we cannot be sure that we will be able to complete 
future transactions on terms favorable to us.

investments, 

We also invest in startups through our Nasdaq Venture program 
and hold minority interests in other entities. Given the size of 
these investments, we do not have operational control of these 
entities and may have limited visibility into risk management 
practices.  Thus,  we  may  be  subject  to  additional  capital 
requirements  in  certain  circumstances  and  financial  and 
reputational risks if there are operational failures.

shareholders. 

We may finance future transactions by issuing additional equity 
and/or  debt. The  issuance  of  additional equity  in  connection 
with  any  such  transaction  could  be  substantially  dilutive  to 
existing 
In  addition,  announcement  or 
implementation of future transactions by us or others could have 
a material effect on the price of our common stock. The issuance 
of additional debt could increase our leverage substantially. We 
could face financial risks associated with incurring additional 
debt, particularly if the debt results in significant incremental 
leverage. Additional debt may reduce our liquidity, curtail our 
access to financing markets, impact our standing with credit 
rating  agencies  and  increase  the  cash  flow  required  for  debt 
service. Any incremental debt incurred to finance a transaction 
could also place significant constraints on the operation of our 
business.

Furthermore, any future transactions could entail a number of 
additional risks, including:

problems with effective integration of operations;

the  inability  to  maintain  key  pre-transaction  business 
relationships;

increased operating costs;

the inability to meet our target for return on invested capital;

increased debt obligations, which may adversely affect our 
targeted debt ratios; 

risks  to  the  continued  achievement  of  our  strategic 
direction;

risks associated with divesting employees, customers or 
vendors when divesting businesses or assets;

declines in the value of investments;

exposure to unanticipated liabilities; 

difficulties  in  realizing  projected  efficiencies,  synergies 
and cost savings; and

changes in our credit rating and financing costs.

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

18

Charges to earnings resulting from acquisition, integration 
and restructuring costs may materially adversely affect the 
market value of our common stock.

In accordance with U.S. GAAP, we account for the completion 
of our acquisitions using the acquisition method of accounting. 
We allocate the total estimated purchase price to net tangible 
and identifiable intangible assets based on their fair values as 
of the date of completion of the acquisition and record the excess 
of the purchase price over those fair values as goodwill. Our 
financial  results,  including  earnings  per  share,  could  be 
adversely  affected  by  a  number  of  financial  adjustments 
including the following:

•  we  may  incur  additional  amortization  expense  over  the 
estimated  useful  lives  of  certain  of  the  intangible  assets 
acquired  in  connection  with  acquisitions  during  such 
estimated useful lives;

•  we may have additional depreciation expense as a result of 
recording  acquired  tangible  assets  at  fair  value,  in 
accordance with U.S. GAAP, as compared to book value 
as recorded;

• 

to  the  extent  the  value  of  goodwill  or  intangible  assets 
becomes impaired, we may be required to incur material 
charges relating to the impairment of those assets;

•  we  may  incur  additional  costs  from  integrating  our 
acquisitions. The success of our acquisitions depends, in 
part, on our ability to integrate these businesses into our 
existing  operations  and  realize  anticipated  cost  savings, 
revenue synergies and growth opportunities; and

•  we may incur restructuring costs in connection with the 

reorganization of any of our businesses.

RISKS  RELATED  TO  LEGAL  AND  REGULATORY 
MATTERS

We operate in a highly regulated industry and may be subject 
to censures, fines and enforcement proceedings if we fail to 
comply  with  regulatory  obligations  that  can  be  ambiguous 
and can change unexpectedly.

We operate in a highly regulated industry and are subject to 
extensive  regulation  in  the  U.S.,  Europe  and  Canada.  The 
securities trading industry is subject to significant regulatory 
oversight and could be subject to increased governmental and 
public  scrutiny  in  the  future  that  can  change  in  response  to 
global conditions and events.

Our ability to comply with complex and changing regulation is 
largely  dependent  on  our  establishment  and  maintenance  of 
compliance, audit and reporting systems that can quickly adapt 
and respond, as well as our ability to attract and retain qualified 
compliance and other risk management personnel. While we 
have policies and procedures to identify, monitor and manage 
our risks and regulatory obligations, we cannot assure you that 
our policies and procedures will always be effective or that we 
will always be successful in monitoring or evaluating the risks 
to which we are or may be exposed.

Our  regulated  markets  are  subject  to  audits,  investigations, 
administrative proceedings and enforcement actions relating to 
compliance with applicable rules and regulations. Regulators 
have broad powers to impose fines, penalties or censure, issue 
cease-and-desist orders, prohibit operations, revoke licenses or 
registrations  and  impose  other  sanctions  on  our  exchanges, 
broker-dealers  and  markets  for  violations  of  applicable 
requirements.

For  example,  during  2016,  the  SFSA  and  the  other  Nordic 
financial  supervisory  authorities  conducted  investigations  of 
cybersecurity  processes  at  our  Nordic  exchanges  and 
clearinghouse. In December 2016, we were issued a $6 million 
fine by the SFSA as a result of findings in connection with its 
investigation. The SFSA’s conclusions related to governance 
issues  rather  than  systems  and  platform  security.  We  have 
appealed this decision and the final outcome is still pending.  

In the future, we could be subject to regulatory investigations 
or  enforcement  proceedings  that  could  result  in  substantial 
sanctions, including revocation of our operating licenses. Any 
such  investigations  or  proceedings,  whether  successful  or 
unsuccessful, could result in substantial costs, the diversion of 
resources, including management time, and potential harm to 
our reputation, which could have a material adverse effect on 
our  business,  results  of  operations  or  financial  condition.  In 
addition,  our  exchanges  could  be  required  to  modify  or 
restructure their regulatory functions in response to any changes 
in the regulatory environment, or they may be required to rely 
on third parties to perform regulatory and oversight functions, 
each of which may require us to incur substantial expenses and 
may harm our reputation if our regulatory services are deemed 
inadequate.

The regulatory framework under which we operate and new 
regulatory  requirements  or  new  interpretations  of  existing 
regulatory requirements could require substantial time and 
resources for compliance, which could make it difficult and 
costly for us to operate our business.

Under current U.S. federal securities laws, changes in the rules 
and operations of our securities markets, including our pricing 
structure,  must  be  reviewed  and  in  many  cases  explicitly 
approved by the SEC. The SEC may approve, disapprove, or 
recommend changes to proposals that we submit. In addition, 
the SEC may delay either the approval process or the initiation 
of  the  public  comment  process.  Favorable  SEC  rulings  and 
interpretations  can  be  challenged  in  and  reversed  by  federal 
courts  of  appeals,  reducing  or  eliminating  the  value  of  such 
prior  interpretations.  NFX,  our  futures  exchange,  is  also 
regulated by the CFTC and subject to a requirement to self-
certify  changes  to  these  rules  by  filing  with  the  CFTC. Any 
delay  in  approving  changes,  or  the  altering  of  any  proposed 
change, could have an adverse effect on our business, financial 
condition and operating results.

We must compete not only with ATSs that are not subject to the 
same SEC approval process but also with other exchanges that 
may have lower regulation and surveillance costs than us. There 
is a risk that trading will shift to exchanges that charge lower 

19

fees because, among other reasons, they spend significantly less 
on regulation.

material adverse effect on our business, financial condition and 
operating results.

required 

In  2016,  the  SEC  approved  a  plan  for  Nasdaq  and  other 
exchanges to establish a CAT, to improve regulators’ ability to 
monitor  trading  activity.  In  addition  to  increased  regulatory 
obligations,  implementation  of  a  consolidated  audit  trail  has 
resulted  in  significant  additional  expenditures,  including  to 
implement the new technology to meet any plan’s requirements. 
Creating  CAT  has 
and 
implementation  of  complex  and  costly  technology.  This 
development effort has been funded by the SROs (including 
Nasdaq) in exchange for promissory notes that Nasdaq expects 
to be repaid at such time that the SEC approves the assessment 
of fees for the funding of CAT. The SEC could determine not 
to approve the assessment of such fees in which case some or 
all of the promissory notes would not be repaid. In addition, the 
ongoing  failure  to  timely  launch  or  properly  operate  such 
technology exposes Nasdaq and other exchanges to SEC fines. 

the  development 

In addition, our registered broker-dealer subsidiaries are subject 
to  regulation  by  the  SEC,  FINRA  and  other  SROs.  These 
subsidiaries are subject to regulatory requirements intended to 
ensure their general financial soundness and liquidity, which 
require  that  they  comply  with  certain  minimum  capital 
requirements. The SEC and FINRA impose rules that require 
notification  when  a  broker-dealer’s  net  capital  falls  below 
certain predefined criteria, dictate the ratio of debt to equity in 
the  regulatory  capital  composition  of  a  broker-dealer  and 
constrain the ability of a broker-dealer to expand its business 
under certain circumstances. Additionally, the SEC’s Uniform 
Net Capital Rule and FINRA rules impose certain requirements 
that may have the effect of prohibiting a broker-dealer from 
distributing or withdrawing capital and requiring prior notice 
to the SEC and FINRA for certain withdrawals of capital. Any 
failure  to  comply  with  these  broker-dealer  regulations  could 
have a material adverse effect on the operation of our business, 
financial condition and operating results.

Our non-U.S. business is subject to regulatory oversight in all 
the countries in which we operate regulated businesses, such 
as exchanges, clearinghouses or central securities depositories. 
In  these  countries,  we  have  received  authorization  from  the 
relevant authorities to conduct our regulated business activities. 
The authorities may issue regulatory fines or may ultimately 
revoke our authorizations if we do not suitably carry out our 
regulated business activities. The authorities are also entitled 
to request that we adopt measures in order to ensure that we 
continue to fulfill the authorities’ requirements. Additionally, 
we  are  subject  to  the  obligations  under  Regulation  (EU) 
2016/1011, compliance with which could be costly or cause a 
change in our business practices.

Furthermore,  certain  of  our  customers  operate  in  a  highly 
regulated  industry.  Regulatory  authorities  could  impose 
regulatory  changes  that  could  impact  the  ability  of  our 
customers  to  use  our  exchanges.  The  loss  of  a  significant 
number of customers or a reduction in trading activity on any 
of  our  exchanges  as  a  result  of  such  changes  could  have  a 

Regulatory  changes  or  future  court  rulings  may  have  an 
adverse  impact  on  our  revenue  from  proprietary  data 
products.

Regulatory and legal developments could reduce the amount of 
revenue that we earn from our proprietary data products. In the 
U.S., we generally are required to file with the SEC to establish 
or modify the fees that we charge for our data products. In recent 
years, certain industry groups have objected to the ability of 
exchanges to charge for certain data products.

In  October  2018,  the  SEC  determined  that  we  had  not 
established that a fee for one of our data products was fair and 
reasonable,  and  also  directed  us  to  establish  a  procedure  for 
reviewing other challenged fees. We have appealed both SEC 
actions to a federal appeals court. If the results of appeals, or 
further  actions  by  the  SEC,  are  detrimental  to  our  U.S. 
exchanges’ ability to charge for data products, there could be a 
negative impact on our revenues. We cannot predict whether, 
or in what form, any regulatory changes will be implemented, 
or their potential impact on our business. A determination by 
the SEC, for example, to link data fees to marginal costs, to take 
a more active role in the data rate-setting process, or to reduce 
the current levels of data fees could have an adverse effect on 
our market data revenues.

In Canada, all new marketplace fees and changes to existing 
fees, including trading and data fees, must be filed with and 
approved by the Ontario Securities Commission. The Canadian 
Securities Administrators  adopted  a  Data  Fees  Methodology 
that restricts the total amount of fees that can be charged by all 
marketplaces  to  a  reference  benchmark.  Currently,  all 
marketplaces are subject to annual reviews of their market data 
fees tying market data revenues to pre- and post- trade market 
share  metrics.  Permitted  fee  ranges  are  based  on  an  interim 
domestic benchmark that is subject to change to an international 
benchmark, which could lower the permitted fees charged by 
marketplaces, which could adversely impact our revenues.

Our  European  exchanges  currently  offer  data  products  to 
customers on a non-discriminatory and reasonable commercial 
basis.  The  MiFID  II/MiFIR  rules  entail  that  the  price  for 
regulated data such as pre- and post-trade data shall be based
on cost plus a reasonable margin. However, these terms are not 
clearly defined. There is a risk that a different interpretation of 
these terms may influence the fees for European data products 
adversely. In addition, any future actions by European Union 
institutions could affect our ability to offer data products in the 
same manner as today, thereby causing an adverse effect on our 
market data revenues.

Regulatory changes and changes in market structure could 
have a material adverse effect on our business.

Regulatory changes adopted by the SEC or other regulators of 
our markets, and regulatory changes that our markets may adopt 
in fulfillment of their regulatory obligations, could materially 
affect our business operations. In recent years, there has been 
increased  regulatory  and  governmental  focus  on  issues 

20

affecting  the  securities  markets,  including  market  structure,  
technological oversight and transaction fees. The SEC, FINRA 
and the national securities exchanges have introduced several 
initiatives to ensure the oversight, integrity and resilience of 
markets.

Industry  responses  to  the  MiFID  II  and  MiFIR  rules,  EU 
Benchmark Regulation or other applicable rules could affect 
our operations in Europe. Changes to the rules themselves could 
also affect our operations in Europe. In addition, actions on any 
of the specific regulatory issues currently under review in the 
U.S. and Europe could have a material impact on our business.

for 

the 

With respect to our regulated businesses, our business model 
can be severely impacted by policy decisions. For example, the 
SEC has proposed an exchange transaction fee pilot program 
that could result in future regulatory changes and we, along with 
other  stock  exchanges,  have  challenged  the  SEC's  order 
adopting the program in a court action. Similarly, the SEC has 
proposed  possible  changes  to  the  governance  of  securities 
information  processors  as  well  as  regulations  to  modify  the 
infrastructure 
and 
dissemination  of  market  data  for  exchange-listed  national 
market stocks, that if approved, may or may not adversely affect 
our revenues. Our opponents in some markets are larger and 
better funded and, if successful in influencing certain policies, 
may successfully advocate for positions that adversely impact 
our business. While we support regulatory efforts to review and 
improve the structure, resilience and integrity of the markets, 
these  proposed  regulatory  changes  and  future  reforms  could 
impose significant costs, including litigation costs, and other 
obligations on the operation of our exchanges and processor 
systems and have other impacts on our business.

consolidation 

collection, 

We are subject to litigation risks and other liabilities.

Many aspects of our business potentially involve substantial 
liability risks. Although under current law we are immune from 
private  suits  arising  from  conduct  within  our  regulatory 
authority and from acts and forbearances incident to the exercise 
of our regulatory authority, this immunity only covers certain 
of our activities in the U.S., and we could be exposed to liability 
under  national  and  local  laws,  court  decisions  and  rules  and 
regulations promulgated by regulatory agencies.

Some  of  our  other  liability  risks  arise  under  the  laws  and 
regulations  relating  to  the  tax,  employment,  intellectual 
property,  anti-money  laundering,  technology  export,  foreign 
asset controls, foreign corrupt practices, employee labor and 
employment areas, including anti-discrimination and fair-pay 
laws and regulations.

Liability  could  also  result  from  disputes  over  the  terms  of  a 
trade,  claims  that  a  system  failure  or  delay  cost  a  customer 
money, claims we entered into an unauthorized transaction or 
claims  that  we  provided  materially  false  or  misleading 
statements in connection with a securities transaction. As we 
intend to defend any such litigation actively, significant legal 
expenses could be incurred. Although we carry insurance that 
may limit our risk of damages in some cases, we still may sustain 

21

uncovered losses or losses in excess of available insurance that 
would affect our financial condition and results of operations.

We  have  self-regulatory  obligations  and  also  operate  for-
profit businesses, and these two roles may create conflicts of 
interest.

We have obligations to regulate and monitor activities on our 
markets  and  ensure  compliance  with  applicable  law  and  the 
rules  of  our  markets  by  market  participants  and  listed 
companies.  In  the  U.S.,  some  have  expressed  concern  about 
potential conflicts of interest of “for-profit” markets performing 
the  regulatory  functions  of  an  SRO.  We  perform  regulatory 
functions and bear regulatory responsibility related to our listed 
companies and our markets. Any failure by us to diligently and 
fairly regulate our markets or to otherwise fulfill our regulatory 
obligations  could  significantly  harm  our  reputation,  prompt 
SEC scrutiny and adversely affect our business and reputation.

Our  Nordic  and  Baltic  exchanges  monitor  trading  and 
compliance  with  listing  standards  in  accordance  with  the 
European  Union’s  Market  Abuse  Regulation  and  other 
applicable  laws.  The  prime  objective  of  such  monitoring 
activities is to promote confidence in the exchanges among the 
general  public  and  to  ensure  fair  and  orderly  functioning 
markets. The monitoring functions within the Nasdaq Nordic 
and  Nasdaq  Baltic  exchanges  are  the  responsibility  of  the 
surveillance departments or other surveillance personnel. The 
surveillance  departments  or  personnel  are 
to 
strengthen the integrity of and confidence in these exchanges 
and to avoid conflicts of interest. Any failure to diligently and 
fairly  regulate  the  Nordic  and  Baltic  exchanges  could 
significantly  harm  our  reputation,  prompt  scrutiny  from 
regulators and adversely affect our business and reputation.

intended 

Laws and regulations regarding the handling of personal data 
and information may affect our services or result in increased 
costs, legal claims or fines against us.

Our  business  relies  on  the  processing  of  data  in  many 
jurisdictions and the movement of data, including personal data, 
across  national  borders.  Legal  and  contractual  requirements 
relating  to  the  collection,  storage,  handling,  use,  disclosure, 
transfer  and  security  of  personal  data  continue  to  evolve; 
regulatory scrutiny and customer requirements in this area are 
increasing around the world. Significant uncertainty exists as 
privacy and data protection laws may be interpreted and applied 
differently across jurisdictions and may create inconsistent or 
conflicting requirements with privacy and other laws to which 
we are subject.

Recently effective laws such as the European Union General 
Data  Protection  Regulation,  or  GDPR,  and  the  California 
Consumer  Privacy Act,  or  CCPA,  can  have  application  and 
effect beyond their territorial limits, and require companies to 
meet new requirements regarding the handling of personal data. 
In  addition  to  directly  applying  to  certain  Nasdaq  business 
activities, these laws impact many of our customers, which may 
affect their requirements and decisions related to services that 
we offer. Although we have implemented a program to address 
privacy requirements, our efforts to comply with GDPR, CCPA 

and  other  privacy  and  data  protection  laws  may  entail 
substantial  expenses,  may  divert  resources  from  other 
initiatives and projects, and could impact the services that we 
offer. Furthermore, enforcement actions and investigations by 
regulatory authorities, as well as third party litigation, related 
to  data  security  incidents  and  privacy  violations  continue  to 
increase.  The  enactment  of  more  restrictive  laws,  rules  or 
regulations, future enforcement actions or investigations, or the 
creation  of  new  rights  to  pursue  damages  could  impact  us 
through  increased  costs  or  restrictions  on  our  business,  and 
noncompliance  could  result  in  regulatory  penalties  and 
significant legal liability.

Changes  in  tax  laws,  regulations  or  policies  could  have  a 
material adverse effect on our financial results.

Like other corporations, we are subject to taxes at the federal, 
state  and  local  levels,  as  well  as  in  non-U.S.  jurisdictions. 
Changes in tax laws, regulations or policies could result in us 
having to pay higher taxes, which may reduce our net income, 
or  could  adversely  affect  our  ability  to  continue  our  capital 
allocation  program  or  effect  strategic  transactions  in  a  tax-
favorable manner. In addition, such changes may increase the 
cost of our offerings, which may cause our clients to reduce 
their use of our services.

In addition, some of our subsidiaries are subject to tax in the 
jurisdictions  in  which  they  are  organized  or  operate.  In 
computing  our  tax  obligation  in  these  jurisdictions,  we  take 
various tax positions. We cannot assure you that upon review 
of these positions the applicable authorities will agree with our 
positions. A successful challenge by a tax authority could result 
in additional taxes imposed on our clients or our subsidiaries.

RISKS  RELATED  TO  LIQUIDITY  AND  CAPITAL 
RESOURCES

Our credit rating could increase the cost of our funding from 
the capital markets.

Our debt is currently rated investment grade by two of the major 
rating  agencies. These  rating  agencies  regularly  evaluate  us, 
and their ratings of our long-term debt and commercial paper 
are  based  on  a  number  of  factors,  including  our  financial 
strength and corporate development activity, as well as factors 
not entirely within our control, including conditions affecting 
our industry generally. There can be no assurance that we will 
maintain  our  current  ratings.  Our  failure  to  maintain  those 
ratings could reduce or eliminate our ability to issue commercial 
paper and adversely affect the cost and other terms upon which 
we are able to obtain funding and increase our cost of capital. 
A reduction in credit ratings would also result in increases in 
the cost of our commercial paper and other outstanding debt as 
the interest rate on the outstanding amounts under our credit 
facilities  and  our  senior  notes  fluctuates  based  on  our  credit 
ratings.

Our  leverage  limits  our  financial  flexibility,  increases  our 
exposure  to  weakening  economic  conditions  and  may 
adversely affect our ability to obtain additional financing.

Our indebtedness as of December 31, 2019 was $3.4 billion. 
We  may  borrow  additional  amounts  by  utilizing  available 
liquidity  under  our  existing  credit  facilities  or  issuing  short-
through  our 
term,  unsecured  commercial  paper  notes 
commercial paper program.

Our leverage could:

• 

• 

• 

• 

• 

reduce  funds  available  to  us  for  operations  and  general 
corporate purposes or for capital expenditures as a result 
of  the  dedication  of  a  substantial  portion  of  our 
consolidated cash flow from operations to the payment of 
principal and interest on our indebtedness;

increase our exposure to a continued downturn in general 
economic conditions;

place us at a competitive disadvantage compared with our 
competitors with less debt;

affect our ability to obtain additional financing in the future 
for  refinancing 
indebtedness,  acquisitions,  working 
capital, capital expenditures or other purposes; and

increase our cost of debt and reduce or eliminate our ability 
to issue commercial paper.

In addition, we must comply with the covenants in our credit 
facilities.  Among  other  things,  these  covenants  restrict  our 
ability to incur additional indebtedness, grant liens on assets, 
dispose of assets and make certain restricted payments. Failure 
to meet any of the covenant terms of our credit facilities could 
result in an event of default. If an event of default occurs, and 
we are unable to receive a waiver of default, our lenders may 
increase  our  borrowing  costs,  restrict  our  ability  to  obtain 
additional borrowings and accelerate all amounts outstanding.

We will need to invest in our operations to maintain and grow 
our business and to integrate acquisitions, and we may need 
additional funds, which may not be readily available.

We depend on the availability of adequate capital to maintain 
and develop our business. Although we believe that we can meet 
our  current  capital  requirements  from  internally  generated 
funds, cash on hand and borrowings under our revolving credit 
facility and commercial paper program, if the capital and credit 
markets experience volatility, access to capital or credit may 
not be available on terms acceptable to us or at all. Limited 
access to capital or credit in the future could have an impact on 
our ability to refinance debt, maintain our credit rating, meet 
our  regulatory  capital  requirements,  engage  in  strategic 
initiatives, make acquisitions or strategic investments in other 
companies,  pay  dividends,  repurchase  our  stock  or  react  to 
changing economic and business conditions. If we are unable 
to  fund  our  capital  or  credit  requirements,  it  could  have  an 
adverse  effect  on  our  business,  financial  condition  and 
operating results.

In addition to our debt obligations, we will need to continue to 
invest in our operations for the foreseeable future to integrate 
acquired businesses and to fund new initiatives. If we do not 
achieve  the  expected  operating  results,  we  will  need  to 
reallocate  our  cash  resources.  This  may  include  borrowing 

22

additional funds to service debt payments, which may impair 
our ability to make investments in our business or to integrate 
acquired businesses.

• 

any  misconduct,  fraudulent  activity  or  theft  by  our 
employees  or  other  persons  formerly  or  currently 
associated with us.

Should we need to raise funds through issuing additional equity, 
our equity holders will suffer dilution. Should we need to raise 
funds  through  incurring  additional  debt,  we  may  become 
subject to covenants even more restrictive than those contained 
in our credit facilities, the indentures governing our notes and 
our other debt instruments. Furthermore, if adverse economic 
conditions occur, we could experience decreased revenues from 
our operations which could affect our ability to satisfy financial 
and other restrictive covenants to which we are subject under 
our existing indebtedness.

RISKS  RELATED  TO  INTELLECTUAL  PROPERTY 
AND BRAND REPUTATION

Damage  to  our  reputation  or  brand  name  could  have  a 
material adverse effect on our businesses.  

One of our competitive strengths is our strong reputation and 
brand name. Various issues may give rise to reputational risk, 
including issues relating to:

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

our ability to maintain the security of our data and systems;

the quality and reliability of our technology platforms and 
systems; 

the ability to fulfill our regulatory obligations; 

the ability to execute our business plan, key initiatives or 
new  business  ventures  and  the  ability  to  keep  up  with 
changing customer demand;

the representation of our business in the media;

the accuracy of our financial statements and other financial 
and statistical information;

the accuracy of our financial guidance or other information 
provided to our investors;

the quality of our corporate governance structure;

the quality of our products, including the reliability of our 
transaction-based,  corporate  solutions  and  market 
technology products, the accuracy of the quote and trade 
information provided by our Market Data business and the 
accuracy of calculations used by our Indexes business for 
indexes and unit investment trusts;

the quality of our disclosure controls or internal controls 
over  financial  reporting,  including  any  failures  in 
supervision;

extreme price volatility on our markets;

any negative publicity surrounding our listed companies;

any negative publicity surrounding the use of our products 
and/or services by our customers, including in connection 
with emerging asset classes such as crypto assets; and

Damage to our reputation could cause some issuers not to list 
their securities on our exchanges, as well as reduce the trading 
volumes  or  values  on  our  exchanges  or  cause  us  to  lose 
customers in our Market Data, Indexes, Corporate Solutions or 
Market  Technology  businesses.  This,  in  turn,  may  have  a 
material adverse effect on our business, financial condition and 
operating results.

Failure  to  protect  our  intellectual  property  rights,  or 
allegations that we have infringed on the intellectual property 
rights of others, could harm our brand-building efforts and 
ability to compete effectively.

To  protect  our  intellectual  property  rights,  we  rely  on  a 
combination of trademark laws, copyright laws, patent laws, 
trade  secret  protection,  confidentiality  agreements  and  other 
contractual arrangements with our affiliates, clients, strategic 
partners, employees and others. However, the efforts we have 
taken to protect our intellectual property and proprietary rights 
might not be sufficient, or effective, at stopping unauthorized 
use of those rights. We may be unable to detect the unauthorized 
use  of,  or  take  appropriate  steps  to  enforce,  our  intellectual 
property rights.

We have registered, or applied to register, our trademarks in the 
United  States  and  in  over  50  foreign  jurisdictions  and  have 
pending U.S. and foreign applications for other trademarks. We 
also maintain copyright protection on our branded materials and 
pursue patent protection for software products, inventions and 
other  processes  developed  by  us. We  also  hold  a  number  of 
patents, patent applications and licenses in the United States 
and other foreign jurisdictions. However, effective trademark, 
copyright,  patent  and  trade  secret  protection  might  not  be 
available  or  cost-effective  in  every  country  in  which  our 
services and products are offered. Moreover, changes in patent 
law, such as changes in the law regarding patentable subject 
matter, could also impact our ability to obtain patent protection 
for our innovations. In particular, amendments to the U.S. patent 
law may affect our ability to protect and defend our innovations. 
There is also a risk that the scope of protection under our patents 
may not be sufficient in some cases, or that existing patents may 
be  deemed  invalid  or  unenforceable.  Failure  to  protect  our 
intellectual property adequately could harm our brand and affect 
our  ability  to  compete  effectively.  Further,  defending  our 
intellectual property rights could result in the expenditure of 
significant financial and managerial resources.

Third  parties  may  assert  intellectual  property  rights  claims 
against us, which may be costly to defend, could require the 
payment of damages and could limit our ability to use certain 
technologies,  trademarks  or  other  intellectual  property. Any 
intellectual  property  claims,  with  or  without  merit,  could  be 
expensive  to  litigate  or  settle  and  could  divert  management 
resources and attention. Successful challenges against us could 
require us to modify or discontinue our use of technology or 
business processes where such use is found to infringe or violate 
the rights of others, or require us to purchase licenses from third 

23

parties,  any  of  which  could  adversely  affect  our  business, 
financial condition and operating results.

RISKS  RELATED  TO  OUR  OPERATIONS  AND 
COMMON STOCK

We are a holding company that depends on cash flow from 
our subsidiaries to meet our obligations, and any restrictions 
on  our  subsidiaries’  ability to  pay  dividends  or  make other 
payments  to  us  may  have  a  material  adverse  effect  on  our 
results of operations and financial condition.

As  a  holding  company,  we  require  dividends  and  other 
payments  from  our  subsidiaries  to  meet  cash  requirements. 
Minimum  capital  requirements  mandated  by  regulatory 
authorities  having  jurisdiction  over  some  of  our  regulated 
subsidiaries  indirectly  restrict  the  amount  of  dividends  paid 
upstream.

In addition, unremitted earnings of certain subsidiaries outside 
of the U.S. are used to finance our international operations and 
are considered to be indefinitely reinvested.

If our subsidiaries are unable to pay dividends and make other 
payments to us when needed, we may be unable to satisfy our 
obligations, which would have a material adverse effect on our 
business, financial condition and operating results.

We  may  experience  fluctuations  in  our  operating  results, 
which may adversely affect the market price of our common 
stock.

Our industry is risky and unpredictable and is directly affected 
by many national and international factors beyond our control, 
including:

• 

• 

• 

• 

• 

• 

• 

• 

economic, political and geopolitical market conditions;

natural  disasters,  terrorism,  pandemics,  war  or  other 
catastrophes;

broad trends in finance and technology;

changes in price levels and volatility in the stock markets;

the level and volatility of interest rates;

changes in government monetary or tax policy;

the perceived attractiveness of the U.S. or European capital 
markets; and

inflation.

Any one of these factors could have a material adverse effect 
on our business, financial condition and operating results by 
causing a substantial decline in the financial services markets 
and reducing trading volumes or values.

Additionally, since borrowings under our credit facilities bear 
interest  at  variable  rates  and  commercial  paper  is  issued  at 
prevailing interest rates, any increase in interest rates on debt 
that we have not fixed using interest rate hedges will increase 
our interest expense, reduce our cash flow or increase the cost 
of future borrowings or refinancings. Other than variable rate 
debt, we believe our business has relatively large fixed costs 
and low variable costs, which magnifies the impact of revenue 

fluctuations on our operating results. As a result, a decline in 
our revenue may lead to a relatively larger impact on operating 
results. A substantial portion of our operating expenses is related 
to personnel costs, regulation and corporate overhead, none of 
which can be adjusted quickly and some of which cannot be 
adjusted at all. Our operating expense levels are based on our 
expectations  for  future  revenue.  If  actual  revenue  is  below 
management’s expectations, or if our expenses increase before 
revenues do, both revenues less transaction-based expenses and 
operating results would be materially and adversely affected. 
Because of these factors, it is possible that our operating results 
or other operating metrics may fail to meet the expectations of 
stock market analysts and investors. If this happens, the market 
price of our common stock may be adversely affected.

We rely on third parties to perform certain functions, and our 
business could be adversely affected if these third parties fail 
to perform as expected.

We rely on third parties for regulatory, data center, data storage, 
data content, clearing and other services. To the extent that any 
of  our  vendors  or  other 
third-party  service  providers 
experiences  difficulties,  materially  changes  their  business 
relationship with us or is unable for any reason to perform their 
obligations, our business or our reputation may be materially 
adversely affected.

We also rely on members of our trading community to maintain 
markets and add liquidity. To the extent that any of our largest 
members  experiences  difficulties,  materially  changes  its 
business  relationship  with  us  or  is  unable  for  any  reason  to 
perform  market  making  activities,  our  business  or  our 
reputation may be materially adversely affected.

Our  operational  processes  are  subject  to  the  risk  of  error, 
which may result in financial loss or reputational damage.

We have instituted extensive controls to reduce the risk of error 
inherent  in  our  operations;  however,  such  risk  cannot 
completely be eliminated. Our businesses are highly dependent 
on our ability to process and report, on a daily basis, a large 
number of transactions across numerous and diverse markets. 
Some  of  our  operations  require  complex  processes,  and  the 
introduction of new products or services or changes in processes 
or reporting due to regulatory requirements may result in an 
increased  risk  of  errors  for  a  period  after  implementation. 
Additionally, the likelihood of such errors or vulnerabilities is 
heightened  as  we  acquire  new  products  from  third  parties, 
whether as a result of acquisitions or otherwise.

Data,  other  content  or  information  that  we  distribute  may 
contain errors or be delayed, causing reputational harm. Use of 
our  products  and  services  as  part  of  the  investment  process 
creates  the  risk  that  clients,  or  the  parties  whose  assets  are 
managed by our clients, may pursue claims against us in the 
event of such delay or error. Even with a favorable outcome, 
litigation  against  us  might  unduly  burden 
significant 
management, personnel, financial and other resources.

In addition, the sophisticated software we sell to our customers 
may contain undetected errors or vulnerabilities, some of which 
may be discovered only after delivery, or could fail to perform 

24

for  critical  business 

its  intended  purpose.  Because  our  clients  depend  on  our 
solutions 
functions,  any  service 
interruptions,  failures  or  other  issues  may  result  in  lost  or 
delayed market acceptance and lost sales, or negative customer 
experiences that could damage our reputation, resulting in the 
loss of customers, loss of revenues and liability for damages, 
which may adversely affect our business and financial results. 

Climate change may have a long-term adverse impact on our 
business.

While we seek to mitigate our business risks associated with 
climate  change  by  establishing  robust  environmental  and 
sustainability programs, there are inherent climate related risks 
wherever our business is conducted. There is an increased focus 
from our investors, clients, employees, and other stakeholders 
concerning  corporate  citizenship  and  sustainability  matters. 
Access to clean water and reliable energy in the communities 
where we conduct our business, whether for our offices, data 
centers, vendors, clients or other stakeholders, is a priority. For 
example, changes in weather where we operate may increase 
the  costs  of  powering  and  cooling  our  data  centers  or  the 
facilities 
to  operate  our  exchanges  and 
clearinghouses, develop our products or provide cloud-based 
services.  Climate  related  events,  including  extreme  weather 
events  and  their  impact  on  the  critical  infrastructure  in  the 
United States and elsewhere, have the potential to disrupt our 
business or the business of our clients, create adverse market 
conditions, including trading volatility beyond historical levels, 
and  adversely  affect  our  business,  reputation,  financial 
condition and operating results.  

that  we  use 

Uncertainty relating to the effects of the United Kingdom’s 
exit from the European Union could cause uncertainty and 
adversely impact our business.

We  continue  to  evaluate  the  potential  effect  of  the  United 
Kingdom’s  departure  from  the  European  Union  (commonly 
referred to as Brexit) on our business operations and financial 
results.  The  withdrawal  of  the  United  Kingdom  from 
membership  in  the  European  Union  may  cause  unfavorable 
consequences, including a deterioration of general economic 
conditions, increased costs from re-imposition of tariffs on trade 
between  the  United  Kingdom  and  the  European  Union  and 
increased  volatility  of  foreign  exchange  rates.  Brexit  could 
adversely affect political, regulatory, or trading conditions in 
the United Kingdom and in Europe and it could contribute to 
instability  in  global  political  institutions  and  regulatory 
agencies.  Brexit  could  also  lead  to  legal  uncertainty  and 
differing  laws  and  regulations  between  the  United  Kingdom 
and  the  European  Union.  Brexit  may  also  have  adverse  tax 
effects  on  movement  of  products  or  activities  between  the 
United Kingdom and the European Union.

Currently, we do not anticipate that Brexit will have a material 
impact on our operations or our financial results. While we have 
operations in the United Kingdom, these operations are limited 
in scope and not material to our overall business. 

However, we may be impacted if our customers in the United 
Kingdom  are  subject  to  additional  costs  or  restrictions  in 

25

accessing  our  products  or  services.  In  addition,  the  overall 
impact  of  Brexit  may  create  further  global  economic 
uncertainty, which may adversely impact the activities of our 
customers.

Failure  to  attract  and  retain  key  personnel  may  adversely 
affect our ability to conduct our business.

Our future success depends, in large part, upon our ability to 
attract  and  retain  highly  qualified  and  skilled  professional 
personnel  that  can  learn  and  embrace  new  technologies. 
Competition  for  key  personnel  in  the  various  localities  and 
business segments in which we operate is intense. Our ability 
to attract and retain key personnel, in particular senior officers 
or  technology  personnel,  will  be  dependent  on  a  number  of 
factors, 
including  prevailing  market  conditions  and 
compensation packages offered by companies competing for 
the same talent. There is no guarantee that we will have the 
continued  service  of  key  employees  who  we  rely  upon  to 
execute our business strategy and identify and pursue strategic 
opportunities and initiatives. In particular, we may have to incur 
costs  to  replace  senior  officers  or  other  key  employees  who 
leave, and our ability to execute our business strategy could be 
impaired if we are unable to replace such persons in a timely 
manner.

Our  non-U.S.  business  operates  in  various  international 
markets,  particularly  emerging  markets  that  are  subject  to 
greater  political,  economic  and  social  uncertainties  than 
developed countries.

Our  non-U.S.  business  operates  in  various  international 
markets,  including  but  not  limited  to  Northern  Europe,  the 
Baltics, the Middle East, Africa and Asia. Therefore, our non-
U.S.  operations  are  subject  to  the  risk  inherent  in  the 
international environment. Political, economic or social events 
or developments in one or more of our non-U.S. locations could 
adversely  affect  our  operations  and  financial  results.  Some 
locations,  such  as  Lithuania,  India  and  the  Philippines,  may 
increase  risk.  Some  of  these  economies  may  be  subject  to 
greater  political,  economic  and  social  uncertainties  than 
countries with more developed institutional structures.

Unforeseen or catastrophic events could interrupt our critical 
business  functions.  In  addition,  our  U.S.  and  European 
businesses are heavily concentrated in particular areas and 
may be adversely affected by events in those areas.

We may incur losses as a result of unforeseen or catastrophic 
events,  such  as  terrorist  attacks,  natural  disasters,  pandemic, 
extreme weather, fire, power loss, telecommunications failures, 
human error, theft, sabotage and vandalism. Given our position 
in the global capital markets, we may be more likely than other 
companies to be a target for malicious disruption activities.

In  addition,  our  U.S.  and  European  business  operations  are 
heavily  concentrated  in  the  U.S.  East  Coast,  and  Stockholm 
respectively. Any event that impacts either of those geographic 
areas  could  potentially  affect  our  ability  to  operate  our 
businesses.

We have disaster recovery and business continuity plans and 
capabilities  for  critical  systems  and  business  functions  to 
mitigate  the  risk  of  an  interruption. Any  interruption  in  our 
critical business functions or systems could negatively impact 
our  financial  condition  and  operating  results.  For  example, 
some colocation customers may lack adequate disaster recovery 
solutions  to  avoid  loss  of  trade  flow  from  a  sustained 
interruption of our critical systems.

Because we have operations in numerous countries, we are 
exposed to currency risk.

board of directors may determine not to declare future dividends 
at  all  or  to  declare  future  dividends  at  a  reduced  amount. 
Accordingly, there can be no guarantee that we will pay future 
dividends to our stockholders.

Provisions  of  our  certificate  of  incorporation,  by-laws, 
exchange rules (including provisions included to address SEC 
concerns)  and  governing  law  restrict  the  ownership  and 
voting  of  our  common  stock.  In  addition,  such  provisions 
could delay or prevent a change in control of us and entrench 
current management.

We have operations in the U.S., the Nordic and Baltic countries, 
the  United  Kingdom,  Australia  and  many  other  foreign 
countries. We therefore have significant exposure to exchange 
rate movements between the Euro, Swedish Krona and other 
foreign currencies towards the U.S. dollar. Significant inflation 
or  disproportionate  changes  in  foreign  exchange  rates  with 
respect to one or more of these currencies could occur as a result 
of  general  economic  conditions,  acts  of  war  or  terrorism, 
changes in governmental monetary or tax policy, changes in 
local  interest  rates  or  other  factors.  These  exchange  rate 
differences will affect the translation of our non-U.S. results of 
operations, interest expense and financial condition into U.S. 
dollars as part of the preparation of our consolidated financial 
statements.

If  our  risk  management  methods  are  not  effective,  our 
business, reputation and financial results may be adversely 
affected.

We utilize widely-accepted methods to identify, assess, monitor 
and manage our risks, including oversight of risk management 
by  Nasdaq’s  Global  Risk  Management  Committee,  which 
comprises senior executives and has responsibility for regularly 
reviewing risks and referring significant risks to the board of 
directors or specific board committees. By definition, some risk 
management methods require subjective evaluation of dynamic 
information  regarding  markets,  customers  or  other  matters. 
That  variable  information  may  not  in  all  cases  be  accurate, 
complete,  up-to-date  or  properly  evaluated.  If  we  do  not 
successfully  identify,  assess,  monitor  or  manage  the  risks  to 
which  we  are  exposed,  our  business,  reputation,  financial 
condition and operating results could be materially adversely 
affected.

Decisions to declare future dividends on our common stock 
will be at the discretion of our board of directors based upon 
a review of relevant considerations. Accordingly, there can be 
no  guarantee  that  we  will  pay  future  dividends  to  our 
stockholders.

Our  board  of  directors  regularly  declares  quarterly  cash 
dividend payments on our outstanding common stock. Future 
declarations  of  quarterly  dividends  and  the  establishment  of 
future  record  and  payment  dates  are  subject  to  approval  by 
Nasdaq’s  board  of  directors.  The  board’s  determination  to 
declare  dividends  will  depend  upon  our  profitability  and 
financial  condition,  contractual  restrictions,  restrictions 
imposed  by  applicable  law  and  other  factors  that  the  board 
deems relevant. Based on an evaluation of these factors, the 

26

Our organizational documents place restrictions on the voting 
rights of certain stockholders. The holders of our common stock 
are entitled to one vote per share on all matters to be voted upon 
by the stockholders except that no person may exercise voting 
rights  in  respect  of  any  shares  in  excess  of  5%  of  the  then 
outstanding shares of our common stock. Any change to the 5% 
voting limitation would require SEC approval.

In response to the SEC’s concern about a concentration of our 
ownership,  the  rules  of  some  of  our  exchange  subsidiaries 
include a prohibition on any member or any person associated 
with a member of the exchange from beneficially owning more 
than  20%  of  our  outstanding  voting  interests.  SEC  consent 
would be required before any investor could obtain more than 
a 20% voting interest in us. The rules of some of our exchange 
subsidiaries also require the SEC’s approval of any business 
ventures with exchange members, subject to exceptions.

Our organizational documents contain provisions that may be 
deemed to have an anti-takeover effect and may delay, deter or 
prevent  a  change  of  control  of  us,  such  as  a  tender  offer  or 
takeover  proposal  that  might  result  in  a  premium  over  the 
market  price  for  our  common  stock. Additionally,  certain  of 
these provisions make it more difficult to bring about a change 
in the composition of our board of directors, which could result 
in entrenchment of current management.

Our certificate of incorporation and by-laws:

• 

• 

• 

do not permit stockholders to act by written consent;

require certain advance notice for director nominations and 
actions to be taken at annual meetings; and

authorize the issuance of undesignated preferred stock, or 
“blank check” preferred stock, which could be issued by 
our board of directors without stockholder approval.

Section 203 of the Delaware General Corporation Law imposes 
restrictions  on  mergers  and  other  business  combinations 
between us and any holder of 15% or more (or, in some cases, 
a holder who previously held 15% or more) of our common 
stock.  In  general,  Delaware  law  prohibits  a  publicly  held 
corporation from engaging in a “business combination” with 
an “interested stockholder” for three years after the stockholder 
becomes  an  interested  stockholder,  unless  the  corporation’s 
board  of  directors  and  stockholders  approve  the  business 
combination in a prescribed manner.

Finally,  many  of  the  European  countries  where  we  operate 
regulated entities require prior governmental approval before 
an investor acquires 10% or greater of our common stock.
Item 1B. Unresolved Staff Comments

None.

Item 2. Properties

We conduct our business operations in leased facilities. We do 
not own any real property. Our U.S. headquarters are located 
in New York, New York, and our European headquarters are 
located in Stockholm, Sweden. We also lease space in multiple 
locations around the world, which are used for research and 
development, sales and support, and administrative activities, 
as well as for data centers and disaster preparedness facilities.

Generally, our properties are not allocated for use by a particular 
segment.  Instead,  most  of  our  properties  are  used  by  two  or 
more segments. We believe the facilities that we occupy are 
adequate for the purposes for which they are currently used and 
are well-maintained.

Item 3. Legal Proceedings

See “Legal and Regulatory Matters - Litigation,” of Note 19, 
the 
“Commitments,  Contingencies  and  Guarantees,” 

to 

consolidated financial statements, which is incorporated herein 
by reference.

Item 4. Mine Safety Disclosures

Not applicable.

PART II

Item 5. Market for Registrant’s Common Equity, Related 
Stockholder  Matters  and  Issuer  Purchases  of  Equity 
Securities

Market Information

Our common stock is listed on The Nasdaq Stock Market under 
the ticker symbol “NDAQ.” As of February 13, 2020, we had 
approximately 235 holders of record of our common stock. 

Issuer Purchases of Equity Securities

Share Repurchase Program

See  “Share  Repurchase  Program,”  of  Note  13,  “Nasdaq 
Stockholders’ Equity,” to the consolidated financial statements 
for further discussion of our share repurchase program.

Purchases of Equity Securities by the Issuer and Affiliated Purchasers

* * * * * *

The following table summarizes the share repurchase activity of our common stock during the fiscal quarter ended December 31, 
2019:

Period

October 2019

Share repurchase program
Employee transactions(1)

November 2019

Share repurchase program
Employee transactions(1)

December 2019

Share repurchase program
Employee transactions(1)

Total Quarter Ended December 31, 2019

Share repurchase program
Employee transactions(1)
____________

(a) Total Number of
Shares Purchased

(b) Average Price
Paid Per Share

(c) Total Number of
Shares Purchased as Part
of Publicly Announced
Plans or Programs

(d) Maximum Dollar
Value of Shares that
May Yet Be Purchased
Under the Plans or
Programs (in millions)

— $

12,578

$

— $
$

1,110

—

98.24

—
99.23

— $

—

58,749

$

106.72

— $

—

72,437

$

105.13

— $

 N/A

— $

 N/A

— $

 N/A

— $

 N/A

632

 N/A

632
 N/A

632

 N/A

632

N/A

N/A  Not applicable.
(1)  Represents shares surrendered to us to satisfy tax withholding obligations arising from the vesting of restricted stock and 

PSUs issued to employees.

27

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
The following graph compares the total return of our common stock to the Nasdaq Composite Index, the S&P 500 and a peer group 
selected by us for the past five years. We changed our peer group in 2019 to include a broader set of global exchanges with sizable 
market capitalization. The new peer group, collectively referred to as the 2019 peer group, is comprised of the following companies:

PERFORMANCE GRAPH

• ASX Limited
• B3 S.A.1
• Bolsas Mexicana de Valores, S.A.B. 

de C.V.1

• Deutsche Börse AG
• Euronext N.V.1
• Hong Kong Exchanges and Clearing 

Limited1

• LSE
• Singapore Exchange Limited1
• TMX Group Limited

2019 Peer Group

• Cboe

• CME Group Inc.

• ICE
• Japan Exchange Group, Inc1

1 Denotes company added to new peer group in 2019.
The old peer group, collectively referred to as the 2018 peer group, was comprised of the following companies:

• ASX Limited
• Cboe
• CME Group Inc.

2018 Peer Group

• Deutsche Börse AG
• ICE
• LSE

• TMX Group Limited

The  figures  represented  below  assume  an  initial  investment  of  $100  in  the  common  stock  or  index  at  the  closing  price  on 
December 31, 2014 and the reinvestment of all dividends.

COMPARISON OF 5 YEAR CUMULATIVE TOTAL RETURN*
Among Nasdaq, Inc., the Nasdaq Composite Index, the S&P 500, and a Peer Group

* $100 invested on 12/31/2014 in stock or index, including reinvestment of dividends.

Nasdaq, Inc.
Nasdaq Composite Index
S&P 500
2019 Peer Group
2018 Peer Group

Fiscal Year Ended December 31,

2014

2015

2016

2017

2018

2019

$

$

100
100
100
100
100

$

123
107
101
113
113

$

145
116
114
125
130

$

169
151
138
168
175

$

183
147
132
180
195

245
200
174
231
252

Copyright© 2020 Standard & Poor's, a division of S&P Global. All rights reserved.

28

Item 6. Selected Financial Data

The following tables present selected financial data and should 
be  read  in  conjunction  with  the  consolidated  financial 
statements  and  notes  thereto  of  Nasdaq  and  Management’s 
Discussion and Analysis of Financial Condition and Results of 
Operations  included  elsewhere  in  this  Form  10-K.  We 
completed  our  acquisition  of  Cinnober  in  January  2019  and 
several  acquisitions  and  divestitures  during  the  years  ended 
2015 through 2019. The financial results of such acquisitions 
are included in our consolidated financial statements from the 
respective acquisition dates. On January 1, 2019, we adopted 
ASU  2016-02,  “Leases,”  or ASU  2016-02,  and  elected  the 

optional transition method to initially apply the standard at the 
January 1, 2019 adoption date. As a result, we applied the new 
lease  standard  prospectively  to  our  leases  existing  or 
commencing on or after January 1, 2019. Comparative periods 
presented were not restated upon adoption. On January 1, 2018, 
we  adopted  ASU  2014-09,  “Revenue  from  Contracts  with 
Customers (Topic 606),” using the full retrospective method 
which  required  restatement  of  our  2017  and  2016  financial 
statements.

Selected Financial Data

2019

2018

2017

2016

2015

(in millions, except share and per share amounts)

Year Ended December 31,

$

4,262
(1,727)

$

4,277
(1,751)

$

3,948
(1,537)

$

3,704
(1,428)

3,403
(1,313)

2,535

1,518
1,017
774

4.69
4.63

1.85

$
$

$

2,526

1,498
1,028
458

2.77
2.73

1.70

$
$

$

2,411

1,420
991
729

4.38
4.30

1.46

$
$

$

2,276

1,440
836
106

0.64
0.63

1.21

$
$

$

2,090

1,370
720
428

2.56
2.50

0.90

Statements of Income Data:
Total revenues
Transaction-based expenses
Revenues less transaction-based

expenses

Total operating expenses
Operating income
Net income attributable to Nasdaq
Per share information:
Basic earnings per share
Diluted earnings per share
Cash dividends declared per common

share

Weighted-average common shares

outstanding for earnings per share:

$

$
$

$

Basic
Diluted

164,931,628
166,970,161

165,349,471
167,691,299

166,364,299
169,585,031

165,182,290
168,800,997

167,285,450
171,283,271

Balance Sheets Data:
Cash and cash equivalents and financial investments
Default funds and margin deposits
Goodwill
Total assets
Long-term debt
Total Nasdaq stockholders' equity

2019

2018

December 31,

2017

(in millions)

2016

2015

$

$

623
2,996
6,366
13,924
2,996
5,639

$

813
4,742
6,363
15,700
2,956
5,449

$

$

612
3,988
6,586
15,354
3,727
5,880

648
3,301
6,027
13,411
3,603
5,428

502
2,228
5,395
11,257
2,364
5,609

29

Item 7. Management’s Discussion and Analysis of Financial 
Condition and Results of Operations

The following discussion and analysis of the financial condition 
and  results  of  operations  of  Nasdaq  should  be  read  in 
conjunction  with  our  consolidated  financial  statements  and 
related  notes  included  in  this  Form  10-K,  as  well  as  the 
discussion  under  “Item  1A.  Risk  Factors.”  For  further 
discussion of our growth strategy, products and services, and 
competitive  strengths,  see  “Item  1.  Business.”  Unless  stated 
otherwise,  the  comparisons  presented  in  this  discussion  and 
analysis refer to the year-over-year comparison of changes in 
our financial condition and results of operations as of and for 
the fiscal years ended December 31, 2019 and December 31, 
2018. Discussion of fiscal year 2017 items and the year-over-
year  comparison  of  changes  in  our  financial  condition  and 
results  of  operations  as  of  and  for  the  fiscal  years  ended 
December 31, 2018 and December 31, 2017 can be found in 
Part  II,  “Item  7.  Management’s  Discussion  and Analysis  of 
Financial Condition and Results of Operations” of our Annual 
Report on Form 10-K for the fiscal year ended December 31, 
2018, which was previously filed with the SEC on February 22, 
2019.

Business Segments

We manage, operate and provide our products and services in 
four business segments: Market Services, Corporate Services, 
Information  Services  and  Market  Technology. See  Note  1, 
“Organization  and  Nature  of  Operations,”  and  Note  20, 
“Business Segments,” to the consolidated financial statements 
for  further  discussion  of  our  reportable  segments  and 
geographic  data,  as  well  as  how  management  allocates 
resources, assesses performance and manages these businesses 
as four separate segments.

Sources of Revenues and Transaction-Based Expenses

See “Revenue Recognition and Transaction-Based Expenses,” 
of Note 2, “Summary of Significant Accounting Policies,” to 
the consolidated financial statements for further discussion of 
our sources of revenues and transaction-based expenses.

30

Nasdaq’s Operating Results
Key Drivers 
The following table includes key drivers for our Market Services, Corporate Services, Information Services and Market Technology 
segments. In evaluating the performance of our business, our senior management closely evaluates these key drivers. 

Market Services
Equity Derivative Trading and Clearing
U.S. equity options
Total industry average daily volume (in millions)
Nasdaq PHLX matched market share
The Nasdaq Options Market matched market share
Nasdaq BX Options matched market share
Nasdaq ISE Options matched market share
Nasdaq GEMX Options matched market share
Nasdaq MRX Options matched market share
Total matched market share executed on Nasdaq’s exchanges
Nasdaq Nordic and Nasdaq Baltic options and futures
Total average daily volume of options and futures contracts(1)
Cash Equity Trading
Total U.S.-listed securities
Total industry average daily share volume (in billions)
Matched share volume (in billions)
The Nasdaq Stock Market matched market share
Nasdaq BX matched market share
Nasdaq PSX matched market share
Total matched market share executed on Nasdaq’s exchanges
Market share reported to the FINRA/Nasdaq Trade Reporting Facility
Total market share(2)
Nasdaq Nordic and Nasdaq Baltic securities
Average daily number of equity trades executed on Nasdaq’s exchanges
Total average daily value of shares traded (in billions)
Total market share executed on Nasdaq’s exchanges
FICC
Fixed Income
U.S. fixed income volume ($ billions traded)
Total average daily volume of Nasdaq Nordic and Nasdaq Baltic fixed income

contracts
Commodities
Power contracts cleared (TWh)(3)
Corporate Services
IPOs

The Nasdaq Stock Market
Exchanges that comprise Nasdaq Nordic and Nasdaq Baltic

Total new listings

The Nasdaq Stock Market(4)
Exchanges that comprise Nasdaq Nordic and Nasdaq Baltic(5)

Number of listed companies

The Nasdaq Stock Market(6)
Exchanges that comprise Nasdaq Nordic and Nasdaq Baltic(7)

Information Services
Number of licensed ETPs
ETP AUM tracking Nasdaq indexes (in billions)
Market Technology
Order intake (in millions)(8)
Annualized recurring revenue, or ARR, (in millions)(9)

31

Year Ended December 31,

2019

2018

2017

17.5
15.9%
8.8%
0.2%
9.0%
4.2%
0.2%
38.3%

18.2
15.7%
9.4%
0.4%
8.8%
4.5%
0.1%
38.9%

14.7
17.3%
9.2%
0.7%
9.1%
5.2%
0.1%
41.6%

366,289

339,139

330,218

7.03
348.1
17.2%
1.7%
0.7%
19.6%
29.8%
49.4%

7.32
358.5
15.9%
2.8%
0.8%
19.5%
31.3%
50.8%

6.53
295.9
14.2%
3.1%
0.8%
18.1%
34.5%
52.6%

$

590,705
4.5
70.9%

$

618,579
5.6
67.0%

$

552,104
5.3
67.5%

$ 10,465

$ 15,983

$ 17,800

112,738

132,475

116,357

842

1,067

1,199

188
34

313
53

3,140
1,040

332
233

366
260

186
53

303
72

3,058
1,019

365
172

223
222

$

$
$

$

$
$

136
88

268
108

2,949
984

324
167

249
205

$

$
$

 
 
 
____________
(1) 

(2) 

Includes Finnish option contracts traded on Eurex.
Includes transactions executed on The Nasdaq Stock Market’s, Nasdaq BX’s and Nasdaq PSX’s systems plus trades reported 
through the FINRA/Nasdaq Trade Reporting Facility.

(3)  Transactions  executed  on  Nasdaq  Commodities  or  OTC  and  reported  for  clearing  to  Nasdaq  Commodities  measured  by 

Terawatt hours (TWh).

(4)  New listings include IPOs, including those completed on a best efforts basis, issuers that switched from other listing venues, 

closed-end funds and separately listed ETPs.

(5)  New listings include IPOs and represent companies listed on the Nasdaq Nordic and Nasdaq Baltic exchanges and companies 

on the alternative markets of Nasdaq First North.

(6)  Number of total listings on The Nasdaq Stock Market at period end, including 412 ETPs as of December 31, 2019, 392 as of 

December 31, 2018 and 373 as of December 31, 2017.

(7)  Represents companies listed on the Nasdaq Nordic and Nasdaq Baltic exchanges and companies on the alternative markets 

of Nasdaq First North.

(8)  Total contract value of orders signed during the period.
(9)  ARR is the annualized fourth quarter revenue of Market Technology support and SaaS subscription contracts. ARR is currently 
one of our key performance metrics to assess the health and trajectory of our business. ARR does not have any standardized 
definition and is therefore unlikely to be comparable to similarly titled measures presented by other companies. ARR should 
be viewed independently of revenue and deferred revenue and is not intended to be combined with or to replace either of those 
items. ARR is not a forecast and the active contracts during the reporting period used in calculating ARR may or may not be 
extended or renewed by our customers.

Financial Summary

* * * * * *

The following table summarizes our financial performance for the year ended December 31, 2019 when compared with the same 
period in 2018 and for the year ended December 31, 2018 when compared with the same period in 2017. The comparability of 
our results of operations between reported periods is impacted by our acquisition of Cinnober in January 2019, the divestiture of 
the BWise enterprise governance, risk and compliance software platform in March 2019, the divestiture of the Public Relations 
Solutions and Digital Media Services businesses in April 2018, and an increase in net income from unconsolidated investees. See 
Note 4, “Acquisitions and Divestitures,” and “Equity Method Investments,” of Note 7, “Investments,” to the consolidated financial 
statements for further discussion of these transactions. For a detailed discussion of our results of operations, see “Segment Operating 
Results” below. 

Year Ended December 31,

Percentage Change

2019

2018

2017

2019 vs. 2018

2018 vs. 2017

(in millions, except per share amounts)

Revenues less transaction-based expenses

$

2,535

$

2,526

$

2,411

Operating expenses

Operating income
Interest expense

Gain on sale of investment security

Net gain on divestiture of businesses

Net income from unconsolidated investees

Income before income taxes

Income tax provision

Net income attributable to Nasdaq

Diluted earnings per share

Cash dividends declared per common share

_______
N/M 

Not meaningful.

1,518

1,017
(124)
—

27

84

1,498

1,028
(150)
118

33

18

1,019

1,064

245

774

4.63

1.85

$

$

$

606

458

2.73

1.70

$

$

$

$

$

$

1,420

991
(143)

—

15

872

143

729

4.30

1.46

— (100.0)%

0.4 %

1.3 %

(1.1)%
(17.3)%

(18.2)%

366.7 %

(4.2)%

4.8 %

5.5 %

3.7 %
4.9 %

N/M

N/M

20.0 %

22.0 %

(59.6)% 323.8 %

69.0 %

69.6 %

8.8 %

(37.2)%

(36.5)%

16.4 %

In countries with currencies other than the U.S. dollar, revenues and expenses are translated using monthly average exchange rates. 
Impacts on our revenues less transaction-based expenses and operating income associated with fluctuations in foreign currency 
are discussed in more detail under “Item 7A. Quantitative and Qualitative Disclosures about Market Risk.”

32

Segment Operating Results

The following table shows our revenues by segment, transaction-based expenses for our Market Services segment and total revenues 
less transaction-based expenses:

Market Services

Transaction-based expenses

Market Services revenues less transaction-based expenses

Corporate Services

Information Services

Market Technology
Other revenues(1)
Total revenues less transaction-based expenses

Year Ended December 31,

Percentage Change

2019

2018

2017

2019 vs. 2018

2018 vs. 2017

(in millions)

$

$

2,639
(1,727)
912

$

2,709
(1,751)
958

2,418
(1,537)
881

496

779

338

10

487

714

270

97

459

588

247

236

(2.6)%

(1.4)%

(4.8)%

1.8 %

9.1 %

25.2 %

12.0 %

13.9 %

8.7 %

6.1 %

21.4 %

9.3 %

(89.7)%

(58.9)%

$

2,535

$

2,526

$

2,411

0.4 %

4.8 %

____________
(1) 

Includes the revenues from the BWise enterprise governance, risk and compliance software platform which was sold in March 
2019 and the Public Relations Solutions and Digital Media Services businesses which were sold in April 2018. Prior to the 
sale dates, these revenues were included in our Corporate Solutions business within our Corporate Services segment. See 
“2019  Divestitures,”  and  “2018  Divestiture,”  of  Note  4,  “Acquisitions  and  Divestitures,”  to  the  consolidated  financial 
statements for further discussion.

The following charts show our Market Services, Corporate Services, Information Services, and Market Technology segments as 
a percentage of our total revenues less transaction-based expenses of $2,535 million in 2019, $2,526 million in 2018 and $2,411 
million in 2017:

33

 
 
 
 
  
34

MARKET SERVICES

The following table shows total revenues, transaction-based expenses, and total revenues less transaction-based expenses from 
our Market Services segment:

Market Services Revenues:
Equity Derivative Trading and Clearing Revenues(1)

Transaction-based expenses:

Transaction rebates
Brokerage, clearance and exchange fees(1)
Equity derivative trading and clearing revenues

less transaction-based expenses

Cash Equity Trading Revenues(2)

Transaction-based expenses:

Transaction rebates
Brokerage, clearance and exchange fees(2)
Cash equity trading revenues less transaction-

based expenses

FICC Revenues

Transaction-based expenses:

Transaction rebates

Brokerage, clearance and exchange fees
FICC revenues less transaction-based expenses

Year Ended December 31,

Percentage Change

2019

2018

2017

2019 vs. 2018

2018 vs. 2017

(in millions)

$

816

$

849

$

752

(3.9 )%

12.9 %

(477)
(47)

292

(506)
(44)

299

(450)
(43)

(5.7 )%
6.8 %

12.4 %

2.3 %

259

(2.3)%

15.4 %

1,462

1,476

1,279

(0.9 )%

15.4 %

(847)
(352)

263

70

(3)
(1)
66

(830)
(361)

285

92

(8)
(2)
82

(692)
(334)

2.0 %
(2.5 )%

19.9 %

8.1 %

253

(7.7)%

12.6 %

96

(23.9 )%

(4.2)%

(16)
(2)
78

291

881

(62.5 )%
(50.0 )%
(19.5)%

(0.3)%

(50.0)%

— %
5.1 %

0.3 %

(4.8)%

8.7 %

Trade Management Services Revenues

291

292

Total Market Services revenues less transaction-

based expenses

$

912

$

958

$

____________
(1) 

(2) 

Includes Section 31 fees of $43 million in 2019, $39 million in 2018, and $40 million in 2017. Section 31 fees are recorded 
as equity derivative trading and clearing revenues with a corresponding amount recorded in transaction-based expenses. 
Includes Section 31 fees of $337 million in 2019, $343 million in 2018, and $319 million in 2017. Section 31 fees are recorded 
as cash equity trading revenues with a corresponding amount recorded in transaction-based expenses.   

Equity Derivative Trading and Clearing Revenues 

Equity  derivative  trading  and  clearing  revenues  and  equity 
derivative trading and clearing revenues less transaction-based 
expenses decreased in 2019 compared with 2018, reflecting in 
large part a significantly lower volume and volatility market 
environment in the U.S. as compared to 2018. The decrease in 
equity  derivative  trading  and  clearing  revenues  in  2019  was 
primarily due to lower U.S. industry trading volumes and lower 
overall  U.S.  matched  market  share  executed  on  Nasdaq's 
exchanges, partially offset by a higher U.S. gross capture rate 
and higher Section 31 pass-through fee revenue. The decrease 
in  equity  derivative  trading  and  clearing  revenues  less 
transaction-based expenses in 2019 was primarily due to lower 
U.S. industry trading volumes and lower overall U.S. matched 
market share executed on Nasdaq's exchanges, partially offset 
by  a  higher  U.S.  net  capture  rate.  The  decreases  in  equity 
derivative trading and clearing revenues and equity derivative 

trading and clearing revenues less transaction-based expenses 
also included an unfavorable impact from foreign exchange of 
$3 million related to Nasdaq's Nordic exchanges.

Section 31 fees are recorded as equity derivative trading and 
clearing  revenues  with  a  corresponding  amount  recorded  as 
transaction-based expenses. In the U.S., we are assessed these 
fees from the SEC and pass them through to our customers in 
the form of incremental fees. Pass-through fees can increase or 
decrease due to rate changes by the SEC, our percentage of the 
overall  industry  volumes  processed  on  our  systems,  and 
differences in actual dollar value of shares traded. Since the 
amount recorded in revenues is equal to the amount recorded 
as  transaction-based  expenses,  there  is  no  impact  on  our 
revenues  less  transaction-based  expenses.  Section  31  fees 
increased in 2019 compared with 2018 primarily due to higher 
average SEC fee rates, partially offset by lower dollar value 
traded on Nasdaq's exchanges.

35

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Transaction rebates, in which we credit a portion of the per share 
execution charge to the market participant, decreased in 2019 
compared  with  2018  primarily  due  to  lower  U.S.  industry 
trading volumes, a decrease in our overall U.S. matched market 
share executed on Nasdaq's exchanges, and a decrease in the 
U.S. rebate capture rate.

Brokerage,  clearance  and  exchange  fees  increased  in  2019 
compared with 2018 primarily due to higher Section 31 pass-
through fees, as discussed above.

Cash Equity Trading Revenues

Cash equity trading revenues and cash equity trading revenues 
less transaction-based expenses decreased in 2019 compared 
with 2018 reflecting in large part the lower volume and volatility 
market  environment  in  the  U.S.  as  compared  to  2018  as 
mentioned above in “Equity Derivative Trading and Clearing 
Revenues.” The  decrease  in  cash  equity  trading  revenues  in 
2019 was primarily due to lower U.S. industry trading volumes 
and lower Section 31 pass-through fee revenue, partially offset 
by a higher U.S. gross capture rate.

The decrease in cash equity trading revenues less transaction-
based  expenses  in  2019  primarily  reflects  lower  U.S.  and 
European industry trading volumes and a lower U.S. net capture 
rate due to a particularly strong 2018 period, partially offset by 
a higher European net capture rate.  

The decreases in cash equity trading revenues and cash equity 
trading revenues less transaction-based expenses also included 
an  unfavorable  impact  from  foreign  exchange  of  $7  million 
related to Nasdaq's Nordic exchanges.

Similar to equity derivative trading and clearing, in the U.S. we 
record Section 31 fees as cash equity trading revenues with a 
corresponding amount recorded as transaction-based expenses. 
We are assessed these fees from the SEC and pass them through 

to  our  customers  in  the  form  of  incremental  fees.  Since  the 
amount recorded as revenues is equal to the amount recorded 
as  transaction-based  expenses,  there  is  no  impact  on  our 
revenues  less  transaction-based  expenses.  Section 31  fees 
decreased in 2019 compared with 2018 primarily due to lower 
dollar value traded on Nasdaq’s exchanges, partially offset by 
higher average SEC fee rates. 

Transaction rebates increased in 2019 compared with 2018. For 
The Nasdaq Stock Market, Nasdaq PSX and Nasdaq Canada 
CXC, we credit a portion of the per share execution charge to 
the market participant that provides the liquidity, and for Nasdaq 
BX and Nasdaq Canada CX2, we credit a portion of the per 
share execution charge to the market participant that takes the 
liquidity. The increase in 2019 was primarily due to a higher 
U.S. rebate capture rate, partially offset by lower U.S. industry 
trading volumes.

Brokerage,  clearance  and  exchange  fees  decreased  in  2019 
compared with 2018 primarily due to lower Section 31 pass-
through fees, as discussed above, and lower routing fees.

FICC Revenues

FICC  revenues  and  FICC  revenues  less  transaction-based 
expenses decreased in 2019 compared with 2018 primarily due 
to a decline in U.S. fixed income products revenues as well as 
a decrease in European commodities products revenues due to 
lower  volumes  and  an  unfavorable  impact  from  foreign 
exchange of $4 million. 

Trade Management Services Revenues

Trade  management  services  revenues  decreased  slightly  in 
2019  compared  with  2018  primarily  due  to  an  unfavorable 
impact from foreign exchange of $3 million, partially offset by 
an increase in colocation and port connectivity revenues.

CORPORATE SERVICES

The following table shows revenues from our Corporate Services segment: 

* * * * * *

Corporate Services:

Listing Services

Corporate Solutions

Total Corporate Services

Listing Services Revenues
Listing  services  revenues  increased  in  2019  compared  with 
2018 primarily due to higher listings revenues resulting from 
an increase in the number of listed companies, partially offset 
by  the  run-off  of  fees  earned  from  U.S.  listing  of  additional 
shares and an unfavorable impact from foreign exchange of $5 
million. 

Year Ended December 31,

Percentage Change

2019

2018

2017

2019 vs. 2018

2018 vs. 2017

(in millions)

$

$

296

200

496

$

$

290

197

487

$

$

267

192

459

2.1%

1.5%

1.8%

8.6%

2.6%

6.1%

Corporate Solutions Revenues 
Corporate solutions revenues increased in 2019 compared with 
2018 primarily due to an increase in both governance solutions 
revenues and investor relations intelligence revenues, partially 
offset by an unfavorable impact from foreign exchange of $2 
million. 

36

 
INFORMATION SERVICES

The following table shows revenues from our Information Services segment:

Year Ended December 31,

Percentage Change

2019

2018

2017

2019 vs. 2018

2018 vs. 2017

(in millions)

$

$

398

223

158

779

$

$

390

206

118

714

$

$

369

171

48

588

2.1%

8.3%

33.9%

9.1%

5.7%

20.5%

145.8%

21.4%

Investment Data & Analytics Revenues

Investment  data  &  analytics  revenues  increased  in  2019 
compared with 2018 primarily due to an increase in eVestment 
revenues  resulting  from  a  $23  million  purchase  price 
adjustment on deferred revenue in 2018, organic growth, and 
the impact of our acquisition of Quandl. 

Information Services:

Market Data

Index

Investment Data & Analytics

Total Information Services

Market Data Revenues

Market data revenues increased in 2019 compared with 2018 
primarily due to new proprietary data sales, notably growth in 
the Asia  Pacific  region,  and  higher  U.S.  tape  revenues  from 
under-reported data usage. The increase was partially offset by 
an unfavorable impact from foreign exchange of $4 million.

Index Revenues

Index  revenues  increased  in  2019  compared  with  2018 
primarily due to higher average AUM in ETPs linked to Nasdaq 
indexes  and  higher  licensing  revenues  from  futures  trading 
linked to the Nasdaq 100 Index. 

MARKET TECHNOLOGY

The following table shows revenues from our Market Technology segment:

* * * * * *

Market Technology

Market Technology Revenues

Year Ended December 31,

Percentage Change

2019

2018

2017

2019 vs. 2018

2018 vs. 2017

$

338

(in millions)
270
$

$

247

25.2%

9.3%

Market technology revenues increased in 2019 compared with 2018 primarily due to the inclusion of revenues associated with the 
acquisition of Cinnober, an increase in the size and number of software delivery projects, an increase in SaaS surveillance revenues, 
and higher change request revenues, partially offset by an unfavorable impact from foreign exchange of $6 million.

OTHER REVENUES

Other revenues include the revenues from the BWise enterprise governance, risk and compliance software platform, which was 
sold in March 2019 and the revenues from the Public Relations Solutions and Digital Media Services businesses which were sold 
in April 2018. Prior to the sale dates, these revenues were included in our Corporate Solutions business. See “2019 Divestitures,” 
and “2018 Divestiture,” of Note 4, “Acquisitions and Divestitures,” to the consolidated financial statements for further discussion 
of these divestitures.

37

 
Expenses

Operating Expenses 

The following table shows our operating expenses:

Compensation and benefits
Professional and contract services
Computer operations and data communications
Occupancy
General, administrative and other
Marketing and advertising
Depreciation and amortization
Regulatory
Merger and strategic initiatives
Restructuring charges

Total operating expenses

_______
N/M  Not meaningful.

Year Ended December 31,

Percentage Change

2019

2018

2017

2019 vs. 2018

2018 vs. 2017

(in millions)

$

$

707
127
133
97
125
39
190
31
30
39
1,518

$

$

712
144
127
95
120
37
210
32
21
—
1,498

$

$

670
153
125
94
82
31
188
33
44
—
1,420

(0.7)%
(11.8)%
4.7 %
2.1 %
4.2 %
5.4 %
(9.5)%
(3.1)%
42.9 %
N/M
1.3 %

6.3 %
(5.9)%
1.6 %
1.1 %
46.3 %
19.4 %
11.7 %
(3.0)%
(52.3)%
— %
5.5 %

Compensation  and  benefits  expense  decreased  in  2019 
compared with 2018 primarily due to lower compensation costs 
resulting  from  our  2019  and  2018  divestitures,  lower 
performance incentives, and a favorable impact from foreign 
exchange of $17 million, partially offset by higher salary costs 
and  higher  compensation  expense  from  our  2019  and  2018 
acquisitions.

Headcount increased to 4,361 employees as of December 31, 
2019 from 4,099 as of December 31, 2018 primarily due to our 
2019 acquisitions and growth in our Market Technology and 
Investment Data & Analytics businesses, partially offset by our 
2019 divestitures. 

Professional and contract services expense decreased in 2019 
compared  with  2018  primarily  due  to  our  2019  and  2018 
divestitures,  lower  consulting  costs,  and  a  favorable  impact 
from foreign exchange of $3 million, partially offset by higher 
litigation costs.

Computer  operations  and  data  communications  expense 
increased in 2019 compared with 2018 primarily due to higher 
market data feed costs, partially offset by lower costs resulting 
from our 2018 divestiture and a favorable impact from foreign 
exchange of $2 million.

Occupancy  expense  increased  in  2019  compared  with  2018 
mainly due to higher costs associated with additional facility 
and  rent  costs  resulting  from  expansion  of  our  new  U.S. 
headquarters in New York and our 2019 and 2018 acquisitions, 
partially offset by lower costs due to our 2018 divestiture and 
a favorable impact from foreign exchange of $3 million.

General, administrative and other expense increased in 2019 
compared with 2018 primarily due to a provision recorded for 
notes  receivable  associated  with  the  funding  of  technology 
development for the CAT, a charge related to a tax reserve for 

certain prior year examinations, and a charge for a make-whole 
redemption price premium paid on the early extinguishment of 
our 2020 Notes, partially offset by charges associated with the 
clearing default which occurred in 2018, lower costs resulting 
from our 2019 and 2018 divestitures, and a favorable impact 
from foreign exchange of $2 million. The provision for notes 
receivable is a consequence of changes to the CAT project, and 
particularly the decision by Nasdaq and the other exchanges to 
impair the value of the technology built by the original vendor, 
who has been replaced. For further discussion of the clearing 
default, see “Nasdaq Commodities Clearing Default,” of Note 
16,  “Clearing  Operations,”  to  the  consolidated  financial 
statements.

Marketing and advertising expense increased in 2019 compared 
with 2018 primarily due to an increase in advertising spend.

Depreciation  and  amortization  expense  decreased  in  2019 
compared with 2018 primarily due to a decrease in amortization 
expense recorded on capitalized software as a result of our 2019 
restructuring plan, a decrease in amortization expense recorded 
on intangible assets which became fully amortized, a decrease 
in depreciation expense related to the divestiture of BWise, and 
a  favorable  impact  from  foreign  exchange  of  $3  million. 
Partially offsetting these decreases was additional amortization 
expense associated with acquired intangible assets. See Note 
21,  “Restructuring  Charges,”  to  the  consolidated  financial 
statements for further discussion of our 2019 restructuring plan 
and charges associated with this plan. 

Merger  and  strategic  initiatives  expense  increased  in  2019 
compared  with  2018.  We  have  pursued  various  strategic 
initiatives and completed acquisitions and divestitures in recent 
years which have resulted in expenses which would not have 
otherwise  been  incurred.  These  expenses  generally  include 
integration costs, as well as legal, due diligence and other third 

38

 
party  transaction  costs  and  will  vary  based  on  the  size  and 
frequency of the activities described above.

statements for further discussion of our 2019 restructuring plan 
and charges associated with this plan.

Restructuring charges were $39 million in 2019. See Note 21, 
the  consolidated  financial 
to 
“Restructuring  Charges,” 

Non-operating Income and Expenses

The following table shows our non-operating income and expenses:

* * * * * *

Interest income
Interest expense

Net interest expense

Gain on sale of investment security

Net gain on divestiture of businesses
Other income
Net income from unconsolidated investees
Total non-operating income (expenses)

_______
N/M 

Not meaningful.

Interest Expense

Year Ended December 31,

Percentage Change

2019

2018

2017

2019 vs. 2018

2018 vs. 2017

(in millions)
10
$
(150)
(140)
118

33
7
18
36

$

$

$

10
(124)
(114)
—

27
5
84
2

$

$

7
(143)
(136)

— %
(17.3)%
(18.6)%
— (100.0)%

42.9 %
4.9 %
2.9 %
N/M

—
2
15
(119)

N/M
(18.2)%
250.0 %
(28.6)%
366.7 %
20.0 %
(94.4)% (130.3)%

Interest expense decreased in 2019 compared with 2018 primarily due to the refinancing of the 2020 Notes with the 2029 Notes 
at a lower interest rate and lower outstanding debt obligations. See Note 10, “Debt Obligations,” to the consolidated financial 
statements for further discussion of our debt obligations.

The following table shows our interest expense:

Interest expense on debt

Accretion of debt issuance costs and debt discount

Other fees

Interest expense

Year Ended December 31,

Percentage Change

2019

2018

2017

2019 vs. 2018

2018 vs. 2017

(in millions)
140
$

$

135

7

3

6

2

115

6

3

(17.9)%

(14.3)%

— %

124

$

150

$

143

(17.3)%

$

$

3.7%

16.7%

50.0%

4.9%

* * * * * *

Gain on Sale of Investment Security

In December 2018, we recorded a pre-tax gain of $118 million 
($93 million after tax) on the sale of an investment security. See 
“Equity  Securities,”  of  Note  7,  “Investments,”  to  the 
consolidated financial statements for further discussion.

Net Gain on Divestiture of Businesses

The  net  gain  on  divestiture  of  businesses  in  2019  primarily 
relates to our divestiture of BWise. See “2019 Divestitures,” of 
Note  4,  “Acquisitions  and  Divestitures,”  to  the  consolidated 
financial statements for further discussion.

The net gain on divestiture of businesses in 2018 relates to our 
2018  divestiture.  See  “2018  Divestiture,”  of  Note  4, 
“Acquisitions and Divestitures,” to the consolidated financial 
statements for further discussion.

Net Income from Unconsolidated Investees

Net income from unconsolidated investees increased in 2019 
compared with 2018 primarily due to income recognized from 
our equity method investment in OCC. See “Equity Method 
Investments,”  of  Note  7,  “Investments,”  to  the  consolidated 
financial statements for further discussion.

39

 
 
Tax Matters

The following table shows our income tax provision and effective tax rate:

Income tax provision

Effective tax rate

Year Ended December 31,

Percentage Change

2019

2018

2017

2019 vs. 2018

2018 vs. 2017

($ in millions)

$

245

$

606

$

143

(59.6)%

323.8%

24.0%

57.0%

16.4%

For further discussion of our tax matters, see Note 18, “Income Taxes,” to the consolidated financial statements.

* * * * * *

Non-GAAP Financial Measures

this  non-GAAP 

In addition to disclosing results determined in accordance with 
U.S.  GAAP,  we  also  have  provided  non-GAAP  net  income 
attributable  to  Nasdaq  and  non-GAAP  diluted  earnings  per 
share.  Management  uses 
information 
internally, along with U.S. GAAP information, in evaluating 
our  performance  and  in  making  financial  and  operational 
decisions.  We  believe  our  presentation  of  these  measures 
provides investors with greater transparency and supplemental 
data relating to our financial condition and results of operations. 
In addition, we believe the presentation of these measures is 
useful  to  investors  for  period-to-period  comparisons  of  our 
ongoing operating performance.

These measures are not in accordance with, or an alternative 
to, U.S. GAAP, and may be different from non-GAAP measures 
used  by  other  companies.  In  addition,  other  companies, 
including  companies  in  our  industry,  may  calculate  such 
measures  differently,  which  reduces  their  usefulness  as 
comparative measures. Investors should not rely on any single 
financial  measure  when  evaluating  our  business.  This  non-
GAAP  information should  be  considered  as  supplemental  in 
nature and is not meant as a substitute for our operating results 
in  accordance  with  U.S.  GAAP.  We  recommend  investors 
review  the  U.S.  GAAP  financial  measures  included  in  this 
Annual  Report  on  Form  10-K,  including  our  consolidated 
financial  statements  and  the  notes  thereto.  When  viewed  in 
conjunction with our U.S. GAAP results and the accompanying 
reconciliation, we believe these non-GAAP measures provide 
greater  transparency  and  a  more  complete  understanding  of 
factors affecting our business than U.S. GAAP measures alone.

We understand that analysts and investors regularly rely on non-
GAAP  financial  measures,  such  as  non-GAAP  net  income 
attributable  to  Nasdaq  and  non-GAAP  diluted  earnings  per 
share, to assess operating performance. We use non-GAAP net 
income attributable to Nasdaq and non-GAAP diluted earnings 
per  share  because  they  highlight  trends  more  clearly  in  our 
business that may not otherwise be apparent when relying solely 
on  U.S.  GAAP  financial  measures,  since  these  measures 
eliminate from our results specific financial items that have less 
bearing on our ongoing operating performance. Non-GAAP net 
income attributable to Nasdaq for the periods presented below 
is calculated by adjusting for the following items:

Amortization  expense  of  acquired  intangible  assets:  We 
amortize intangible assets acquired in connection with various 

acquisitions.  Intangible  asset  amortization  expense  can  vary 
from period to period due to episodic acquisitions completed, 
rather than from our ongoing business operations. As such, if 
intangible  asset  amortization  is  included  in  performance 
measures, it is more difficult to assess the day-to-day operating 
performance  of 
the  relative  operating 
performance  of  the  businesses  between  periods,  and  the 
earnings power of Nasdaq. Performance measures excluding 
intangible asset amortization therefore provide investors with 
a useful representation of our businesses’ ongoing activity in 
each period.

the  businesses, 

Merger  and  strategic  initiatives  expense:  We  have  pursued 
various  strategic  initiatives  and  completed  acquisitions  and 
divestitures in recent years that have resulted in expenses which 
would  not  have  otherwise  been  incurred.  These  expenses 
generally  include  integration  costs,  as  well  as  legal,  due 
diligence and other third party transaction costs. The frequency 
and the amount of such expenses vary significantly based on 
the size, timing and complexity of the transaction. Accordingly, 
we exclude these costs for purposes of calculating non-GAAP 
measures  which  provide  a  more  meaningful  analysis  of 
Nasdaq’s  ongoing  operating  performance  or  comparisons  in 
Nasdaq’s performance between periods. 

Restructuring  charges:  We  initiated  the  transition  of  certain 
technology platforms to advance our strategic opportunities as 
a  technology  and  analytics  provider  and  continue  the  re-
alignment  of  certain  business  areas.  See  Note  21, 
the  consolidated  financial 
to 
“Restructuring  Charges,” 
statements for further discussion of our 2019 restructuring plan. 
Charges associated with this plan represent a fundamental shift 
in our strategy and technology as well as executive re-alignment 
and will be excluded for purposes of calculating non-GAAP 
measures  as  they  are  not  reflective  of  ongoing  operating 
performance or comparisons in Nasdaq's performance between 
periods.

Net income from unconsolidated investee: See “OCC Capital 
Plan,” of Note 7, “Investments,” to the consolidated financial 
statements for further discussion. Our income on our investment 
in OCC may vary significantly compared to prior years due to 
the disapproval of the OCC's capital plan. Accordingly, we will 
exclude this income from current and prior periods for purposes 
of  calculating  non-GAAP  measures  which  provide  a  more 
meaningful  analysis  of  Nasdaq’s  ongoing  operating 
performance or comparisons in Nasdaq’s performance between 
periods.

40

general,  administrative  and  other  expense  in  the 
Consolidated Statements of Income; and 

litigation  costs  which  are  recorded 

in 
certain 
professional  and  contract  services  expense  in  the 
Consolidated Statements of Income. 

Significant tax items: 

The  non-GAAP  adjustment  to  the  income  tax  provision 
included the tax impact of each non-GAAP adjustment and:

• 

• 

for 2019, a tax benefit of $10 million primarily related to 
an adjustment to the 2018 federal and state tax returns and 
a tax benefit of $10 million related to capital distributions 
from  the  OCC.  See  “OCC Capital  Plan,”  of  Note  7, 
“Investments,” to the consolidated financial statements for 
further discussion of our OCC investment.

for 2018, a net $7 million increase to tax expense due to a 
remeasurement  of  unrecognized  tax  benefits  (excluding 
the  reversal  of  certain  Swedish  tax  benefits  discussed 
below) and the impact of state tax rate changes. 

Additional adjustments included the following items:

• 

for 2019 and 2018, excess tax benefits related to employee 
share-based compensation to reflect the recognition of the 
income tax effects of share-based awards when awards vest 
or are settled. This item is subject to volatility and will vary 
based on the timing of the vesting of employee share-based 
compensation arrangements and fluctuation in our stock 
price.

• 

for 2018:

the  impact  of  enacted  U.S.  tax  legislation,  which 
related to the Tax Cuts and Jobs Act that was enacted 
in  December  2017. We  recorded  an  increase  to  tax 
expense of $290 million and a reduction to deferred 
tax assets related to foreign currency translation as a 
result of the finalization of the provisional estimate 
related to this act; and

a reversal of certain Swedish tax benefits. See Note 
18,  “Income  Taxes,”  to  the  consolidated  financial 
statements for further discussion.

Clearing default loss: In 2018, we recorded a $31 million charge 
related to a default of a Nasdaq Clearing commodities member 
that occurred in September 2018. See “Nasdaq Commodities 
Clearing Default,” of Note 16, “Clearing Operations,” to the 
consolidated financial statements for further discussion of the 
default. We have excluded the charge related to the default as 
we believe it is non-recurring, as there has never been another 
loss due to member default in our clearinghouse, and should be 
excluded when evaluating the ongoing operating performance 
of Nasdaq. Any expenses associated with the evaluation and 
enhancement of processes and procedures will not be excluded 
from our GAAP results.

Other significant items: We have excluded certain other charges 
or gains, including certain tax items, that are the result of other 
non-comparable events to measure operating performance. We 
believe the exclusion of such amounts allows management and 
investors to better understand the ongoing financial results of 
Nasdaq. 

For 2019, other significant items primarily included:

• 

• 

• 

a provision for notes receivable associated with the funding 
of technology development for the CAT which is recorded 
in  general,  administrative  and  other  expense  in  the 
Consolidated Statements of Income;

a  loss  on  extinguishment  of  debt  which  is  recorded  in 
general,  administrative  and  other  expense 
the 
Consolidated Statements of Income; and

in 

a  net  gain  on  divestiture  of  businesses  which  primarily 
represents our pre-tax net gain of $27 million on the sale 
of BWise;

• 

other items: 

a tax reserve for certain prior year examinations which 
is  recorded  in  general,  administrative  and  other 
expense in the Consolidated Statements of Income;

litigation  costs  which  are  recorded 

certain 
in 
professional  and  contract  services  expense  in  the 
Consolidated Statements of Income.

For 2018, other significant items primarily included:

• 

• 

a net gain on divestiture of businesses which represents our 
pre-tax net gain of $33 million on the sale of the Public 
Relations  Solutions  and  Digital  Media  Services 
businesses;

a  gain  on  the  sale  of  an  investment  security  which 
represents our pre-tax gain of $118 million on the sale of 
our  5.0%  ownership  interest  in  LCH  Group  Holdings 
Limited, or LCH;

• 

other items: 

charges  related  to  uncertain  positions  pertaining  to 
sales  and  use  tax  and  VAT  which  are  recorded  in 

41

 
 
 
 
 
 
The following table shows reconciliations between U.S. GAAP net income attributable to Nasdaq and diluted earnings per 
share and non-GAAP net income attributable to Nasdaq and diluted earnings per share:

Year Ended December 31, 2019

Year Ended December 31, 2018

Year Ended December 31, 2017

(in millions, except share and per share amounts)

Net
Income

Diluted Earnings Per
Share

Net
Income

Diluted Earnings Per
Share

Net
Income

Diluted Earnings Per
Share

U.S. GAAP net income attributable to
Nasdaq and diluted earnings per
share

$ 774

$

4.63

$ 458

$

2.73

$ 729

$

4.30

Non-GAAP adjustments:

Amortization expense of acquired

intangible assets

Merger and strategic initiatives

expense

Restructuring charges

Net income from unconsolidated

investee

Clearing default loss

Provision for notes receivable

Extinguishment of debt

Net gain on divestiture of businesses

Gain on sale of investment security

Other

Total non-GAAP adjustments

Adjustment to the income tax

provision to reflect non-GAAP
adjustments and other tax items

Excess tax benefits related to

employee share-based
compensation

Impact of enacted U.S. tax legislation

Reversal of certain Swedish tax

benefits

Total non-GAAP tax adjustments

Total non-GAAP adjustments, net

of tax

Non-GAAP net income attributable to
Nasdaq and diluted earnings per
share

Weighted-average common shares

outstanding for diluted earnings per
share

101

30

39

(82)

—

20

11

(27)

—

17

109

(43)

(5)

—

—

(48)

61

0.60

109

0.18

0.23

(0.49)
—

0.12

21

—

(16)
31

—

0.07
(0.16)

—
(33)
— (118)
17

0.11

0.66

11

0.65

0.13

—

(0.10)
0.18

—

—
(0.20)
(0.69)
0.10

0.07

92

44

—

(13)
—

—

10

—

—

3

136

0.54

0.26

—

(0.08)
—

—

0.06

—

—

0.02

0.80

(0.26)

6

0.03

(66)

(0.39)

(0.03)
—

—
(0.29)

0.37

(9)
290

41

328

339

(0.05)
1.73

0.24

1.95

2.02

(40)
(89)

—
(195)

(59)

(0.24)
(0.52)

—
(1.15)

(0.35)

$ 835

$

5.00

$ 797

$

4.75

$ 670

$

3.95

166,970,161

167,691,299

169,585,031

Liquidity and Capital Resources

Historically, we have funded our operating activities and met 
our  commitments  through  cash  generated  by  operations, 
augmented by the periodic issuance of our common stock and 
debt.  Currently,  our  cost  and  availability  of  funding  remain 
healthy. 

In  March  2019,  we  used  net  proceeds  from  the  sale  of 
commercial paper and cash on hand to redeem all of our 2019 
Notes. In April 2019, we issued the 2029 Notes and in May 

2019, we primarily used the net proceeds from the 2029 Notes 
to repay in full and terminate our 2020 Notes. In addition, in 
June  2019,  we  used  proceeds  from  issuances  of  commercial 
paper to repay in full and terminate our 2016 Credit Facility, 
and  in  February  2020,  we  issued  the  2030  Notes.  We  will 
primarily use the net proceeds from the 2030 Notes to redeem 
the 2021 Notes and for other general corporate purposes. See 
“1.75%  Senior  Unsecured  Notes  Due  2029,”  “Early 
Extinguishment of 5.55% Senior Unsecured Notes Due 2020,” 
“Early  Extinguishment  of  2016  Credit  Facility,”  “0.875% 

42

 
 
 
 
Senior  Unsecured  Notes  Due  2030,”  and  “3.875%  Senior 
Unsecured Notes Due 2021,” of Note 10, “Debt Obligations,” 
to the consolidated financial statements for further discussion.

We  have  the  2017  Credit  Facility  and  a  commercial  paper 
program, which enable us to borrow efficiently at reasonable 
short-term  interest  rates.  The  commercial  paper  program  is 
supported by our 2017 Credit Facility. See “Commercial Paper 
Program,”  and  “2017  Credit  Facility,”  of  Note  10,  “Debt 
Obligations,”  to  the  consolidated  financial  statements  for 
further discussion.

As of December 31, 2019, no amounts were outstanding on the 
2017  Credit  Facility.  The  $2  million  balance  represents 
unamortized  debt  issuance  costs.  Of  the  $1  billion  that  is 
available  for  borrowing,  $392  million  provides  liquidity 
support for the commercial paper program and for a letter of 
credit. As such, as of December 31, 2019, the total remaining 
amount  available  under  the  2017  Credit  Facility  was  $608 
million,  excluding  the  amounts  that  support  the  commercial 
paper program and letter of credit.

As  part  of  the  purchase  price  consideration  of  a  prior 
acquisition, Nasdaq has contingent future obligations to issue 
992,247  shares  of  Nasdaq  common  stock  annually  through 
2027. See “Non-Cash Contingent Consideration,” of Note 19, 
“Commitments,  Contingencies  and  Guarantees,” 
the 
consolidated financial statements for further discussion.

to 

In  the  near  term,  we  expect  that  our  operations  and  the 
availability  under  our  revolving  credit  commitment  and 
commercial paper program will provide sufficient cash to fund 
our operating expenses, capital expenditures, debt repayments, 
any share repurchases, and any dividends. 

The value of various assets and liabilities, including cash and 
cash  equivalents,  receivables,  accounts  payable  and  accrued 
expenses, the current portion of long-term debt, and commercial 
paper,  can  fluctuate  from  month  to  month.  Working  capital 
(calculated  as  current  assets  less  current  liabilities)  was  $63 
million as of December 31, 2019, compared with $(200) million 
as of December 31, 2018, an increase of $263 million. Current 
asset  balance  changes  decreased  working  capital  by  $2,080 
million, with decreases in default funds and margin deposits, 
cash and cash equivalents, other current assets, and restricted 
cash,  partially  offset  by  increases  in  receivables,  net  and 
financial  investments.  Current  liability  balance  changes 
increased working capital by $2,343 million, due to decreases 
in  default  funds  and  margin  deposits,  short-term  debt,  other 
current liabilities, accounts payable and accrued expenses, and 
accrued personnel costs, partially offset by increases in Section 
31 fees payable to the SEC and deferred revenue. 

Principal  factors  that  could  affect  the  availability  of  our 
internally-generated funds include:
• 

deterioration  of  our  revenues  in  any  of  our  business 
segments;

• 

• 

changes in regulatory and working capital requirements; 
and
an increase in our expenses.

Principal factors that could affect our ability to obtain cash from 
external sources include:

• 

• 

• 

• 

• 

operating covenants contained in our credit facilities that 
limit our total borrowing capacity;

increases in interest rates under our credit facilities;

credit rating downgrades, which could limit our access to 
additional debt;

a decrease in the market price of our common stock; and

volatility  or  disruption  in  the  public  debt  and  equity 
markets.

The  following  sections  discuss  the  effects  of  changes  in  our 
financial  assets,  debt  obligations, 
regulatory  capital 
requirements,  and  cash  flows  on  our  liquidity  and  capital 
resources.

Financial Assets

The following table summarizes our financial assets:

December 31, 2019

December 31, 2018

Cash and cash equivalents

$

Restricted cash

Financial investments

Total financial assets

$

(in millions)

332

$

30

291

653

$

545

41

268

854

Cash and Cash Equivalents and Restricted Cash

Cash and cash equivalents includes all non-restricted cash in 
banks and highly liquid investments with original maturities of 
90 days or less at the time of purchase. The balance retained in 
cash and cash equivalents is a function of anticipated or possible 
short-term cash needs, prevailing interest rates, our investment 
policy, and alternative investment choices. As of December 31, 
2019,  our  cash  and  cash  equivalents  of  $332  million  were 
primarily invested in bank deposits, money market funds and 
commercial paper. In the long-term, we may use both internally 
generated  funds  and  external  sources  to  satisfy  our  debt 
obligations  and  other  long-term  liabilities.  Cash  and  cash 
equivalents as of December 31, 2019 decreased $213 million
from December 31, 2018, primarily due to:

• 

• 

• 

• 

• 

• 

• 

• 

• 

repayments of debt obligations; 

cash dividends paid on our common stock;

cash paid for acquisitions, net of cash and cash equivalents 
acquired; 

repurchases of our common stock; and 

purchases of property and equipment, partially offset by;

net cash provided by operating activities; 

proceeds from issuances of long-term debt, net of issuance 
costs;

proceeds from the divestiture of a business; and

proceeds from commercial paper, net.

See “Cash Flow Analysis” below for further discussion. 

43

 
 
Restricted cash is restricted from withdrawal due to contractual 
or regulatory requirements or is not available for general use. 
Restricted cash was $30 million as of December 31, 2019 and 
$41 million as of December 31, 2018, a decrease of $11 million. 
The decrease primarily relates to a decrease in cash pledged as 
collateral. Restricted cash is classified as restricted cash in the 
Consolidated Balance Sheets. 

Repatriation of Cash

Our cash and cash equivalents held outside of the U.S. in various 
foreign subsidiaries totaled $160 million as of December 31, 
2019 and $367 million as of December 31, 2018. The remaining 
balance held in the U.S. totaled $172 million as of December 31, 
2019 and $178 million as of December 31, 2018.

Unremitted earnings of subsidiaries outside of the U.S. are used 
to finance our international operations and are considered to be 
indefinitely reinvested.

Share Repurchase Program

See  “Share  Repurchase  Program,”  of  Note  13,  “Nasdaq 
Stockholders’ Equity,” to the consolidated financial statements 
for further discussion of our share repurchase program.

Cash Dividends on Common Stock

The following table shows quarterly cash dividends paid per 
common share on our outstanding common stock:

First quarter

Second quarter

Third quarter

Fourth quarter

Total

2019

2018

0.44

0.47

0.47

0.47

1.85

$

$

0.38

0.44

0.44

0.44

1.70

$

$

See “Cash Dividends on Common Stock,” of Note 13, “Nasdaq 
Stockholders’ Equity,” to the consolidated financial statements 
for further discussion of the dividends. 

Financial Investments

Our  financial 
investments  totaled  $291  million  as  of 
December 31, 2019 and $268 million as of December 31, 2018
and  are  primarily  comprised  of  highly  rated  European 
government debt securities. Of these securities, $169 million
as of December 31, 2019 and $166 million as of December 31, 
2018  are  assets  primarily  utilized  to  meet  regulatory  capital 
requirements,  mainly  for  our  clearing  operations  at  Nasdaq 
Clearing.  See  Note  7,  “Investments,”  to  the  consolidated 
financial statements for further discussion. 

Debt Obligations

The following table summarizes our debt obligations by contractual maturity:

* * * * * *

Short-term debt:

Commercial paper

Senior unsecured floating rate notes
5.55% senior unsecured notes(1)
$400 million senior unsecured term loan facility

Total short-term debt
Long-term debt:

3.875% senior unsecured notes

$1 billion senior unsecured revolving credit facility

1.75% senior unsecured notes

4.25% senior unsecured notes

3.85% senior unsecured notes

1.75% senior unsecured notes

Total long-term debt

Total debt obligations

Maturity Date

December 31, 2019

December 31, 2018

(in millions)

Weighted-average
maturity of 13 days
Repaid March 2019
Repaid May 2019

Repaid June 2019

June 2021

April 2022

May 2023

June 2024

June 2026

March 2029

$

391

$

—

—

—

391

671
(2)
668

497

497

665

2,996

$

3,387

$

275

500

599

100

1,474

686
(4)
682

497

496

—

2,357

3,831

____________
(1)  Balance was reclassified to short-term debt as of March 31, 2019.

In addition to the $1 billion senior unsecured revolving credit facility, we also have other credit facilities primarily related to our 
Nasdaq Clearing operations in order to provide further liquidity. Other credit facilities, which are available in multiple currencies, 

44

 
 
totaled $203 million as of December 31, 2019 and $234 million as of December 31, 2018, in available liquidity, of which $15 
million was utilized as of December 31, 2019 and none of which was utilized as of December 31, 2018.

As of December 31, 2019, we were in compliance with the covenants of all of our debt obligations.

See Note 10, “Debt Obligations,” to the consolidated financial statements for further discussion of our debt obligations.

* * * * * *

Regulatory Capital Requirements

Clearing Operations Regulatory Capital Requirements

We  are  required  to  maintain  minimum  levels  of  regulatory 
capital for the clearing operations of Nasdaq Clearing. The level 
of  regulatory  capital  required  to  be  maintained  is  dependent 
upon  many  factors, 
including  market  conditions  and 
creditworthiness of the counterparty. As of December 31, 2019, 
our required regulatory capital of $147 million is comprised of 
highly  rated  European  government  debt  securities  that  are 
included in financial investments in the Consolidated Balance 
Sheets. 

Broker-Dealer Net Capital Requirements

Our  broker-dealer  subsidiaries,  Nasdaq  Execution  Services, 
Execution Access, NPM Securities, SMTX, and Nasdaq Capital 
Markets  Advisory,  are  subject  to  regulatory  requirements 
intended  to  ensure  their  general  financial  soundness  and 
liquidity.  These  requirements  obligate  these  subsidiaries  to 
comply  with  minimum  net  capital  requirements.  As  of 
December 31,  2019,  the  combined  required  minimum  net 
capital  totaled  $1  million  and  the  combined  excess  capital 
totaled $48 million, substantially all of which is held in cash 

and cash equivalents in the Consolidated Balance Sheets. The 
required minimum net capital is included in restricted cash in 
the Consolidated Balance Sheets. 

Nordic and Baltic Exchange Regulatory Capital Requirements

The entities that operate trading venues in the Nordic and Baltic 
countries are each subject to local regulations and are required 
to maintain regulatory capital intended to ensure their general 
financial soundness and liquidity. As of December 31, 2019, 
our  required  regulatory  capital  of  $33  million  is  invested  in 
European  government  debt  securities  that  are  included  in 
financial investments and restricted cash in the Consolidated 
Balance Sheets.

Other Capital Requirements

We operate several other businesses which are subject to local 
regulation  and  are  required  to  maintain  certain  levels  of 
regulatory  capital. As  of  December 31,  2019,  other  required 
regulatory capital was $11 million and was primarily included 
in restricted cash and financial investments in the Consolidated 
Balance Sheets.

Cash Flow Analysis

The following table summarizes the changes in cash flows:

* * * * * *

Net cash provided by (used in):

(in millions)

Year Ended December 31,

Percentage Change

2019

2018

2017

2019 vs. 2018

2018 vs. 2017

Operating activities

Investing activities
Financing activities

Effect of exchange rate changes on cash and cash equivalents and

restricted cash

Net increase (decrease) in cash and cash equivalents and restricted

cash

Cash and cash equivalents and restricted cash at beginning of period

$ 963

$ 1,028

$ 909

(6.3)%

13.1 %

(240)
(937)

196
(1,027)

(890)
(53)

(222.4)%
(8.8)%

(122.0)%
1,837.7 %

(10)

(10)

15

— %

(166.7)%

(224)
586

187

399

586

(19)
418

$ 399

(219.8)% (1,084.2)%

46.9 %

(38.2)%

(4.5)%

46.9 %

Cash and cash equivalents and restricted cash at end of period

$ 362

$

Net Cash Provided by Operating Activities

Net cash provided by operating activities primarily consists of 
net  income  adjusted  for  certain  non-cash  items  such  as: 
depreciation  and  amortization  expense  of  property  and 
equipment;  amortization  expense  of  acquired  finite-lived 
intangible  assets  which  can  be  episodic,  depending  on  the 
timing  and  size  of  a  related  business  combination;  expense 

associated  with  share-based  compensation;  and  net  income 
from unconsolidated investees.

Net cash provided by operating activities is also impacted by 
the effects of changes in operating assets and liabilities such as: 
accounts  receivable  which  is  impacted  by  the  timing  of 
customer billings and related collections from our customers; 
accounts  payable  and  accrued  expenses  due  to  timing  of 
payments;  accrued  personnel  costs  which  are  impacted  by 
employee  performance  targets  and  the  timing  of  payments 

45

 
related  to  employee  bonus  incentives;  and  Section  31  fees 
payable  to  the  SEC,  which  is  impacted  by  the  timing  of 
collections from customers and payments to the SEC. 

Net cash provided by operating activities decreased $65 million 
in 2019 compared with 2018. The decrease was primarily driven 
by  higher  performance  incentive  payments  made  in  2019 
compared with 2018 primarily due to prior year performance, 
a decline in cash flows related to our 2019 and 2018 divestitures, 
and payments made in 2019 associated with the capital relief 
program,  partially  offset  by  cash  flows  from  our  2019 
acquisitions and growth in net income.

Net Cash Used in (Provided by) Investing Activities

Net cash used in investing activities for 2019 primarily relates 
to $206 million of cash used for acquisitions, net of cash and 
cash  equivalents  acquired,  $127  million  of  purchases  of 
property and equipment, and $36 million of net purchases of 
securities, partially offset by receipt of cash of $132 million 
related to our 2019 divestitures.

Net  cash  provided  by  investing  activities  for  2018  primarily 
relates  to  $286  million  of  cash  received  from  our  2018 
divestiture and $169 million of proceeds from the sale of an 
investment  security,  partially  offset  by  $111  million  of 
purchases of property and equipment, $101 million of cash used 
for our 2018 acquisition, and $47 million of net purchases of 
securities.

Net Cash Used in Financing Activities

Net cash used in financing activities for 2019 primarily relates 
to  $1,215  million  in  repayments  of  debt  obligations,  $305 
million  of  dividend  payments  to  our  shareholders,  and  $200 
million  in  repurchases  of  common  stock,  partially  offset  by 
$680 million from proceeds related to long-term debt issuances 
and $116 million in net borrowings of commercial paper.

Net cash used in financing activities for 2018 primarily relates 
to $394 million in repurchases of common stock, $280 million 
of dividend payments to our shareholders, $205 million of net 
repayments  of  commercial  paper,  and  $115  million  of 
repayments of debt obligations.

See Note 4, “Acquisitions and Divestitures,” to the consolidated 
financial statements for further discussion of our acquisitions 
and divestitures. 

See Note 10, “Debt Obligations,” to the consolidated financial 
statements for further discussion of our debt obligations.

See  “Share  Repurchase  Program,”  and  “Cash  Dividends  on 
Common Stock,” of Note 13, “Nasdaq Stockholders’ Equity,” 
to the consolidated financial statements for further discussion 
of our share repurchase program and cash dividends paid on 
our common stock. 

Contractual Obligations and Contingent Commitments

* * * * * *

Nasdaq has contractual obligations to make future payments under debt obligations by contract maturity, operating lease payments, 
and other obligations. The following table shows these contractual obligations as of December 31, 2019.

Contractual Obligations

Total

Less than 1 year

1-3 years

3-5 years

More than 5
years

Payments Due by Period

Debt obligations by contract maturity(1)
Operating lease obligations(2)
Real estate obligations(3)
Purchase obligations(4)
Other obligations(5)
Total

(in millions)

$

3,847

$

481

$

508

128
54
9
4,546

$

$

77

—
26
9
593

$

827

113

12
28
—
980

$

1,278

$

78

27
—
—
1,383

$

$

1,261

240

89
—
—
1,590

____________
(1)  Our debt obligations include both principal and interest obligations. As of December 31, 2019, an interest rate of 2.73% was 
used to compute the amount of the contractual obligations for interest on the 2017 Credit Facility. All other debt obligations 
were primarily calculated on a 360-day basis at the contractual fixed rate multiplied by the aggregate principal amount as of 
December 31, 2019. See Note 10, “Debt Obligations,” to the consolidated financial statements for further discussion.
(2)  Operating lease obligations represent our undiscounted operating lease liabilities as of December 31, 2019. See Note 17, 

“Leases,” to the consolidated financial statements for further discussion of our leases.

(3)  Real estate obligations include legally binding minimum lease payments for leases signed but not yet commenced.
(4)  Purchase obligations primarily represent minimum outstanding obligations due under software license agreements.
(5)  Other obligations primarily consist of potential future escrow agreement payments related to prior acquisitions.

46

 
Non-Cash Contingent Consideration

See  “Non-Cash  Contingent  Consideration,”  of  Note  19, 
the 
“Commitments,  Contingencies  and  Guarantees,” 
consolidated financial statements for further discussion.

to 

Off-Balance Sheet Arrangements

For discussion of off-balance sheet arrangements see:

•  Note  16,  “Clearing  Operations,”  to  the  consolidated 
financial statements for further discussion of our non-cash 
default  fund  contributions  and  margin  deposits  received 
for clearing operations; and

•  Note 19, “Commitments, Contingencies and Guarantees,” 
to  the  consolidated  financial  statements  for  further 
discussion of:

•  Guarantees issued and credit facilities available;

•  Other guarantees;

•  Non-cash contingent consideration;

•  Escrow agreements;

•  Routing brokerage activities;

•  Legal and regulatory matters; and

•  Tax audits.

Quantitative  and  Qualitative  Disclosures  About  Market 
Risk

As a result of our operating, investing and financing activities, 
we are exposed to market risks such as interest rate risk and 
foreign currency exchange rate risk. We are also  exposed to 
credit risk as a result of our normal business activities.

We  have  implemented  policies  and  procedures  to  measure, 
manage, monitor and report risk exposures, which are reviewed 
regularly  by  management  and  the  board  of  directors.  We 
identify risk exposures and monitor and manage such risks on 
a daily basis.

We  perform  sensitivity  analyses  to  determine  the  effects  of 
market  risk  exposures.  We  may  use  derivative  instruments 
solely to hedge financial risks related to our financial positions 
or risks that are incurred during the normal course of business. 
We do not use derivative instruments for speculative purposes.

Interest Rate Risk

We  are  subject  to  the  risk  of  fluctuating  interest  rates  in  the 
normal  course  of  business.  Our  exposure  to  market  risk  for 
changes  in  interest  rates  relates  primarily  to  our  financial 
investments and debt obligations which are discussed below.

Financial Investments

As  of  December 31,  2019,  our  investment  portfolio  was 
primarily comprised of highly rated European government debt 
securities, which pay a fixed rate of interest. These securities 
are  subject  to  interest  rate  risk  and  the  fair  value  of  these 
securities  will  decrease  if  market  interest  rates  increase.  If 
market  interest  rates  were  to  increase  immediately  and 
uniformly by 100 basis points from levels as of December 31, 
2019, the fair value of this portfolio would have declined by $7 
million. 

Debt Obligations

As  of  December 31,  2019,  substantially  all  of  our  debt 
obligations are fixed-rate obligations. While changes in interest 
rates will have no impact on the interest we pay on fixed-rate 
obligations, we are exposed to changes in interest rates as a 
result of the amounts outstanding from the sale of commercial 
paper  under  our  commercial  paper  program,  which  have 
variable  interest  rates.  As  of  December 31,  2019,  we  had 
principal amounts outstanding of $391 million of commercial 
paper. A hypothetical 100 basis points increase in interest rates 
on our outstanding commercial paper would increase annual 
interest  expense  by  approximately  $4  million  based  on 
borrowings as of December 31, 2019. 

47

Foreign Currency Exchange Rate Risk

We are subject to foreign currency exchange rate risk. Our primary transactional exposure to foreign currency denominated revenues 
less  transaction-based  expenses  and  operating  income  for  the  years  ended  December 31,  2019  and  2018  are  presented  in  the 
following tables:

Year Ended December 31, 2019

Average foreign currency rate to the U.S. dollar

Percentage of revenues less transaction-based expenses
Percentage of operating income(1)
Impact of a 10% adverse currency fluctuation on revenues less

transaction-based expenses

Impact of a 10% adverse currency fluctuation on operating

income

Year Ended December 31, 2018

Average foreign currency rate to the U.S. dollar
Percentage of revenues less transaction-based expenses
Percentage of operating income

Euro

Swedish
Krona

Other
Foreign
Currencies

U.S. Dollar

Total

(in millions, except currency rate)

1.1193

0.1057

7.7%

13.9%

7.6 %

(4.3)%

# 

5.0 %

(5.8)%

N/A

79.7%

96.2%

N/A

100.0%

100.0%

$

$

(19)

(14)

$

$

(19)

(4)

$

$

(13)

$ — $

(51)

(6)

$ — $

(24)

Euro

Swedish
Krona

Other
Foreign
Currencies

U.S. Dollar

Total

(in millions, except currency rate)

1.1800

0.1150

8.9%
11.3%

7.3 %
0.1 %

# 
5.2 %
(7.0)%

N/A
78.6%
95.6%

N/A
100.0%
100.0%

Impact of a 10% adverse currency fluctuation on revenues less

transaction-based expenses

Impact of a 10% adverse currency fluctuation on operating

income

$

$

(23)

$

(18)

$

(13)

$ — $

(54)

(12)

$ — $

(7)

$ — $

(19)

____________
(1) 

# 
N/A  Not applicable.

The decrease in 2019 percentage of operating income in Swedish Krona is primarily driven by costs associated with our 
2019 restructuring plan. See Note 21, “Restructuring Charges,” to the consolidated financial statements for further 
discussion of our 2019 restructuring plan.
Represents multiple foreign currency rates.

Our investments in foreign subsidiaries are exposed to volatility 
in currency exchange rates through translation of the foreign 
subsidiaries’ net assets or equity to U.S. dollars. Substantially 
all of our foreign subsidiaries operate in functional currencies 
other  than  the  U.S.  dollar. The  financial  statements  of  these 
subsidiaries  are  translated  into  U.S.  dollars  for  consolidated 
reporting using a current rate of exchange, with net gains or 
losses  recorded  in  accumulated  other  comprehensive  loss 
within stockholders’ equity in the Consolidated Balance Sheets.

Our primary exposure to net assets in foreign currencies as of 
December 31, 2019 is presented in the following table:

$

Swedish Krona(1)
Norwegian Krone
Canadian Dollar
British Pound
Euro
Australian Dollar

Net Assets

Impact of a 10%
Adverse Currency
Fluctuation

(in millions)

$

3,247
174
120
222
33
105

(325)
(17)
(12)
(22)
(3)
(11)

____________
(1) 

Includes goodwill of $2,397 million and intangible 
assets, net of $600 million.

Credit Risk

Credit risk is the potential loss due to the default or deterioration 
in credit quality of customers or counterparties. We are exposed 
to  credit  risk  from  third  parties,  including  customers, 

48

 
 
 
 
 
 
 
 
 
 
 
 
 
 
counterparties and clearing agents. These parties may default 
on their obligations to us due to bankruptcy, lack of liquidity, 
operational failure or other reasons. We limit our exposure to 
credit risk by evaluating the counterparties with which we make 
investments  and  execute  agreements.  For  our  investment 
portfolio,  our  objective  is  to  invest  in  securities  to  preserve 
principal  while  maximizing  yields,  without  significantly 
increasing  risk.  Credit  risk  associated  with  investments  is 
minimized substantially by ensuring that these financial assets 
are  placed  with  governments  which  have  investment  grade 
ratings,  well-capitalized  financial  institutions  and  other 
creditworthy counterparties. 

Our subsidiary, Nasdaq Execution Services, may be exposed to 
credit  risk  due  to  the  default  of  trading  counterparties  in 
connection with the routing services it provides for our trading 
customers. System trades in cash equities routed to other market 
centers for members of our cash equity exchanges are routed 
by Nasdaq Execution Services for clearing to the NSCC. In this 
function, Nasdaq Execution Services is to be neutral by the end 
of the trading day, but may be exposed to intraday risk if a trade 
extends beyond the trading day and into the next day, thereby 
leaving Nasdaq Execution Services susceptible to counterparty 
risk in the period between accepting the trade and routing it to 
the  clearinghouse.  In  this  interim  period,  Nasdaq  Execution 
Services is not novating like a clearing broker but instead is 
subject to the short-term risk of counterparty failure before the 
clearinghouse enters the transaction. Once the clearinghouse 
officially  accepts  the  trade  for  novation,  Nasdaq  Execution 
Services  is  legally  removed  from  trade  execution  risk. 
However,  Nasdaq  has  membership  obligations  to  NSCC 
independent of Nasdaq Execution Services’ arrangements.

Pursuant  to  the  rules  of  the  NSCC  and  Nasdaq  Execution 
Services’  clearing  agreement,  Nasdaq  Execution  Services  is 
liable for any losses incurred due to a counterparty or a clearing 
agent’s failure to satisfy its contractual obligations, either by 
making payment or delivering securities. Adverse movements 
in the prices of securities that are subject to these transactions 
can increase our credit risk. However, we believe that the risk 
of  material  loss  is  limited,  as  Nasdaq  Execution  Services’ 
customers are not permitted to trade on margin and NSCC rules 
limit  counterparty  risk  on  self-cleared  transactions  by 
establishing credit limits and capital deposit requirements for 
all  brokers  that  clear  with  NSCC.  Historically,  Nasdaq 
Execution  Services  has  never  incurred  a  liability  due  to  a 
customer’s  failure  to  satisfy  its  contractual  obligations  as 
counterparty to a system trade. Credit difficulties or insolvency, 
or the perceived possibility of credit difficulties or insolvency, 
of one or more larger or visible market participants could also 
result  in  market-wide  credit  difficulties  or  other  market 
disruptions. 

Execution Access is an introducing broker which operates the 
trading platform for our Fixed Income business to trade in U.S. 
Treasury  securities.  Execution  Access  has  a  clearing 
arrangement with Industrial and Commercial Bank of China 
Financial Services LLC, or ICBC. As of December 31, 2019, 
we have contributed $15 million of clearing deposits to ICBC 
in connection with this clearing arrangement. These deposits 

are recorded in other current assets in our Consolidated Balance 
Sheets.  Some  of  the  trading  activity  in  Execution Access  is 
cleared  by  ICBC  through  the  Fixed  Income  Clearing 
Corporation,  with  ICBC  acting  as  agent.  Execution Access 
assumes the counterparty risk of clients that do not clear through 
the Fixed Income Clearing Corporation. Counterparty risk of 
clients exists for Execution Access between the trade date and 
settlement date of the individual transactions, which is at least 
one business day (or more, if specified by the U.S. Treasury 
issuance calendar). Counterparties that do not clear through the 
Fixed Income Clearing Corporation are subject to a credit due 
diligence process and may be required to post collateral, provide 
principal letters, or provide other forms of credit enhancement 
to Execution Access for the purpose of mitigating counterparty 
risk. Daily position trading limits are also enforced for such 
counterparties. 

We  have  credit  risk  related  to  transaction  and  subscription-
based revenues that are billed to customers on a monthly or 
quarterly  basis,  in  arrears.  Our  potential  exposure  to  credit 
losses  on  these  transactions  is  represented  by  the  receivable 
balances in our Consolidated Balance Sheets. We review and 
evaluate  changes 
the  status  of  our  counterparties’ 
creditworthiness. Credit losses such as those described above 
could adversely affect our consolidated financial position and 
results of operations.

in 

On January 1, 2020, we adopted ASU 2016-13, “Measurement 
of  Credit  Losses  on  Financial  Instruments.”  See  “Financial 
Instruments  -  Credit  Losses,”  of  “Recent  Accounting 
Pronouncements,”  of  Note  2,  “Summary  of  Significant 
Accounting Policies,” to the consolidated financial statements 
for further discussion. This ASU changes the impairment model 
for certain financial instruments. The new model is a forward 
looking  expected  loss  model  and  applies  to  financial  assets 
subject  to  credit  losses  and  measured  at  amortized  cost  and 
certain off-balance sheet credit exposures. This includes loans, 
held-to-maturity debt securities, loan commitments, financial 
guarantees and trade receivables. 

We  also  are  exposed  to  credit  risk  through  our  clearing 
operations  with  Nasdaq  Clearing.  See  Note  16,  “Clearing 
Operations,” to the consolidated financial statements for further 
discussion.  Our  clearinghouse  holds  material  amounts  of 
clearing  member  cash  deposits  which  are  held  or  invested 
primarily to provide security of capital while minimizing credit, 
market  and  liquidity  risks.  While  we  seek  to  achieve  a 
reasonable  rate  of  return,  we  are  primarily  concerned  with 
preservation of capital and managing the risks associated with 
these  deposits.  As  the  clearinghouse  may  pass  on  interest 
revenues  (minus  costs)  to  the  members,  this  could  include 
negative  or  reduced  yield  due  to  market  conditions.  The 
following  is  a  summary  of  the  risks  associated  with  these 
deposits and how these risks are mitigated.

•  Credit Risk. When the clearinghouse has the ability to hold 
cash collateral at a central bank, the clearinghouse utilizes 
its access to the central bank system to minimize credit risk 
exposures. When funds are not held at a central bank, we 
seek to substantially mitigate credit risk by ensuring that 

49

• 

• 

• 

investments  are  primarily  placed 
government and supranational debt instruments.

in  highly  rated 

Liquidity Risk. Liquidity risk is the risk a clearinghouse 
may not be able to meet its payment obligations in the right 
currency, in the right place and the right time. To mitigate 
this risk, the clearinghouse monitors liquidity requirements 
closely and maintains funds and assets in a manner which 
minimizes  the  risk  of  loss  or  delay  in  the  access  by  the 
clearinghouse  to  such  funds  and  assets.  For  example, 
holding  funds  with  a  central  bank  where  possible  or 
investing  in  highly  liquid  government  or  supranational 
debt instruments serves to reduce liquidity risks.

Interest Rate Risk. Interest rate risk is the risk that interest 
rates  rise  causing  the  value  of  purchased  securities  to 
decline.  If  we  were  required  to  sell  securities  prior  to 
maturity,  and  interest  rates  had  risen,  the  sale  of  the 
securities  might  be  made  at  a  loss  relative  to  the  latest 
market price. Our clearinghouse seeks to manage this risk 
by  making  short  term  investments  of  members'  cash 
deposits.  In  addition,  the  clearinghouse  investment 
guidelines  allow  for  direct  purchases  or  repurchase 
agreements of high quality sovereign debt (for example, 
European  government  and  U.S.  Treasury  securities), 
supranational  debt 
central  bank  certificates  and 
instruments with short dated maturities.

Security Issuer Risk. Security issuer risk is the risk that an 
issuer  of  a  security  defaults  on  its  payment  when  the 
security  matures.  This  risk  is  mitigated  by  limiting 
allowable  investments  and  collateral  under  reverse 
repurchase  agreements 
to  high  quality  sovereign, 
government agency or supranational debt instruments.

Critical Accounting Policies and Estimates 

in 

The preparation of financial statements and related disclosures 
in conformity with U.S. GAAP requires management to make 
judgments, assumptions, and estimates that affect the amounts 
reported 
the  consolidated  financial  statements  and 
accompanying  notes.  Note  2,  “Summary  of  Significant 
Accounting Policies,” to the consolidated financial statements 
describes the significant accounting policies and methods used 
in the preparation of the consolidated financial statements. The 
accounting policies described below are significantly affected 
by  critical  accounting  estimates.  Such  accounting  policies 
require significant judgments, assumptions, and estimates used 
in the preparation of the consolidated financial statements, and 
actual results could differ materially from the amounts reported 
based on these policies.

Revenue Recognition

Corporate Services Revenues

Listing Services Revenues

Listing services revenues primarily include annual renewal fees 
and initial listing fees. Annual renewal fees do not require any 
judgments or assumptions by management as these amounts 
are  recognized  ratably  over  the  following  12-month  period. 
However,  the  initial  listing  fee  is  allocated  to  multiple 

50

performance obligations including initial and subsequent listing 
services  and  corporate  solutions  services  (when  a  company 
qualifies to receive these services under the applicable Nasdaq 
rule), as well as a customer's material right to renew the option 
to list on our exchanges. 

In performing this allocation, the standalone selling price of the 
performance obligations is based on the initial and annual listing 
fees and the standalone selling price of the corporate solutions 
services is based on its market value. All listing fees are billed 
upfront and the identified performance obligations are satisfied 
over time since the customer receives and consumes the benefit 
as Nasdaq provides the listing service. The amount of revenue 
related  to  the  corporate  solutions  services  performance 
obligation is recognized ratably over a two-year period, which 
is  based  on  contract  terms,  with  the  remaining  revenue 
recognized  ratably  over  six  years  which  is  based  on  our 
historical  listing  experience  and  projected  future  listing 
duration.

Market Technology Revenues

We enter into long-term contracts with customers to develop 
customized  technology  solutions,  license  the  right  to  use 
software  and  provide  support  and  other  services  to  our 
customers which results in these contracts containing multiple 
performance obligations. We allocate the contract transaction 
price to each performance obligation using our best estimate of 
the standalone selling price of each distinct good or service in 
the contract. In instances where standalone selling price is not 
directly observable, such as when we do not sell the product or 
service separately, we determine the standalone selling price 
predominantly  through  an  expected  cost  plus  a  margin 
approach.

We  generally  recognize  revenue  over  time  as  our  customers 
simultaneously receive and consume the benefits provided by 
our performance because our customer controls the asset for 
which we are creating, our performance does not create an asset 
with  alternative  use,  and  we  have  a  right  to  payment  for 
performance  completed  to  date.  For  these  services,  we 
recognize revenue over time using costs incurred to date relative 
to  total  estimated  costs  at  completion  to  measure  progress 
toward satisfying our performance obligation. Incurred costs 
represent  work  performed,  which  corresponds  with,  and 
thereby depicts, the transfer of control to the customer.

Accounting  for  our  long-term  contracts  requires  judgment 
relative to assessing risks and their impact on the estimate of 
revenues and costs. Our estimates are impacted by factors such 
as the potential for schedule and technical issues, productivity, 
and the complexity of work performed. When adjustments in 
estimated total contract costs are required, any changes in the 
estimated revenues from prior estimates are recognized in the 
current period for the effect of such change. If estimates of total 
costs  to  be  incurred  on  a  contract  exceed  estimates  of  total 
revenues,  a  provision  for  the  entire  estimated  loss  on  the 
contract is recorded in the period in which the loss is determined. 

For further discussion related to recognition of these fees, see 
“Revenue  From  Contracts  with  Customers  -  Revenue 
Recognition  -  Corporate  Services  -  Listing  Services,”  and 

“Revenue  From  Contracts  with  Customers  -  Revenue 
Recognition - Market Technology,” of Note 2, “Summary of 
Significant Accounting Policies,” to the consolidated financial 
statements.

Goodwill and Related Impairment

Goodwill represents the excess of purchase price over the value 
assigned  to  the  net  assets,  including  identifiable  intangible 
assets,  of  a  business  acquired.  Goodwill  is  allocated  to  our 
reporting units based on the assignment of the fair values of 
each reporting unit of the acquired company. We test goodwill 
for impairment at the reporting unit level annually, or in interim 
periods  if  certain  events  occur  indicating  that  the  carrying 
amount  may  be  impaired,  such  as  changes  in  the  business 
climate, poor indicators of operating performance or the sale 
or disposition of a significant portion of a reporting unit. For 
purposes of performing our goodwill impairment test, our five 
reporting  units  are  the  Market  Services  segment,  the  two 
businesses comprising the Corporate Services segment: Listing 
Services  and  Corporate  Solutions,  the  Information  Services 
segment,  and  the  Market  Technology  segment.  We  test  for 
impairment during the fourth quarter of our fiscal year using 
an  October 1  measurement  date.  When  testing  goodwill  for 
impairment, we have the option of first performing a qualitative 
assessment to determine whether it is more likely than not that 
the fair value of a reporting unit is less than its carrying amount 
as  the  basis  to  determine  if  it  is  necessary  to  perform  a 
quantitative  goodwill  impairment  test.  In  performing  a 
qualitative  assessment,  we  consider  the  extent  to  which 
unfavorable events or circumstances identified, such as changes 
in  economic  conditions,  industry  and  market  conditions  or 
company specific events, could affect the comparison of the 
reporting unit’s fair value with its carrying amount. If we choose 
not to complete a qualitative assessment for a given reporting 
unit, or if the initial assessment indicates that it is more likely 
than not that the carrying amount of a reporting unit exceeds 
its estimated fair value, a quantitative test is required.

When  assessing  goodwill  for  impairment,  our  decision  to 
perform  a  qualitative  impairment  assessment  for  a  reporting 
unit  in  a  given  year  is  influenced  by  a  number  of  factors, 
including  but  not  limited  to,  the  size  of  the  reporting  unit’s 
goodwill, the significance of the excess of the reporting unit’s 
estimated  fair  value  over  its  carrying  amount  at  the  last 
quantitative assessment date, and the amount of time in between 
quantitative fair value assessments.

The quantitative goodwill impairment test consists of two steps 
performed at the reporting unit level.

•  The first step compares the estimated fair value of each 
reporting  unit  to  its  corresponding  carrying  amount, 
including goodwill. The fair value of each reporting unit 
is estimated using a combination of discounted cash flow 
valuation,  which  incorporates  assumptions  regarding 
future growth rates, terminal values, and discount rates, as 
well as guideline public company valuations, incorporating 
relevant trading multiples of comparable companies and 
other factors. The estimates and assumptions used consider 
historical  performance  and  are  consistent  with  the 

• 

assumptions  used  in  determining  future  profit  plans  for 
each reporting unit, which are approved by our board of 
directors.  If  the  reporting  unit’s  estimated  fair  value 
exceeds  its  estimated  carrying  amount,  goodwill  is  not 
impaired.

If the first step results in the carrying amount exceeding 
the fair value of the reporting unit, then a second step must 
be completed in order to determine the amount of goodwill 
impairment that should be recorded, if any. In the second 
step, the implied fair value of the reporting unit’s goodwill 
is determined by allocating the reporting unit’s fair value 
to all of its assets and liabilities other than goodwill in a 
manner similar to a purchase price allocation. The implied 
fair value of the goodwill that results from the application 
of this second step is then compared to the carrying amount 
of the goodwill and an impairment charge is recorded for 
any difference.

On January 1, 2020, we adopted ASU 2017-04, “Simplifying 
the  Test  for  Goodwill  Impairment,”  or  ASU  2017-04.  See 
“Goodwill,” of “Recent Accounting Pronouncements,” of Note 
2,  “Summary  of  Significant  Accounting  Policies,”  to  the 
consolidated financial statements for further discussion.

The following table presents the balances of goodwill for our 
reportable segments at the time of our 2019 annual impairment 
test:

Market Services
Corporate Services
Information Services
Market Technology

October 1, 2019

(in millions)

3,292
439
2,238
263
6,232

$

$

In 2019, we performed a qualitative goodwill impairment test 
for all reporting units, as the excesses of their fair values over 
their  respective  carrying  amounts  at  the  time  of  the  last 
quantitative  test  in  2017  were  significant.  In  conducting  the 
qualitative assessment, we evaluated the performance of each 
of these reporting units since the last quantitative test, as well 
as future financial projections to determine if there were any 
changes in the key inputs used to determine the fair values of 
each reporting unit. We also considered the qualitative factors 
in  FASB  Accounting  Standards  Codification  Topic  350, 
“Intangibles–Goodwill  and  Other,”  as  well  as  other  relevant 
events and circumstances. Based on the results of the qualitative 
assessment for each reporting unit, we concluded based on a 
predominance  of  positive  indicators  and  the  weight  of  such 
indicators that the fair values of our reporting units are more 
likely than not greater than their respective carrying amounts 
and  as  a  result,  quantitative  analyses  were  not  needed.  No 
goodwill impairment was recorded in 2019, 2018 and 2017.

Although we believe our estimates of fair value are reasonable, 
the  determination  of  certain  valuation  inputs  is  subject  to 
management’s  judgment.  Changes  in  these  inputs  could 
materially affect the results of our impairment review. If our 

51

 
 
 
forecasts of cash flows or other key inputs are negatively revised 
in  the  future,  the  estimated  fair  value  of  each  reporting  unit 
would  be  adversely  impacted,  potentially  leading  to  an 
impairment  in  the  future  that  could  materially  affect  our 
operating results.

Subsequent  to  our  annual  impairment  test,  no  indications  of 
impairment were identified.

Indefinite-Lived Intangible Assets and Related Impairment

Intangible  assets  deemed  to  have  indefinite  useful  lives, 
primarily exchange and clearing registrations, are not amortized 
but instead are tested for impairment at least annually and more 
frequently  whenever  events  or  changes  in  circumstances 
indicate  that  the  fair  value  of  the  asset  may  be  less  than  its 
carrying amount. Similar to goodwill impairment testing, we 
test for impairment of indefinite-lived intangible assets during 
the  fourth  quarter  of  our  fiscal  year  using  an  October 1 
measurement  date  and  may  first  perform  a  qualitative 
assessment, considering similar factors as discussed above in 
the goodwill impairment discussion, to determine if it is more 
likely  than  not  that  the  fair  value  of  the  indefinite-lived 
intangible asset is less than its carrying amount. If we elect to 
perform or are required to perform a quantitative assessment, 
the  test  consists  of  a  comparison  of  the  fair  value  of  the 
indefinite-lived intangible asset to its carrying amount as of the 
impairment  testing  date.  If  the  carrying  amount  of  the 
indefinite-lived  intangible  asset  exceeds  its  fair  value,  an 
impairment charge is recorded for the difference. The fair value 
of indefinite-lived intangible assets is primarily determined on 
the basis of estimated discounted value, using the Greenfield 
Approach for exchange and clearing registrations and licenses 
and  the  relief  from  royalty  approach  or  excess  earnings 
approach  for  trade  names,  both  of  which  incorporate 
assumptions regarding future revenue projections and discount 
rates.  During  our  annual  indefinite-lived  intangible  asset 
impairment test during the fourth quarter of 2019, we performed 
a  qualitative  test  as  the  excess  fair  value  of  each  individual 
indefinite-lived  intangible  asset  over  its  respective  carrying 
amount  at  the  time  of  the  last  quantitative  test  in  2017  was 
significant. Based on the results of the qualitative assessment, 
we concluded based on a predominance of positive indicators 
and  the  weight  of  such  indicators  that  the  fair  values  of  our 
indefinite-lived  intangible  assets  are  more  likely  than  not 
greater than their respective carrying amounts and as a result, 
quantitative  analyses  were  not  needed.  There  were  no 
indefinite-lived intangible asset impairment charges in 2019, 
2018 and 2017. 

Subsequent to our annual indefinite-lived impairment test, no 
indications of impairment were identified.

Other Long-Lived Assets and Related Impairment

We  review  our  other  long-lived  assets,  such  as  finite-lived 
intangible  assets,  equity  method  investments  and  equity 
securities,  as  well  as  property  and  equipment,  for  potential 
impairment when there is evidence that events or changes in 
circumstances indicate that the carrying amount of an asset may 
not  be  recoverable.  The  carrying  amount  of  an  asset  is  not 

recoverable if it exceeds the sum of the undiscounted cash flows 
expected to result from the use and eventual disposition of the 
asset. Fair value of finite-lived intangible assets and property 
and equipment is based on various valuation techniques. We 
evaluate  our  equity  method  investments  for  other-than-
temporary declines in value by considering a variety of factors 
such  as  the  earnings  capacity  of  the  investment  and  the  fair 
value of the investment compared to its carrying amount. In 
addition,  for  investments  where  the  market  value  is  readily 
determinable,  we  consider  the  underlying  stock  price  as  an 
additional  factor.  For  equity  securities,  when  assessing 
investments in private companies for impairment, we consider 
such factors as, among others, the share price from the investee's 
latest  financing  round,  the  performance  of  the  investee  in 
relation to its own operating targets, the investee's liquidity and 
cash  position,  and  general  market  conditions. Any  required 
impairment  loss  is  measured  as  the  amount  by  which  the 
carrying  amount  of  the  asset  exceeds  its  fair  value  and  is 
recorded as a reduction in the carrying amount of the related 
asset and a charge to operating results.

No material impairments were recorded to reduce the carrying 
value  of  our  finite-lived  intangible  assets,  equity  method 
investments or equity securities during 2019, 2018 or 2017.

We recorded pre-tax, non-cash property and equipment asset 
impairment  charges  of  $24  million  in  2019.  The  asset 
impairment  charge  in  2019  primarily  related  to  capitalized 
software that was retired and is included in restructuring charges 
in the Consolidated Statements of Income for 2019. See Note 
21,  “Restructuring  Charges,”  to  the  consolidated  financial 
statements for a discussion of our 2019 restructuring plan. There 
were no other material impairments of property and equipment 
recorded in 2019, 2018 or 2017.

Income Taxes

Estimates  and  judgments  are  required  in  the  calculation  of 
certain  tax  liabilities  and  in  the  determination  of  the 
recoverability of certain deferred tax assets, which arise from 
net operating loss carryforwards, tax credit carryforwards and 
temporary differences between the tax and financial statement 
recognition of revenue and expense. Our deferred tax assets are 
reduced by a valuation allowance if it is more likely than not 
that some portion or all of the recorded deferred tax assets will 
not be realized in future periods. Management is required to 
determine whether a tax position is more likely than not to be 
sustained upon examination, including resolution of any related 
appeals or litigation processes, based on the technical merits of 
the position. Once  it is determined that a  position meets the 
recognition thresholds, the position is measured to determine 
the  amount  of  benefit  to  be  recognized  in  the  consolidated 
financial statements. 

In assessing the need for a valuation allowance, we consider all 
available  evidence  including  past  operating  results,  the 
existence of cumulative losses in the most recent fiscal years, 
estimates  of  future  taxable  income  and  the  feasibility  of  tax 
planning  strategies.  In  the  event  that  we  change  our 
determination as to the amount of deferred tax assets that can 
be  realized,  we  will  adjust  our  valuation  allowance  with  a 

52

corresponding impact to the provision for income taxes in the 
period in which such determination is made.

Item 7A.  Quantitative  and  Qualitative  Disclosures About 
Market Risk

In  addition,  the  calculation  of  our  tax  liabilities  involves 
uncertainties in the application of tax regulations in the U.S. 
and other tax jurisdictions. We recognize potential liabilities for 
anticipated tax audit issues in such jurisdictions based on our 
estimate of whether, and the extent to which, additional taxes 
and interest may be due. While we believe that our tax liabilities 
reflect the probable outcome of identified tax uncertainties, it 
is reasonably possible that the ultimate resolution of any tax 
matter may be greater or less than the amount accrued. If events 
occur  and  the  payment  of  these  amounts  ultimately  proves 
unnecessary, the reversal of the liabilities would result in tax 
benefits being recognized in the period when we determine the 
liabilities  are  no  longer  necessary.  If  our  estimate  of  tax 
liabilities  proves  to  be  less  than  the  ultimate  assessment,  a 
further charge to expense would result.

Recent Accounting Pronouncements

See  “Recent  Accounting  Pronouncements,”  of Note  2, 
“Summary  of  Significant  Accounting  Policies,” 
the 
consolidated  financial  statements  for  further  discussion  of 
recently  adopted  accounting  pronouncements 
that  are 
applicable to Nasdaq.

to 

Information  about  quantitative  and  qualitative  disclosures 
about  market  risk  is  incorporated  herein  by  reference  from 
“Item 7. Management’s Discussion and Analysis of Financial 
Condition  and  Results  of  Operations  -  Quantitative  and 
Qualitative Disclosures About Market Risk.”

Item 8. Financial Statements and Supplementary Data

statements, 

Nasdaq’s  consolidated 
including 
financial 
Consolidated  Balance  Sheets  as  of  December 31,  2019  and 
2018, Consolidated Statements of Income for the years ended 
December 31, 2019, 2018 and 2017, Consolidated Statements 
of Comprehensive Income for the years ended December 31, 
2019, 2018 and 2017, Consolidated Statements of Changes in 
Stockholders' Equity for the years ended December 31, 2019, 
2018 and 2017, Consolidated Statements of Cash Flows for the 
years ended December 31, 2019, 2018 and 2017 and notes to 
our  consolidated  financial  statements,  together  with  a  report 
thereon of Ernst & Young LLP, dated February 25, 2020, are 
attached hereto as pages F-1 through F-49 and incorporated by 
reference herein.

Summarized Quarterly Financial Data (Unaudited)

* * * * * *

Total revenues

Transaction-based expenses

Revenues less transaction-based expenses

Total operating expenses

Operating income

Net income attributable to Nasdaq

Basic earnings per share

Diluted earnings per share
Cash dividends declared per common share

Total revenues

Transaction-based expenses

Revenues less transaction-based expenses

Total operating expenses

Operating income

Net income (loss) attributable to Nasdaq

Basic earnings (loss) per share

Diluted earnings (loss) per share
Cash dividends declared per common share

1st Qtr

2019

2nd Qtr

3rd Qtr

2019

2019

4th Qtr

2019

(in millions, except per share amounts)

1,039
(405)
634

359

275

247

1.49

1.48
0.44

$

$

$

$
$

1,061
(438)
623

367

256

174

1.05

1.04
0.47

$

$

$

$
$

1,096
(464)
632

406

226

150

0.91

0.90
0.47

$

$

$

$
$

1,065
(419)
646

386

260

202

1.23

1.21
0.47

1st Qtr

2018

2nd Qtr

3rd Qtr

2018

2018

4th Qtr

2018

(in millions, except per share amounts)

1,151
(485)
666

393

273

177

1.06

1.05
0.82

$

$

$

$
$

1,027
(412)
615

346

269

162

0.98

$

$

$

0.97

$
— $

964
(364)
600

354

246

163

0.99

0.97
0.44

$

$

$

$
$

1,136
(491)
645

404

241
(44)
(0.27)
(0.27)
0.44

$

$

$

$
$

$

$

$

$
$

53

Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

None.

Item 9A. Controls and Procedures

Disclosure controls and procedures. Nasdaq’s management, with the participation of Nasdaq’s President and Chief Executive 
Officer, and Executive Vice President, Corporate Strategy and Chief Financial Officer, has evaluated the effectiveness of Nasdaq’s 
disclosure controls and procedures (as defined in Rule 13a-15(e) and Rule 15d-15(e) under the Exchange Act) as of the end of the 
period covered by this report. Based upon that evaluation, Nasdaq’s President and Chief Executive Officer and Executive Vice 
President, Corporate Strategy and Chief Financial Officer, have concluded that, as of the end of such period, Nasdaq’s disclosure 
controls and procedures are effective.

 Changes in internal control over financial reporting. During the quarter ended June 30, 2019, we implemented a new enterprise 
resource  planning,  or  ERP,  system,  by  transitioning  certain  of  our  operations,  including  the  general  ledger,  to  the  new  ERP 
system. We have modified our existing controls infrastructure, as well as added other processes and internal controls, to adapt to 
our new ERP system and to take advantage of the increased functionality of the new system. 

There have been no changes in Nasdaq’s internal control over financial reporting (as defined in Rule 13a-15(f) and Rule 15d-15(f) 
under the Exchange Act) that occurred during the quarter ended December 31, 2019 that have materially affected, or are reasonably 
likely to materially affect, Nasdaq’s internal control over financial reporting.  

Management’s Report on Internal Control Over Financial Reporting

Management is responsible for the preparation and integrity of the consolidated financial statements appearing in the reports that 
we file with the SEC. The consolidated financial statements were prepared in conformity with U.S. generally accepted accounting 
principles and include amounts based on management’s estimates and judgments.

Management is also responsible for establishing and maintaining adequate internal control over Nasdaq’s financial reporting. 
Although there are inherent limitations in the effectiveness of any system of internal control over financial reporting, we maintain 
a system of internal control that is designed to provide reasonable assurance as to the fair and reliable preparation and presentation 
of the consolidated financial statements, as well as to safeguard assets from unauthorized use or disposition that could have a 
material effect on the financial statements.

Our management assessed the effectiveness of our internal control over financial reporting as of December 31, 2019, based on 
criteria  established  in  Internal  Control  -  Integrated  Framework  issued  by  the  Committee  of  Sponsoring  Organizations  of  the 
Treadway Commission (COSO) (2013 framework). This evaluation included review of the documentation of controls, evaluation 
of the design effectiveness of controls, testing of the operating effectiveness of controls and a conclusion on this evaluation. Based 
on its assessment, our management believes that, as of December 31, 2019, our internal control over financial reporting is effective.

Ernst & Young LLP, an independent registered public accounting firm, has issued an attestation report on Nasdaq’s internal control 
over financial reporting, which is included herein.

54

To the Shareholders and the Board of Directors of Nasdaq, Inc.

Report of Independent Registered Public Accounting Firm

Opinion on Internal Control over Financial Reporting
We have audited Nasdaq, Inc.’s internal control over financial reporting as of December 31, 2019, based on criteria established in 
Internal Control-Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (2013 
framework) (the COSO criteria). In our opinion, Nasdaq, Inc. (the Company) maintained, in all material respects, effective internal 
control over financial reporting as of December 31, 2019, based on the COSO criteria.

We  also  have  audited,  in  accordance  with  the  standards  of  the  Public  Company Accounting  Oversight  Board  (United  States) 
(PCAOB), the consolidated balance sheets of the Company as of December 31, 2019 and 2018, and the related consolidated 
statements of income, comprehensive income, changes in stockholders’ equity and cash flows for each of the three years in the 
period ended December 31, 2019, and the related notes and our report dated February 25, 2020 expressed an unqualified opinion 
thereon. 

Basis for Opinion
The Company’s management is responsible for maintaining effective internal control over financial reporting and for its assessment 
of the effectiveness of internal control over financial reporting included in the accompanying Management’s Report on Internal 
Control Over Financial Reporting. Our responsibility is to express an opinion on the Company’s internal control over financial 
reporting based on our audit. We are a public accounting firm registered with the PCAOB and are required to be independent with 
respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities 
and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the 
audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all material 
respects.  

Our audit included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness 
exists, testing and evaluating the design and operating effectiveness of internal control based on the assessed risk, and performing 
such other procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for 
our opinion. 

Definition and Limitations of Internal Control Over Financial Reporting 
A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability 
of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted 
accounting principles. A company’s internal control over financial reporting includes those policies and procedures that (1) pertain 
to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets 
of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial 
statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are 
being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable 
assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company’s assets that 
could have a material effect on the financial statements.

Because  of  its  inherent  limitations,  internal  control  over  financial  reporting  may  not  prevent  or  detect  misstatements. Also, 
projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because 
of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

/s/ Ernst & Young LLP

New York, New York
February 25, 2020 

55

 
 
Item 9B. Other Information

None. 

PART III

Item 10. Directors, Executive Officers and Corporate Governance

Information about Nasdaq’s directors, as required by Item 401 of Regulation S-K, is incorporated by reference from the discussion 
under the caption “Board of Directors-Proposal I: Election of Directors” in Nasdaq’s Proxy Statement. Information about Nasdaq’s 
executive officers, as required by Item 401 of Regulation S-K, is incorporated by reference from the discussion under the caption 
“Other  Items-Executive  Officers”  in  the  Proxy  Statement.  Information  about  Section 16  reports,  as  required  by  Item 405  of 
Regulation S-K, is incorporated by reference from the discussion under the caption “Other Items-Delinquent Section 16(a) Reports” 
in the Proxy Statement. Information about Nasdaq’s code of ethics, as required by Item 406 of Regulation S-K, is incorporated by 
reference  from  the  discussion  under  the  caption  “Our  Ethical  Culture”  in  the  Proxy  Statement.  Information  about  Nasdaq’s 
nomination procedures, audit committee and audit committee financial experts, as required by Items 407(c)(3), 407(d)(4) and 
407(d)(5) of Regulation S-K, is incorporated by reference from the discussions under the headings “Board of Directors-Proposal 
I: Election of Directors” and “Board of Directors-Board Committees” in the Proxy Statement.

Item 11. Executive Compensation

Information about Nasdaq’s director and executive compensation, as required by Items 402, 407(e)(4) and 407(e)(5) of Regulation 
S-K,  is  incorporated  by  reference  from  the  discussions  under  the  headings  “Board  of  Directors-Director  Compensation”  and 
“Named Executive Officer Compensation” in the Proxy Statement.

Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

Information about security ownership of certain beneficial owners and management, as required by Item 403 of Regulation S-K, 
is incorporated by reference from the discussion under the heading “Other Items-Security Ownership of Certain Beneficial Owners 
and Management” in the Proxy Statement.

Equity Compensation Plan Information

Nasdaq’s Equity Plan provides for the issuance of our equity securities to our officers and other employees, directors and consultants. 
In addition, nearly all employees of Nasdaq and its subsidiaries are eligible to participate in the ESPP at 85.0% of the fair market 
value of our common stock on the price calculation date. Employees in certain of our locations are ineligible due to local securities 
laws and regulations. In jurisdictions where participation in the ESPP is permitted, all of our employees may participate. The 
Equity Plan and the ESPP have been approved previously by our stockholders. The following table sets forth information regarding 
outstanding options and shares reserved for future issuance under all of Nasdaq’s compensation plans as of December 31, 2019.

Plan Category

Equity compensation plans approved by

stockholders

Equity compensation plans not approved by

stockholders

Total
____________

Number of shares
to be issued upon exercise 
of outstanding options, 
warrants and rights(a)(1)

Weighted-average
 exercise price of
outstanding options, 
warrants and rights(b) 

Number of shares 
remaining available
for future issuance under 
equity 
compensation plans 
(excluding shares 
reflected in column(a))(c)

379,102

$

—

379,102

$

54.32

—

54.32

12,082,402 (2) 

—

12,082,402 (2) 

(1)  The amounts in this column include only the number of shares to be issued upon exercise of outstanding options, warrants 
and rights. As of December 31, 2019, we also had 2,601,458 shares to be issued upon vesting of outstanding restricted stock 
and PSUs.

(2)  This amount includes 10,427,582 shares of common stock that may be awarded pursuant to the Equity Plan and 1,654,820 

shares of common stock that may be issued pursuant to the ESPP.

Item 13. Certain Relationships and Related Transactions, and Director Independence

Information about certain relationships and related transactions, as required by Item 404 of Regulation S-K, is incorporated herein 
by reference from the discussion under the heading “Other Items-Certain Relationships and Related Transactions” in the Proxy 
Statement. Information about director independence, as required by Item 407(a) of Regulation S-K, is incorporated herein by 
reference from the discussion under the heading “Board of Directors-Proposal I: Election of Directors” in the Proxy Statement.

56

Item 14. Principal Accounting Fees and Services

Information about principal accounting fees and services, as required by Item 9(e) of Schedule 14A, is incorporated herein by 
reference from the discussion under the heading “Audit Committee Matters-Annual Evaluation and 2020 Selection of Independent 
Auditors” in the Proxy Statement.

PART IV

Item 15. Exhibits, Financial Statement Schedules

(a)(1) Financial Statements

See “Index to Consolidated Financial Statements.”

(a)(2) Financial Statement Schedules

All schedules are omitted because they are not applicable or the required information is included in the consolidated financial 
statements or notes.

(a)(3) Exhibits

Exhibit Number

Exhibit Index

Purchase Agreement, dated as of April 1, 2013, among Nasdaq, Inc. (f/k/a The NASDAQ OMX Group, Inc.), 
BGC Partners, Inc., BGC Holdings, L.P., BGC Partners, L.P., and, solely for purposes of certain sections thereof, 
Cantor Fitzgerald, L.P. (incorporated herein by reference to Exhibit 2.1 to the Quarterly Report on Form 10-Q for 
the quarter ended June 30, 2013 filed on August 8, 2013).

Amended and Restated Certificate of Incorporation of Nasdaq (incorporated herein by reference to Exhibit 3.1 to 
the Current Report on Form 8-K filed on January 28, 2014).

Certificate of Elimination of Nasdaq’s Series A Convertible Preferred Stock (incorporated herein by reference to 
Exhibit 3.1.1 to the Current Report on Form 8-K filed on January 28, 2014).

Certificate of Amendment of Nasdaq’s Amended and Restated Certificate of Incorporation (incorporated herein 
by reference to Exhibit 3.1 to the Current Report on Form 8-K filed on November 19, 2014).

Certificate of Amendment of Nasdaq’s Amended and Restated Certificate of Incorporation (incorporated herein 
by reference to Exhibit 3.1 to the Current Report on Form 8-K filed on September 8, 2015).

Nasdaq’s By-Laws (incorporated herein by reference to Exhibit 3.2 to the Current Report on Form 8-K filed on 
November 21, 2016).

Form of Common Stock certificate (incorporated herein by reference to Exhibit 4.1 to the Quarterly Report on 
Form 10-Q for the quarter ended September 30, 2015 filed on November 4, 2015).

Stockholders’ Agreement, dated as of February 27, 2008, between Nasdaq, Inc. (f/k/a The NASDAQ OMX Group, 
Inc.) and Borse Dubai Limited (incorporated herein by reference to Exhibit 10.2 to the Current Report on Form 
8-K filed on March 3, 2008).

First Amendment to Stockholders’ Agreement, dated as of February 19, 2009, between Nasdaq, Inc. (f/k/a The 
NASDAQ OMX Group, Inc.) and Borse Dubai Limited (incorporated herein by reference to Exhibit 4.10.1 to the 
Annual Report on Form 10-K for the year ended December 31, 2008 filed on February 27, 2009).

Registration Rights Agreement, dated as of February 27, 2008, among Nasdaq, Inc. (f/k/a The NASDAQ OMX 
Group, Inc.), Borse Dubai Limited and Borse Dubai Nasdaq Share Trust (incorporated herein by reference to 
Exhibit 10.3 to the Current Report on Form 8-K filed on March 3, 2008).

First Amendment to Registration Rights Agreement, dated as of February 19, 2009, among Nasdaq, Inc. (f/k/a 
The NASDAQ OMX Group, Inc.), Borse Dubai Limited and Borse Dubai Nasdaq Share Trust (incorporated herein 
by reference to Exhibit 4.11.1 to the Annual Report on Form 10-K for the year ended December 31, 2008 filed 
on February 27, 2009).

Stockholders’ Agreement, dated  as  of  December 16,  2010,  between  Nasdaq,  Inc.  (f/k/a The NASDAQ  OMX 
Group, Inc.) and Investor AB (incorporated herein by reference to Exhibit 4.12 to the Annual Report on Form 10-
K for the year ended December 31, 2010 filed on February 24, 2011).

Indenture, dated as of June 7, 2013, between Nasdaq, Inc. (f/k/a The NASDAQ OMX Group, Inc.) and Wells 
Fargo Bank, National Association, as Trustee (incorporated herein by reference to Exhibit 4.1 to the Current Report 
on Form 8-K filed on June 10, 2013).

2.1

3.1

3.1.1

3.1.2

3.1.3

3.2

4.1

4.2

4.2.1

4.3

4.3.1

4.4

4.5

57

 
 
 
 
 
 
 
 
 
 
 
 
 
First Supplemental Indenture, dated as of June 7, 2013, among Nasdaq, Inc. (f/k/a The NASDAQ OMX Group, 
Inc.), Wells Fargo Bank, National Association, as Trustee, Deutsche Bank AG, London Branch, as paying agent, 
and Deutsche Bank Luxembourg S.A., as registrar and transfer agent (incorporated herein by reference to Exhibit 
4.2 to the Current Report on Form 8-K filed on June 10, 2013).

Second Supplemental Indenture, dated as of May 29, 2014, among Nasdaq, Inc. (f/k/a The NASDAQ OMX Group, 
Inc.) and Wells Fargo Bank, National Association, as Trustee (incorporated herein by reference to Exhibit 4.1 to 
the Current Report on Form 8-K filed on May 30, 2014).

Third  Supplemental  Indenture,  dated  as  of  May  20,  2016,  among  Nasdaq,  Inc.,  Wells Fargo  Bank,  National 
Association, as Trustee, and HSBC Bank USA, National Association, as paying agent and as registrar and transfer 
agent (incorporated herein by reference to the Current Report on Form 8-K filed on May 23, 2016).

Fifth Supplemental Indenture, dated as of September 22, 2017, among Nasdaq, Inc. and Wells Fargo Bank,
National Association, as Trustee (incorporated herein by reference to Exhibit 4.1 to the Current Report on Form
8-K filed on September 22, 2017).

Sixth  Supplemental  Indenture,  dated  as  of April  1,  2019,  among  Nasdaq,  Inc.,  Wells  Fargo  Bank,  National 
Association, as Trustee, and HSBC Bank USA, National Association, as paying agent and as registrar and transfer 
agent (incorporated by reference to Exhibit 4.2 to the Form 8-A filed on April 1, 2019).

Registration Rights Agreement, dated as of June 28, 2013, by and among Nasdaq, Inc. (f/k/a The NASDAQ OMX 
Group, Inc.), BGC Partners, Inc., BGC Holdings, L.P. and BGC Partners, L.P. (incorporated herein by reference 
to Exhibit 10.1 to the Current Report on Form 8-K filed on July 1, 2013).

Description of Securities.

Amended and Restated Board Compensation Policy, effective on April 23, 2019 (incorporated herein by reference 
to Exhibit 10.1 to the Quarterly Report on Form 10-Q for the quarter ended June 30, 2019 filed on August 5, 
2019).*

Nasdaq Executive Corporate Incentive Plan, effective as of January 1, 2015 (incorporated herein by reference to 
Exhibit 10.1 to the Current Report on Form 8-K filed on May 11, 2015).*

Nasdaq, Inc. Equity Incentive Plan (as amended and restated as of April 24, 2018) (incorporated herein by reference 
to Exhibit 10.1 to the Form S-8 filed on May 25, 2018).*

Form of Nasdaq Non-Qualified Stock Option Award Certificate (incorporated herein by reference to Exhibit 10.3 
to the Annual Report on Form 10-K for the year ended December 31, 2010 filed on February 24, 2011).*

Form of Nasdaq Restricted Stock Unit Award Certificate (employees) (incorporated herein by reference to
Exhibit 10.2 to the Quarterly Report on Form 10-Q for the quarter ended June 30, 2019 filed on August 5,
2019).*

Form of Nasdaq Restricted Stock Unit Award Certificate (directors) (incorporated herein by reference to
Exhibit 10.3 to the Quarterly Report on Form 10-Q for the quarter ended June 30, 2019 filed on August 5,
2019).*

Form of Nasdaq One-Year Performance Share Unit Agreement (incorporated herein by reference to Exhibit
10.4 to the Quarterly Report on Form 10-Q for the quarter ended June 30, 2019 filed on August 5, 2019).*

Form of Nasdaq Three-Year Performance Share Unit Agreement (incorporated herein by reference to Exhibit
10.5 to the Quarterly Report on Form 10-Q for the quarter ended June 30, 2019 filed on August 5, 2019).*

Form of Nasdaq Continuing Obligations Agreement (incorporated herein by reference to Exhibit 10.1 to the
Quarterly Report on Form 10-Q for the quarter ended March 31, 2017 filed on May 10, 2017).*

4.6

4.7

4.8

4.9

4.10

4.11

4.12

10.1

10.2

10.3

10.4

10.5

10.6

10.7

10.8

10.9

Amended and Restated Supplemental Executive Retirement Plan, dated as of December 17, 2008 (incorporated
herein by reference to Exhibit 10.6 to the Annual Report on Form 10-K for the year ended December 31, 2008
filed on February 27, 2009).*

Amendment No. 1 to Amended and Restated Supplemental Executive Retirement Plan, effective as of
December 31, 2008 (incorporated herein by reference to Exhibit 10.6.1 to the Annual Report on Form 10-K for
the year ended December 31, 2008 filed on February 27, 2009).*

Nasdaq Supplemental Employer Retirement Contribution Plan, dated as of December 17, 2008 (incorporated
herein by reference to Exhibit 10.7 to the Annual Report on Form 10-K for the year ended December 31, 2008
filed on February 27, 2009).*

Employment Agreement between Nasdaq and Adena Friedman, made and entered into on November 14, 2016
and effective as of January 1, 2017 (incorporated herein by reference to Exhibit 10.10 to the Annual Report on
Form 10-K for the year ended December 31, 2016 filed on March 1, 2017).*

10.10

10.10.1

10.11

10.12

58

 
 
 
 
 
 
 
 
Nonqualified Stock Option Award Certificate to Adena T. Friedman from Nasdaq, Inc. in connection with grant 
made on January 3, 2017 (incorporated herein by reference to Exhibit 10.1 to the Quarterly Report on Form 10-
Q for the quarter ended September 30, 2017 filed on November 7, 2017).*

Employment Offer Letter, dated as of May 10, 2016, between Nasdaq, Inc. and Michael Ptasznik (incorporated 
herein by reference to Exhibit 10.2 to the Quarterly Report on Form 10-Q for the quarter ended March 31, 2017 
filed on May 10, 2017).*

Employment Agreement between Nasdaq and Bradley J. Peterson, dated August 1, 2016 (incorporated herein by 
reference to Exhibit 10.1 to the Quarterly Report on Form 10-Q for the quarter ended September 30, 2016 filed 
on November 8, 2016).*

Employment Offer Letter, dated as of April 30, 2019, between Nasdaq, Inc. and Lauren B. Dillard 
(incorporated herein by reference to Exhibit 10.6 to the Quarterly Report on Form 10-Q for the quarter ended 
June 30, 2019 filed on August 5, 2019).*

Nasdaq Change in Control Severance Plan for Executive Vice Presidents and Senior Vice Presidents, effective 
November 26, 2013 (incorporated herein by reference to Exhibit 10.1 to the Current Report on Form 8-K filed 
on November 29, 2013).*

Credit Agreement, dated as of April 25, 2017, among Nasdaq, Inc., the various lenders from time to time party
thereto, Bank of America, N.A., as administrative agent and an issuing bank, and the other financial institutions
party thereto (incorporated herein by reference to Exhibit 10.1 to the Current Report on Form 8-K filed on
April 26, 2017).

Form  of  Commercial  Paper  Dealer Agreement between  Nasdaq,  Inc.,  as  Issuer, and  the  Dealer  party  thereto 
(incorporated herein by reference to Exhibit 10.3 to the Current Report on Form 8-K filed on April 26, 2017).

Statement regarding computation of per share earnings (incorporated herein by reference from Note 14 to the 
consolidated financial statements under Part II, Item 8 of this Form 10-K).

  List of all subsidiaries.

  Consent of Ernst & Young LLP.

  Powers of Attorney.

Certification of President and Chief Executive Officer pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 
(“Sarbanes-Oxley”).

Certification of Executive Vice President, Corporate Strategy and Chief Financial Officer pursuant to Section 302 
of Sarbanes-Oxley.

Certifications Pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of Sarbanes-Oxley.

The following materials from the Nasdaq, Inc. Annual Report on Form 10-K for the year ended December 31, 
2019, formatted in iXBRL (Inline eXtensible Business Reporting Language): (i) Consolidated Balance Sheets as 
of  December  31,  2019  and  December  31,  2018;  (ii)  Consolidated  Statements  of  Income  for  the  years  ended 
December 31, 2019, 2018 and 2017; (iii) Consolidated Statements of Comprehensive Income for the years ended 
December 31, 2019, 2018 and 2017; (iv) Consolidated Statements of Changes in Stockholders' Equity for the 
years ended December 31, 2019, 2018 and 2017; (v) Consolidated Statements of Cash Flows for the years ended 
December 31, 2019, 2018 and 2017; and (vi) notes to consolidated financial statements.

Cover Page Interactive Data File, formatted in iXBRL and contained in Exhibit 101.

10.13

10.14

10.15

10.16

10.17

10.18

10.19

11

21.1

23.1

24.1

31.1

31.2

32.1

101

104

____________
*  Management contract or compensatory plan or arrangement.

†   Schedules have been omitted pursuant to Item 601(b)(2) of Regulation S-K. 

(b)   Exhibits:

See Item 15(a)(3) above.

(c)   Financial Statement Schedules:

All schedules are omitted because they are not applicable or the required information is included in the consolidated 
financial statements or notes.

Item 16. Form 10-K Summary

None.

59

 
 
 
 
 
 
 
 
Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this 
report to be signed on its behalf by the undersigned, thereunto duly authorized, on February 25, 2020.

SIGNATURES

Nasdaq, Inc.
(Registrant)

By:

Name:

Title:

/s/ Adena T. Friedman
Adena T. Friedman

President and Chief Executive Officer

Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following 
persons on behalf of the registrant and in the capacities indicated as of February 25, 2020.

Name

Title

/s/ Adena T. Friedman
Adena T. Friedman

President and Chief Executive Officer and Director
(Principal Executive Officer)

/s/ Michael Ptasznik
Michael Ptasznik

/s/ Ann M. Dennison
Ann M. Dennison

*
Michael R. Splinter

*
Melissa M. Arnoldi

*
Charlene T. Begley

*
Steven D. Black

*
Essa Kazim

*
Thomas A. Kloet

*
John D. Rainey

*
Jacob Wallenberg

*
Lars R. Wedenborn

*
Alfred W. Zollar

  Executive Vice President, Corporate Strategy and Chief Financial Officer

  (Principal Financial Officer)

  Senior Vice President and Controller

  (Principal Accounting Officer)

  Chairman of the Board

  Director

  Director

  Director

  Director

  Director

  Director

  Director

  Director

Director

* Pursuant to Power of Attorney  

By:

/s/ John A. Zecca
John A. Zecca
Attorney-in-Fact

60

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Nasdaq, Inc.

INDEX TO CONSOLIDATED FINANCIAL STATEMENTS

The following consolidated financial statements of Nasdaq, Inc. and its subsidiaries are presented herein on the page indicated:

Report of Independent Registered Public Accounting Firm 
Consolidated Balance Sheets
Consolidated Statements of Income
Consolidated Statements of Comprehensive Income
Consolidated Statements of Changes in Stockholders' Equity
Consolidated Statements of Cash Flows
Notes to Consolidated Financial Statements

F-2
F-4
F-5
F-6
F-7
F-8
F-9

F-1

 
Report of Independent Registered Public Accounting Firm

To the Shareholders and the Board of Directors of Nasdaq, Inc.

Opinion on the Financial Statements
We have audited the accompanying consolidated balance sheets of Nasdaq, Inc. (the Company) as of December 31, 2019 and 
2018, the related consolidated statements of income, comprehensive income, changes in stockholders’ equity and cash flows for 
each of the three years in the period ended December 31, 2019 and the related notes (collectively referred to as the “consolidated 
financial statements”). In our opinion, the consolidated financial statements present fairly, in all material respects, the financial 
position of the Company at December 31, 2019 and 2018, and the results of its operations and its cash flows for each of the three 
years in the period ended December 31, 2019, in conformity with U.S. generally accepted accounting principles.

We  also  have  audited,  in  accordance  with  the  standards  of  the  Public  Company Accounting  Oversight  Board  (United  States) 
(PCAOB), the Company's internal control over financial reporting as of December 31, 2019, based on criteria established in Internal 
Control-Integrated  Framework  issued  by  the  Committee  of  Sponsoring  Organizations  of  the  Treadway  Commission  (2013 
framework), and our report dated February 25, 2020 expressed an unqualified opinion thereon. 

Adoption of ASU No. 2016-02
As discussed in Note 2 to the consolidated financial statements, the Company changed its method of accounting for Leases in 
2019 due to the adoption of ASU No. 2016-02, Leases (Topic 842). 

Basis for Opinion
These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the 
Company’s financial statements based on our audits. We are a public accounting firm registered with the PCAOB and are required 
to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and 
regulations of the Securities and Exchange Commission and the PCAOB. 

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the 
audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error 
or fraud. Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether 
due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, 
evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting 
principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial 
statements. We believe that our audits provide a reasonable basis for our opinion. 

Critical Audit Matter
The critical audit matter communicated below is a matter arising from the current period audit of the financial statements that was 
communicated or required to be communicated to the audit committee and that: (1) relates to accounts or disclosures that are 
material  to  the  financial  statements  and  (2)  involved  our  especially  challenging,  subjective  or  complex  judgments.  The 
communication of the critical audit matter does not alter in any way our opinion on the consolidated financial statements, taken 
as a whole, and we are not, by communicating the critical audit matter below, providing a separate opinion on the critical audit 
matter or on the accounts or disclosures to which it relates.

F-2

 
 
 
Description of
the Matter

Market Technology Revenue Recognition
As described in Notes 3 and 9 to the consolidated financial statements, the Company enters into long-term 
market technology contracts with customers to develop customized technology solutions, license the right to 
use  software,  and  provide  support  and  other  services  which  results  in  these  contracts  containing  multiple 
performance obligations. The Company recorded market technology deferred revenue of $66 million as of 
December 31, 2019 and recognized $338 million in revenue for the year ended December 31, 2019. The Company 
allocates the contract transaction price to each performance obligation using their best estimate of the standalone 
selling price of each distinct good or service in the respective market technology contract. In instances where 
standalone selling price is not directly observable, such as when a product or service is not sold separately, the 
Company  determines  the  standalone  selling  price  predominantly  through  an  expected  cost  plus  a  margin 
approach. The Company recognizes revenue over time using costs incurred to date relative to total estimated 
costs at completion to measure progress toward satisfying the performance obligation. Auditing the Company’s 
calculation of the standalone selling price and timing of revenue recognition was complex and involved a high 
degree of subjective auditor judgment because of the significant management judgment required to develop 
the estimates. The standalone selling price is based on an estimate of total project costs, ongoing monitoring 
of completion of performance obligations and establishing margins for goods or services where a standalone 
selling price is not directly observable.

How We
Addressed the
Matter in Our
Audit

We obtained an understanding, evaluated the design and tested the operating effectiveness of controls over the 
Company's processes with respect to estimates that impact the timing and measurement of revenue recognition. 
For example, we tested controls over the allocation of contract transaction price to performance obligations, 
including management’s review of the estimated margin used when applying the cost plus an estimated margin 
to determine the standalone selling price. We also evaluated the design and tested the operating effectiveness 
of controls over the completeness and accuracy of the data utilized to measure the estimate and recognize the 
revenue in the appropriate period.

We  performed  substantive  audit  procedures  that  included,  among  other  things,  evaluating  the  significant 
assumptions  and  the  accuracy  and  completeness  of  the  underlying  data  used  in  management’s  calculation. 
Specifically,  we  inspected  certain  customer  contracts,  including  contract  modifications,  and  tested 
management’s determination of the standalone selling price and its allocation to performance obligations in 
accordance with the cost plus a margin approach, including comparing the margin assumptions to actual margins 
earned on completed contracts. We also tested the accuracy of the revenue recognized in the current period by 
inspecting reports relating to the hours recorded on a project. We evaluated the adequacy of the Company’s 
disclosures  in  notes  3  and  9  to  the  consolidated financial statements  related to  market  technology revenue 
recognition.

We have served as the Company’s auditor since 1986. 

New York, New York
February 25, 2020

F-3

Nasdaq, Inc. 
Consolidated Balance Sheets
(in millions, except share and par value amounts)

December 31, 2019

December 31, 2018

Assets
Current assets:

Cash and cash equivalents
Restricted cash
Financial investments
Receivables, net
Default funds and margin deposits
Other current assets

Total current assets
Property and equipment, net
Goodwill
Intangible assets, net
Operating lease assets
Other non-current assets
Total assets
Liabilities
Current liabilities:

Accounts payable and accrued expenses
Section 31 fees payable to SEC
Accrued personnel costs
Deferred revenue
Other current liabilities
Default funds and margin deposits
Short-term debt
Total current liabilities
Long-term debt
Deferred tax liabilities, net
Operating lease liabilities
Other non-current liabilities
Total liabilities
Commitments and contingencies
Equity
Nasdaq stockholders’ equity:

Common stock, $0.01 par value, 300,000,000 shares authorized, shares issued:
171,075,011 at December 31, 2019 and 170,709,425 at December 31, 2018; shares
outstanding: 165,094,440 at December 31, 2019 and 165,165,104 at December 31, 2018

Additional paid-in capital

Common stock in treasury, at cost: 5,980,571 shares at December 31, 2019 and
5,544,321 shares at December 31, 2018
Accumulated other comprehensive loss
Retained earnings

Total Nasdaq stockholders’ equity

Total liabilities and equity

See accompanying notes to consolidated financial statements.

F-4

$

$

$

$

$

$

332
30
291
422
2,996
219
4,290
384
6,366
2,249
346
289
13,924

148
132
188
211
161
2,996
391
4,227
2,996
552
331
179
8,285

2

2,632

(336)
(1,686)
5,027
5,639

$

13,924

$

545
41
268
384
4,742
390
6,370
376
6,363
2,300
—
291
15,700

198
109
199
194
253
4,742
875
6,570
2,956
501
—
224
10,251

2

2,716

(297)
(1,530)
4,558
5,449
15,700                                             

Nasdaq, Inc.
Consolidated Statements of Income
(in millions, except per share amounts)

Revenues:
Market Services
Corporate Services
Information Services
Market Technology
Other revenues

Total revenues

Transaction-based expenses:
Transaction rebates
Brokerage, clearance and exchange fees
Revenues less transaction-based expenses

Operating expenses:
Compensation and benefits
Professional and contract services
Computer operations and data communications
Occupancy
General, administrative and other
Marketing and advertising
Depreciation and amortization
Regulatory
Merger and strategic initiatives
Restructuring charges

Total operating expenses

Operating income
Interest income
Interest expense
Gain on sale of investment security
Net gain on divestiture of businesses
Other income
Net income from unconsolidated investees
Income before income taxes
Income tax provision
Net income attributable to Nasdaq

Per share information:
Basic earnings per share
Diluted earnings per share
Cash dividends declared per common share

Years Ended December 31,

2019

2018

2017

$

$

$
$
$

2,639
496
779
338
10
4,262

(1,327)
(400)
2,535

707
127
133
97
125
39
190
31
30
39
1,518
1,017
10
(124)
—
27
5
84
1,019
245
774

4.69
4.63
1.85

$

$

$
$
$

$

2,709
487
714
270
97
4,277

2,418
459
588
247
236
3,948

(1,344)
(407)
2,526

(1,158)
(379)
2,411

712
144
127
95
120
37
210
32
21
—
1,498
1,028
10
(150)
118
33
7
18
1,064
606
458

2.77
2.73
1.70

$

$
$
$

670
153
125
94
82
31
188
33
44
—
1,420
991
7
(143)
—
—
2
15
872
143
729

4.38
4.30
1.46

See accompanying notes to consolidated financial statements.

F-5

 
 
 
 
 
 
 
 
 
 
 
 
Nasdaq, Inc.
Consolidated Statements of Comprehensive Income
(in millions)

Net income

Other comprehensive income (loss):

Foreign currency translation gains (losses)
Income tax expense(1)

Foreign currency translation, net

Employee benefit plan adjustment gains (losses)

Employee benefit plan income tax (benefit) expense

Employee benefit plan, net

Total other comprehensive income (loss), net of tax(2)
Comprehensive income attributable to Nasdaq

Years Ended December 31,

2019

2018

2017

$

774

$

458

$

729

(122)
(31)
(153)

(4)
1
(3)

(240)
(11)
(251)

9
(9)
—

(156)
618

$

(251)
207

$

$

214
(96)
118

(2)
1
(1)

117

846

____________
(1) Primarily relates to the tax effect of unrealized gains on Euro denominated notes.
(2) Excludes a reclassification impact of $417 million from accumulated other comprehensive income to retained earnings within 
stockholders' equity in the Consolidated Statements of Changes in Stockholders' Equity for stranded tax effects related to the 
Tax Cuts and Jobs Act.

See accompanying notes to consolidated financial statements.

F-6

 
 
Nasdaq, Inc. 
Consolidated Statements of Changes in Stockholders' Equity
(in millions)

Common stock

Additional paid-in capital
Beginning balance

Share repurchase program
Share-based compensation
Stock option exercises, net
Other issuances of common stock, net

Ending balance

Common stock in Treasury, at Cost
Beginning balance

Other employee stock activity

Ending balance

Accumulated Other Comprehensive Loss
Beginning balance

Other comprehensive income (loss)
Reclassification impact of Tax Reform

Ending balance

Retained Earnings
Beginning balance

Net income
Reclassification impact of Tax Reform

Cash dividends declared per common share

Ending balance

Year Ended December 31,

2019

2018

2017

Shares

165

$

2

Shares

167

$

2

Shares

167

$

2

(2)

1

0

0

0

2,716

(200)

79

2

35

2,632

(297)

(39)

(336)

(1,530)

(156)

—

(1,686)

4,558

774

—

(305)

5,027

(5)

2

0

0

0

3,024

(394)

69

3

14

2,716

(247)

(50)

(297)

(862)

(251)

(417)

(1,530)

3,963

458

417

(280)

4,558

(3)

2

1

0

(1)

3,104

(203)

70

24

29

3,024

(176)

(71)

(247)

(979)

117

—

(862)

3,477

729

—

(243)

3,963

Issuance of Nasdaq common stock related to a prior

acquisition

1

—

1

—

1

—

Total Stockholders' Equity

165

$

5,639

165

$

5,449

167

$

5,880

See accompanying notes to consolidated financial statements.

F-7

Nasdaq, Inc.
Consolidated Statements of Cash Flows
(in millions)

Year Ended December 31,

2019

2018

2017

Cash flows from operating activities:
Net income
Adjustments to reconcile net income to net cash provided by operating activities:

$

774

$

458

$

Depreciation and amortization
Share-based compensation
Deferred income taxes
Reversal of certain Swedish tax benefits
Net gain on divestiture of businesses
Gain on sale of investment security
Non-cash restructuring charges
Net income from unconsolidated investees
Other reconciling items included in net income

Net change in operating assets and liabilities, net of effects of divestiture and acquisitions:

Receivables, net
Other assets
Accounts payable and accrued expenses
Section 31 fees payable to SEC
Accrued personnel costs
Deferred revenue
Other liabilities

Net cash provided by operating activities
Cash flows from investing activities:
Purchases of securities
Proceeds from sales and redemptions of securities
Proceeds from divestiture of businesses, net
Proceeds from sale of investment security
Acquisition of businesses, net of cash and cash equivalents acquired
Purchases of property and equipment
Other investing activities
Net cash provided by (used in) investing activities
Cash flows from financing activities:
Proceeds from (repayments of) commercial paper, net
Repayments of debt obligations
Payment of debt extinguishment cost
Proceeds from issuances of long-term debt, net of issuance costs
Repurchases of common stock
Dividends paid
Proceeds received from employee stock activity and other issuances
Payments related to employee shares withheld for taxes
Net cash used in financing activities
Effect of exchange rate changes on cash and cash equivalents and restricted cash
Net increase (decrease) in cash and cash equivalents and restricted cash
Cash and cash equivalents and restricted cash at beginning of period
Cash and cash equivalents and restricted cash at end of period
Supplemental Disclosure Cash Flow Information
Cash paid for:

Interest
Income taxes, net of refund

190
79
35
—
(27)
—
25
(84)
19

(42)
(173)
(49)
23
(9)
(15)
217
963

(579)
543
132
11
(206)
(127)
(14)
(240)

116
(1,215)
(11)
680
(200)
(305)
37
(39)
(937)
(10)
(224)
586
362

120
205

$

$
$

210
69
301
41
(33)
(118)
—
(18)
15

(35)
(40)
33
(19)
37
7
120
1,028

(421)
374
286
169
(75)
(111)
(26)
196

(205)
(115)
—
—
(394)
(280)
17
(50)
(1,027)
(10)
187
399
586

148
221

$

$
$

$

$
$

See accompanying notes to consolidated financial statements.

729

188
70
7
—
—
—
—
(15)
25

11
(30)
(12)
20
(41)
(29)
(14)
909

(392)
424
—
—
(776)
(144)
(2)
(890)

480
(708)
(9)
648
(203)
(243)
53
(71)
(53)
15
(19)
418
399

129
154

F-8

Nasdaq, Inc.

Notes to Consolidated Financial Statements

1. Organization and Nature of Operations

Nasdaq  is  a  global  technology  company  serving  the  capital 
markets  and  other  industries.  Our  diverse  offerings  of  data, 
analytics, software and services enables clients to optimize and 
execute their business vision with confidence.

We manage, operate and provide our products and services in 
four business segments: Market Services, Corporate Services, 
Information Services and Market Technology.

Market Services

Our Market Services segment includes our Equity Derivative 
Trading and Clearing, Cash Equity Trading, FICC and Trade 
Management  Services  businesses.  We  operate  multiple 
exchanges and other marketplace facilities across several asset 
classes, including derivatives, commodities, cash equity, debt, 
structured products and ETPs. In addition, in some countries 
where we operate exchanges, we also provide broker services, 
clearing, settlement and central depository services. In October 
2019, we sold the Nordic Fund Market, an electronic mutual 
fund  service  which  was  a  small  unit  of  our  Broker  Services 
business  and  in  November  2019,  we  sold  NFX’s  futures 
exchange business to a third party which acquired the core assets 
of  NFX,  including  the  portfolio  of  open  interest  in  NFX 
contracts. Customers on the platform are migrating their open 
interest to other exchanges. Also, in January 2020, management 
commenced  an  orderly  wind-down  of  our  broker  services 
operations  business.  We  expect  this  wind-down  to  continue 
through the second quarter of 2021.

Our  transaction-based  platforms  provide  market  participants 
with the ability to access, process, display and integrate orders 
and quotes. The platforms allow the routing and execution of 
buy  and  sell  orders  as  well  as  the  reporting  of  transactions, 
providing fee-based revenues.

For further discussion of our Market Services businesses, see 
“Products and Services,” of “Item 1. Business.” 

Corporate Services

Our Corporate Services segment includes our Listing Services 
and Corporate Solutions businesses.

Our Listing Services business includes our U.S. and European 
Listing  Services  businesses.  We  operate  a  variety  of  listing 
platforms around the world to provide multiple global capital 
raising solutions for private and public companies. Our main 
listing markets are The Nasdaq Stock Market and the Nasdaq 
Nordic  and  Nasdaq  Baltic  exchanges. Through  Nasdaq  First 
North, our Nordic and Baltic operations also offer alternative 
marketplaces  for  smaller  companies  and  growth  companies. 
Our  Listing  Services  business  also  includes  NPM,  which 
provides liquidity solutions for private companies and private 
funds.

We are continuing to grow our recently launched U.S. Corporate 
Bond exchange for the listing and trading of corporate bonds. 

F-9

This exchange operates pursuant to The Nasdaq Stock Market 
exchange license and is powered by NFF.

As of December 31, 2019, there were 3,140 total listings on 
The Nasdaq Stock Market, including 412 ETPs. The combined 
market  capitalization  was  approximately  $14.9  trillion.  In 
Europe,  the  Nasdaq  Nordic  and  Nasdaq  Baltic  exchanges, 
together with Nasdaq First North, were home to 1,040 listed 
companies  with  a  combined  market  capitalization  of 
approximately $1.6 trillion.

Our  Corporate  Solutions  business  includes  our  Investor 
Relations Intelligence and Governance Solutions businesses, 
which  serve  both  public  and  private  companies  and 
organizations. Our public company clients can be companies 
listed on our exchanges or other U.S. and global exchanges. We 
help  organizations  enhance  their  ability  to  understand  and 
expand  their  global  shareholder  base  and  improve  corporate 
governance  through  our  suite  of  advanced  technology, 
analytics, and consultative services. In October 2019, Nasdaq 
acquired  CBE,  a  provider  of  corporate  governance  and 
compliance solutions for boards of directors, CEOs, corporate 
secretaries and general counsels. Nasdaq combined CBE with 
its  Nasdaq  Governance  Solutions  business,  which  includes 
board portal and collaboration technology solutions. We expect 
the combination will enhance Nasdaq's position as a leading 
provider  of  technology,  research,  insights  and  consultative 
services  designed  to  advance  governance  excellence  and 
collaboration at organizations worldwide.

For further  discussion of our  Corporate Services businesses, 
see “Products and Services,” of “Item 1. Business.” 

In March 2019, we sold our BWise enterprise governance, risk 
and compliance software platform and in April 2018, we sold 
our  Public  Relations  Solutions  and  Digital  Media  Services 
businesses.  See  Note  4,  “Acquisitions  and  Divestitures,”  for 
further discussion. 

As of December 31, 2018, BWise was classified as held for 
sale.  See  Note  5,  “Assets  and  Liabilities  Held  for  Sale,”  for 
further discussion.

For segment reporting purposes, we have included the revenues 
and expenses of BWise and the Public Relations Solutions and 
Digital  Media  Services  businesses  in  corporate  items. These 
businesses were part of the Corporate Solutions business, within 
our Corporate Services segment, prior to the date of sale. For 
discussion  of  business  segments,  see  Note  20,  “Business 
Segments.”

Information Services

Our Information Services segment includes our Market Data, 
Index and Investment Data & Analytics businesses.

Our Market Data business sells and distributes historical and 
real-time quote and trade information to the sell-side, the buy-
side,  retail  online  brokers,  proprietary  trading  shops,  other 
venues, internet portals and data distributors. Our market data 
products enhance transparency of market activity within our 

exchanges and provide critical information to professional and 
non-professional investors globally. 

Our  Index  business  develops  and  licenses  Nasdaq-branded 
indexes, associated derivatives, and financial products and also 
provides custom calculation services for third-party clients. As 
of December 31, 2019, we had 332 ETPs licensed to Nasdaq’s 
indexes which had $233 billion in AUM.

Our Investment Data & Analytics business is a leading content 
and  analytics  cloud-based  solutions  provider  used  by  asset 
managers,  investment  consultants  and  asset  owners  to  help 
facilitate better investment decisions. 

For further discussion of our Information Services businesses, 
see “Products and Services,” of “Item 1. Business.” 

necessary for a fair statement of the results. These adjustments 
are of a normal recurring nature. All significant intercompany 
accounts  and 
in 
consolidation.

transactions  have  been  eliminated 

Certain prior year amounts have been reclassified to conform 
to the current year presentation.

Use of Estimates

The  preparation  of  consolidated  financial  statements  in 
conformity  with  U.S.  GAAP  requires  management  to  make 
estimates and assumptions that affect the reported amounts and 
the  disclosure  of  contingent  amounts  in  the  consolidated 
financial  statements  and  accompanying  notes. Actual  results 
could differ from those estimates.

Market Technology 

Foreign Currency

Our Market Technology segment is a leading global technology 
solutions  provider  and  partner 
to  exchanges,  clearing 
organizations, central securities depositories, regulators, banks, 
brokers, buy-side firms and corporate businesses. Our Market 
Technology  business  is  the  sales  channel  for  our  complete 
global  offering  to  other  marketplaces.  In  January  2019,  we 
acquired Cinnober, a Swedish financial technology provider to 
brokers, exchanges and clearinghouses worldwide.

and 

settlement, 

surveillance 

Market Technology provides technology solutions for trading, 
clearing, 
information 
dissemination  to  markets  with  wide-ranging  requirements, 
from  the  leading  markets  in  the  U.S.,  Europe  and  Asia  to 
emerging  markets  in  the  Middle  East,  Latin  America,  and 
Africa. Our marketplace solutions can handle a wide array of 
assets, including cash equities, equity derivatives, currencies, 
interest-bearing  securities,  commodities,  energy 
various 
products  and  digital  currencies,  and  are  currently  powering 
more than 100 marketplaces in more than 50 countries. Market 
Technology  also  provides  market  surveillance  services  to 
broker-dealer  firms  worldwide,  as  well  as  risk  management 
solutions.

For further discussion of our Market Technology business, see 
“Products and Services,” of “Item 1. Business.” 

2. Summary of Significant Accounting Policies

Basis of Presentation and Principles of Consolidation

in 
The  consolidated  financial  statements  are  prepared 
accordance  with  U.S.  GAAP  and  include  the  accounts  of 
Nasdaq,  its  wholly-owned  subsidiaries  and  other  entities  in 
which Nasdaq has a controlling financial interest. When we do 
not  have  a  controlling  interest  in  an  entity  but  exercise 
significant influence over the entity’s operating and financial 
policies,  such  investment  is  accounted  for  under  the  equity 
method of accounting. We recognize our share of earnings or 
losses of an equity method investee based on our ownership 
percentage.  See  “Equity  Method  Investments,”  of  Note  7, 
“Investments,”  for  further  discussion  of  our  equity  method 
investments.

The accompanying consolidated financial statements reflect all 
adjustments  which  are,  in  the  opinion  of  management, 

Foreign denominated assets and liabilities are remeasured into 
the functional currency at exchange rates in effect at the balance 
sheet date and recorded through the income statement. Gains 
or  losses  resulting  from  foreign  currency  transactions  are 
remeasured using the rates on the dates on which those elements 
are recognized during the period, and are included in general, 
administrative  and  other  expense 
the  Consolidated 
Statements of Income.

in 

Translation  gains  or  losses  resulting  from  translating  our 
subsidiaries’  financial  statements  from  the  local  functional 
currency to the reporting currency, net of tax, are included in 
accumulated  other  comprehensive  loss  within  stockholders’ 
equity in the Consolidated Balance Sheets. Assets and liabilities 
are  translated  at  the  balance  sheet  date  while  revenues  and 
expenses are translated at the date the transaction occurs or at 
an applicable average rate.

Cash and Cash Equivalents

Cash  and  cash  equivalents  include  all  non-restricted  cash  in 
banks and highly liquid investments with original maturities of 
90  days  or  less  at  the  time  of  purchase.  Such  equivalent 
investments  included  in  cash  and  cash  equivalents  in  the 
Consolidated  Balance  Sheets  were  $135  million  as  of 
December 31, 2019 and $198 million as of December 31, 2018. 
Cash equivalents are carried at cost plus accrued interest, which 
approximates  fair  value  due  to  the  short  maturities  of  these 
investments.

Restricted Cash

Current  restricted  cash,  which  was  $30  million  as  of 
December 31, 2019 and $41 million as of December 31, 2018, 
is restricted from withdrawal due to a contractual or regulatory 
requirement or not available for general use and is classified as 
restricted  cash  in  the  Consolidated  Balance  Sheets.  As  of 
December 31, 2019 and 2018, current restricted cash primarily 
includes  restricted  cash  held  for  our  trading  and  clearing 
businesses.

Receivables, net

Our  receivables  are  concentrated  with  our  member  firms, 
market  data  distributors,  listed  companies  and  corporate 

F-10

solutions  and  market  technology  customers.  Receivables  are 
shown net of a reserve for uncollectible accounts. The reserve 
for bad debts is maintained at a level that management believes 
to  be  sufficient  to  absorb  estimated  losses  in  the  accounts 
receivable portfolio. The reserve is increased by the provision 
for bad debts which is charged against operating results and 
decreased by the amount of charge-offs, net of recoveries. The 
provision for bad debts is included in general, administrative 
and other expense in the Consolidated Statements of Income. 
The  amount  charged  against  operating  results  is  based  on 
several factors including, but not limited to, the length of time 
a receivable is past due and our historical experience with the 
particular  customer.  In  circumstances  where  a  specific 
customer’s inability to meet its financial obligations is known 
(i.e., bankruptcy filings), we record a specific provision for bad 
debts  against  amounts  due  to  reduce  the  receivable  to  the 
amount  we  reasonably  believe  will  be  collected.  Accounts 
receivable are written-off against the reserve for bad debts when 
collection efforts cease. Due to changing economic, business 
and  market  conditions,  we  review  the  reserve  for  bad  debts 
monthly and make changes to the reserve through the provision 
for  bad  debts  as  appropriate.  If  circumstances  change  (i.e., 
higher than expected defaults or an unexpected material adverse 
change in a major customer’s ability to pay), our estimates of 
recoverability could be reduced by a material amount. The total 
reserve netted against receivables in the Consolidated Balance 
Sheets was $9 million as of December 31, 2019, $13 million as 
of December 31, 2018 and $9 million as of December 31, 2017. 
The changes in the balance between periods was immaterial.

Investments

Purchases and sales of investment securities are recognized on 
settlement date.

Financial investments

Financial  investments  are  primarily  comprised  of  short-term 
investments  with  maturities  greater  than  90  days.  These  
investments are bought principally to meet regulatory capital 
requirements  mainly  for  our  clearing  operations  at  Nasdaq 
Clearing. These investments are classified as trading securities 
as they are generally sold in the near term. Changes in fair value 
of  trading  securities  are  included  in  other  income  in  the 
Consolidated  Statements  of  Income.  Debt  securities  that  are 
classified  as  available-for-sale  investment  securities  are 
primarily comprised of commercial paper and are carried at fair 
value with unrealized gains and losses, net of tax, reported in 
accumulated  other  comprehensive  loss  within  stockholders’ 
equity in the Consolidated Balance Sheets. Realized gains and 
losses  on  these  securities  are  included  in  earnings  upon 
disposition  of  the  securities  using  the  specific  identification 
method.  In  addition,  realized  losses  are  recognized  when 
management determines that a decline in value is other than 
temporary, which requires judgment regarding the amount and 
timing of recovery. For financial investments that are classified 
as available-for-sale securities, we also consider the extent to 
which cost exceeds fair value, the duration of that difference, 
management’s  judgment  about  the  issuer’s  current  and 

prospective financial condition, as well as our intent and ability 
to hold the security until recovery of the unrealized losses.

Fair  value  of  both  trading  and  available-for-sale  investment 
securities is generally obtained from third party pricing sources. 
When available, quoted market prices are used to determine fair 
value. If quoted market prices are not available, fair values are 
estimated using pricing models with observable market inputs. 
The inputs to the valuation models vary by the type of security 
being  priced  but  are  typically  benchmark  yields,  reported 
trades,  broker-dealer  quotes,  and  prices  of  similar  assets. 
Pricing  models  generally  do  not  entail  material  subjectivity 
because the methodologies employed use inputs observed from 
active  markets.  See  “Fair  Value  Measurements,”  below  for 
further discussion of fair value measures.

Equity Securities

Investments in equity securities with readily determinable fair 
values (other than those accounted for under the equity method 
or  those  that  result  in  consolidation  of  the  investee)  are 
measured  at  fair  value  and  any  changes  in  fair  value  are 
recognized in other income in the Consolidated Statements of 
Income.

Equity investments without readily determinable fair values are 
accounted for under the measurement alternative, under which 
investments are measured at cost, less any impairment, plus or 
minus  changes  resulting  from  observable  price  changes  in 
orderly transactions for the identical or a similar investment of 
the  same  issuer  on  a  prospective  basis.  We  assess  relevant 
transactions that occur on or before the balance sheet date to 
identify observable price changes, and we  regularly monitor 
these investments to evaluate whether there is an indication that 
the investment is impaired, based on the share price from the 
investee's  latest  financing  round,  the  performance  of  the 
investee in relation to its own operating targets, the investee's 
liquidity and cash position, and general market conditions. If a 
qualitative assessment indicates that the security is impaired, 
Nasdaq will estimate the fair value of the security, and if the 
fair  value  is  less  than  the  carrying  amount  of  the  security, 
recognize  an  impairment  loss  in  net  income  equal  to  the 
difference  in  the  period  the  impairment  occurs.  See  Note  7, 
“Investments,” for further discussion of our equity securities.

For the years ended December 31, 2019, 2018 and 2017, no
material  impairment  charges  were  recorded  on  our  equity 
securities and there were no upward or downward adjustments 
recorded.

Our investments in equity securities are included in other non-
current assets in the Consolidated Balance Sheets, as we intend 
to hold these investments for more than one year. 

Equity Method Investments

In general, the equity method of accounting is used when we 
own 20% to 50% of the outstanding voting stock of a company 
or when we are able to exercise significant influence over the 
operating and financial policies of a company. We have certain 
investments  in  which  we  have  determined  that  we  have 
significant influence and as such account for the investments 

F-11

under the equity method of accounting. We record our pro-rata 
share of earnings or losses each period and record any dividends 
as a reduction in the investment balance. We evaluate our equity 
method investments for other-than-temporary declines in value 
by considering a variety of factors such as the earnings capacity 
of the investment and the fair value of the investment compared 
to its carrying amount. In addition, for investments where the 
market  value  is  readily  determinable,  we  consider  the 
underlying  stock  price.  If  the  estimated  fair  value  of  the 
investment is less than the carrying amount and management 
considers the decline in value to be other than temporary, the 
excess of the carrying amount over the estimated fair value is 
recognized in net income in the period the impairment occurs. 
See Note 7, “Investments,” for further discussion of our equity 
method investments.

No material impairments were recorded to reduce the carrying 
value of our equity method investments in 2019, 2018 or 2017.

Default Funds and Margin Deposits

Nasdaq Clearing members’ cash contributions are included in 
default funds and margin deposits in the Consolidated Balance 
Sheets  as  both  a  current  asset  and  a  current  liability.  These 
balances may fluctuate over time due to changes in the amount 
of deposits required and whether members choose to provide 
cash or non-cash contributions. Non-cash contributions include 
highly rated government debt securities that must meet specific 
criteria approved by Nasdaq Clearing. Non-cash contributions 
are  pledged  assets  that  are  not  recorded  in  the  Consolidated 
Balance  Sheets  as  Nasdaq  Clearing  does  not  take  legal 
ownership of these assets and the risks and rewards remain with 
the clearing members.

Derivative Financial Instruments and Hedging Activities

Non-Designated Derivatives

We use foreign exchange forward contracts to manage foreign 
currency exposure of intercompany loans, accounts receivable, 
accounts payable and other balance sheet items. These contracts 
are not designated as hedges for financial reporting purposes. 
The  change  in  fair  value  of  these  contracts  is  recognized  in 
general, administrative and other expense in the Consolidated 
Statements  of  Income  and  offsets  the  foreign  currency 
exposure.

As of December 31, 2019 and 2018, the fair value amounts of 
our derivative instruments were immaterial.

Net Investment Hedges

Net assets of our foreign subsidiaries are exposed to volatility 
in  foreign  currency  exchange  rates.  We  may  utilize  net 
investment hedges to offset the translation adjustment arising 
from re-measuring our investment in foreign subsidiaries.

Our 2021, 2023, 2029, and 2030 Notes have been designated 
as a hedge of our net investment in certain foreign subsidiaries 
to mitigate the foreign exchange risk associated with certain 
investments  in  these  subsidiaries. Any  increase  or  decrease 
related to the remeasurement of the 2021, 2023, 2029, and 2030 
Notes  into  U.S.  dollars  is  recorded  in  accumulated  other 

comprehensive  loss  within  stockholders’  equity  in  the 
Consolidated Balance Sheets. See “3.875% Senior Unsecured 
Notes Due 2021,” “1.75% Senior Unsecured Notes Due 2023,” 
“1.75%  Senior  Unsecured  Notes  Due  2029,”  and  “0.875%
Senior  Unsecured  Notes  Due  2030,”  of  Note  10,  “Debt 
Obligations,” for further discussion.

Property and Equipment, net

Property  and  equipment,  including  leasehold  improvements, 
are  carried  at  cost  less  accumulated  depreciation  and 
amortization.  Depreciation  and  amortization  are  recognized 
using the straight-line method over the estimated useful lives 
of  the  related  assets,  which  range  from  10  to  40  years  for 
buildings and improvements, 2 to 5 years for data processing 
equipment, and 5 to 10 years for furniture and equipment.

We  develop  systems  solutions  for  both  internal  and  external 
use. Certain costs incurred in connection with developing or 
obtaining  internal  use  software  are  capitalized.  In  addition, 
certain  costs  of  computer  software  to  be  sold,  leased,  or 
otherwise marketed as a separate product or as part of a product 
or  process  are  capitalized  beginning  when  a  product’s 
technological feasibility has been established and ending when 
a  product  is  available  for  general  release.  Technological 
feasibility is established upon completion of a detailed program 
design  or,  in  its  absence,  completion.  Prior  to  reaching 
technological  feasibility,  all  costs  are  charged  to  expense. 
Unamortized capitalized costs are included in data processing 
equipment and software, within property and equipment, net in 
the  Consolidated  Balance  Sheets.  Capitalized  software  costs 
are amortized on a straight-line basis over the estimated useful 
lives of the software, generally 5 to 10 years. Amortization of 
these costs is included in depreciation and amortization expense 
in the Consolidated Statements of Income.

Leasehold improvements are amortized using the straight-line 
method over the shorter of their estimated useful lives or the 
remaining term of the related lease.

See  Note  8,  “Property  and  Equipment,  net,”  for  further 
discussion.

Leases

On January 1, 2019, we adopted ASU 2016-02 and elected the 
optional transition method to initially apply the standard at the 
January 1, 2019 adoption date. As a result, we applied the new 
lease  standard  prospectively  to  our  leases  existing  or 
commencing on or after January 1, 2019. Comparative periods 
presented  were  not  restated  upon  adoption.  Similarly,  new 
disclosures under the standard were made for periods beginning 
January 1, 2019, and not for prior comparative periods. Prior 
periods will continue to be reported under guidance in effect 
prior to January 1, 2019. In addition, we elected the package of 
practical  expedients  permitted  under  the  transition  guidance 
within the standard, which among other things, allowed us to 
not reassess contracts to determine if they contain leases, lease 
classification  and  initial  direct  costs.  Adoption  of  the  new 
standard  resulted  in  the  recording  of  operating  lease  assets 
of $384 million, a lease liability of $425 million, as well as the 
elimination of deferred rent and sublease reserves of $41 million

F-12

as  of  January  1,  2019.  The  standard  did  not  impact  our 
statements of income and had no impact on our cash flows.

At contract inception, we determine whether a contract is or 
contains a lease. As of December 31, 2019, we have operating 
leases which are primarily real estate leases for our U.S. and 
European  headquarters  and  for  general  office  space.  These 
leases  have  varying  lease  terms  with  remaining  maturities 
ranging from 3 months to 17 years. Operating lease balances 
are included in operating lease assets, other current liabilities, 
and  operating  lease  liabilities  in  our  Consolidated  Balance 
Sheets as of December 31, 2019. As of December 31, 2019, we 
do not have any finance leases. 

Operating lease assets represent our right to use an underlying 
asset  for  the  lease  term  and  lease  liabilities  represent  our 
obligation  to  make  lease  payments  arising  from  the  lease. 
Operating  lease  assets  and  liabilities  are  recognized  at 
commencement  date  based  on  the  present  value  of  lease 
payments over the lease term. Since our leases do not provide 
an implicit rate, we use our incremental borrowing rate based 
on the estimated rate of interest for collateralized borrowing 
over a similar term of the lease payments at commencement 
date in determining the present value of lease payments. The 
operating lease asset also includes any lease payments made 
and excludes lease incentives. Our lease terms include options 
to extend or terminate the lease when we are reasonably certain 
that  we  will  exercise  that  option.  Lease  expense  for  lease 
payments is recognized on a straight-line basis over the lease 
term. Certain of our lease agreements include rental payments 
adjusted periodically for inflation based on an index or rate. 
These payments are included in the initial measurement of the 
operating  lease  liability  and  operating  lease  asset.  However, 
rental payments that are based on a change in an index or a rate 
are  considered  variable  lease  payments  and  are  expensed  as 
incurred.

lease  agreements  with 

lease  and  non-lease 
We  have 
components, which are accounted for as a single performance 
obligation to the extent that the timing and pattern of transfer 
are similar for the lease and non-lease components and the lease 
component qualifies as an operating lease. We do not recognize 
lease liabilities and operating lease assets for leases with a term 
of 12 months or less. We recognize these lease payments on a 
straight-line basis over the lease term.

See Note 17, “Leases,” for further discussion.

Goodwill and Indefinite-Lived Intangible Assets

Goodwill represents the excess of purchase price over the value 
assigned  to  the  net  assets,  including  identifiable  intangible 
assets,  of  a  business  acquired.  Goodwill  is  assessed  for 
impairment  annually  in  the  fourth  quarter  of  our  fiscal  year 
using  an  October 1  measurement  date,  or  more  frequently  if 
conditions exist that indicate that the asset may be impaired, 
such  as  changes  in  the  business  climate,  poor  indicators  of 
operating performance or the sale or disposition of a significant 
portion  of  a  reporting  unit.  When  testing  goodwill  for 
impairment, we have the option of first performing a qualitative 
assessment to determine whether it is more likely than not that 

the fair value of a reporting unit is less than its carrying amount 
as  the  basis  to  determine  if  it  is  necessary  to  perform  a 
quantitative  goodwill 
test.  When  assessing 
impairment 
goodwill for impairment, our decision to perform a qualitative 
impairment assessment for a reporting unit in a given year is 
influenced by a number of factors, including but not limited to, 
the size of the reporting unit’s goodwill, the significance of the 
excess  of  the  reporting  unit’s  estimated  fair  value  over  its 
carrying amount at the last quantitative assessment date, and 
the  amount  of  time  in  between  quantitative  fair  value 
assessments.

In performing a qualitative assessment, we consider the extent 
to which unfavorable events or circumstances identified, such 
as  changes  in  economic,  industry  and  market  conditions  or 
company specific events, could affect the comparison of the 
reporting unit’s fair value with its carrying amount. If we choose 
not to complete a qualitative assessment for a given reporting 
unit, or if the initial assessment indicates that it is more likely 
than not that the carrying amount of a reporting unit exceeds 
its estimated fair value, a quantitative test is required.

The quantitative goodwill test consists of two steps:
•  The first step compares the fair value of each reporting unit 
with  its  carrying  amount,  including  goodwill.  If  the 
reporting  unit’s  fair  value  exceeds  its  carrying  amount, 
goodwill is not impaired.
If the fair value of a reporting unit is less than its carrying 
amount, the second step of the goodwill test is performed 
to  measure  the  amount  of  impairment,  if  any.  An 
impairment is equal to the excess of the carrying amount 
of goodwill over its fair value.

• 

On January 1, 2020, we adopted ASU 2017-04. See “Goodwill,” 
of  “Recent Accounting  Pronouncements,”  below  for  further 
discussion.

We  also  evaluate  indefinite-lived  intangible  assets  for 
impairment  annually  in  the  fourth  quarter  of  our  fiscal  year 
using  an  October 1  measurement  date,  or  more  frequently 
whenever events or changes in circumstances indicate that the 
fair value of the asset may be less than its carrying amount.
Such evaluation includes determining the fair value of the asset 
and  comparing  the  fair  value  of  the  asset  with  its  carrying 
amount. If the fair value of the indefinite-lived intangible asset 
is  less  than  its  carrying  amount,  an  impairment  charge  is 
recognized in an amount equal to the difference.

For  indefinite-lived  intangible  assets  impairment  testing,  we 
also have the option to first perform a qualitative assessment to 
determine whether it is more likely than not that the fair value 
of an indefinite-lived intangible asset is less than the carrying 
amount.  If,  after  assessing 
totality  of  events  or 
circumstances, we determine that it is more likely than not that 
the fair value of an indefinite-lived intangible asset is less than 
its carrying amount, then we must perform additional testing 
of  the  asset.  Otherwise,  we  conclude  that  no  impairment  is 
indicated and further testing is not performed.

the 

There  was  no  impairment  of  goodwill  for  the  years  ended 
December 31,  2019,  2018  and  2017  and  there  were  no

F-13

indefinite-lived intangible asset impairment charges in 2019, 
2018 and 2017. Disruptions to our business and events, such as 
extended  economic  weakness  or  unexpected  significant 
declines in operating results of any of our reporting units or 
businesses, may result in goodwill or indefinite-lived intangible 
asset impairment charges in the future.

Valuation of Other Long-Lived Assets

We  review  our  other  long-lived  assets,  such  as  finite-lived 
intangible  assets  and  property  and  equipment,  for  potential 
impairment when there is evidence that events or changes in 
circumstances indicate that the carrying amount of an asset may 
not  be  recoverable.  The  carrying  amount  of  an  asset  is  not 
recoverable if it exceeds the sum of the undiscounted cash flows 
expected to result from the use and eventual disposition of the 
asset. Fair value of finite-lived intangible assets and property 
and equipment is based on various valuation techniques. Any 
required impairment loss is measured as the amount by which 
the carrying amount of the asset exceeds its fair value and is 
recorded as a reduction in the carrying amount of the related 
asset and a charge to operating results. 

We recorded pre-tax, non-cash property and equipment asset 
impairment  charges  of  $24  million  in  2019.  See  Note  8, 
“Property and Equipment, net,” for a discussion of this charge. 
There  were  no  other  material  impairments  of  finite-lived 
intangible assets or property and equipment recorded in 2019, 
2018 or 2017.

listings,  market 
solutions  and 
technology,  corporate 
information  services  contracts.  Deferred  revenue  is  the  only 
significant contract asset or liability as of December 31, 2019. 
See Note 9, “Deferred Revenue,” for our discussion of deferred 
revenue balances, activity, and expected timing of recognition. 
See “Revenue Recognition” below for further descriptions of 
our revenue contracts.

Sales  commissions  earned  by  our  sales  force  are  considered 
incremental and recoverable costs of obtaining a contract with 
a customer. These costs are deferred and amortized on a straight-
line basis over the period of benefit that we have determined to 
be  the  contract  term  or  estimated  service  period.  Sales 
commissions for renewal contracts are deferred and amortized 
on  a  straight-line  basis  over  the  related  contractual  renewal 
period. Amortization expense is included in compensation and 
benefits expense in the Consolidated Statements of Income. The 
balance of deferred costs and related amortization expense are 
not  material  to  our  consolidated  financial  statements.  Sales 
commissions are expensed when incurred if contract durations 
are one year or less. Sales taxes are excluded from transaction 
prices.

Certain judgments and estimates were used in the identification 
and timing of satisfaction of performance obligations and the 
related allocation of transaction price and are discussed below. 
We  believe  that  these  represent  a  faithful  depiction  of  the 
transfer of services to our customers.

Revenue Recognition and Transaction-Based Expenses

Revenue Recognition

Revenue From Contracts With Customers

Our revenue recognition policies under Topic 606 are described 
in the following paragraphs.

Contract Balances

Substantially all of our revenues are considered to be revenues 
from contracts with customers. The related accounts receivable 
balances are recorded in our Consolidated Balance Sheets as 
receivables which is net of allowance for doubtful accounts of 
$9  million  as  of  December 31,  2019  and  $13  million  as  of 
December 31,  2018.  The  changes  in  the  balance  between 
periods  were  immaterial.  We  do  not  have  obligations  for 
warranties, returns or refunds to customers.

For the majority of our contracts with customers, except for our 
market  technology  and  listings  services  contracts,  our 
performance obligations are short-term in nature and there is 
no significant variable consideration.

We  do  not  have  revenues  recognized  from  performance 
obligations  that  were  satisfied  in  prior  periods.  We  do  not 
provide  disclosures  about  transaction  price  allocated  to 
unsatisfied  performance  obligations  if  contract  durations  are 
less than one year. For contract durations that are one-year or 
greater, we do not have a material portion of transaction price 
allocated  to  unsatisfied  performance  obligations  that  are  not 
included  in  deferred  revenue  other  than  for  our  market 
technology contracts which are discussed below under “Market 
Technology.”  Deferred  revenue  primarily  represents  our 
contract  liabilities  related  to  our  fees  for  annual  and  initial 

Our  primary  revenue  contract  classifications  are  described 
below. Although we may discuss additional revenue details in 
our  “Management's  Discussion  and  Analysis  of  Financial 
Condition and Results of Operations,” the categories below best 
represent those that depict similar economic characteristics of 
the nature, amount, timing and uncertainty of our revenues and 
cash flows.

Market Services

Transaction-Based Trading and Clearing

Transaction-based 
includes  equity 
trading  and  clearing 
derivative trading and clearing, cash equity trading and FICC 
revenues. Nasdaq charges transaction fees for trades executed 
on our exchanges, as well as on orders that are routed to and 
executed on other market venues. Nasdaq charges clearing fees 
for contracts cleared with Nasdaq Clearing.

In the U.S., transaction fees are based on trading volumes for 
trades  executed  on  our  U.S.  exchanges  and  in  Europe, 
transaction fees are based on the volume and value of traded 
and cleared contracts. In Canada, transaction fees are based on 
trading volumes for trades executed on our Canadian exchange.

Nasdaq satisfies its performance obligation for trading services 
upon the execution of a customer trade and clearing services 
when a contract is cleared, as trading and clearing transactions 
are substantially complete when they are executed and we have 
no further obligation to the customer at that time. Transaction-
based trading and clearing fees can be variable and are based 
on trade volume tiered discounts. Transaction revenues, as well 

F-14

as  any  tiered  volume  discounts,  are  calculated  and  billed 
monthly in accordance with our published fee schedules. In the 
U.S., we also pay liquidity payments to customers based on our 
published fee schedules. We use these payments to improve the 
liquidity  on  our  markets  and  therefore  recognize  those 
payments as a cost of revenue.

The majority of our FICC trading and clearing customers are 
charged transaction fees, as discussed above, which are based 
on the volume and value of traded and cleared contracts. We 
also enter into annual fixed contracts with customers trading 
U.S. Treasury securities. The customers are charged an annual 
fixed fee which is billed per the agreement, on a monthly or 
quarterly  basis. Revenues  earned  on  fixed  contracts  are 
recognized over time on a ratable basis over the contract period 
beginning on the date that our service is made available to the 
customer since the customer receives and consumes the benefit 
as Nasdaq provides the service.

For U.S. equity derivative trading, we credit a portion of the 
per  share  execution  charge  to  the  market  participant  that 
provides the liquidity. For U.S. cash equity trading, for Nasdaq 
and Nasdaq PSX, we credit a portion of the per share execution 
charge to the market participant that provides the liquidity and 
for Nasdaq BX, we credit a portion of the per share execution 
charge  to  the  market  participant  that  takes  the  liquidity.  We 
record these credits as transaction rebates that are included in 
transaction-based expense in the Consolidated Statements of 
Income. These transaction rebates are paid on a monthly basis 
and  the  amounts  due  are  included  in  accounts  payable  and 
accrued expenses in the Consolidated Balance Sheets.

In the U.S., we pay Section 31 fees to the SEC for supervision 
and regulation of securities markets. We pass these costs along 
to  our  customers  through  our  equity  derivative  trading  and 
clearing fees and our cash equity trading fees. We collect the 
fees  as  a  pass-through  charge  from  organizations  executing 
eligible trades on our options exchanges and our cash equity 
platforms and we recognize these amounts in transaction-based 
expenses when incurred. Section 31 fees received are included 
in cash and cash equivalents in the Consolidated Balance Sheets 
at the time of receipt and, as required by law, the amount due 
to the SEC is remitted semiannually and recorded as Section 
31 fees payable to the SEC in the Consolidated Balance Sheets 
until paid. Since the amount recorded as revenues is equal to 
the amount recorded as transaction-based expenses, there is no 
impact on our revenues less transaction-based expenses. As we 
hold the cash received until payment to the SEC, we earn interest 
income on the related cash balances.

Under our Limitation of Liability Rule and procedures, we may, 
subject to certain caps, provide compensation for losses directly 
resulting from our systems’ actual failure to correctly process 
an order, quote, message or other data into our platform. We do 
not  record  a  liability  for  any  potential  claims  that  may  be 
submitted under the Limitation of Liability Rule unless they 
meet the provisions required in accordance with U.S. GAAP. 
As such, losses arising as a result of the rule are accrued and 
charged to expense only if the loss is probable and estimable.

Trade Management Services

We  provide  market  participants  with  a  wide  variety  of 
alternatives for connecting to and accessing our markets for a 
fee.  We  also  offer  market  participants  colocation  services, 
whereby we charge firms for cabinet space and power to house 
their own equipment and servers within our data centers. These 
participants  are  charged  monthly  fees  for  cabinet  space, 
connectivity and support in accordance with our published fee 
schedules. These fees are recognized on a monthly basis when 
the performance obligation is met. We also earn revenues from 
annual  and  monthly  exchange  membership  and  registration 
fees. Revenues for providing access to our markets, colocation 
services and monthly exchange membership and registration 
fees are recognized on a monthly basis as the service is provided. 
Revenues  from  annual  fees  for  exchange  membership  and 
registration fees are recognized ratably over the following 12-
month  period  since  the  customer  receives  and  consumes  the 
benefit as Nasdaq provides the service. We also offer broker 
services to financial participants in the Nordic market primarily 
offering technology and customized securities administration 
solutions.  Such  services  and  solutions  primarily  consist  of 
flexible  back-office  systems,  which  allow  customers  to 
efficiently  manage  safekeeping,  settlement  and  corporate 
actions and reporting, and include connectivity to exchanges 
and  central  securities  depositories.  Revenues  from  broker 
services are based on a fixed basic fee for administration or 
licensing, maintenance and operations, and an incremental fee 
depending  on  the  number  of  transactions  completed.  Broker 
services revenues are generally billed and recognized monthly. 
As  previously  noted, 
in  January  2020,  management 
commenced  an  orderly  wind-down  of  this  broker  services 
operations  business.  We  expect  this  wind-down  to  continue 
through the second quarter of 2021.

Corporate Services

Listing Services

Listing services revenues primarily include initial listing fees 
and annual renewal fees. Under Topic 606, the initial listing fee 
is  allocated  to  multiple  performance  obligations  including 
initial and subsequent listing services and corporate solutions 
services (when a company qualifies to receive these services 
under  the  applicable  Nasdaq  rule),  as  well  as  a  customer's 
material right to renew the option to list on our exchanges. In 
performing this allocation, the standalone selling price of the 
performance obligations is based on the initial and annual listing 
fees and the standalone selling price of the corporate solutions 
services is based on its market value. All listing fees are billed 
upfront and the identified performance obligations are satisfied 
over time since the customer receives and consumes the benefit 
as Nasdaq provides the listing service. The amount of revenue 
related  to  the  corporate  solutions  services  performance 
obligation is recognized ratably over a two-year period, which 
is  based  on  contract  terms,  with  the  remaining  revenue 
recognized  ratably  over  six  years  which  is  based  on  our 
historical  listing  experience  and  projected  future  listing 
duration.

F-15

In  the  U.S.,  annual  renewal  fees  are  charged  based  on  the 
number of outstanding shares of companies listed in the U.S. 
at the end of the prior year and are recognized ratably over the 
following  12-month  period  since  the  customer  receives  and 
consumes the benefit as Nasdaq provides the service. European 
annual renewal fees, which are received from companies listed 
on our Nasdaq Nordic and Nasdaq Baltic exchanges and Nasdaq 
First North, are directly related to the listed companies’ market 
capitalization on a trailing 12-month basis and are recognized 
ratably over the following 12-month period since the customer 
receives  and  consumes  the  benefit  as  Nasdaq  provides  the 
service.

Corporate Solutions

Our  Corporate  Solutions  business  includes  our  Investor 
Relations Intelligence and Governance Solutions businesses, 
which  serve  both  public  and  private  companies  and 
organizations.

As  of  December 31,  2019,  corporate  solutions  revenues 
primarily  include  subscription  and  transaction-based  income 
from  our  investor  relations  intelligence  and  governance 
solutions products and services. Subscription-based revenues 
earned  are  recognized  over  time  on  a  ratable  basis  over  the 
contract period beginning on the date that our service is made 
available  to  the  customer  since  the  customer  receives  and 
consumes the benefit as Nasdaq provides the service. Generally, 
fees  are  billed  in  advance  and  the  contract  provides  for 
automatic  renewal.  As  part  of  subscription  agreements, 
customers can also be charged usage fees based upon actual 
usage of the services provided. Revenues from usage fees are 
recognized at a point in time when the service is provided.

Information Services

Market Data 

Market  data  revenues  are  earned  from  U.S.  and  European 
proprietary  market  data  products.  In  the  U.S.,  we  also  earn 
revenues from U.S. shared tape plans.

We  earn  revenues  primarily  based  on  the  number  of  data 
subscribers and distributors of our data. Market data revenues 
are subscription-based and are recognized on a monthly basis. 

For U.S. tape plans, revenues are collected monthly based on 
published fee schedules and distributed quarterly to the U.S. 
exchanges  based  on  a  formula  required  by  Regulation  NMS 
that  takes  into  account  both  trading  and  quoting  activity. 
Revenues are presented on a net basis as we are acting as an 
agent in this arrangement.

Market Data Revenue Sharing

The  most  significant  component  of  market  data  revenues 
recorded on a net basis is the UTP Plan revenue sharing in the 
U.S. All indicators of principal versus agent reporting under 
U.S. GAAP have been considered in analyzing the appropriate 
presentation of the revenue sharing. However, the following are 
the primary indicators of net reporting:

•  We are the administrator for the plan, in addition to being 
a participant in the plan. In our unique role as administrator, 

we facilitate the collection and dissemination of revenues 
on behalf of the plan participants. As a participant, we share 
in the net distribution of revenues according to the plan on 
the same terms as all other plan participants.

•  The operating committee of the plan, which is comprised 
of representatives from each of the participants, including 
us solely in our capacity as a plan participant, is responsible 
for setting the level of fees to be paid by distributors and 
subscribers  and  taking  action  in  accordance  with  the 
provisions of the plan, subject to SEC approval.

•  Risk of loss on the revenue is shared equally among plan 

participants according to the plan.

The exchanges that comprise Nasdaq Nordic and Nasdaq Baltic 
do  not  have  any  material  market  data  revenue  sharing 
agreements.

Index

We develop and license Nasdaq branded indexes, associated 
derivatives and financial products as part of our Global Index 
Family.  We  also  provide  index  data  products  and  custom 
calculation services for third-party clients. Revenues primarily 
include  license  fees  from  these  branded  indexes,  associated 
derivatives and financial products in the U.S. and abroad. We 
primarily have two types of license agreements: transaction-
based  licenses  and  asset-based  licenses. Transaction-based 
licenses  are  generally  renewable  agreements. Customers  are 
charged based on transaction volume or a minimum contract 
amount, or both. If a customer is charged based on transaction 
volume, we recognize revenue when the transaction occurs. If 
a customer is charged based on a minimum contract amount, 
we recognize revenue on a pro-rata basis over the licensing term 
since the customer receives and consumes the benefit as Nasdaq 
provides  the  service. Asset-based  licenses  are  also  generally 
renewable  agreements. Customers  are  charged  based  on  a 
percentage of AUM for licensed products, per the agreement, 
on a monthly or quarterly basis. These revenues are recognized 
over  the  term  of  the  license  agreement  since  the  customer 
receives  and  consumes  the  benefit  as  Nasdaq  provides  the 
service. Revenue from index data subscriptions are recognized 
on a monthly basis.

Investment Data & Analytics

Investment  data  &  analytics  revenues  are  earned  from 
investment content and analytics products. We earn revenues 
primarily  based  on  the  number  of  content  and  analytics 
subscribers and distributors.

Subscription agreements are generally annual in term, payable 
in advance, and provide for automatic renewal. Subscription-
based revenues are recognized over time on a ratable basis over 
the  contract  period  beginning  on  the  date  that  our  service  is 
made available to the customer since the customer receives and 
consumes the benefit as Nasdaq provides the service.

Market Technology

Market Technology provides technology solutions for trading, 
clearing, 
information 
dissemination, as well as risk management solutions. Revenues 

surveillance 

settlement, 

and 

F-16

primarily  consist  of  software,  license  and  support  revenues, 
change request revenues, and SaaS revenues.

In our Market Technology business, we enter into long-term 
contracts  with  customers  to  develop  customized  technology 
solutions, license the right to use software, and provide support 
and  other  services  to  our  customers.  We  also  enter  into 
agreements to modify the system solutions sold by Nasdaq after 
delivery has occurred. In addition, we enter into subscription 
agreements which allow customers to connect to our servers to 
access our software.

Our long-term contracts with customers to develop customized 
technology  solutions,  license  the  right  to  use  software  and 
provide  support  and  other  services  to  our  customers  have 
multiple performance obligations. The performance obligations 
are generally: (i) software license and installation service and 
(ii)  software  support. We  have  determined  that  the  software 
license and installation service are not distinct as the license 
and the customized installation service are inputs to produce 
the  combined  output,  a  functional  and  integrated  software 
system.

For  contracts  with  multiple  performance  obligations,  we 
allocate  the  contract  transaction  price  to  each  performance 
obligation using our best estimate of the standalone selling price 
of  each distinct good  or  service in  the  contract. In instances 
where standalone selling price is not directly observable, such 
as when we do not sell the product or service separately, we 
determine the standalone selling price predominantly through 
an expected cost plus a margin approach.

Contract modifications are routine in the performance of our 
contracts. Contracts are often modified to account for changes 
in contract specifications or requirements. In most instances, 
contract modifications are for goods and services that are not 
distinct, and, therefore, are accounted for as part of the existing 
contract.

For  our  long-term  contracts,  payments  are  generally  made 
throughout  the  contract  life  and  can  be  dependent  on  either 
reaching certain milestones or paid upfront in advance of the 
service  period  depending  on  the  stage  of  the  contract.  For 
subscription  agreements,  contract  payment  terms  can  be 
quarterly,  annually  or  monthly,  in  advance.  For  all  other 
contracts, payment terms vary.

We  generally  recognize  revenue  over  time  as  our  customers 
simultaneously receive and consume the benefits provided by 
our performance because our customer controls the asset for 
which we are creating, our performance does not create an asset 
with  alternative  use,  and  we  have  a  right  to  payment  for 
performance  completed  to  date.  For  these  services,  we 
recognize revenue over time using costs incurred to date relative 
to  total  estimated  costs  at  completion  to  measure  progress 
toward satisfying our performance obligation. Incurred costs 
represent  work  performed,  which  corresponds  with,  and 
thereby depicts, the transfer of control to the customer. Contract 
costs generally include labor and direct overhead. For software 
support and update services, and for subscription agreements 
which allow customers to connect to our servers to access our 

software,  we  generally  recognize  revenue  ratably  over  the 
service  period  beginning  on  the  date  our  service  is  made 
available  to  the  customer  since  the  customer  receives  and 
consumes the benefit consistently over the period as Nasdaq 
provides the services.

Accounting  for  our  long-term  contracts  requires  judgment 
relative to assessing risks and their impact on the estimate of 
revenues and costs. Our estimates are impacted by factors such 
as the potential for schedule and technical issues, productivity, 
and the complexity of work performed. When adjustments in 
estimated total contract costs are required, any changes in the 
estimated revenues from prior estimates are recognized in the 
current period for the effect of such change. If estimates of total 
costs  to  be  incurred  on  a  contract  exceed  estimates  of  total 
revenues,  a  provision  for  the  entire  estimated  loss  on  the 
contract is recorded in the period in which the loss is determined.

Other Revenues

Other revenues include the revenues from the BWise enterprise 
governance, risk and compliance software platform, which was 
sold  in  March  2019  and  revenues  from  the  Public  Relations 
Solutions and Digital Media Services businesses which were 
sold in April 2018. Prior to the sale dates, these revenues were 
included  in  our  Corporate  Solutions  business  and  were  both 
subscription and transaction-based revenues.

Earnings Per Share

We  present  both  basic  and  diluted  earnings  per  share.  Basic 
earnings  per  share  is  computed  by  dividing  net  income 
attributable  to  Nasdaq  by  the  weighted-average  number  of 
common shares outstanding for the period. Diluted earnings per 
share is computed by dividing net income attributable to Nasdaq 
by  the  weighted-average  number  of  common  shares  and 
common share equivalents outstanding during the period and 
reflects the assumed conversion of all dilutive securities, which 
primarily consist of employee stock options, restricted stock, 
and PSUs. Common share equivalents are excluded from the 
computation  in  periods  for  which  they  have  an  anti-dilutive 
effect. Stock options for which the exercise price exceeds the 
average  market  price  over  the  period  are  anti-dilutive  and, 
accordingly, are excluded from the calculation. PSUs, which 
are  considered  contingently  issuable,  are  included  in  the 
computation  of  dilutive  earnings  per  share  on  a  weighted 
average  basis  when  management  determines  the  applicable 
performance criteria would have been met if the performance 
period ended as of the date of the relevant computation. See 
Note 14, “Earnings Per Share,” for further discussion.

Pension and Post-Retirement Benefits

Pension and other post-retirement benefit plan information for 
financial  reporting  purposes  is  developed  using  actuarial 
valuations. We  assess  our  pension  and  other  post-retirement 
benefit plan assumptions on a regular basis. In evaluating these 
assumptions, we consider many factors, including evaluation 
of  the  discount  rate,  expected  rate  of  return  on  plan  assets, 
mortality  rate,  healthcare  cost  trend  rate,  retirement  age 
assumption, our historical assumptions compared with actual 
results  and  analysis  of  current  market  conditions  and  asset 

F-17

allocations.  See  Note  11,  “Retirement  Plans,”  for  further 
discussion.

Discount  rates  used  for  pension  and  other  post-retirement 
benefit plan calculations are evaluated annually and modified 
to reflect the prevailing market rates at the measurement date 
of a high-quality fixed-income debt instrument portfolio that 
would provide the future cash flows needed to pay the benefits 
included in the benefit obligations as they come due. Actuarial 
assumptions are based upon management’s best estimates and 
judgment.

represents  our 

long-term  assessment  of 

The expected rate of return on plan assets for our U.S. pension 
plans 
return 
expectations which may change based on significant shifts in 
economic and financial market conditions. The long-term rate 
of return on plan assets is derived from return assumptions based 
on  targeted  allocations  for  various  asset  classes.  While  we 
consider  the  pension  plans’  recent  performance  and  other 
economic growth and inflation factors, which are supported by 
long-term  historical  data,  the  return  expectations  for  the 
targeted  asset  categories  represent  a  long-term  prospective 
return.

Share-Based Compensation

Nasdaq uses the fair value method of accounting for share-based 
awards. Share-based awards, or equity awards, include stock 
options,  restricted  stock,  and  PSUs.  The  fair  value  of  stock 
options are estimated using the Black-Scholes option-pricing 
model. The fair value of restricted stock awards and PSUs, other 
than PSUs granted with market conditions, is determined based 
on the grant date closing stock price less the present value of 
future  cash  dividends.  We  estimate  the  fair  value  of  PSUs 
granted with market conditions using a Monte Carlo simulation 
model at the date of grant.

We  generally  recognize  compensation  expense  for  equity 
awards on a straight-line basis over the requisite service period 
of the award, taking into account an estimated forfeiture rate. 
Granted  but  unvested  shares  are  generally  forfeited  upon 
termination of employment.

Excess tax benefits or expense related to employee share-based 
payments,  if  any,  are  recognized  as  income  tax  benefit  or 
expense in the Consolidated Statements of Income when the 
awards vest or are settled.

Nasdaq  also  has  an  ESPP  that  allows  eligible  employees  to 
purchase a limited number of shares of our common stock at 
six-month  intervals,  called  offering  periods,  at  85.0%  of  the 
lower of the fair market value on the first or the last day of each 
offering period. The 15.0% discount given to our employees is 
included  in  compensation  and  benefits  expense  in  the 
Consolidated Statements of Income.

See  Note  12,  “Share-Based  Compensation,”  for  further 
discussion of our share-based compensation plans.

Merger and Strategic Initiatives

We incur incremental direct merger and strategic initiative costs 
relating  to  various  completed  and  potential  acquisitions, 

divestitures,  and  other  strategic  opportunities.  These  costs 
include outside advisor fees, and other external costs directly 
related  to  proposed  or  closed  transactions.  We  also  incur 
integration  costs  primarily  related  to  employee  termination 
costs, and professional services costs incurred relating to the 
integrations. As of December 31, 2019, all planned integrations 
for our 2018 and 2017 acquisitions have been completed. 

Fair Value Measurements

the 

Fair value is defined as the price that would be received from 
selling an asset or paid to transfer a liability, or the exit price, 
in  an  orderly  transaction  between  market  participants  at  the 
measurement  date.  When  determining 
fair  value 
measurements for assets and liabilities required or permitted to 
be either recorded or disclosed at fair value, we consider the 
principal  or  most  advantageous  market  in  which  we  would 
transact,  and  we  also  consider  assumptions  that  market 
participants would use when pricing the asset or liability. Fair 
value  measurement  establishes  a  hierarchy  of  valuation 
techniques  based  on  whether  the  inputs  to  those  valuation 
techniques are observable or unobservable. Observable inputs 
reflect market data obtained from independent sources, while 
unobservable  inputs  reflect  Nasdaq’s  market  assumptions. 
These  two  types  of  inputs  create  the  following  fair  value 
hierarchy:

•  Level 1-Quoted prices for identical instruments in active 

markets.

•  Level  2-Quoted  prices  for  similar  instruments  in  active 
markets; quoted prices for identical or similar instruments 
in  markets  that  are  not  active;  and  model-derived 
valuations  whose 
inputs  are  observable  or  whose 
significant value drivers are observable.

•  Level  3-Instruments  whose  significant  value  drivers  are 

unobservable.

This hierarchy requires the use of observable market data when 
available.

See Note 15, “Fair Value of Financial Instruments,” for further 
discussion.

Tax Matters

We use the asset and liability method to determine income taxes 
on  all  transactions  recorded  in  the  consolidated  financial 
statements. Deferred tax assets (net of valuation allowances) 
and deferred tax liabilities are presented net by jurisdiction as 
either  a  non-current  asset  or  liability  in  our  Consolidated 
Balance  Sheets,  as  appropriate.  Deferred  tax  assets  and 
liabilities  are  determined  based  on  differences  between  the 
financial  statement  carrying  amounts  and  the  tax  basis  of 
existing assets and liabilities (i.e., temporary differences) and 
are measured at the enacted rates that will be in effect when 
these  differences  are  realized.  If  necessary,  a  valuation 
allowance  is  established  to  reduce  deferred  tax  assets  to  the 
amount that is more likely than not to be realized.

In  order  to  recognize  and  measure  our  unrecognized  tax 
benefits, management determines whether a tax position is more 
likely  than  not  to  be  sustained  upon  examination,  including 
resolution of any related appeals or litigation processes, based 

F-18

on the technical merits of the position. Once it is determined 
that a position meets the recognition thresholds, the position is 
measured to determine the amount of benefit to be recognized 
in  the  consolidated  financial  statements.  Interest  and/or 
penalties related to income tax matters are recognized in income 
tax expense.

Assets Held for Sale

We  classify  assets  or  disposal  groups  as  held  for  sale  in  the 
period in which all of the following criteria are met:
•  management commits to a plan to sell; 
• 

the asset or disposal group is available for immediate sale 
in its present condition subject only to terms that are usual 
and customary for sales of such assets or disposal groups; 
an  active  program  to  locate  a  buyer  and  other  actions 
required to complete the plan to sell have been initiated; 
the sale is probable within one year; 
the asset or disposal group is being actively marketed for 
sale at a price that is reasonable in relation to its current 
fair value; and 

• 

• 
• 

• 

it is unlikely that significant changes to the plan will be 
made or that the plan will be withdrawn.

Assets  and  disposal  groups  classified  as  held  for  sale  are 
measured at the lower of their carrying amount or fair value 
less costs to sell. Any loss resulting from this measurement is 
recognized in the period in which the held for sale criteria are 
met. Conversely, gains are not recognized until the date of sale. 
The fair value of an asset less any costs to sell is assessed each 
reporting period it remains classified as held for sale, and any 
change in fair value is reported as an adjustment to the carrying 
value of the asset, except that increases in fair value are limited 
to  prior  decreases  recorded.  Assets  are  not  depreciated  or 
amortized while they are classified as held for sale. See Note 
5, “Assets and Liabilities Held For Sale,” for further discussion 
of our assets held for sale.

Subsequent Events

We have evaluated subsequent events through the issuance date 
of this Annual Report on Form 10-K.

F-19

Recent Accounting Pronouncements

Accounting
Standard
Income Taxes
In December 
2019, the FASB 
issued ASU 
2019-12, 
“Simplifying the 
Accounting for 
Income Taxes.”

Goodwill 
In January 2017, 
the FASB issued 
ASU 2017-04, 
“Simplifying the 
Test for Goodwill 
Impairment.”

Financial 
Instruments - 
Credit Losses
In June 2016, the 
FASB issued 
ASU 2016-13, 
“Measurement of 
Credit Losses on 
Financial 
Instruments.”

Description
This ASU simplifies the accounting for 
income  taxes  by  eliminating  certain 
exceptions  related  to  the  approach  for 
intraperiod 
the 
methodology  for  calculating  income 
taxes  in  an  interim  period,  and  the 
recognition of deferred tax liabilities for 
outside basis differences. It also clarifies 
and  simplifies  other  aspects  of  the 
accounting for income taxes.

allocation, 

tax 

impairment 

This ASU  simplifies  how  an  entity  is 
required to test goodwill for impairment 
and  removes  the  second  step  of  the 
goodwill 
test,  which 
required  a  hypothetical  purchase  price 
allocation if the fair value of a reporting 
unit  is  less  than  its  carrying  amount. 
Goodwill  impairment  will  now  be 
measured using the difference between 
the carrying amount and the fair value 
of  the  reporting  unit  and  the  loss 
recognized should not exceed the total 
amount  of  goodwill  allocated  to  that 
reporting unit. The amendments in this 
ASU should be applied on a prospective 
basis. 

sheet 

off-balance 

This  ASU  changes  the  impairment 
model for certain financial instruments. 
The  new  model  is  a  forward  looking 
expected  loss  model  and  applies  to 
financial assets subject to credit losses 
and  measured  at  amortized  cost  and 
certain 
credit 
exposures. This includes loans, held-to-
maturity 
loan 
commitments, financial guarantees and 
trade receivables. For available-for-sale 
debt  securities  with  unrealized  losses, 
credit losses are measured in a manner 
similar  to  previous  accounting,  except 
losses  are  recognized  as 
that 
allowances rather than reductions in the 
amortized cost of the securities.

securities, 

debt 

the 

Effective Date
January 1,
2021, with
early adoption
permitted in
any annual or
interim period
for which
financial
statements
have not yet
been issued or
made
available for
issuance. We
early adopted
this standard
as of October
1, 2019.

January 1,
2020.

Effect on the Financial Statements or Other Significant
Matters
There was no impact to the financial statements or 
our disclosures as a result of the adoption of this 
standard.

We adopted this standard on January 1, 2020. We 
do  not  anticipate  a  material  impact  on  our 
consolidated  financial  statements  at  the  time  of 
adoption  of  this  new  standard  as  the  carrying 
amounts of our reporting units have been less than 
their  corresponding  fair  values  in  recent  years. 
However,  changes  in  future  projections,  market 
conditions and other factors may cause a change in 
the excess of fair value of our reporting units over 
their corresponding carrying amounts.

January 1,
2020.

We adopted this standard on January 1, 2020 using 
the modified retrospective transition method. We 
recorded an immaterial non-cash cumulative effect 
adjustment  to  retained  earnings  on  our  opening 
consolidated balance sheet as of January 1, 2020.

F-20

3. Revenue From Contracts With Customers

Disaggregation of Revenue

The following tables summarize the disaggregation of revenue by major product and service and by segment for the years ended 
December 31, 2019, 2018 and 2017:

Market Services

Corporate
Services

Information
Services

Market
Technology

Other
Revenues

Consolidated

Year Ended December 31, 2019

$

— $

— $

— $

— $

(in millions)

$

912

$

496

$

779

$

338

$

$

2,535

Market Services

Corporate
Services

Information
Services

Market
Technology

Other
Revenues

Consolidated

Year Ended December 31, 2018

(in millions)

$

— $

— $

— $

— $

Transaction-based trading and clearing, net

$

Trade management services

Listing services

Corporate solutions

Market data

Index

Investment data & analytics

Market technology

Other revenues
Revenues less transaction-based expenses

Transaction-based trading and clearing, net

$

Trade management services

Listing services

Corporate solutions

Market data

Index

Investment data & analytics

Market technology

Other revenues
Revenues less transaction-based expenses

Transaction-based trading and clearing, net

$

Trade management services

Listing services

Corporate solutions

Market data

Index

Investment data & analytics

Market technology

Other revenues
Revenues less transaction-based expenses

621

291

—

—

—

—

—

—

—

666

292

—

—

—

—

—

—

—

590

291

—

—

—

—

—

—

—

—

296

200

—

—

—

—

—

—

—

—

398

223

158

—

—

—

—

—

—

—

—

338

—

—

290

197

—

—

—

—

—

—

—

—

390

206

118

—

—

—

—

—

—

—

—

270

—

—

267

192

—

—

—

—

—

—

—

—

369

171

48

—

—

—

—

—

—

—

—

247

—

—

—

—

—

—

—

—

10

10

—

—

—

—

—

—

—

97

97

—

—

—

—

—

—

—

236

236

$

958

$

487

$

714

$

270

$

$

2,526

Market Services

Corporate
Services

Information
Services

Market
Technology

Other
Revenues

Consolidated

Year Ended December 31, 2017

(in millions)

$

— $

— $

— $

— $

621

291

296

200

398

223

158

338

10

666

292

290

197

390

206

118

270

97

590

291

267

192

369

171

48

247

236

$

881

$

459

$

588

$

247

$

F-21

$

2,411

 
 
 
 
 
 
For the year ended December 31, 2019, approximately 65.1% of Market Services revenues were recognized at a point in time and 
34.9% were recognized over time. For the year ended December 31, 2018, approximately 63.6% of Market Services revenues 
were recognized at a point in time and 36.4% were recognized over time. For the year ended December 31, 2017, approximately 
62.7% Market Services revenues were recognized at a point in time and 37.3% recognized over time. Substantially all revenues 
from the Corporate Services, Information Services and Market Technology segments were recognized over time for the years 
ended December 31, 2019, 2018 and 2017.

* * * * * *

Contract Balances

Substantially all of our revenues are considered to be revenues 
from contracts with customers. The related accounts receivable 
balances are recorded in our Consolidated Balance Sheets as 
receivables which are net of allowance for doubtful accounts 
of $9 million as of December 31, 2019 and $13 million as of 
December 31,  2018.  The  changes  in  the  balance  between 
periods  were  immaterial.  We  do  not  have  obligations  for 
warranties, returns or refunds to customers.

For the majority of our contracts with customers, except for our 
market  technology  and  listings  services  contracts,  our 
performance obligations are short-term in nature and there is 
no significant variable consideration.

We  do  not  have  revenues  recognized  from  performance 
obligations  that  were  satisfied  in  prior  periods.  We  do  not 

provide  disclosures  about  transaction  price  allocated  to 
unsatisfied  performance  obligations  if  contract  durations  are 
less than one year. Excluding our market technology contracts, 
for contract durations that are one-year or greater, materially 
all of the transaction price allocated to unsatisfied performance 
obligations  is  included  in  deferred  revenue.  For  our  market 
technology contracts, the portion of transaction price allocated 
to  unsatisfied  performance  obligations  is  shown  in  the  table 
below.  Deferred  revenue  primarily  represents  our  contract 
liabilities  related  to  our  fees  for  annual  and  initial  listings, 
market  technology,  corporate  solutions  and  information 
services  contracts.  Deferred  revenue  is  the  only  significant 
contract asset or liability as of December 31, 2019. See Note 9, 
“Deferred Revenue,” for our discussion on deferred revenue 
balances, activity, and expected timing of recognition.

Transaction Price Allocated to Remaining Performance Obligations

* * * * * *

As stated above, for contract durations that are one-year or greater, we do not have a material portion of transaction price allocated 
to unsatisfied performance obligations that are not included in deferred revenue other than for our market technology contracts. 
For our market technology contracts, the following table summarizes the amount of the transaction price allocated to performance 
obligations that are unsatisfied as of December 31, 2019: 

2020
2021
2022
2023
2024
2025 and thereafter
Total

(in millions)

320
235
108
74
56
94
887

$

$

Market technology deferred revenue, as discussed in Note 9, “Deferred Revenue,” represents consideration received that is yet to 
be recognized as revenue for unsatisfied performance obligations.

4. Acquisitions and Divestitures

2019 Acquisitions and Divestitures

We completed various acquisitions and divestitures in 2019. The financial results of each transaction are included in our consolidated 
financial statements from the date of each acquisition or divestiture. 

2019 Divestitures

Divestiture of BWise

In March 2019, we sold our BWise enterprise governance, risk and compliance software platform, which was part of our Corporate 
Solutions business within our Corporate Services segment, to SAI Global and recognized a pre-tax gain on the sale of $27 million, 
net of disposal costs ($20 million after tax). The pre-tax gain is included in net gain on divestiture of businesses in the Consolidated 
Statements of Income for the year ended December 31, 2019.

F-22

As of December 31, 2018, the assets and liabilities of BWise were held for sale. See Note 5, “Assets and Liabilities Held For Sale,” 
for further discussion.

Divestiture of Nordic Fund Market

In October 2019, we sold the Nordic Fund Market, an electronic mutual fund service which was a small part of our Broker Services 
business.

2019 Acquisitions

Acquisition of Cinnober 

Cinnober

$

219

$

18

$

(19) $

74

$

146

Purchase
Consideration

Total Net Assets
Acquired

Total Net Deferred
Tax Liability

Acquired
Intangible Assets

Goodwill

(in millions)

In January 2019, we acquired Cinnober, a Swedish financial 
technology provider to brokers, exchanges and clearinghouses 
worldwide  for  $219  million.  Cinnober  is  part  of  our  Market 
Technology segment.

Nasdaq used cash on hand to fund this acquisition. 

The amounts in the table above represent the final allocation of 
the purchase price. The allocation of the purchase price was 
subject to revision during the measurement period, a period not 
to exceed 12 months from the acquisition date. Adjustments to 
the  provisional  values,  which  may  include  tax  and  other 
estimates, during the measurement period are recorded in the 
reporting  period  in  which  the  adjustment  amounts  are 
determined.  In  2019,  we  recorded  a  measurement  period 
adjustment of $4 million which resulted in a decrease to net 
assets acquired and an increase in goodwill and a measurement 
period adjustment of $5 million which resulted in a decrease to 
acquired intangible assets and an increase in goodwill. These 
adjustments  relate  to  new  information  obtained  during  the 
period regarding the acquisition date fair values of an acquired 
equity  investment  and  an  acquired  customer  relationship 
intangible asset. These adjustments did not result in an impact 
to our Consolidated Statements of Income. The allocation of 
the  purchase  price  for  Cinnober  was  finalized  in  December 
2019. 

See  “Intangible  Assets”  below  for  further  discussion  of 
intangible assets acquired in the Cinnober acquisition.

Acquisition of Center for Board Excellence

In  October  2019,  we  acquired  CBE,  a  provider  of  corporate 
governance and compliance solutions for boards of directors, 
CEOs, corporate secretaries and general counsels. CBE is part 
of our Corporate Services segment.

2018 Acquisition and Divestiture

We  completed  an  acquisition  and  a  divestiture  in  2018. 
Financial  results  of  each  transaction  are  included  in  our 
consolidated  financial  statements  from  the  date  of  the 
acquisition or divestiture.

2018 Acquisition

Acquisition of Quandl

In  November  2018,  we  acquired  Quandl,  Inc.,  a  provider  of 
alternative  and  core  financial  data.  Quandl  is  part  of  our 
Information Services segment.

Nasdaq  used  issuances  of  commercial  paper  to  fund  this 
acquisition.

2018 Divestiture

In April  2018,  we  sold  our  Public  Relations  Solutions  and 
Digital  Media  Services  businesses,  which  were  part  of  our 
Corporate  Solutions  business,  to  West  Corporation  and 
recognized a pre-tax net gain on the sale of $33 million, net of 
disposal costs ($14 million after tax), which includes a post-
closing working capital adjustment of $8 million ($5 million
after tax) recorded in September 2018. The total net pre-tax gain 
is  included  in  net  gain  on  divestiture  of  businesses  in  the 
Consolidated Statements of Income for 2018.

Intangible Assets

The  following  table  presents  the  details  of  the  customer 
relationships  intangible  asset  at  the  date  of  acquisition  for 
Cinnober which was the significant acquired intangible asset 
for this acquisition. All acquired intangible assets with finite 
lives are amortized using the straight-line method.

Customer relationships (in millions)

$

Discount rate used

Estimated average useful life

Customer Relationships

67

9.5%

13 years

Customer  relationships  represent  the  non-contractual  and 
contractual relationships with customers. 

Methodology 

Customer relationships were valued using the income approach, 
specifically an excess earnings method. The excess earnings 
method  examines  the  economic  returns  contributed  by  the 
identified tangible and intangible assets of a company, and then 
isolates the excess return that is attributable to the intangible 
asset being valued.

F-23

Discount Rate 

The discount rates used reflect the amount of risk associated 
with the hypothetical cash flows for the customer relationships 
relative to the overall business. In developing a discount rate 
for  the  customer  relationships,  we  estimated  a  weighted-
average cost of capital for the overall business and we employed 
this  rate  when  discounting  the  cash  flows.  The  resulting 
discounted cash flows were then tax-effected at the applicable 
statutory rate.

Receivables, net

Property and equipment, net
Goodwill(1)
Intangible assets, net(2)
Other assets

Total assets held for sale(3)

For our acquisition of Cinnober, a discounted tax amortization 
benefit  was  added  to  the  fair  value  of  the  assets  under  the 
assumption that the customer relationships would be amortized 
for tax purposes over a period of 5 years.

Deferred tax liabilities

Deferred revenue

Other current liabilities

Estimated Useful Life 

Total liabilities held for sale(4)

$

$

$

$

December 31, 2018

(in millions)

13

10

47

16

3

89

4

12

4

20

____________
(1)  The assignment of goodwill was based on the relative fair 
value of the disposal group and the portion of the remaining 
reporting unit.

(2)      Primarily represents customer relationships.
(3)    Included  in  other  current  assets  in  the  Consolidated 

Balance Sheets as of December 31, 2018.

(4) 

Included  in  other  current  liabilities  in  the  Consolidated 
Balance Sheets as of December 31, 2018.

We estimate the useful life based on the historical behavior of 
the customers and a parallel analysis of the customers using the 
excess earnings method.

Pro Forma Results and Acquisition-Related Costs

The  consolidated  financial  statements  for  the  years  ended 
December 31, 2019, 2018 and 2017 include the financial results 
of the above acquisitions from the date of each acquisition. Pro 
forma  financial  results  have  not  been  presented  since  these 
acquisitions  both  individually  and  in  the  aggregate  were  not 
material to our financial results.

Acquisition-related costs for the transactions described above
were  expensed  as  incurred  and  are  included  in  merger  and 
strategic initiatives expense in the Consolidated Statements of 
Income.

5. Assets and Liabilities Held For Sale

In 2018, we decided to sell BWise, our enterprise governance, 
risk and compliance software platform and this business was 
recorded as held for sale as of December 31, 2018. BWise was 
part of our Corporate Solutions business within our Corporate 
Services segment.

We determined that we met all of the criteria to classify the 
assets and liabilities of BWise as held for sale. The disposal of 
BWise did not represent a strategic shift that would have a major 
effect on our operations and financial results and was, therefore, 
not  classified  as  discontinued  operations. As  a  result  of  this 
classification,  the  assets  and  liabilities  of  this  business  were 
recorded at the lower of their carrying amount or fair value less 
costs to sell.

In March 2019, we completed the sale of BWise and recognized 
a pre-tax gain on the sale of $27 million, net of disposal costs 
($20  million  after  tax).  See  “2019  Divestitures,”  of  Note  4, 
“Acquisitions and Divestitures,” for further discussion.

Major Classes of Assets and Liabilities Held For Sale

The  carrying  amounts  of  the  major  classes  of  assets  and 
liabilities that were classified as held for sale at December 31, 
2018 were as follows:

F-24

6. Goodwill and Acquired Intangible Assets

Goodwill

The following table presents the changes in goodwill by business segment during the year ended December 31, 2019:

Market 
Services

Corporate
Services

Information
Services

(in millions)

Market
Technology

Total

Balance at December 31, 2018

$

3,430

$

455

$

2,333

$

Goodwill acquired

Measurement period adjustments

Sale of business

Foreign currency translation adjustment

—

—

(16)

(72)

Balance at December 31, 2019

$

3,342

$

10

—

—
(5)
460

$

—

—

—
(50)
2,283

$

145

137

9

—
(10)
281

$

$

6,363

147

9
(16)
(137)
6,366

The  goodwill  acquired  for  Corporate  Services  shown  above 
relates to our acquisition of CBE and the goodwill acquired for 
Market Technology relates to our acquisition of Cinnober. See 
“2019  Acquisitions,”  of  Note  4,  “Acquisitions  and 
Divestitures,” for further discussion of these acquisitions. As 
of December 31, 2019, the amount of goodwill that is expected 
to be deductible for tax purposes in future periods related to 
Cinnober is $141 million.

For further discussion of the measurement period adjustments 
of $9 million shown above, see “2019 Acquisitions,” of Note 
4,  “Acquisitions  and  Divestitures.”  These  adjustments  are 
included 
in  our  Consolidated  Balance  Sheets  as  of 
December 31, 2019.

The  sale  of  business  relates  to  the  sale  of  the  Nordic  Fund 
Market, which was a small unit of our Broker Services business.

Goodwill represents the excess of purchase price over the value 
assigned  to  the  net  assets,  including  identifiable  intangible 

assets,  of  a  business  acquired.  Goodwill  is  allocated  to  our 
reporting units based on the assignment of the fair values of 
each reporting unit of the acquired company. We test goodwill 
for impairment at the reporting unit level annually, or in interim 
periods  if  certain  events  occur  indicating  that  the  carrying 
amount  may  be  impaired,  such  as  changes  in  the  business 
climate, poor indicators of operating performance or the sale 
or disposition of a significant portion of a reporting unit. There 
was  no  impairment  of  goodwill  for  the  years  ended 
December 31,  2019  and  2018;  however,  events  such  as 
extended  economic  weakness  or  unexpected  significant 
declines in operating results of any of our reporting units or 
businesses may result in goodwill impairment charges in the 
future.

F-25

Acquired Intangible Assets

The following table presents details of our total acquired intangible assets, both finite- and indefinite-lived:

December 31, 2019

December 31, 2018

Gross
Amount

Accumulated
Amortization

(in millions)

Net Amount

Gross
Amount

Accumulated
Amortization

(in millions)

Net Amount

Finite-Lived Intangible Assets

Technology

Customer relationships

Other

Foreign currency translation adjustment

Total finite-lived intangible assets

Indefinite-Lived Intangible Assets

Exchange and clearing registrations

Trade names

Licenses

Foreign currency translation adjustment

Total indefinite-lived intangible assets

Total intangible assets

$

$

$

$

121

52
(198)
1,232

2,750

Amortization expense for acquired finite-lived intangible assets 
was $101 million for the year ended December 31, 2019, $109 
million for the year ended December 31, 2018, and $92 million 
for the year ended December 31, 2017. Amortization expense 
decreased in 2019 primarily due to certain assets becoming fully 
amortized  in  the  fourth  quarter  of  2018,  partially  offset  by 
additional  amortization  expense  associated  with  acquired 
intangible  assets  in  2019.  These  amounts  are  included  in 
depreciation  and  amortization  expense  in  the  Consolidated 
Statements of Income.

The  estimated  future  amortization  expense  (excluding  the 
impact  of  foreign  currency  translation  adjustments  of  $104 
million  as  of  December 31,  2019)  of  acquired  finite-lived 
intangible assets as of December 31, 2019 is as follows:

2020

2021

2022

2023

2024

2025 and thereafter

Total

(in millions)

$

105

104

100

98

97

617

$

1,121

$

63

$

1,596

18
(159)
1,518

$

(19) $
(532)
(5)
55
(501) $

44

$

54

$

1,064

13
(104)
1,017

$

1,532

17
(149)
1,454

$

(15) $
(456)
(2)
64
(409) $

39

1,076

15
(85)
1,045

1,257

$

— $

1,257

$

1,257

$

— $

1,257

121

52
(198)
1,232

2,249

$

$

122

52
(176)
1,255

2,709

—

—

—

$

$

— $
(409) $

122

52
(176)
1,255

2,300

—

—

—

$

$

— $
(501) $

7. Investments

The following table presents the details of our investments:

December 31,
2019

December 31,
2018

(in millions)

291

$

—

291

156

49

$

$

$

259

9

268

135

44

$

$

$

$

Trading securities
Available-for-sale investment

securities

Financial investments

Equity method investments

Equity securities

Financial Investments

Trading Securities 

Trading securities, which are included in financial investments 
in the Consolidated Balance Sheets, are primarily comprised of 
highly  rated  European  government  debt  securities,  time 
deposits and highly rated corporate debt, of which $169 million
as of December 31, 2019 and $166 million as of December 31, 
2018, are assets primarily utilized to meet regulatory capital 
requirements,  mainly  for  our  clearing  operations  at  Nasdaq 
Clearing.

Available-for-Sale Investment Securities

As  of  December 31,  2018,  available-for-sale  investment 
securities, which are included in financial investments in the 
Consolidated  Balance  Sheets,  were  primarily  comprised  of 
commercial  paper. As  of  December 31,  2019  and  2018,  the 

F-26

 
 
 
 
 
 
 
 
 
 
 
 
cumulative unrealized gains and losses on these securities were 
immaterial.

Equity Method Investments

As  of  December 31,  2019  and  2018,  our  equity  method 
investments primarily included our equity interest in OCC. 

The  carrying  amounts  of  our  equity  method  investments  are 
included  in  other  non-current  assets  in  the  Consolidated 
Balance  Sheets.  No  material  impairments  were  recorded  to 
reduce the carrying value of our equity method investments for 
the years ended December 31, 2019, 2018 or 2017. 

Net income recognized from our equity interest in the earnings 
and losses of these equity method investments was $84 million 
for the year ended December 31, 2019, $18 million for the year 
ended December 31, 2018, and $15 million for the year ended 
December 31, 2017. 

The change for the year ended December 31, 2019 compared 
with the same period in 2018 is primarily due to an increase in 
income recognized from our investment in OCC. Following the 
disapproval  of  the  OCC  capital  plan  in  February  2019, 
described  below,  OCC  suspended  customer  rebates  and 
dividends to owners, including the unpaid dividend on 2018 
results which Nasdaq expected to receive in March 2019. We 
were not able to determine the impact of the disapproval of the 
OCC capital plan on OCC's 2018 net income until March 2019, 
when OCC's 2018 financial statements were made available to 
us. As a result, in March 2019, we recognized an additional $36 
million of income relating to our share of OCC's net income for 
the  year  ended  December  31,  2018. We  also  recognized  our 
share of OCC's net income of $48 million for the year ended 
December 31, 2019. 

OCC Capital Plan 

In March 2015, OCC implemented a capital plan under which 
the options exchanges that are OCC’s stockholders contributed 
$150 million of new equity capital to OCC, committed to make 
future  replenishment  capital  contributions  under  certain 
circumstances,  and  received  commitments  regarding  future 
dividend payments and related matters. Nasdaq PHLX and ISE 
each contributed $30 million of new equity capital under the 
OCC capital plan. OCC adopted specific policies with respect 
to  fees,  customer  refunds  and  stockholder  dividends,  which 
envisioned an annual dividend equal to the portion of OCC’s 
after-tax  income  that  exceeded  OCC’s  capital  requirements 
after  payment  of  refunds  to  OCC’s  clearing  members  (such 
refunds were generally 50% of the portion of OCC’s pre-tax 
income that exceeded OCC’s capital requirements). In 2018, 
2017  and  2016,  OCC  disbursed  annual  dividends  under  the 
capital plan and Nasdaq, as the beneficial owner of shares held 
by Nasdaq PHLX and ISE, received $13 million in 2018 and 
$10 million in 2017. 

In  February  2016,  after  the  SEC  approved  the  rule  change 
establishing the OCC capital plan, certain industry participants 
appealed that approval in the U.S. Court of Appeals. In February 
2019,  on  remand  from  the  Court  of  Appeals,  the  SEC 
disapproved the OCC rule change that established the capital 

plan. OCC began a phased return of capital contributed under 
the capital plan, and we received $44 million in February 2019, 
and the remaining $16 million in November 2019. As a result 
of the SEC's disapproval of the rule change, we are also released 
from  any  future  capital  replenishment  obligations  under  the 
2015 capital plan.

Equity Securities 

The carrying amounts of our equity securities are included in 
other non-current assets in the Consolidated Balance Sheets. 
We elected the measurement alternative for primarily all of our 
equity securities as they do not have a readily determinable fair 
value. No material adjustments were made to the carrying value 
of our equity securities during the years ended December 31, 
2019, 2018 and 2017. As of December 31, 2019 and 2018, our 
equity securities represent various strategic investments made 
through  our  corporate  venture  program  and  as  of  December 
2019,  also  include  investments  acquired  through  various 
acquisitions.

In December 2018, we sold our 5.0% ownership interest in LCH 
for $169 million in cash. As a result of the sale, we recognized 
a pre-tax gain of $118 million ($93 million after tax). The gain 
is  included  in  gain  on  sale  of  investment  security  in  the 
Consolidated  Statements  of  Income  for  the  year  ended 
December 31, 2018.

8. Property and Equipment, net

The following table presents our major categories of property 
and equipment, net:

Data processing equipment and

software

Furniture, equipment and leasehold

improvements

Total property and equipment

Less: accumulated depreciation and

amortization

Year Ended December 31,

2019

2018

(in millions)

$

565

$

526

305

870

274

800

(486)

(424)

Total property and equipment, net

$

384

$

376

Depreciation  and  amortization  expense  for  property  and 
equipment was $89 million for the year ended December 31, 
2019, $101 million for the year ended December 31, 2018, and 
$96  million  for  the  year  ended  December 31,  2017.  These 
amounts are included in depreciation and amortization expense 
in the Consolidated Statements of Income.

In 2019, we recorded pre-tax, non-cash property and equipment 
asset impairment charges of $24 million related to capitalized 
software  that  was  retired.  This  charge  is  included  in 
restructuring  charges  in  the  Consolidated  Statements  of 
Income. See Note 21, “Restructuring Charges,” for a discussion 
of our 2019 restructuring plan. There were no other material 
impairments of property and equipment recorded in 2019, 2018 
or 2017. 

F-27

 
 
As of December 31, 2019 and 2018, we did not own any real 
estate properties.

9. Deferred Revenue          

* * * * * *

Deferred revenue represents consideration received that is yet to be recognized as revenue. The changes in our deferred revenue 
during the year ended December 31, 2019 are reflected in the following table: 

Initial Listing
Revenues

Annual
Listings
Revenues

Corporate 
Solutions 
 Revenues

Information
Services
Revenues

Market
Technology
Revenues

(1)

Other

Total

Balance at December 31, 2018

$

66

$

Deferred revenue billed in the current

period, net of recognition

Revenue recognized that was included

in the beginning of the period

Translation adjustment
Balance at December 31, 2019

$

30

(26)
(1)
69

$

4

2

(4)
—
2

$

$

36

41

(36)
—
41

$

(in millions)
$

80

$

75

$

20

$

281

62

(59)
(1)
82

$

34

(40)
(3)
66

9

178

(13)
(2)
14

$

(178)
(7)
274

$

____________
(1)  Primarily includes deferred revenue from listing of additional shares fees. In the U.S., these fees will continue to run-off as 
a result of the implementation of our all-inclusive annual fee. Listing of additional shares fees are included in our Listing 
Services business. 

As of December 31, 2019, we estimate that our deferred revenue will be recognized in the following years:

Fiscal year ended:

2020
2021
2022
2023
2024 and thereafter
Total

Initial Listing
Revenues

Annual
Listings
Revenues

Corporate
Solutions
Revenues

Information
Services
Revenues

Market
Technology
Revenues

(1)

Other

Total

(in millions)

$

$

26
19
11
8
5
69

$

$

2
—
—
—
—
2

$

$

39
2
—
—
—
41

$

$

80
2
—
—
—
82

$

$

54
12
—
—
—
66

$

$

10
3
1
—
—
14

$

$

211
38
12
8
5
274

____________
(1)

  Other  primarily includes  revenues from  U.S.  listing of  additional shares fees  which are  included in  our Listing  Services 

business.

The timing of recognition of our deferred market technology revenues is primarily dependent upon the completion of customization 
and any significant modifications made pursuant to existing market technology contracts. As such, as it relates to market technology 
revenues, the timing represents our best estimate.

F-28

 
 
 
 
10. Debt Obligations

The following table presents the changes in the carrying amount of our debt obligations during the year ended December 31, 2019: 

December 31,
2018

Additions

Payments, 
Accretion
and Other

December 31,
2019

Short-term debt:

Commercial paper

$

Senior unsecured floating rate notes repaid on March 22, 2019
5.55% senior unsecured notes repaid on May 1, 2019(1)
$400 million senior unsecured term loan facility repaid on June

28, 2019 (average interest rate of 4.00% for the period January
1, 2019 through June 28, 2019)

Total short-term debt

Long-term debt:

3.875% senior unsecured notes due June 7, 2021

4.25% senior unsecured notes due June 1, 2024

1.75% senior unsecured notes due May 19, 2023

3.85% senior unsecured notes due June 30, 2026

1.75% senior unsecured notes due March 28, 2029

$1 billion senior unsecured revolving credit facility due April 25,
2022

Total long-term debt

Total debt obligations

(in millions)

$

4,678

$

—

—

—

4,678

—

—

—

—

665

15

680

275

500

599

100

1,474

686

497

682

496

—

(4)
2,357

$

3,831

$

5,358

$

(4,562) $
(500)
(599)

(100)
(5,761)

(15)
—
(14)
1

—

391

—

—

—

391

671

497

668

497

665

(13)
(41)
(5,802) $

(2)
2,996

3,387

____________
(1)  Balance was reclassified to short-term debt as of March 31, 2019.

Commercial Paper Program

Our U.S. dollar commercial paper program is supported by our 
2017 Credit Facility which provides liquidity support for the 
repayment of commercial paper issued through the commercial 
paper program. See “2017 Credit Facility” below for further 
discussion of our 2017 Credit Facility. The effective interest 
rate  of  commercial  paper  issuances  fluctuates  as  short  term 
interest  rates  and  demand  fluctuate. The  fluctuation  of  these 
rates due to market conditions may impact our interest expense.

As of December 31, 2019, commercial paper notes in the table 
above  reflect  the  aggregate  principal  amount,  less  the 
unamortized discount which is being accreted through interest 
expense  over  the  life  of  the  applicable  notes.  The  original 
maturities of these notes range from 17 days to 45 days and as 
of  December 31,  2019,  the  weighted-average  maturity  is  13 
days  with  the  weighted-average  effective  interest  rate  being 
2.05% per annum. 

Senior Unsecured Notes

Our senior unsecured notes were all issued at a discount. As a 
result of the discount, the proceeds received from each issuance 
were  less  than  the  aggregate  principal  amount.  As  of 
December 31, 2019, the amounts in the table above reflect the 
aggregate principal amount, less the unamortized debt discount 
and  the  unamortized  debt  issuance  costs  which  are  being 
accreted through interest expense over the life of the applicable 
notes.  For  our  Euro  denominated  notes,  the  “Payments, 
Accretion  and  Other”  column  also  includes  the  impact  of 

foreign  currency  translation.  Our  senior  unsecured  notes  are 
general unsecured obligations of ours and rank equally with all 
of our existing and future unsubordinated obligations and they 
are  not  guaranteed  by  any  of  our  subsidiaries.  The  senior 
unsecured notes were issued under indentures that, among other 
things,  limit  our  ability  to  consolidate,  merge  or  sell  all  or 
substantially all of our assets, create liens, and enter into sale 
and leaseback transactions.

Upon a change of control triggering event (as defined in the 
various note indentures), the terms require us to repurchase all 
or part of each holder’s notes for cash equal to 101% of the 
aggregate principal amount purchased plus accrued and unpaid 
interest, if any.

Senior Unsecured Floating Rate Notes

In  March  2019,  we  used  net  proceeds  from  the  sale  of 
commercial paper and cash on hand and repaid all of our 2019 
Notes.

Nasdaq issued the 2019 Notes in September 2017. The 2019 
Notes paid interest quarterly in arrears at a rate equal to the 
three-month U.S. dollar LIBOR as determined at the beginning 
of each quarterly period plus 0.39% per annum until March 22, 
2019.

Early Extinguishment of 5.55% Senior Unsecured Notes Due 
2020

Nasdaq issued the 2020 Notes in January 2010. The 2020 Notes 
paid interest semiannually at a rate of 5.55% per annum.

F-29

In May 2019, we primarily used the net proceeds from the 2029 
Notes to repay in full and terminate our 2020 Notes. For further 
discussion of the 2029 Notes, see “1.75% Senior Unsecured 
Notes  Due  2029”  below.  In  connection  with  the  early 
extinguishment of the 2020 Notes, we recorded a charge of $11 
million, which primarily included a make-whole redemption 
price  premium.  This  charge 
in  general, 
is 
the  Consolidated 
administrative  and  other  expense 
Statements of Income for the year ended December 31, 2019.

included 
in 

3.875% Senior Unsecured Notes Due 2021

In February 2020, we issued a redemption notice to redeem all 
€600  million  aggregate  principal  amount  outstanding  of  our 
2021 Notes, in accordance with the redemption provisions in 
the indenture governing the 2021 Notes. Upon completion of 
the redemption, no 2021 Notes will remain outstanding.

Nasdaq issued the 2021 Notes in June 2013. The 2021 Notes 
pay interest annually at a rate of 3.875% per annum. 

Nasdaq will primarily use the net proceeds from the sale of the 
2030  Notes  to  redeem  the  2021  Notes  and  for  other  general 
corporate purposes. For further discussion of the 2030 Notes, 
see “0.875% Senior Unsecured Notes Due 2030” below.

The  2021  Notes  were  designated  as  a  hedge  of  our  net 
investment in certain foreign subsidiaries to mitigate the foreign 
exchange  risk  associated  with  certain  investments  in  these 
subsidiaries. The decrease in the carrying amount of $15 million 
noted in the “Payments, Accretion and Other” column in the 
table above primarily reflects the translation of the 2021 Notes 
into  U.S.  dollars  and  is  recorded  in  accumulated  other 
comprehensive 
the 
Consolidated Balance Sheets as of December 31, 2019.

loss  within  stockholders’  equity in 

4.25% Senior Unsecured Notes Due 2024

In May 2014, Nasdaq issued the 2024 Notes. The 2024 Notes 
pay interest semiannually at a rate of 4.25% per annum until 
June 1, 2024 and such rate may vary with Nasdaq’s debt rating 
up to a rate not to exceed 6.25%. 

1.75% Senior Unsecured Notes Due 2023

In May 2016, Nasdaq issued the 2023 Notes. The 2023 Notes 
pay interest annually at a rate of 1.75% per annum until May 19, 
2023 and such rate may vary with Nasdaq’s debt rating up to a 
rate not to exceed 3.75%. 

The 2023 Notes have been designated as a hedge of our net 
investment in certain foreign subsidiaries to mitigate the foreign 
exchange rate risk associated with certain investments in these 
subsidiaries. The decrease in the carrying amount of $14 million 
noted in the “Payments, Accretion and Other” column in the 
table above primarily reflects the translation of the 2023 Notes 
into  U.S.  dollars  and  is  recorded  in  accumulated  other 
comprehensive  loss  within  stockholders’  equity  in  the 
Consolidated Balance Sheets as of December 31, 2019.

3.85% Senior Unsecured Notes Due 2026

In June 2016, Nasdaq issued the 2026 Notes. The 2026 Notes 
pay interest semiannually at a rate of 3.85% per annum until 

June 30, 2026 and such rate may vary with Nasdaq’s debt rating 
up to a rate not to exceed 5.85%.

1.75% Senior Unsecured Notes Due 2029

In April 2019, Nasdaq issued the 2029 Notes. The 2029 Notes 
pay interest annually in arrears, beginning on March 28, 2020 
at a rate of 1.75% per annum until March 28, 2029 and such 
rate may vary with Nasdaq’s debt rating up to a rate not to exceed 
3.75%. The 2029 Notes may be redeemed by Nasdaq at any 
time, subject to a make-whole amount. The proceeds from the 
2029  Notes,  approximately  $665  million  after  deducting  the 
underwriting  discount  and  expenses  of  the  offering,  were 
primarily used to redeem the 2020 Notes. For further discussion 
of the 2020 Notes, see “Early Extinguishment of 5.55% Senior 
Unsecured Notes Due 2020” above.

The 2029 Notes have been designated as a hedge of our net 
investment in certain foreign subsidiaries to mitigate the foreign 
exchange  risk  associated  with  certain  investments  in  these 
subsidiaries. The translation impact of the 2029 Notes into U.S. 
dollars was immaterial as of December 31, 2019.

0.875% Senior Unsecured Notes Due 2030

In  February  2020,  Nasdaq  issued  the  2030  Notes. The  2030 
Notes pay interest annually in arrears, beginning on February 
13, 2021 and may be redeemed by Nasdaq at any time, subject 
to a make-whole amount. The proceeds from the 2030 Notes, 
approximately $648 million after deducting the underwriting 
discount and expenses of the offering, will primarily be used to 
redeem  the  2021  Notes  and  for  other  general  corporate 
purposes. For further discussion of the 2021 Notes, see “3.875%
Senior Unsecured Notes Due 2021” above.

The 2030 Notes have been designated as a hedge of our net 
investment in certain foreign subsidiaries to mitigate the foreign 
exchange  risk  associated  with  certain  investments  in  these 
subsidiaries.

Credit Facilities

Early Extinguishment of 2016 Credit Facility

In March 2016, Nasdaq entered into the 2016 Credit Facility. 
Under our 2016 Credit Facility, borrowings bore interest on the 
principal amount outstanding at a variable interest rate based 
on either the LIBOR or the base rate (or other applicable rate 
with  respect  to  non-dollar  borrowings),  plus  an  applicable 
margin that varied with Nasdaq’s debt rating. 

In June 2019, we used proceeds from issuances of commercial 
paper to repay in full and terminate our 2016 Credit Facility.

2017 Credit Facility

In April 2017, Nasdaq entered into the 2017 Credit Facility. The 
2017 Credit Facility consists of a $1 billion five-year revolving 
credit  facility  (with  sublimits  for  non-dollar  borrowings, 
swingline borrowings and letters of credit), which replaced a 
former  credit  facility.  Nasdaq  intends  to  use  funds  available 
under the 2017 Credit Facility for general corporate purposes 
and  to  provide  liquidity  support  for  the  repayment  of 
commercial  paper  issued  through  the  commercial  paper 

F-30

program. Nasdaq is permitted to repay borrowings under our 
2017 Credit Facility at any time in whole or in part, without 
penalty.

As of December 31, 2019, no amounts were outstanding on the 
2017  Credit  Facility.  The  $2  million  balance  represents 
unamortized  debt  issuance  costs  which  are  being  accreted 
through interest expense over the life of the credit facility. Of 
the  $1  billion  that  is  available  for  borrowing,  $392  million 
provides liquidity support for the commercial paper program 
and for a letter of credit. As such, as of December 31, 2019, the 
total remaining amount available under the 2017 Credit Facility 
was  $608  million  excluding  the  amounts  that  support  the 
commercial  paper  program  and 
letter  of  credit.  See 
“Commercial Paper Program” above for further discussion of 
our commercial paper program.

Under our 2017 Credit Facility, borrowings under the revolving 
credit  facility  and  swingline  borrowings  bear  interest  on  the 
principal amount outstanding at a variable interest rate based 
on either the LIBOR or the base rate (as defined in the credit 
agreement) (or other applicable rate with respect to non-dollar 
borrowings),  plus  an  applicable  margin  that  varies  with 
Nasdaq’s  debt  rating.  We  are  charged  commitment  fees  of 
0.125% to 0.4%, depending on our credit rating, whether or not 
amounts  have  been  borrowed.  These  commitment  fees  are 
included in interest expense and were not material for both the 
years ended December 31, 2019 and 2018.

The  2017  Credit  Facility  contains  financial  and  operating 
covenants.  Financial  covenants  include  a  minimum  interest 
expense  coverage  ratio  and  a  maximum  leverage  ratio. 
Operating covenants include, among other things, limitations 
on Nasdaq’s ability to incur additional indebtedness, grant liens 
on  assets,  dispose  of  assets  and  make  certain  restricted 
payments.  The  facility  also  contains  customary  affirmative 
covenants, including access to financial statements, notice of 
defaults  and  certain  other  material  events,  maintenance  of 
properties and insurance, and events of default, including cross-
defaults to our material indebtedness. 

The  2017  Credit  Facility  includes  an  option  for  Nasdaq  to 
increase the available aggregate amount by up to $500 million, 
subject to the consent of the lenders funding the increase and 
certain other conditions.

Other Credit Facilities

We also have credit facilities primarily related to our Nasdaq 
Clearing operations in order to provide further liquidity. These 
credit  facilities,  which  are  available  in  multiple  currencies, 
totaled $203 million as of December 31, 2019 and $234 million 
as of December 31, 2018 in available liquidity, of which $15 
million was utilized as of December 31, 2019 and none of which 
was utilized as of December 31, 2018.

Debt Covenants

As  of  December 31,  2019,  we  were  in  compliance  with  the 
covenants of all of our debt obligations.

Transition from LIBOR

Nasdaq is currently evaluating the impact of the transition from 
LIBOR  as  an  interest  rate  benchmark  to  other  potential 
alternative  reference  rates.  Currently,  Nasdaq  has  debt 
instruments in place that reference LIBOR-based rates. As of 
December 31, 2019, we do not have material risk exposure to 
LIBOR  through  our  outstanding  debt  instruments.  The 
transition from LIBOR is estimated to take place in 2021 and 
Nasdaq will continue to actively assess the related opportunities 
and risks involved in this transition.

11. Retirement Plans

Defined Contribution Savings Plan

We sponsor a 401(k) Plan for U.S. employees. Employees are 
immediately eligible to make contributions to the plan and are 
also eligible for an employer contribution match at an amount 
equal  to  100.0%  of  the  first  6.0%  of  eligible  employee 
contributions. Savings plan expense included in compensation 
and benefits expense in the Consolidated Statements of Income 
was $13 million for the year ended December 31, 2019, $14 
million for the year ended December 31, 2018, and $13 million
for the year ended December 31, 2017.

Pension and Supplemental Executive Retirement Plans

We maintain non-contributory, defined-benefit pension plans, 
non-qualified  SERPs  for  certain  senior  executives  and  other 
post-retirement benefit plans for eligible employees in the U.S., 
collectively  referred  to  as  the  Nasdaq  Benefit  Plans.  Our 
pension plans and SERPs are frozen. Future service and salary 
for all participants do not count toward an accrual of benefits 
under the pension plans and SERPs. Most employees outside 
the U.S. are covered by local retirement plans or by applicable 
social laws. Benefits under social laws are generally expensed 
in the periods in which the costs are incurred. The total expense 
for these plans is included in compensation and benefits expense 
in the Consolidated Statements of Income and was $20 million
for the year ended December 31, 2019, $22 million for the year 
ended December 31, 2018, and $21 million for the year ended 
December 31, 2017.

Nasdaq  recognizes  the  funded  status  of  the  Nasdaq  Benefit 
Plans, measured as the difference between the fair value of the 
plan  assets  and  the  benefit  obligation,  in  the  Consolidated 
Balance  Sheets.  The  fair  value  of  our  U.S.  defined-benefit 
pension plans' assets was $110 million as of December 31, 2019 
and  $94  million  as  of  December  31,  2018  and  the  benefit 
obligation was $110 million as of December 31, 2019 and $94 
million as of December 31, 2018. As a result, the U.S. defined-
benefit pension plans are fully funded as of December 31, 2019 
and 2018. During 2019, we did not make any contributions to 
our  U.S.  defined-benefit  pension  plans  and  contributed  $22 
million in 2018. For our SERP and other post-retirement benefit 
plans,  the  net  underfunded  liability  was  $33  million  as  of 
December 31, 2019 and $28 million as of December 31, 2018. 
The  underfunded  liability  for  the  above  plans  is  included  in 
accrued personnel costs and other non-current liabilities in the 
Consolidated Balance Sheets. The plan assets of the Nasdaq 
Benefit  Plans  are  invested  per  target  allocations  adopted  by 

F-31

Nasdaq’s  Pension  and  401(k)  Committee  and  are  primarily 
invested in collective fund investments that have underlying 
investments  in  fixed  income  securities.  The  collective  fund 
investments are valued at net asset value which is a practical 
expedient to estimate fair value.

Accumulated Other Comprehensive Loss

As of December 31, 2019, accumulated other comprehensive
loss for the Nasdaq Benefit Plans was $25 million reflecting an 
unrecognized  net  loss  of  $32  million,  partially  offset  by  an 
income tax benefit of $7 million, primarily due to our pension
plans.

Estimated Future Benefit Payments

We  expect  to  make  the  following  benefit  payments  to 
participants in the next ten fiscal years under the Nasdaq Benefit 
Plans:

In addition to the above, we recorded excess tax benefits of $5 
million in 2019, $9 million in 2018 and $40 million in 2017. 
The benefit was included in income tax expense.

Common Shares Available Under Our Equity Plan

As of December 31, 2019, we had approximately 10.4 million
shares of common stock authorized for future issuance under 
our Equity Plan.

Restricted Stock

We grant restricted stock to most active employees. The grant 
date fair value of restricted stock awards is based on the closing 
stock price at the date of grant less the present value of future 
cash dividends. Restricted stock awards granted generally vest 
25.0% on the second anniversary of the grant date, 25.0% on 
the third anniversary of the grant date, and 50.0% on the fourth 
anniversary of the grant date. 

Pension

SERP

Post-
retirement

Total

Summary of Restricted Stock Activity

Fiscal Year Ended:

(in millions)

$

— $ 15

The following table summarizes our restricted stock activity for 
the years ended December 31, 2019, 2018 and 2017:

2020

2021

2022

2023

2024

$

$

8

6

7

7

8

2025 through 2029

40

7

2

2

2

2

9

$ 76

$ 24

$

—

—

—

—

1

1

8

9

9

10

50

$ 101

12. Share-Based Compensation

We have a share-based compensation program for employees 
and non-employee directors. Share-based awards granted under 
this program include stock options, restricted stock (consisting 
of restricted stock units), and PSUs. For accounting purposes, 
we consider PSUs to be a form of restricted stock.

Summary of Share-Based Compensation Expense

Unvested balances at
December 31, 2016

Granted
Vested
Forfeited
Unvested balances at
December 31, 2017

Granted

Vested

Forfeited

Unvested balances at
December 31, 2018

The following table shows the total share-based compensation 
expense resulting from equity awards and the 15.0% discount 
for the ESPP for the years ended December 31, 2019, 2018 and 
2017 in the Consolidated Statements of Income:

Granted

Vested
Forfeited

Restricted Stock

Number of Awards

Weighted-Average
Grant Date Fair
Value

$
2,560,578
$
737,864
(1,102,823) $
(207,119) $

1,988,500

550,544

$

$

(702,832) $

(252,837) $

1,583,375

605,033

$

$

(548,588) $
(153,064) $

45.92
67.48
38.56
52.29

57.34

81.66

48.64

63.86

68.62

85.03

61.45
73.99

Share-based compensation

expense before income taxes

Income tax benefit
Share-based compensation

expense after income taxes

Year Ended December 31,

2019

2018

2017

(in millions)

$

79

$ 69

$

70

(21)

(19)

(29)

$

58

$ 50

$

41

Unvested balances at
December 31, 2019

1,486,756

$

77.38

As of December 31, 2019, $58 million of total unrecognized 
compensation cost related to restricted stock is expected to be 
recognized over a weighted-average period of 1.7 years.

PSUs

PSUs  are  based  on  performance  measures  that  impact  the 
amount of shares that each recipient will receive upon vesting. 
We have two performance-based long-term PSU programs for 
certain officers, a one-year performance-based program and a 
three-year cumulative performance-based program that focuses 
on TSR.

F-32

 
 
 
 
The  following  weighted-average  assumptions  were  used  to 
determine the weighted-average fair values of the PSU awards 
granted under the three-year PSU program:

Weighted-average risk free interest 

rate(1)

Expected volatility(2)
Weighted-average grant date share

price

Weighted-average fair value at grant

date

Year Ended December 31,

2019

2018

2.26%

16.5%

2.36%

18.7%

$89.00

$ 86.24

$97.65

$116.86

____________
(1)  The risk-free interest rate for periods within the expected 
life of the award is based on the U.S. Treasury yield curve 
in effect at the time of grant.

(2)  We use historic volatility for PSU awards issued under the 
three-year PSU program, as implied volatility data could 
not be obtained for all the companies in the peer groups 
used  for  relative  performance  measurement  within  the 
program.

In  addition,  the  annual  dividend  assumption  utilized  in  the 
Monte Carlo simulation model is based on Nasdaq’s dividend 
yield at the date of grant.

One-Year PSU Program

The  grant  date  fair  value  of  PSUs  under  the  one-year 
performance-based program is based on the closing stock price 
at  the  date  of  grant  less  the  present  value  of  future  cash 
dividends. Under this program, an eligible employee receives 
a target grant of PSUs, but may receive from 0.0% to 150.0% 
of the target amount granted, depending on the achievement of 
performance measures. These awards vest ratably on an annual 
basis over a three-year period commencing with the end of the 
one-year performance period. Compensation cost is recognized 
over the performance period and the three-year vesting period 
based on the probability that such performance measures will 
be achieved, taking into account an estimated forfeiture rate. 

During  2019,  grants  of  PSUs  with  a  one-year  performance 
period exceeded the applicable performance parameters. As a 
result, an additional 26,780 units above the original target were 
granted in the first quarter of 2020. 

Three-Year PSU Program

Under the three-year performance-based program, each eligible 
individual receives PSUs, subject to market conditions, with a 
three-year cumulative performance period that vest at the end 
of the performance period. Compensation cost is recognized 
over the three-year performance period, taking into account an 
estimated  forfeiture  rate,  regardless  of  whether  the  market 
condition is satisfied, provided that the requisite service period 
has  been  completed.  Performance  will  be  determined  by 
comparing Nasdaq’s TSR to two peer groups, each weighted 
50.0%. The first peer group consists of exchange companies, 
and the second peer group consists of all companies in the S&P 
500.  Nasdaq’s  relative  performance  ranking  against  each  of 
these groups will determine the final number of shares delivered 
to each individual under the program. The payout under this 
program will be between 0.0% and 200.0% of the number of 
PSUs  granted  and  will  be  determined  by  Nasdaq’s  overall 
performance against both peer groups. However, if Nasdaq’s 
TSR  is  negative  for  the  three-year  performance  period, 
regardless of TSR ranking, the payout will not exceed 100.0% 
of the number of PSUs granted. We estimate the fair value of 
PSUs  granted  under  the  three-year  PSU  program  using  the 
Monte  Carlo  simulation  model,  as  these  awards  contain  a 
market condition. 

Grants  of  PSUs  that  were  issued  in  2017  with  a  three-year 
performance  period  exceeded  the  applicable  performance 
parameters. As a result, an additional 43,684 units above the 
original target were granted in the first quarter of 2020 and are 
fully vested upon issuance.

F-33

Summary of PSU Activity

The following table summarizes our PSU activity for the years 
ended December 31, 2019, 2018 and 2017:

PSUs

One-Year Program

Three-Year Program

Weighted-
Average
Grant
Date Fair
Value

Number of
Awards

Number of
Awards

Weighted-
Average
Grant
Date Fair
Value

performance goal for 2019 was met, resulting in the settlement 
of 89,606 stock options, the final one-third of the grant. There 
were no stock option awards granted during the years ended 
December 31, 2019 and 2018. 

The weighted-average grant date fair value for the 2017 grant 
was $66.68. We estimated the fair value of this stock option 
award  using  the  Black-Scholes  valuation  model  using  the 
following assumptions:

378,766

$ 52.55

1,314,668   $ 63.18

Expected volatility

Expected life (in years)

Weighted-average risk free interest rate

Dividend yield

6

2.1%

25.6%

1.92%

Unvested

balances at
December
31, 2016
Granted(1)
Vested
Forfeited
Unvested

balances at
December
31, 2017
Granted(1)

Forfeited
Unvested

balances at
December
31, 2018
Granted(1)
Vested

Forfeited
Unvested

balances at
December
31, 2019
____________
(1) 

Vested

(170,257) $ 58.49

(655,204) $ 64.08

197,075
$ 65.51
(202,073) $ 49.93
(40,764) $ 55.92

803,712

$ 55.57
(1,079,925) $ 42.83
(28,497) $ 87.86

333,004

$ 61.39

1,009,958   $ 78.18

177,831

$ 80.97

484,075

$ 90.92

(26,347) $ 61.83

(1,079) $ 81.57

314,231

$ 74.01

837,750

$ 96.57

179,599

$ 83.56

397,553

$ 96.55

(147,984) $ 70.64

(431,751) $ 93.25

(28,595) $ 75.43

(6,101) $103.29

317,251

$ 80.87

797,451

$ 98.31

Includes  target  awards  granted  and  certain  additional 
awards granted based on overachievement of performance 
parameters.

As of December 31, 2019, $11 million of total unrecognized 
compensation  cost  related  to  the  one-year  PSU  program  is 
expected to be recognized over a weighted-average period of 
1.4 years. For the three-year PSU program, $29 million of total 
unrecognized compensation cost is expected to be recognized 
over a weighted-average period of 1.3 years. 

Stock Options 

In January 2017 and in connection with her appointment, our 
CEO received 268,817 performance-based non-qualified stock 
options  which  vested  one-third  annually  over  a  three-year 
period, with each vesting contingent upon the achievement of 
annual performance parameters. Compensation cost equal to 
the grant date fair value is recognized over the vesting period. 
On  February  25,  2020,  Nasdaq's  management  compensation 
committee  and  board  of  directors  determined  that  the 

F-34

Our computation of expected life was based on an estimate of 
the average length of time between option grant and exercise. 
The interest rate for periods within the expected life of the award 
was based on the U.S. Treasury yield curve in effect at the time 
of grant. Our computation of expected volatility was an estimate 
of the future upward/downward fluctuations in the underlying 
share  price.  We  used  Nasdaq's  historical  volatility  for  the 
trailing 6-year period as of the grant date. Our computation of 
dividend yield was based on annualized dividends expressed as 
a percentage of share price. 

Summary of Stock Option Activity

A  summary  of  stock  option  activity  for  the  years  ended 
December 31, 2019, 2018 and 2017 is as follows:

Number of
Stock Options

Weighted-
Average
Exercise
Price

Outstanding at December 31, 2016

1,406,371

$ 22.32

Granted

Exercised

Forfeited

268,817

(1,102,830)

(978)

66.68

21.98

21.33

Outstanding at December 31, 2017

571,380

$ 43.84

Exercised

Forfeited
Outstanding at December 31, 2018

Exercised

Forfeited

(118,094)

24.44

(4,320)
448,966

26.11
$ 49.25

(69,699)

(165)

20.84

25.28

Outstanding at December 31, 2019

379,102

$ 54.32

Exercisable at December 31, 2019

289,496

$ 50.50

We received net cash proceeds of $2 million from the exercise 
of 69,699 stock options for the year ended December 31, 2019, 
received net cash proceeds of $3 million from the exercise of 
118,094 stock options for the year ended December 31, 2018
and received net cash proceeds of $24 million from the exercise 
of 1,102,830 stock options for the year ended December 31, 
2017.

 
 
 
The following table summarizes significant ranges of outstanding and exercisable stock options as of December 31, 2019:

Range of Exercise Prices

$ 18.67 - $ 25.28

$ 66.68

Total

Number of
Stock Options

110,285

268,817

379,102

Outstanding

Exercisable

Weighted-
Average
Remaining
Contractual
Term (in
years)

1.04

7.01

5.27

Weighted-
Average
Exercise
Price

$

$

24.20

66.68

54.32

$

$

Aggregate
Intrinsic
Value (in
millions)

Number of
Stock Options

Weighted-
Average
Remaining
Contractual
Term (in
years)

9

11

20

110,285

179,211

289,496

1.04

7.01

4.73

Weighted-
Average
Exercise
Price

$ 24.20

66.68

$ 50.50

$

$

Aggregate
Intrinsic
Value (in
millions)

9

7

16

The aggregate intrinsic value in the above table represents the total pre-tax intrinsic value (i.e., the difference between our closing 
stock price on December 31, 2019 of $107.10 and the exercise price, times the number of shares), which would have been received 
by the option holders had the option holders exercised their stock options on that date. This amount can change based on the fair 
market value of our common stock. The total number of in-the-money stock options exercisable as of December 31, 2019 was 0.3 
million and the weighted-average exercise price was $50.50. As of December 31, 2018, 0.3 million outstanding stock options were 
exercisable and the weighted-average exercise price was $37.51. 

The total pre-tax intrinsic value of stock options exercised was $6 million during 2019, $7 million during 2018, and $54 million
during 2017. 

* * * * * *

ESPP

We have an ESPP under which approximately 1.7 million shares 
of our common stock have been reserved for future issuance as 
of  December 31,  2019.  Under  our  ESPP,  employees  may 
purchase shares having a value not exceeding 10.0% of their 
annual  compensation,  subject  to  applicable  annual  Internal 
Revenue Service limitations. We record compensation expense 
related to the 15.0% discount that is given to our employees. 
The  following  table  summarizes  employee  activity  and 
expenses  associated  with  the  ESPP  for  the  years  ended 
December 31, 2019, 2018 and 2017.

reduction  to  Nasdaq  stockholders’  equity  and  included  in 
common stock in treasury, at cost in the Consolidated Balance 
Sheets. Shares repurchased under our share repurchase program 
are currently retired and canceled and are therefore not included 
in the common stock in treasury balance. When treasury shares 
are reissued, they are recorded at the average cost of the treasury 
shares acquired. We held 5,980,571 shares of common stock in 
treasury as of December 31, 2019 and 5,544,321 shares as of 
December 31, 2018, most of which are related to shares of our 
common  stock  withheld  for  the  settlement  of  employee  tax 
withholding obligations arising from the vesting of restricted 
stock and PSUs. 

Year Ended December 31,

Share Repurchase Program

As  of  December  31,  2019,  the  aggregate  authorized  amount 
under the existing share repurchase program, which includes 
an additional $500 million authorized by the board in October 
2019, is $632 million.

These purchases may be made from time to time at prevailing 
market prices in open market purchases, privately-negotiated 
transactions,  block  purchase  techniques  or  otherwise,  as 
determined by our management. The purchases are primarily 
funded  from  existing  cash  balances.  The  share  repurchase 
program may be suspended, modified or discontinued at any 
time. The share repurchase program has no defined expiration 
date.

2019

2018

2017

Number of shares

purchased

Weighted-average price of

shares purchased

229,172

205,785

235,859

$ 73.79

$ 66.79

$ 58.26

Compensation expense

$

4

$

3

$

3

13. Nasdaq Stockholders’ Equity

Common Stock

As of December 31, 2019, 300,000,000 shares of our common 
stock  were  authorized,  171,075,011  shares  were  issued  and 
165,094,440 shares were outstanding. The holders of common 
stock are entitled to one vote per share, except that our certificate 
of incorporation limits the ability of any person to vote in excess 
of  5.0%  of  the  then-outstanding  shares  of  Nasdaq  common 
stock.

Common Stock in Treasury, at Cost

We account for the purchase of treasury stock under the cost 
method  with  the  shares  of  stock  repurchased  reflected  as  a 

F-35

The following is a summary of our share repurchase activity, 
reported  based  on  settlement  date,  for  the  year  ended 
December 31, 2019 and 2018:

Number of shares of
common stock
repurchased

Year Ended December 31,

2019

2018

2,053,855

4,508,426

Average price paid per share

Total purchase price (in

millions)

$

$

97.37

200

$

$

87.43

394

As discussed above in “Common Stock in Treasury, at Cost,” 
shares  repurchased  under  our  share  repurchase  program  are 
currently retired and cancelled. 

Other Repurchases of Common Stock

During  the  year  ended  December  31,  2019,  we  repurchased 
436,250 shares of our common stock in settlement of employee 
tax  withholding  obligations  arising  from  the  vesting  of 
restricted stock and PSUs.

Preferred Stock

Our  certificate  of  incorporation  authorizes  the  issuance  of 
30,000,000 shares of preferred stock, par value $0.01 per share, 
issuable  from  time  to  time  in  one  or  more  series.  As  of 
December 31, 2019 and 2018, no shares of preferred stock were 
issued or outstanding.

Cash Dividends on Common Stock

During 2019, our board of directors declared the following cash dividends:

* * * * * *

Declaration Date

Dividend Per
Common 
Share

Record Date

Total Amount Paid

Payment Date

(in millions)

January 29, 2019

April 23, 2019

July 23, 2019

October 22, 2019

$

0.44 March 15, 2019

0.47

June 14, 2019

0.47 September 13, 2019

0.47 December 13, 2019

$

$

73 March 29, 2019

77

June 28, 2019

78 September 27, 2019

77 December 27, 2019
305

The total amount paid of $305 million was recorded in retained earnings in the Consolidated Balance Sheets at December 31, 
2019. 

In January 2020, the board of directors approved a regular quarterly cash dividend of $0.47 per share on our outstanding common 
stock. The dividend is payable on March 27, 2020 to shareholders of record at the close of business on March 13, 2020. The 
estimated amount of this dividend is $78 million. Future declarations of quarterly dividends and the establishment of future record 
and payment dates are subject to approval by the board of directors.

Our board of directors maintains a dividend policy with the intention to provide stockholders with regular and growing dividends 
over the long term as earnings and cash flow grow.

F-36

 
 
 
 
14. Earnings Per Share

The following table sets forth the computation of basic and diluted earnings per share:

Numerator:

Year Ended December 31,

2019

2018

2017

(in millions, except share and per share amounts)

Net income attributable to common shareholders

$

774

$

458

$

729

Denominator:

Weighted-average common shares outstanding for basic earnings per share

164,931,628

165,349,471

166,364,299

Weighted-average effect of dilutive securities:

Employee equity awards(1)
Contingent issuance of common stock(2)

1,679,922

1,988,610

2,861,892

358,611

353,218

358,840

Weighted-average common shares outstanding for diluted earnings per share

166,970,161

167,691,299

169,585,031

Basic and diluted earnings per share:

Basic earnings per share

Diluted earnings per share

$

$

4.69

4.63

$

$

2.77

2.73

$

$

4.38

4.30

____________
(1)  PSUs, which are considered contingently issuable, are included in the computation of dilutive earnings per share on a weighted 
average basis when management determines that the applicable performance criteria would have been met if the performance 
period ended as of the date of the relevant computation.

(2)  See “Non-Cash Contingent Consideration,” of Note 19, “Commitments, Contingencies and Guarantees,” for further discussion.

Securities  that  were  not  included  in  the  computation  of  diluted  earnings  per  share  because  their  effect  was  antidilutive  were 
immaterial for the years ended December 31, 2019, 2018 and 2017.

15. Fair Value of Financial Instruments

The following tables present our financial assets and financial liabilities that are measured at fair value on a recurring basis as of 
December 31, 2019 and 2018.

Assets at Fair Value

Debt securities:

European government

Time deposits

Corporate

State owned enterprises and

municipalities

Swedish mortgage bonds

December 31, 2019

December 31, 2018

Total

Level 1

Level 2

Level 3

Total

Level 1

Level 2

Level 3

(in millions)

(in millions)

$

157

$

157

$ — $ — $

134

$

134

$ — $ —

57

34

24

19

—

—

—

—

57

34

24

19

—

—

—

—

30

41

14

40

—

—

—

—

30

41

14

40

—

—

—

—

Total debt securities

$

291

$

157

$

134

$ — $

259

$

134

$

125

$ —

Available-for-sale investment securities:

Commercial paper

Total assets at fair value

Liabilities at Fair Value

$ — $ — $ — $ — $
$ — $
$
$

157

134

291

$

9
268

$ — $
$
134
$

9
134

$ —
$ —

Other financial instruments

$ — $ — $ — $ — $

Total liabilities at fair value

$ — $ — $ — $ — $

112

112

$ — $

$ — $

112

112

$ —

$ —

F-37

 
 
 
 
Liabilities at Fair Value 

Our Level 2 other financial instruments at December 31, 2018 
liability  associated  with  Nasdaq  Clearing's 
include  a 
requirement to fulfill the settlement of certain contracts of a 
defaulted member. The fair value of this guarantee was $112 
million as of December 31, 2018 and is included in other current 
liabilities  in  the  Consolidated  Balance  Sheets.  Collateral  of 
$112 million as of December 31, 2018 was recorded in other 
current assets which offsets this liability. See Note 16, “Clearing 
Operations,” for further discussion of default fund contributions 
and margin deposits.

Financial  Instruments  Not  Measured  at  Fair  Value  on  a 
Recurring Basis

Some of our financial instruments are not measured at fair value 
on  a  recurring  basis  but  are  recorded  at  amounts  that 
approximate fair value due to their liquid or short-term nature. 
Such financial assets and financial liabilities include: cash and 
cash equivalents, restricted cash, receivables, net, certain other 
current  assets,  accounts  payable  and  accrued  expenses, 
Section 31  fees  payable  to  SEC,  accrued  personnel  costs, 
commercial paper and certain other current liabilities.

Our  investment  in  OCC  is  accounted  for  under  the  equity 
method  of  accounting.  We  have  elected  the  measurement 
alternative  for  the  majority  of  our  equity  securities,  which 
primarily represent various strategic investments made through 
our  corporate  venture  program.  See  “Equity  Method 
Investments,”  and  “Equity  Securities,”  of  Note  7, 
“Investments,” for further discussion.

We  also  consider  our  debt  obligations  to  be  financial 
instruments. The  fair  value  of  our  debt  obligations,  utilizing 
discounted cash flow analyses for our floating rate debt and 
prevailing market rates for our fixed rate debt, was $3.6 billion 
as of December 31, 2019 and $3.9 billion as of December 31, 
2018.  The  discounted  cash  flow  analyses  are  based  on 
borrowing rates currently available to us for debt with similar 
terms and maturities. The fair value of our commercial paper 
approximates the carrying value since the rates of interest on 
this  short-term  debt  approximate  market  rates  as  of 
December 31, 2019. Our commercial paper and our fixed rate 
and floating rate debt are categorized as Level 2 in the fair value 
hierarchy.

For  further  discussion  of  our  debt  obligations,  see  Note 10, 
“Debt Obligations.”

Non-Financial Assets  Measured  at  Fair  Value  on  a  Non-
Recurring Basis

Our non-financial assets, which include goodwill, intangible 
assets, and other long-lived assets, are not required to be carried 
at fair value on a recurring basis. Fair value measures of non-
financial assets are primarily used in the impairment analysis 
of these assets. Any resulting asset impairment would require 
that the non-financial asset be recorded at its fair value. Nasdaq 
uses Level 3 inputs to measure the fair value of the above assets 
on a non-recurring basis. As of December 31, 2019 and 2018, 

there were no non-financial assets measured at fair value on a 
non-recurring basis.

16. Clearing Operations

Nasdaq Clearing

Nasdaq Clearing is authorized and supervised under EMIR as 
a multi-asset clearinghouse by the SFSA. Such authorization is 
effective  for  all  member  states  of  the  European  Union  and 
certain other non-member states that are part of the European 
Economic Area, including Norway. The clearinghouse acts as 
the CCP for exchange and OTC trades in equity derivatives, 
fixed  income  derivatives,  resale  and  repurchase  contracts, 
power derivatives, emission allowance derivatives, and seafood 
derivatives. 

Through our clearing operations in the financial markets, which 
include  the  resale  and  repurchase  market,  the  commodities 
markets, and the seafood market, Nasdaq Clearing is the legal 
counterparty  for,  and  guarantees  the  fulfillment  of,  each 
contract  cleared.  These  contracts  are  not  used  by  Nasdaq 
Clearing for the purpose of trading on its own behalf. As the 
legal counterparty of each transaction, Nasdaq Clearing bears 
the counterparty risk between the purchaser and seller in the 
contract. In its guarantor role, Nasdaq Clearing has precisely 
equal and offsetting claims to and from clearing members on 
opposite sides of each contract, standing as the CCP on every 
contract cleared. In accordance with the rules and regulations 
of  Nasdaq  Clearing,  default  fund  and  margin  collateral 
requirements  are  calculated  for  each  clearing  member’s 
positions  in  accounts  with  the  CCP.  See  “Default  Fund 
Contributions  and  Margin  Deposits”  below  for  further 
discussion  of  Nasdaq Clearing’s  default  fund  and  margin 
requirements.

Nasdaq  Clearing  maintains  four  member  sponsored  default 
funds:  one  related  to  financial  markets,  one  related  to 
commodities markets, one related to the seafood market, and a 
mutualized fund. Under this structure, Nasdaq Clearing and its 
clearing members must contribute to the total regulatory capital 
related  to  the  clearing  operations  of  Nasdaq  Clearing.  This 
structure  applies  an  initial  separation  of  default  fund 
contributions  for  the  financial,  commodities  and  seafood 
markets  in  order  to  create  a  buffer  for  each  market’s 
counterparty risks. Simultaneously, a mutualized default fund 
provides  capital  efficiencies  to  Nasdaq  Clearing’s  members 
with regard to total regulatory capital required. See “Default 
Fund Contributions” below for further discussion of Nasdaq 
Clearing’s  default  fund.  Power  of  assessment  and  a  liability 
waterfall  also  have  been  implemented.  See  “Power  of 
Assessment”  and  “Liability  Waterfall”  below  for  further 
discussion.  These  requirements  align  risk  between  Nasdaq 
Clearing and its clearing members.

Nasdaq Commodities Clearing Default 

In  September  2018,  a  member  of  the  Nasdaq  Clearing 
commodities market defaulted due to inability to post sufficient 
collateral  to  cover  increased  margin  requirements  for  the 
positions of the relevant member, which had experienced losses 
due to sharp adverse movements in the Nordic - German power 

F-38

market spread. Nasdaq Clearing followed default procedures 
and offset the future market risk on the defaulting member’s 
positions. The default resulted in an initial loss of $133 million. 
In accordance with the liability waterfall, the first $8 million of 
the loss was allocated to Nasdaq Clearing’s junior capital and 
the  remainder  was  allocated  on  a  pro-rata  basis  to  the 
commodities clearing members’ default funds. In September 
2018, these funds were replenished.

In December 2018, we initiated a capital relief program. The 
capital relief program was a voluntary program open to each 
commodities  default  fund  participant;  each  such  participant 
who agreed to the capital relief program received a proportion 
of the funds made available under the capital relief program as 
reflected by their proportionate share of the aggregate of the 
clearing  members'  default  fund  replenishments.  As  of 
December 31, 2019, we have disbursed substantially all of the 
$23  million  offered  through  the  program.  In  addition  to  the 
capital relief program, we are pursuing recovery of assets from 
the defaulted member which will be allocated back to default 
fund participants. 

As  a  result  of  the  default,  a  liability  of  $112  million  as  of 
December 31, 2018 was recorded in other current liabilities and 
collateral  of  $112  million  as  of  December 31,  2018  was 
recorded in other current assets in the Consolidated Balance 
Sheets in order to allow Nasdaq Clearing to fulfill the settlement 
of certain contracts of the defaulted member arising from the 
default  management  process.  We  had  established  mitigating 
positions.  As  of  December  31,  2019,  these  contracts  and 
mitigating positions have either expired or were sold to a third 
party  together  with  associated  collateral.  The  collateral  and 
liability were previously included in default funds and margin 
deposits. 

Default Fund Contributions and Margin Deposits

As  of  December 31,  2019,  clearing  member  default  fund 
contributions and margin deposits were as follows:

December 31, 2019

Cash
Contributions

Non-Cash
Contributions

Total
Contributions

(in millions)

Default fund

contributions
Margin deposits

Total

$

$

387

$

183

$

2,609

3,544

570

6,153

2,996

$

3,727

$

6,723

Of the total default fund contributions of $570 million, Nasdaq 
Clearing  can  utilize  $458  million  as  capital  resources  in  the 
event of a counterparty default. The remaining balance of $112 
million pertains to member posted surplus balances.

Our clearinghouse holds material amounts of clearing member 
cash deposits which are held or invested primarily to provide 
security of capital while minimizing credit, market and liquidity 
risks. While we seek to achieve a reasonable rate of return, we 
are  primarily  concerned  with  preservation  of  capital  and 
managing the risks associated with these deposits. 

Clearing member cash contributions are maintained in demand 
deposits held at central banks and large, highly rated financial 
institutions  or  secured  through  direct  investments,  primarily 
central  bank  certificates  and  European  government  debt 
securities with original maturities of 90 days or less, reverse 
repurchase  agreements,  supranationals  and  state  owned 
enterprise  debt  securities.  Investments  in  reverse  repurchase 
agreements are secured with highly rated government securities 
with  maturity  dates  that  range  from  7  days  to  10  days. The 
carrying value of these securities approximates their fair value 
due  to  the  short-term  nature  of  the  instruments  and  reverse 
repurchase agreements.

Nasdaq Clearing has invested the total cash contributions of
$2,996 million as of December 31, 2019 and $4,742 million on 
as of December 31, 2018, in accordance with its investment 
policy as follows: 

December 31,
2019

December 31,
2018

(in millions)

Demand deposits

$

1,328

$

3,094

Central bank certificates

European government debt

securities

Reverse repurchase agreements

Supranationals and state owned
enterprise debt securities

896

508

116

148

1,017

380

166

85

Total

$

2,996

$

4,742

In the investment activity related to default fund and margin 
contributions, we are exposed to counterparty risk related to 
reverse  repurchase  agreement  transactions,  which  reflect  the 
risk that the counterparty might become insolvent and, thus, fail 
to meet its obligations to Nasdaq Clearing. We mitigate this risk 
by only engaging in transactions with high credit quality reverse 
repurchase  agreement  counterparties  and  by  limiting  the 
acceptable collateral under the reverse repurchase agreement 
to  high  quality  issuers,  primarily  government  securities  and 
other  securities  explicitly  guaranteed  by  a  government.  The 
value of the underlying security is monitored during the lifetime 
of  the  contract,  and  in  the  event  the  market  value  of  the 
underlying security falls below the reverse repurchase amount, 
our clearinghouse may require additional collateral or a reset 
of the contract.

Default Fund Contributions

Required contributions to the default funds are proportional to 
the  exposures  of  each  clearing  member.  When  a  clearing 
member is active in more than one market, contributions must 
be made to all markets’ default funds in which the member is 
active. Clearing members’ eligible contributions may include 
cash and non-cash contributions. Cash contributions received 
are held in cash or invested by Nasdaq Clearing, in accordance 
with its investment policy, either in highly rated government 
debt  securities,  time  deposits,  central  bank  certificates  or 
reverse repurchase agreements with highly rated government 
debt  securities  as  collateral.  Nasdaq  Clearing  maintains  and 

F-39

 
 
manages all cash deposits related to margin collateral. All risks 
and rewards of collateral ownership, including interest, belong 
to Nasdaq Clearing. Clearing members’ cash contributions are 
included  in  default  funds  and  margin  deposits  in  the 
Consolidated  Balance  Sheets  as  both  a  current  asset  and  a 
current liability. Non-cash contributions include highly rated 
government  debt  securities  that  must  meet  specific  criteria 
approved  by  Nasdaq  Clearing.  Non-cash  contributions  are 
pledged assets that are not recorded in the Consolidated Balance 
Sheets as  Nasdaq Clearing does not take legal ownership of 
these assets and the risks and rewards remain with the clearing 
members.  These  balances  may  fluctuate  over  time  due  to 
changes  in  the  amount  of  deposits  required  and  whether 
members  choose  to  provide  cash  or  non-cash  contributions. 
Assets  pledged  are  held  at  a  nominee  account  in  Nasdaq 
Clearing’s name for the benefit of the clearing members and 
are immediately accessible by Nasdaq Clearing in the event of 
a  default.  In  addition 
to  clearing  members’  required 
contributions to the liability waterfall, Nasdaq Clearing is also 
required  to  contribute  capital  to  the  liability  waterfall  and 
overall regulatory capital as specified under its clearinghouse 
rules. As of December 31, 2019, Nasdaq Clearing committed 
capital totaling $147 million to the liability waterfall and overall 
regulatory capital, in the form of government debt securities, 
which are recorded as financial investments in the Consolidated 
Balance Sheets. The combined regulatory capital of the clearing 
members  and  Nasdaq  Clearing  is  intended  to  secure  the 
obligations  of  a  clearing  member  exceeding  such  member’s 
own margin and default fund deposits and may be used to cover 
losses sustained by a clearing member in the event of a default.

Margin Deposits

Nasdaq  Clearing  requires  all  clearing  members  to  provide 
collateral,  which  may  consist  of  cash  and  non-cash 
contributions,  to  guarantee  performance  on  the  clearing 
members’ open positions, or initial margin. In addition, clearing 
members must also provide collateral to cover the daily margin 
call  if  needed.  See  “Default  Fund  Contributions”  above  for 
further discussion of cash and non-cash contributions.

Similar  to  default  fund  contributions,  Nasdaq  Clearing 
maintains  and  manages  all  cash  deposits  related  to  margin 
collateral.  All  risks  and  rewards  of  collateral  ownership, 
including interest, belong to Nasdaq Clearing and are recorded 
in revenues. These cash deposits are recorded in default funds 
and margin deposits in the Consolidated Balance Sheets as both 
a current asset and a current liability. Pledged margin collateral 
is not recorded in our Consolidated Balance Sheets as all risks 
and rewards of collateral ownership, including interest, belong 
to  the  counterparty.  Assets  pledged  are  held  at  a  nominee 
account  in  Nasdaq  Clearing’s  name  for  the  benefit  of  the 
clearing members and are immediately accessible by Nasdaq 
Clearing in the event of a default.

Nasdaq Clearing marks to market all outstanding contracts and 
requires payment from clearing members whose positions have 
lost  value.  The  mark-to-market  process  helps  identify  any 
clearing members that may not be able to satisfy their financial 
obligations in a timely manner allowing Nasdaq Clearing the 

ability to mitigate the risk of a clearing member defaulting due 
to exceptionally large losses. In the event of a default, Nasdaq 
Clearing can access the defaulting member’s margin and default 
fund deposits to cover the defaulting member’s losses.

Regulatory Capital and Risk Management Calculations

Nasdaq  Clearing  manages  risk  through  a  comprehensive 
counterparty risk management framework, which is comprised 
of policies, procedures, standards and financial resources. The 
level  of  regulatory  capital  is  determined  in  accordance  with 
Nasdaq Clearing’s regulatory capital policy, as approved by the 
SFSA.  Regulatory  capital  calculations  are  continuously 
updated through a proprietary capital-at-risk calculation model 
that establishes the appropriate level of capital.

As mentioned above, Nasdaq Clearing is the legal counterparty 
for each contract cleared and thereby guarantees the fulfillment 
of each contract. Nasdaq Clearing accounts for this guarantee 
as a performance guarantee. We determine the fair value of the 
performance  guarantee  by  considering  daily  settlement  of 
contracts and other margining and default fund requirements, 
the risk management program, historical evidence of default 
payments,  and  the  estimated  probability  of  potential  default 
payouts. The calculation is determined using proprietary risk 
management software that simulates gains and losses based on 
historical  market  prices,  extreme  but  plausible  market 
scenarios, volatility and other factors present at that point in 
time  for  those  particular  unsettled  contracts.  Based  on  this 
analysis,  excluding  any  liability  related  to  the  Nasdaq 
commodities  clearing  default  (see  discussion  above),  the 
estimated liability was nominal and no liability was recorded 
as of December 31, 2019.

Power of Assessment 

To further strengthen the contingent financial resources of the 
clearinghouse, Nasdaq Clearing has power of assessment that 
provides the ability to collect additional funds from its clearing 
members to cover a defaulting member’s remaining obligations 
up to the limits established under the terms of the clearinghouse 
rules. The power of assessment corresponds to 100.0% of the 
clearing  member’s  aggregate  contribution  to  the  financial, 
commodities and seafood markets’ default funds.

Liability Waterfall

The liability waterfall is the priority order in which the capital 
resources would be utilized in the event of a default where the 
defaulting clearing member’s collateral would not be sufficient 
to cover the cost to settle its portfolio. If a default occurs and 
the  defaulting  clearing  member’s  collateral,  including  cash 
deposits and pledged assets, is depleted, then capital is utilized 
in the following amount and order:

• 

• 

junior  capital  contributed  by  Nasdaq  Clearing,  which 
totaled $34 million as of December 31, 2019;

a loss sharing pool related only to the financial market that 
is contributed to by clearing members and only applies if 
the  defaulting  member’s  portfolio  includes  interest  rate 
swap products;

F-40

• 

• 

specific market default fund where the loss occurred (i.e., 
the  financial,  commodities,  or  seafood  market),  which 
includes capital contributions of the clearing members on 
a pro-rata basis;

senior  capital  contributed  to  each  specific  market  by 
Nasdaq  Clearing,  calculated 
in  accordance  with 
clearinghouse  rules,  which  totaled  $21  million  as  of 
December 31, 2019; and

•  mutualized  default 

includes  capital 
contributions of the clearing members on a pro-rata basis.

fund,  which 

If additional funds are needed after utilization of the liability 
waterfall,  then  Nasdaq  Clearing  will  utilize  its  power  of 
assessment and additional capital contributions will be required 
by non-defaulting members up to the limits established under 
the terms of the clearinghouse rules.

In addition to the capital held to withstand counterparty defaults 
described above, Nasdaq Clearing also has committed capital 
of $92 million to ensure that it can handle an orderly wind-down 
of  its  operation,  and  that  it  is  adequately  protected  against 
investment, operational, legal, and business risks.

Market Value of Derivative Contracts Outstanding 

The  following  table  includes  the  market  value  of  derivative 
contracts outstanding prior to netting:

December 31, 2019

(in millions)

Commodity and seafood options, futures 

and forwards(1)(2)(3)

Fixed-income options and futures(1)(2)
Stock options and futures(1)(2)
Index options and futures(1)(2)
Total

$

$

267

602

114

65

1,048

____________
(1)  We determined the fair value of our option contracts using 
standard  valuation  models  that  were  based  on  market-
based  observable  inputs  including  implied  volatility, 
interest  rates  and  the  spot  price  of  the  underlying 
instrument.

(2)  We determined the fair value of our futures contracts based 
upon  quoted  market  prices  and  average  quoted  market 
yields.

(3)  We determined the fair value of our forward contracts using 
standard  valuation  models  that  were  based  on  market-
based  observable  inputs  including  LIBOR  rates  and  the 
spot price of the underlying instrument.

Derivative Contracts Cleared

The  following  table  includes  the  total  number  of  derivative 
contracts cleared through Nasdaq Clearing for the years ended 
December 31, 2019 and 2018:

Commodity and seafood 
options, futures and 
forwards(1)(2)

Fixed-income options and

futures

Stock options and futures

Index options and futures

Total

____________

December 31, 2019

December 31, 2018

542,557

1,649,912

21,464,522

23,777,980

47,595,114

93,380,173

22,839,794

24,978,684

49,038,297

98,506,687

(1)  The total volume in cleared power related to commodity 
contracts was 842 Terawatt hours (TWh) for the year ended 
December 31,  2019  and  1,067 TWh  for  the  year  ended 
December 31, 2018.

(2)  As discussed elsewhere in this Form 10-K, in November 
2019, Nasdaq sold the core assets of NFX to a third-party 
and  the  freight  contracts  with  open  interest  are  being 
migrated from NFX to other exchanges.

The  outstanding  contract  value  of  resale  and  repurchase 
agreements was $0.3 billion as of December 31, 2019 and $0.5 
billion as of December 31, 2018. The total number of contracts 
cleared was 6,627,103 for the year ended December 31, 2019
and was 9,223,246 for the year ended December 31, 2018.

17. Leases

As discussed in “Leases,” of Note 2, “Summary of Significant 
Accounting Policies,” effective January 1, 2019, we adopted 
ASU 2016-02 using the optional transition method. As a result, 
we applied the new lease standard prospectively to our leases 
existing  or  commencing  on  or  after  January  1,  2019. 
Comparative  periods  presented  were  not  restated  upon 
adoption. Similarly, new disclosures under the standard were 
made for periods beginning January 1, 2019, and not for prior 
comparative periods. Prior periods will continue to be reported 
under guidance in effect prior to January 1, 2019.

F-41

 
 
We have operating leases which are primarily real estate leases 
for our U.S. and European headquarters and for general office 
space. The following table provides supplemental balance sheet 
information related to Nasdaq's operating leases: 

Leases

Balance Sheet Classification

The following table provides information related to Nasdaq's 
lease term and discount rate:

December 31,
2019

(in millions)

Weighted-average remaining lease term

(in years)

Weighted-average discount rate

December 31, 2019

10.4

4.6%

Assets:
Operating lease

assets

Liabilities:

Current lease
liabilities

Operating lease assets

$

346

The following table provides supplemental cash flow 
information related to Nasdaq's operating leases:

Other current
liabilities

Non-current lease

liabilities

Operating lease
liabilities

Total lease liabilities

$

$

61

331

392

The following table summarizes Nasdaq's lease cost:  

Year Ended
December 31, 2019

(in millions)

Cash paid for amounts included in the
measurement of operating lease
liabilities

Lease assets obtained in exchange for

new operating lease liabilities

$

$

78

26

Operating lease cost(1)
Variable lease cost

Sublease income

Total lease cost

Year Ended
December 31, 2019

(in millions)

Disclosures Related to Periods Prior to the Adoption of ASU 
2016-02 are as follows:

$

$

79
23

(5)

97

Rental expense for operating leases was $82 million in 2018 
and $83 million in 2017, which are net of immaterial amounts 
of sublease income. As of December 31, 2018, future minimum 
lease payments under non-cancelable operating leases, which 
are net of immaterial sublease income, were as follows:

____________
(1) 

Includes short-term lease cost, which was immaterial.

The following table reconciles the undiscounted cash flows for 
each of the first five years and total of the remaining years to 
the  operating  lease  liabilities  recorded  in  our  consolidated 
balance sheet.

December 31, 2019

(in millions)

$

2020

2021

2022

2023

2024

Thereafter

Total lease payments
      Less: interest(1)
Present value of lease liabilities(2)
____________
(1)  Calculated using the interest rate for each lease.
(2) 
Includes the current portion of $61 million.

$

77

67

46

43

35

240

508

(116)
392

Total lease payments in the above table exclude $128 million 
of legally binding minimum lease payments for leases signed 
but not yet commenced primarily related to the expansion of 
our world headquarters. These leases will commence in 2020 
with a lease term of 16 years.

Year ending December 31:

(in millions)

2019

2020

2021

2022

2023

Thereafter

Total minimum lease payments

18. Income Taxes

$

$

75

69

62

44

42

345

637

The Tax Cuts and Jobs Act was enacted in December 2017 and 
included a number of changes to previous U.S. tax laws that 
impacted  Nasdaq,  most  notably  a  reduction  of  the  U.S. 
corporate income tax rate from 35 percent to 21 percent for tax 
years beginning after December 31, 2017. We recognized a non-
cash provisional tax benefit of $89 million for the year ended 
December  31,  2017,  substantially  all  of  which  reflects  the 
estimated impact associated with the remeasurement of our net 
U.S. deferred tax liability at the lower U.S. federal corporate 
income tax rate. In accordance with Staff Accounting Bulletin 
No.118, during the fourth quarter of 2018, we completed our 
accounting for the tax effects of the act, finalizing our analysis 
of the act and subsequent guidance issued by the U.S. Internal 
Revenue Service. As a result, we recorded a $290 million non-
cash tax charge, reducing deferred tax assets relating to foreign 
currency translation.

F-42

Income Before Income Tax Provision

The  following  table  presents  the  domestic  and  foreign 
components of income before income tax provision:

Year Ended December 31,

2019

2018

2017

(in millions)

$

$

691

328

$

636

428

556

316

Domestic

Foreign

Income before income tax

provision

$ 1,019

$ 1,064

$

872

Income Tax Provision

Federal income tax provision

at the statutory rate

State income tax provision, net

of federal effect

Change in deferred taxes due
to U.S. tax law changes

Excess tax benefits related to

employee share-based
compensation

Year Ended December 31,

2019

2018

2017

21.0 % 21.0 % 35.0 %

4.1 % 3.7 % 2.6 %

— % 27.0 % (9.9)%

(0.5)% (0.7)% (4.0)%

Non-U.S. subsidiary earnings

0.3 % 0.1 % (6.0)%

Tax credits and deductions

(0.2)% (0.2)% (1.0)%

The income tax provision consists of the following amounts:

Change in unrecognized tax

Year Ended December 31,

2019

2018

2017

(in millions)

benefits

Other, net

(0.1)% 4.7 % (0.8)%

(0.6)% 1.4 % 0.5 %

Actual income tax provision

24.0 % 57.0 % 16.4 %

Current income taxes

provision:

Federal

State

Foreign

Total current income taxes

provision

Deferred income taxes
provision (benefit):

Federal

State

Foreign

Total deferred income
taxes provision

$

120

$

103

$

40

50

210

27

7

1

35

56

146

305

185

116

—

301

606

The majority of the decrease in our effective tax rate in 2019 
compared to 2018 and the increase in our effective tax rate in 
2018 compared to 2017 was the result of the remeasurement of 
our U.S. deferred tax inventory from the Tax Cuts and Jobs Act. 
The higher effective tax rate in 2018 was also impacted by the 
reversal of certain Swedish tax benefits recorded in prior years.

The effective tax rate may vary from period to period depending 
on, among other factors, the geographic and business mix of 
earnings and losses. These same and other factors, including 
history of pre-tax earnings and losses, are taken into account in 
assessing the ability to realize deferred tax assets.

Deferred Income Taxes

The temporary differences, which give rise to our deferred tax
assets and (liabilities), consisted of the following:

51

17

68

136

(16)

24

(1)

7

Total income tax provision $

245

$

$

143

We have determined that undistributed earnings of certain non-
U.S. subsidiaries will be reinvested for an indefinite period of 
time. We have both the intent and ability to indefinitely reinvest 
these  earnings.  As  of  December  31,  2019,  the  cumulative 
amount of undistributed earnings in these subsidiaries is $260 
million.  Given  our  intent  to  reinvest  these  earnings  for  an 
indefinite period of time, we have not accrued a deferred tax 
liability on these earnings. A determination of an unrecognized 
deferred tax liability related to these earnings is not practicable.

A reconciliation of the income tax provision, based on the U.S. 
federal statutory rate, to our actual income tax provision for the 
years ended December 31, 2019, 2018 and 2017 is as follows:

F-43

 
 
 
 
 
 
$ 175

$ 98

Ending balance

December 31,

2019

2018

(in millions)

$ 10

$ 19

4

2

32

6

101

20

175

—

23

4

33

17

—

25

121

(23)

Deferred tax assets:

Deferred revenues

Foreign net operating loss

State net operating loss

Compensation and benefits

Federal benefit of uncertain tax positions

Operating lease liabilities

Other

Gross deferred tax assets

Less: valuation allowance

Total deferred tax assets, net of valuation

allowance

Deferred tax liabilities:

Amortization of software development

costs and depreciation

(42)

(41)

Amortization of acquired intangible assets

(495)

(498)

Investments

Unrealized gains

Operating lease assets

Other

Gross deferred tax liabilities

Net deferred tax liabilities

Reported as:
Non-current deferred tax assets(1)
Deferred tax liabilities, net

Net deferred tax liabilities

(37)

(31)

(89)

(32)

(34)

—

—

(22)

(726)

(595)

$ (551) $ (497)

$

1

$

4

(552)

(501)

$ (551) $ (497)

____________
(1)  Included  in  other  non-current  assets  in  the  Consolidated 
Balance Sheets.

As of December 31, 2019, we did not recognize a valuation 
allowance against Nasdaq’s deferred tax assets. Based on all 
available positive and negative evidence, we believe the sources 
of  future  taxable  income  are  sufficient  to  realize  the  entire 
deferred  tax  asset  inventory.  The  valuation  allowance  as  of 
December 31, 2018, is related to net operating losses, or NOLs, 
in  the  United  Kingdom  and  the  Netherlands,  which  were 
recorded on entities that were divested or liquidated in 2019.

As  of  December  31,  2019,  Nasdaq  has  deferred  tax  assets 
associated  with  NOLs  in  U.S.  state  and  local  and  non-U.S. 
jurisdictions with the following expiration dates:

Jurisdiction

Amount

Expiration Date

Foreign NOL

State NOL

(in millions)

$

4 No expiration

2 2025-2036

Unrecognized Tax Benefits

A  reconciliation  of  the  beginning  and  ending  amount  of 
unrecognized tax benefits is as follows:

Beginning balance

Additions as a result of tax positions

taken in prior periods

Additions as a result of tax positions

taken in the current period

Reductions related to settlements with

taxing authorities

Reductions as a result of lapses of the
applicable statute of limitations

Year Ended December 31,

2019

2018

2017

(in millions)

$ 52

$ 45

$ 48

10

1

28

6

2

5

(10)

(23) —

(5)

(4)

(10)

$ 48

$ 52

$ 45

We  had  $48  million  of  unrecognized  tax  benefits  as  of 
December 31, 2019, $52 million as of December 31, 2018, and 
$45 million as of December 31, 2017 which, if recognized in 
the future, would affect our effective tax rate. Nasdaq does not 
believe  that  our  unrecognized  tax  benefits  will  materially 
change over the next 12 months.

We  recognize  interest  and/or  penalties  related  to  income  tax 
matters in the provision for income taxes in our Consolidated 
Statements of Income, which were $3 million for the year ended 
December 31, 2019, $2 million for 2018, and $1 million for 
2017. Accrued interest and penalties, net of tax effect were $12 
million  as  of  December  31,  2019  and  $10  million  as  of 
December 31, 2018.

Tax Audits

Nasdaq  and  its  eligible  subsidiaries  file  a  consolidated  U.S. 
federal income tax return and applicable state and local income 
tax returns and non-U.S. income tax returns. We are subject to 
examination  by  federal,  state  and  local,  and  foreign  tax 
authorities.  Federal  income  tax  returns  for  the  years  2008 
through 2016 are currently under examination by the Internal 
Revenue  Service  and  we  are  subject  to  examination  by  the 
Internal Revenue Service for 2017 and 2018. Several state tax 
returns are currently under examination by the respective tax 
authorities  for  the  years  2007  through  2018.  Non-U.S.  tax 
returns  are  subject  to  examination  by  the  respective  tax 
authorities for the years 2013 through 2018. We regularly assess 
the likelihood of additional assessments by each jurisdiction 
and have established tax reserves that we believe are adequate 
in  relation  to  the  potential  for  additional  assessments. 
Examination  outcomes  and  the  timing  of  examination 
settlements are subject to uncertainty. Although the results of 
such examinations may have an impact on our unrecognized 
tax  benefits,  we  do  not  anticipate  that  such  impact  will  be 
material  to  our  consolidated  financial  position  or  results  of 
operations. We do not expect to settle any material tax audits 
in the next twelve months.

The Swedish Tax Agency disallowed certain interest expense 
deductions for the years 2013 - 2018. We appealed this decision 

F-44

 
 
 
 
 
 
 
to the Lower Administrative Court which denied our appeal in 
2018. During 2018, we further appealed to the Administrative 
Court of Appeal, however, we were no longer able to assert that 
we  were  more  than  likely  to  be  successful  and,  as  such,  we 
recorded  a  related  tax  expense.  In  November  2019,  the 
Administrative  Court  of Appeal  upheld  the  disallowance  of 
these  deductions.  As  we  have  not  recognized  any  benefits 
related  to  the  disallowed  deductions  and  we  have  paid  the 
related assessments from the Swedish Tax Agency, the decision 
of  the Administrative  Court  of Appeal  does  not  impact  our 
consolidated financial statements.

19. Commitments, Contingencies and Guarantees

Guarantees Issued and Credit Facilities Available

In  addition  to  the  default  fund  contributions  and  margin 
collateral pledged by clearing members discussed in Note 16, 
“Clearing Operations,” we have obtained financial guarantees 
and credit facilities which are guaranteed by us through counter 
indemnities, to provide further liquidity related to our clearing 
businesses. Financial guarantees issued to us totaled $11 million 
as of December 31, 2019 and $12 million as of December 31, 
2018. As  discussed  in  “Other  Credit  Facilities,”  of  Note  10, 
“Debt  Obligations,”  we  also  have  credit  facilities  primarily 
related to our Nasdaq Clearing operations, which are available 
in  multiple  currencies,  and  totaled  $203  million  as  of 
December 31, 2019 and $234 million as of December 31, 2018, 
in available liquidity, of which $15 million was utilized as of 
December  31,  2019  and  none  of  which  was  utilized  as  of 
December 31, 2018.

Execution Access is an introducing broker which operates the 
trading platform for our Fixed Income business to trade in U.S. 
securities. Execution  Access  has  a  clearing 
Treasury 
arrangement with Industrial and Commercial Bank of China 
Financial Services LLC, or ICBC. As of December 31, 2019, 
we have contributed $15 million of clearing deposits to ICBC 
in connection with this clearing arrangement. These deposits 
are recorded in other current assets in our Consolidated Balance 
Sheets.  Some  of  the  trading  activity  in  Execution Access  is 
cleared  by  ICBC  through  the  Fixed  Income  Clearing 
Corporation,  with  ICBC  acting  as  agent.  Execution Access 
assumes the counterparty risk of clients that do not clear through 
the Fixed Income Clearing Corporation. Counterparty risk of 
clients exists for Execution Access between the trade date and 
the settlement date of the individual transactions, which is at 
least one business day (or more, if specified by the U.S. Treasury 
issuance calendar). Counterparties that do not clear through the 
Fixed Income Clearing Corporation are subject to a credit due 
diligence process and may be required to post collateral, provide 
principal letters, or provide other forms of credit enhancement 
to Execution Access for the purpose of mitigating counterparty 
risk. Daily position trading limits are also enforced for such 
counterparties. 

We  believe  that  the  potential  for  us  to  be  required  to  make 
payments under these arrangements is mitigated through the 
pledged  collateral  and  our  risk  management  policies. 
Accordingly,  no  contingent  liability  is  recorded  in  the 
Consolidated Balance Sheets for these arrangements. However, 

no guarantee can be provided that these arrangements will at 
all times be sufficient.

Other Guarantees

Through  our  clearing  operations  in  the  financial  markets, 
Nasdaq Clearing is the legal counterparty for, and guarantees 
the  performance  of,  its  clearing  members.  See  Note  16, 
“Clearing  Operations,”  for  further  discussion  of  Nasdaq 
Clearing performance guarantees.

We have provided a guarantee related to lease obligations for 
The Nasdaq Entrepreneurial Center, Inc., which is a not-for-
profit organization designed to convene, connect and engage 
aspiring and current entrepreneurs. This entity is not included 
in the consolidated financial statements of Nasdaq.

We  believe  that  the  potential  for  us  to  be  required  to  make 
payments under these arrangements is unlikely. Accordingly, 
no contingent liability is recorded in the Consolidated Balance 
Sheets for the above guarantees.

Non-Cash Contingent Consideration 

As  part  of  the  purchase  price  consideration  of  a  prior 
acquisition,  we  have  agreed  to  future  annual  issuances  of 
992,247 shares of Nasdaq common stock which approximated 
certain  tax  benefits  associated  with  the  transaction.  Such 
contingent future issuances of Nasdaq common stock will be 
issued annually through 2027 if Nasdaq’s total gross revenues 
equal or exceed $25 million in each such year. The contingent 
future issuances of Nasdaq common stock are subject to anti-
dilution protections and acceleration upon certain events.

Escrow Agreements

In connection with prior acquisitions, we entered into escrow 
agreements to secure the payment of post-closing adjustments 
and  to  ensure  other  closing  conditions. As  of  December 31, 
2019, these escrow agreements provide for future payment by 
us of up to an aggregate of $9 million, which is included in other 
current liabilities in the Consolidated Balance Sheets.

Routing Brokerage Activities

One  of  our  broker-dealer  subsidiaries,  Nasdaq  Execution 
Services, provides a guarantee to securities clearinghouses and 
exchanges under its standard membership agreements, which 
require  members  to  guarantee  the  performance  of  other 
members. If a member becomes unable to satisfy its obligations 
to  a  clearinghouse  or  exchange,  other  members  would  be 
required to meet its shortfalls. To mitigate these performance 
risks, the exchanges and clearinghouses often require members 
to post collateral, as well as meet certain minimum financial 
standards.  Nasdaq  Execution  Services’  maximum  potential 
liability  under  these  arrangements  cannot  be  quantified. 
However, we believe that the potential for Nasdaq Execution 
Services  to  be  required  to  make  payments  under  these 
arrangements is unlikely. Accordingly, no contingent liability 
is  recorded  in  the  Consolidated  Balance  Sheets  for  these 
arrangements.

F-45

connectivity.  We  have  defeated  two  challenges  in  federal 
appeals  court  pertaining  to  market  data  and  an  additional 
challenge at the administrative level within the SEC. However, 
in October 2018, the SEC reversed that administrative decision 
and found that Nasdaq had not met a burden of demonstrating 
that  certain  challenged  fees  were  fair  and  reasonable;  we 
estimate that this decision will reduce our annual revenues by 
approximately $1 million. Nasdaq has appealed this decision 
to the U.S. Court of Appeals for the District of Columbia Circuit. 
In addition, the SEC remanded a series of additional challenges 
to market data and connectivity fees back to Nasdaq for further 
consideration.  Nasdaq  has  also  appealed  this  decision  to  the 
U.S. Court of Appeals for the District of Columbia Circuit. We 
are unable to predict the outcome or the timing of the ultimate 
resolution of these matters.

Other Matters

Except as disclosed above and in prior reports filed under the 
Exchange Act, we are not currently a party to any litigation or 
proceeding that we believe could have a material adverse effect 
on our business, consolidated financial condition, or operating 
results. However, from time to time, we have been threatened 
with,  or  named  as  a  defendant  in,  lawsuits  or  involved  in 
regulatory proceedings.

In the normal course of business, Nasdaq discusses matters with 
its  regulators  raised  during  regulatory  examinations  or 
otherwise subject to their inquiries. Management believes that 
censures, fines, penalties or other sanctions that could result 
from  any  ongoing  examinations  or  inquiries  will  not  have  a 
material impact on its consolidated financial position or results 
of operations. However, we are unable to predict the outcome 
or the timing of the ultimate resolution of these matters, or the 
potential fines, penalties or injunctive or other equitable relief, 
if any, that may result from these matters.

Tax Audits

We are engaged in ongoing discussions and audits with taxing 
authorities on various tax matters, the resolutions of which are 
uncertain. Currently,  there  are  matters  that  may  lead  to 
assessments, some of which may not be resolved for several 
years. Based on currently available information, we believe we 
have adequately provided for any assessments that could result 
from those proceedings where it is more likely than not that we 
will be assessed. We review our positions on these matters as 
they progress. See “Tax Audits,” of Note 18, “Income Taxes,” 
for further discussion.

Legal and Regulatory Matters 

Litigation

As  previously  disclosed,  we  are  named  as  one  of  many 
defendants in City of Providence v. BATS Global Markets, Inc., 
et al., 14 Civ. 2811 (S.D.N.Y.), which was filed on April 18, 
2014 in the United States District Court for the Southern District 
of New York. The district court appointed lead counsel, who 
filed  an  amended  complaint  on  September  2,  2014.  The 
amended  complaint  names  as  defendants  seven  national 
exchanges, as well as Barclays PLC, which operated a private 
alternative  trading  system.  On  behalf  of  a  putative  class  of 
securities  traders,  the  plaintiffs  allege  that  the  defendants 
engaged in a scheme to manipulate the markets through high-
frequency  trading;  the  amended  complaint  asserts  claims 
against us under Section 10(b) of the Exchange Act and Rule 
10b-5, as well as under Section 6(b) of the Exchange Act. The 
plaintiffs seek injunctive and monetary relief of an unspecified 
amount. We filed a motion to dismiss the amended complaint 
on November 3, 2014. In response, the plaintiffs filed a second 
amended complaint on November 24, 2014, which names the 
same defendants and alleges essentially the same violations. 
We  then  filed  a  motion  to  dismiss  the  second  amended 
complaint on January 23, 2015. On August 26, 2015, the district 
court  entered  an  order  dismissing  the  second  amended 
complaint in its entirety. The plaintiffs appealed the judgment 
of dismissal to the United States Court of Appeals for the Second 
Circuit (although opting not to appeal the dismissal with respect 
to Barclays PLC or the dismissal of claims under Section 6(b) 
of  the  Exchange Act).  On  December  19,  2017,  the  Second 
Circuit issued an opinion vacating the district court’s judgment 
of  dismissal  and  remanding  to  the  district  court  for  further 
proceedings. On May 18, 2018, the exchanges filed a motion 
to dismiss the amended complaint, raising issues not addressed 
in the proceedings to date. On May 28, 2019, the district court 
denied the exchanges’ renewed motion to dismiss. On June 17, 
2019, the exchanges filed a motion to certify the district court’s 
order for immediate review by the Second Circuit and on July 
16,  2019,  the  district  court  denied  the  motion.  Given  the 
preliminary nature of the proceedings, we are unable to estimate 
what, if any, liability may result from this litigation. However, 
we believe that the claims are without merit and will continue 
to litigate vigorously. 

Nasdaq Commodities Clearing Default

During  September  2018,  a  clearing  member  of  Nasdaq 
Clearing's  commodities  market  was  declared  in  default.  We 
have been cooperating fully with the SFSA in the associated 
regulatory audits. While we are currently unable to predict the 
final outcome of this matter, it could include penalties, such as 
a fine. We do not expect this matter will have a material impact 
on  our  consolidated  financial  statements.  See  “Nasdaq 
Commodities  Clearing  Default,”  of  Note  16,  “Clearing 
Operations,” for further information on this event.

SEC Decisions

In  recent  years,  certain  industry  groups  have  challenged  the 
level of fees that U.S. exchanges charge for market data and 

F-46

20. Business Segments

We  manage,  operate  and  provide  our  products  and  services  in  four  business  segments:  Market  Services,  Corporate  Services, 
Information Services and Market Technology. See Note 1, “Organization and Nature of Operations,” for further discussion of our 
reportable segments.

Our management allocates resources, assesses performance and manages these businesses as four separate segments. We evaluate 
the performance of our segments based on several factors, of which the primary financial measure is operating income. Results 
of individual businesses are presented based on our management accounting practices and structure. Our chief operating decision 
maker does not review total assets or statements of income below operating income by segments as key performance metrics; 
therefore, such information is not presented below.

The following table presents certain information regarding our business segments for the years ended December 31, 2019, 2018 
and 2017:

Year Ended December 31, 2019
Total revenues
Transaction-based expenses
Revenues less transaction-based expenses
Depreciation and amortization
Operating income (loss)
Purchase of property and equipment
Year Ended December 31, 2018
Total revenues
Transaction-based expenses
Revenues less transaction-based expenses
Depreciation and amortization
Operating income (loss)
Purchase of property and equipment
Year Ended December 31, 2017
Total revenues
Transaction-based expenses
Revenues less transaction-based expenses
Depreciation and amortization
Operating income (loss)
Purchase of property and equipment

Market
Services

Corporate
Services

Information
Services

Market
Technology

Corporate
Items

Consolidated

$

$

$

$

$

$

2,639
(1,727)
912
74
516
30

2,709
(1,751)
958
95
544
28

2,418
(1,537)
881
95
481
59

$

$

$

496
—
496
34
178
27

487
—
487
36
155
29

459
—
459
40
149
41

(in millions)

$

$

$

$

779
—
779
52
490
30

714
—
714
51
460
17

588
—
588
26
418
10

$

$

$

338
—
338
30
54
40

270
—
270
21
34
37

247
—
247
14
57
34

$

$

$

10
—
10
—
(221)
—

97
—
97
7
(165)
—

236
—
236
13
(114)
—

4,262
(1,727)
2,535
190
1,017
127

4,277
(1,751)
2,526
210
1,028
111

3,948
(1,537)
2,411
188
991
144

Certain  amounts  are  allocated  to  corporate  items  in  our 
management reports as we believe they do not contribute to a 
meaningful  evaluation  of  a  particular  segment's  ongoing 
operating performance. These items, which are shown in the 
table below, include the following:

managers  or  when  making  decisions  to  allocate  resources. 
Therefore,  we  believe  performance  measures  excluding 
intangible  asset  amortization  expense  provide  management 
with a useful representation of our segments' ongoing activity 
in each period.

Amortization  expense  of  acquired  intangible  assets:  We 
amortize intangible assets acquired in connection with various 
acquisitions.  Intangible  asset  amortization  expense  can  vary 
from period to period due to episodic acquisitions completed, 
rather than from our ongoing business operations. As such, if 
intangible  asset  amortization  is  included  in  performance 
measures, it is more difficult to assess the day-to-day operating 
performance  of  the  segments,  and  the  relative  operating 
performance  of  the  segments  between  periods.  Management 
does not consider intangible asset amortization expense for the 
purpose of evaluating the performance of our segments or their 

Merger  and  strategic  initiatives  expense:  We  have  pursued 
various  strategic  initiatives  and  completed  acquisitions  and 
divestitures in recent years that have resulted in expenses which 
would  not  have  otherwise  been  incurred.  These  expenses 
generally  include  integration  costs,  as  well  as  legal,  due 
diligence and other third party transaction costs. The frequency 
and the amount of such expenses vary significantly based on 
the size, timing and complexity of the transaction. Management 
does not consider merger and strategic initiatives expense for 
the purpose of evaluating the performance of our segments or 
their managers or when making decisions to allocate resources. 

F-47

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Therefore, we believe performance measures excluding merger 
and strategic initiatives expense provide management with a 
useful representation of our segments' ongoing activity in each 
period.

Restructuring  charges:  In  September  2019,  we  initiated  a 
restructuring plan. See Note 21, “Restructuring Charges,” for 
a  discussion  of  the  plan.  We  believe  performance  measures 
excluding  restructuring  charges  provide  management  with  a 
useful representation of our segments' ongoing activity in each 
period.

Clearing  default  loss:  For  2018,  we  recorded  a  $31  million 
charge related to a default of a Nasdaq Clearing commodities 
member  that  occurred  in  September  2018.  See  “Nasdaq 
Commodities  Clearing  Default,”  of  Note  16,  “Clearing 
Operations,”  for  further  discussion  of  the  default.  We  have 
included this charge as we believe it is non-recurring, as there 
has  never  been  another  loss  due  to  member  default  in  our 
clearinghouse,  and  should  be  excluded  when  evaluating  the 
ongoing  operating  performance  of  the  Market  Services 
segment.  Any  expenses  associated  with  the  evaluation  and 
enhancement  of  processes  and  procedures  relating  to  our 
clearing business will be reflected within the Market Services 
segment.

2019  and  2018  divestitures:  We  have  included  in  corporate 
items  the  revenues  and  expenses  of  BWise  and  the  Public 
Relations  Solutions  and  Digital  Media  Services  businesses 
which were part of the Corporate Solutions business within our 
Corporate Services segment as BWise was sold in March 2019 
and the Public Relations Solutions and Digital Media Services 

businesses were sold in April 2018. See “2019 Divestitures,” 
and  “2018  Divestiture,”  of  Note  4,  “Acquisitions  and 
Divestitures,” for further discussion.

Other significant items: We have included certain other charges 
or gains in corporate items, to the extent we believe they should 
be  excluded  when  evaluating 
the  ongoing  operating 
performance  of  each  individual  segment.  For  2019,  other 
significant  items  included  loss  on  extinguishment  of  debt,  a 
provision for notes receivable associated with the funding of 
technology  development  for  the  CAT,  and  a  tax  reserve  for 
certain prior year examinations which are recorded in general, 
the  Consolidated 
administrative  and  other  expense 
Statements  of  Income,  and  certain  litigation  costs  which  are 
recorded in professional and contract services expense in the 
Consolidated Statements of Income. For 2018, other significant 
items  included  certain  litigation  costs  which  are  recorded  in 
professional and contract services expense in the Consolidated 
Statements of Income and charges related to uncertain positions 
pertaining to sales and use tax and VAT which are recorded in 
general, administrative and other expense in the Consolidated 
Statements  of  Income.  For  2017,  other  significant  items 
included loss on extinguishment of debt which is recorded in 
general, administrative and other expense in the Consolidated 
Statements of Income.

in 

Accordingly,  we  do  not  allocate  these  costs  for  purposes  of 
disclosing segment results because they do not contribute to a 
meaningful  evaluation  of  a  particular  segment’s  ongoing 
operating performance.

A summary of our corporate items is as follows:

* * * * * *

Revenues - divested businesses

Expenses:

Amortization expense of acquired intangible assets
Merger and strategic initiatives expense

Restructuring charges

Clearing default loss

Provision for notes receivable

Extinguishment of debt

Expenses - divested businesses

Other

Total expenses

Operating loss

Year Months Ended December 31,

2019

2018

2017

$

10

(in millions)
$

97

$

236

101
30

39

—

20

11

8

22

109
21

—

31

—

—

83

18

231
(221) $

262
(165) $

$

92
44

—

—

—

10

200

4

350
(114)

For further discussion of our segments’ results, see “Item 7. Management’s Discussion and Analysis of Financial Condition and 
Results of Operations-Segment Operating Results.”

F-48

The  following  table  presents  a  summary  of  the  2019 
restructuring plan charges in the Consolidated Statements of 
Income for the year ended December 31, 2019 which primarily 
consisted  of  asset  impairment  charges  mainly  related  to 
capitalized software that was retired.

Year Ended December 31, 2019

(in millions)

Asset impairments

$

Severance and employee-related

costs

Accelerated depreciation

Contract terminations

Consulting services

Other

Total restructuring charges

$

24

8

2

2

2

1

39

Geographic Data

The following table presents total revenues and property and 
equipment, net by geographic area for 2019, 2018 and 2017. 
Revenues are classified based upon the location of the customer. 
Property and equipment information is based on the physical 
location of the assets.

Total
Revenues

Property and
Equipment,
Net

(in millions)

$

$

$

$

$

$

3,409

853

4,262

3,379

898

4,277

3,081

867

3,948

$

$

$

$

$

$

250

134

384

224

152

376

247

153

400

2019:

United States

All other countries

Total

2018:

United States

All other countries

Total

2017:

United States

All other countries

Total

Our  property  and  equipment,  net  for  all  other  countries 
primarily includes assets held in Sweden. No single customer 
accounted for 10.0% or more of our revenues in 2019, 2018 and 
2017.

21. Restructuring Charges

In  September  2019,  we  initiated  the  transition  of  certain 
technology  platforms  to  advance  the  company's  strategic 
opportunities  as  a  technology  and  analytics  provider  and 
continue  the  re-alignment  of  certain  business  areas.  In 
connection  with  these  restructuring  efforts,  we  are  retiring 
certain  elements  of  our  marketplace  infrastructure  and 
technology product offerings as we implement NFF and other 
technologies  internally  and  externally.  This  represents  a 
fundamental  shift  in  our  strategy  and  technology  as  well  as 
executive re-alignment. As a result of these actions, we expect 
to incur $70 million to $80 million in pre-tax charges over a 
two year period related primarily to non-cash items such as asset 
impairments,  accelerated  depreciation  as  well  as  third-party 
consulting costs. Severance and employee-related charges also 
will  be  incurred.  Restructuring  charges  are  recorded  on 
restructuring plans that have been committed to by management 
and are, in part, based upon management’s best estimates of 
future events.

F-49

 
 
 
 
 
 
 
 
Exhibit 4.12

DESCRIPTION OF THE REGISTRANT’S SECURITIES
REGISTERED PURSUANT TO SECTION 12 OF THE
SECURITIES EXCHANGE ACT OF 1934

Nasdaq, Inc. (the “Company”) has five classes of securities registered under Section 12 of 

the Securities Exchange Act of 1934, as amended (the “Exchange Act”):

(1) 

(2) 

(3) 

(4) 

(5) 

Common Stock, par value $0.01 per share (“Common Stock”); 

0.875% Senior Notes due 2030;

1.75% Senior Notes due 2029; 

1.750% Senior Notes due 2023; and

3.875% Senior Notes due 2021.

As used in this summary, the terms “Nasdaq,” “the Company,” “we,” “our,” and “us” refer 

solely to Nasdaq, Inc. and not its subsidiaries, unless otherwise specified.

Description of Common Stock

The following is a description of the material terms and provisions relating to our common 
stock.  Because it is a summary, the following description is not complete and is subject to and 
qualified in its entirety by reference to our Amended and Restated Certificate of Incorporation, as 
amended, or Certificate, and by-laws, and provisions of Delaware law which define the rights of 
our stockholders.

The holders of our common stock are entitled to one vote per share on all matters to be voted 
upon by the stockholders except that no person may exercise voting rights in respect of any shares 
in excess of 5% of the then outstanding shares of our Common Stock. Subject to certain additional 
conditions, this limitation does not apply to persons exempted from this limitation by our Board of 
Directors prior to the time such person owns more than 5.0% of the then-outstanding shares of our 
common stock. 

At any meeting of our stockholders, a majority of the votes entitled to be cast will constitute 

a quorum for such meeting. 

Holders of common stock are entitled to receive ratably such dividends, if any, as may be 
declared from time to time by our board of directors out of funds legally available for them. In the 
event of our liquidation, dissolution, or winding-up, the holders of our common stock are entitled 
to share ratably in all assets remaining after payment of liabilities, subject to prior distribution rights 
of preferred stock, if any, then outstanding. Our common stock has no preemptive or conversion 

1

 
rights or other subscription rights. There are no redemption or sinking fund provisions applicable 
to our common stock. All outstanding shares of common stock are fully paid and non-assessable. 
Future dividends, if any, will be determined by our board of directors. 

Certain Provisions of our Certificate and By-Laws 

Some provisions of our r Certificate and by-laws, which provisions are summarized below, 
may be deemed to have an anti-takeover effect and may delay, defer, or prevent a tender offer or 
takeover attempt that a stockholder might consider in its best interest, including those attempts that 
might result in a premium over the market price for the shares held by stockholders. 

Advance Notice Requirements for Stockholder Proposals and Directors Nominations 

Our by-laws provide that stockholders seeking to bring business before an annual meeting of 
stockholders, or to nominate candidates for election as directors at an annual meeting of stockholders, 
must provide timely notice in writing. To be timely, a stockholder’s notice must be delivered to or 
mailed and received at our principal executive offices not less than 90 nor more than 120 days prior 
to the anniversary date of the immediately preceding annual meeting of stockholders; provided, 
that in the event that the annual meeting is called for a date that is not within 30 days before or 70 
days after such anniversary date, notice by the shareholder in order to be timely must be received 
not earlier than 120 days prior to the meeting and not later than the later of 90 days prior to the 
meeting and the close of business on the 10th day following the date on which notice of the date 
of the annual meeting was first publicly announced by Nasdaq. In the case of a special meeting of 
stockholders called for the purpose of electing directors, notice by the stockholder in order to be 
timely must be received not earlier than 120 days prior to the meeting and not later than the later 
of 90 days prior to the meeting or the close of business on the 10th day following the day on which 
public disclosure of the date of the special meeting and our nominees was first made. In addition, 
our by-laws specify certain requirements as to the form and content of a stockholder’s notice. These 
provisions  may  preclude  stockholders  from  bringing  matters  before  an  annual  meeting  of 
stockholders  or  from  making  nominations  for  directors  at  an  annual  or  special  meeting  of 
stockholders. 

Proxy Access 

Our  by-laws  include  a  proxy  access  provision  that  permits  a  stockholder,  or  a  group  of 
stockholders, owning at least three percent of our outstanding shares of common stock continuously 
for at least three years to nominate and include in the proxy materials for an annual meeting of 
stockholders director nominees constituting up to the greater of two individuals and 25% of the 
total number of directors then in office, provided that the stockholder(s) and nominee(s) satisfy the 
requirements specified in the by-laws. 

Stockholder Action 

Our Certificate provides that stockholders are not entitled to act by written consent in lieu of 

a meeting. 

2

Right to Call Special Meeting 

Our by-laws provide that stockholders representing 15% or more of our outstanding shares 

can convene a special meeting of shareholders. 

Amendments; Vote Requirements 

The General Corporation Law of the State of Delaware provides generally that the affirmative 
vote of a majority of the shares entitled to vote on any matter is required to amend a corporation’s 
certificate of incorporation, unless a corporation’s certificate of incorporation requires a greater 
percentage. Our Certificate imposes majority voting requirements in connection with stockholder 
amendments to the by-laws and in connection with the amendment of certain provisions of the 
Certificate, including those provisions of the Certificate relating to the limitations on voting rights 
of certain persons, removal of directors and prohibitions on stockholder action by written consent. 

Authorized But Unissued Shares 

The authorized but unissued shares of our common stock will be available for future issuance 
without stockholder approval in most cases. These additional shares may be utilized for a variety 
of  corporate  purposes,  including  future  public  or  private  offerings  to  raise  additional  capital, 
corporate acquisitions and employee benefit plans. The existence of authorized but unissued shares 
of our common stock could render more difficult, or discourage, an attempt to obtain control of us 
by means of a proxy contest, tender offer, merger or otherwise. 

Delaware Business Combination Statute 

We are organized under Delaware law. Delaware law generally prohibits a publicly-held or 
widely-held  corporation  from  engaging  in  a  “business  combination”  with  an  “interested 
stockholder” for three years after the stockholder becomes an interested stockholder. An “interested 
stockholder” is a person who, together with affiliates and associates, owns (or, in some cases, within 
three years, did own) directly or indirectly 15% or more of the corporation’s outstanding voting 
stock. A “business combination” includes a merger, asset sale or other transaction that results in a 
financial  benefit  to  the  interested  stockholder.  However,  Delaware  law  does  not  prohibit  these 
business combinations if: 

1. before the stockholder becomes an interested stockholder, the corporation’s board approved 
either the business combination or the transaction that resulted in the stockholder becoming 
an interested stockholder;

2. after the transaction that results in the stockholder becoming an interested stockholder, the 
interested stockholder owns at least 85% of the corporation’s outstanding voting stock 
(excluding certain shares); or

3

 
 
 
 
3.

the corporation’s board approves the business combination and the holders of at least two-
thirds of the corporation’s outstanding voting stock that the interested stockholder does 
not own authorize the business combination at a meeting of stockholders.

Stockholders’ Agreements

On December 16, 2010, we entered into a stockholders’ agreement with Investor AB. We 

are obligated by the terms of the stockholders’ agreement to nominate and generally use best 
efforts to cause the election to our board of directors one individual designated by Investor AB, 
subject to certain conditions.

On February 27, 2008, we entered into a stockholders’ agreement with Borse Dubai 

Limited, or Borse Dubai, which was amended on February 19, 2009. Subject to certain 
conditions, we are obligated by the terms of the stockholders’ agreement to nominate and 
generally use best efforts to cause the election to our board of directors one individual designated 
by Borse Dubai.

Transfer Agent and Registrar

The transfer agent and registrar for our common stock is Computershare. Its address is 
480 Washington Boulevard, Jersey City, New Jersey 07310 and its telephone number is (800) 
736-3001.

Listing

Our common stock is listed on The Nasdaq Stock Market under the trading symbol 

“NDAQ.”

4

 
 
 
 
Description of the 0.875% Senior Notes Due 2030

The 0.875% Senior Notes due 2030 (the “2030 Notes”) were issued under an indenture, 
dated as of June 7, 2013 (the “base indenture”) between Nasdaq, Inc. and Wells Fargo Bank, National 
Association, as trustee (the “Trustee”) and a seventh supplemental indenture dated as of February 
13, 2020 (the “supplemental indenture” and, together with the base indenture, the “indenture”).   
The indenture is publicly available at www.sec.gov.

We issued €600  million aggregate principal amount of the 2030 Notes on February 13, 2020.

This summary is subject to, and qualified in its entirety by reference to, all the provisions 

of the 2030 Notes and the indenture, including definitions of certain terms used therein.  

General 

The 2030 Notes: 

•  are senior unsecured obligations of ours;

•  rank equally in right of payment with all of our other senior unsecured indebtedness from 
time to time outstanding, commercial paper issuances and indebtedness under our credit 
facility;

•  are structurally subordinated in right of payment to all existing and future obligations of 

our subsidiaries, including claims with respect to trade payables; and

•  are effectively subordinated in right of payment to all of our existing and future secured 
indebtedness  and  other  secured  obligations  to  the  extent  of  the  value  of  the  collateral 
securing any such indebtedness and other obligations.

The 2030 Notes were issued in minimum denominations of €100,000  and integral multiples 

of €1,000  in excess thereof. 

Principal, Maturity and Interest 

The 2030 Notes will bear interest at a rate of 0.875% per year. Interest on the Notes is payable 
annually  in  arrears  on  February  13  of  each  year,  beginning  on  February 13,  2021,  and  will  be 
computed on the basis of the actual number of days in the period for which interest is being calculated 
and the actual number of days from and including the last date on which interest was paid on the 
2030 Notes (or the settlement date if no interest has been paid or duly provided for on the 2030 
Notes), to but excluding the next date on which interest is paid or duly provided for. This payment 
convention  is  referred  to  as  ACTUAL/ACTUAL  (ICMA)  as  defined  in  the  rulebook  of  the 
International Capital Market Association. Interest on the 2030 Notes will accrue from and including 
the settlement date and will be paid to holders of record on the day immediately prior to the applicable 
interest payment date. 

5

 
The 2030 Notes will mature on February 13, 2030. On the maturity date of the 2030 Notes, 
the holders will be entitled to receive 100% of the principal amount of such 2030 Notes. The 2030 
2030 Notes will not have the benefit of any sinking fund. 

If any interest payment date, redemption date or maturity date falls on a day that is not a 
business day, then the relevant payment may be made on the next succeeding business day and no 
interest will accrue because of such delayed payment. With respect to the 2030 Notes, when we use 
the term “business day” we mean any day except a Saturday, a Sunday or a day on which banking 
institutions  in  the  applicable  place  of  payment  are  authorized  or  required  by  law,  regulation  or 
executive order to close. 

Claims against the Company for payment of principal, interest and additional amounts, if 
any, on the 2030 Notes will become void unless presentment for payment is made (where so required 
under the indenture) within, in the case of principal and additional amounts, if any, a period of ten 
years or, in the case of interest, a period of five years, in each case from the applicable original date 
of payment therefor. 

Euro Notes—Issuance in Euros 

Initial holders of the 2030 Notes paid for the 2030 Notes in euros, and principal, premium, 
if any, and interest payments and additional amounts, if any, in respect of the 2030 Notes will be 
payable in euros. If, on or after the date of this prospectus supplement, the euro is unavailable to 
us due to the imposition of exchange controls or other circumstances beyond our control or the euro 
is no longer used by the then member states of the European Monetary Union that have adopted 
the euro as their currency or for the settlement of transactions by public institutions within the 
international banking community, then all payments in respect of the 2030 Notes will be made in 
U.S. dollars until the euro is again available to us or so used. 

The amount payable on any date in euros will be converted to U.S. dollars on the basis of 
the most recently available market exchange rate for euros as determined by us in our sole discretion. 
Any payment in respect of the 2030 Notes so made in U.S. dollars will not constitute an event of 
default under the indenture or the 2030 Notes. Neither the trustee nor the paying agent will be 
responsible  for  obtaining  exchange  rates,  effecting  conversions  or  otherwise  handling 
redenominations. 

Ranking 

The 2030 Notes are general unsecured obligations of ours and will rank equally with all of 

our existing and future unsubordinated obligations. 

Holders of any secured indebtedness and other secured obligations of the Company will 
have claims that are prior to your claims as holders of the 2030 Notes, to the extent of the value of 
the  assets  securing  such  indebtedness  and  other  obligations,  in  the  event  of  any  bankruptcy, 
liquidation or similar proceeding. 

Further Issues 

The 2030 Notes constituted a separate series of debt securities under the indenture, limited 
to €600  million. Under the indenture, we may, without the consent of the holders of the 2030 Notes, 

6

issue additional 2030 Notes of the same or a different series from time to time in the future in an 
unlimited  aggregate  principal  amount;  provided  that  if  any  such  additional  2030  Notes  are  not 
fungible with the 2030 Notes offered hereby (or any other tranche of additional 2030 Notes) for 
U.S. federal income tax purposes, then such additional 2030 Notes will have different ISIN and/or 
Common Code numbers than the Notes offered hereby (and any such other tranche of additional 
2030 Notes). The 2030 Notes and any additional 2030 Notes of the same series would rank equally 
and ratably and would be treated as a single class for all purposes under the indenture. This means 
that, in circumstances where the indenture provides for the holders of debt securities of any series 
to vote or take any action, any of the outstanding 2030 Notes, as well as any additional 2030 Notes 
that we may issue by reopening such series, will vote or take action as a single class. 

Redemption 

Optional Redemption 

The 2030 Notes will be redeemable, in whole at any time or in part from time to time, at 
our option, at a redemption price (the “make-whole redemption price”) equal to the greater of (i) 
100% of the principal amount of the 2030 Notes and (ii) as determined by the Quotation Agent (as 
defined below), the sum of the present values of the remaining scheduled payments of principal 
and interest on the 2030 Notes (exclusive of interest accrued and unpaid as of the date of redemption), 
discounted to the date of redemption on an annual basis (ACTUAL/ACTUAL (ICMA)) at the Bund 
Rate (as defined below), plus 20 basis points, plus accrued and unpaid interest thereon to the date 
of  redemption.  However,  if  the  redemption  date  is  after  a  record  date  and  on  or  prior  to  a 
corresponding interest payment date, the interest will be paid on the redemption date to the holder 
of record on the record date. 

Notwithstanding the foregoing, at any time on or after November 13, 2029 (three months 
before their maturity date), the 2030 Notes will be redeemable, in whole or in part, at our option 
and at any time or from time to time, at a redemption price equal to 100% of the principal amount 
of the 2030 Notes to be redeemed plus accrued and unpaid interest thereon to, but excluding, the 
date of redemption. 

Notice of any redemption will be mailed at least 30 days, but not more than 60 days, before 
the  redemption  date  to  each  registered  holder  of  2030  Notes  to  be  redeemed.  Once  notice  of 
redemption is mailed, the 2030 Notes called for redemption will become due and payable on the 
redemption date and at the applicable redemption price, plus accrued and unpaid interest to, but not 
including, the redemption date. Unless we default in payment of the redemption price, on and after 
the  redemption  date,  interest  will  cease  to  accrue  on  the  2030  Notes  (or  portion  thereof)  to  be 
redeemed on such redemption date. 

“Bund Rate” means, with respect to any redemption date, the rate per annum equal to the 
annual equivalent yield to maturity of the Comparable German Bund Issue, assuming a price for 
the Comparable German Bund Issue (expressed as a percentage of its principal amount) equal to 
the Comparable German Bund Price for such redemption date. 

“Comparable German Bund Issue” means that German Bundesanleihe security selected by 
the Quotation Agent as having a maturity comparable to the remaining term of the 2030 Notes to 
be redeemed that would be utilized, at the time of selection and in accordance with customary 

7

financial practice, in pricing new issues of corporate notes of comparable maturity to the remaining 
term of the Notes. 

“Comparable  German  Bund  Price”  means,  with  respect  to  any  redemption  date,  (i) the 
average of four Reference German Bund Dealer Quotations for such redemption date, after excluding 
the highest and lowest such Reference German Bund Dealer Quotations or (ii) if the Quotation 
Agent obtains fewer than four such Reference German Bund Dealer Quotations, the average of all 
such quotations. 

“Quotation Agent” means a Reference German Bund Dealer appointed by us. 

“Reference German Bund Dealer” means any dealer of German Bundesanleihe securities 

selected by us in good faith. 

“Reference  German  Bund  Dealer  Quotations”  means,  with  respect  to  each  Reference 
German Bund Dealer and any redemption date, the average, as determined by us, of the bid and 
asked prices for the Comparable German Bund Issue (expressed in each case as a percentage of its 
principal amount) quoted in writing to the Quotation Agent by such Reference German Bund Dealer 
at 3:30 p.m., Frankfurt, Germany time, on the third business day preceding such redemption date. 

If we elect to redeem less than all of the 2030 Notes, and such 2030 Notes are at the time 
represented by a global note, then the depositary will select by lot the particular interests to be 
redeemed. If we elect to redeem less than all of the 2030 Notes, and any of such 2030 Notes are 
not represented by a global note, then the trustee will select the particular 2030 Notes to be redeemed 
in a manner it deems appropriate and fair (and the depositary will select by lot the particular interests 
in any global note to be redeemed). 

We may at any time, and from time to time, purchase the 2030 Notes at any price or prices 

in the open market or otherwise. 

Repurchase upon Change of Control Triggering Event 

If a Change of Control Triggering Event (as defined below) occurs with respect to the 2030 
Notes, unless we have exercised our right to redeem the 2030 Notes, we will be required to make 
an offer to repurchase all or, at the holder’s option, any part (equal to €100,000  or any integral 
multiple of €1,000  in excess thereof) of each holder’s 2030 Notes pursuant to the offer described 
below (the “Change of Control Offer”). 

In the Change of Control Offer, we will be required to offer payment in cash equal to 101% 
of the aggregate principal amount of 2030 Notes repurchased plus accrued and unpaid interest, if 
any, on the 2030 Notes repurchased to, but not including, the date of purchase (the “Change of 
Control Payment”). 

“Change of Control” means the occurrence of any of the following: (1) the direct or indirect 
sale, transfer, conveyance or other disposition (other than by way of merger or consolidation), in 
one or a series of related transactions, of all or substantially all of the assets of us and our Subsidiaries 
taken as a whole to any Person or group of related Persons for purposes of Section 13(d) of the 
Exchange Act (a “Group”) other than us or one of our subsidiaries; (2) the approval by the holders 
of our common stock of any plan or proposal for our liquidation or dissolution; (3) the consummation 
of any transaction (including, without limitation, any merger or consolidation) the result of which 
8

 
is that any Person or Group becomes the beneficial owner, directly or indirectly, of more than 50% 
of the then outstanding number of shares of our Voting Stock; or (4) the first day on which a majority 
of the members of our board of directors are not Continuing Directors. 

Notwithstanding the foregoing, a transaction will not be deemed to involve a Change of 
Control if (1) we become a direct or indirect wholly owned subsidiary of a holding company and 
(2)(A) the direct or indirect holders of the Voting Stock of such holding company immediately 
following that transaction are substantially the same as the holders of our Voting Stock immediately 
prior to that transaction or (B) immediately following that transaction no Person or Group (other 
than a holding company satisfying the requirements of this sentence) is the beneficial owner, directly 
or indirectly of more than 50% of the Voting Stock of such holding company. 

“Change of Control Triggering Event” means the occurrence of both a Change of Control 
and a Below Investment Grade Rating Event (as such term is defined in the indenture) occurring 
in respect of that Change of Control. 

“Continuing Directors” means, as of any date of determination, any member of our board 
of directors who (1) was a member of our board of directors on the date of the issuance of the 2030 
Notes; or (2) was nominated or approved for election, elected or appointed to our board of directors 
with the approval of a majority of the Continuing Directors who were members of our board of 
directors at the time of such nomination, approval, election or appointment (either by a specific 
vote or by approval of the proxy statement issued by us in which such member was named as a 
nominee for election as a director). 

“Person” means any individual, firm, limited liability company, corporation, partnership, 
association,  joint  venture,  tribunal,  trust,  government  or  political  subdivision  or  agency  or 
instrumentality  thereof,  or  any  other  entity  or  organization  and  includes  a  “person”  as  used  in 
Section 13(d)(3) of the Exchange Act. 

“Voting Stock” of any specified Person as of any date means the capital stock of such Person 
that is at the time entitled to vote generally in the election of the board of directors of such Person. 

The  definition  of  “Change  of  Control”  includes  a  phrase  relating  to  the  sale,  transfer, 
conveyance or other disposition of “all or substantially all” of our consolidated assets. There is no 
precise, established definition of the phrase “substantially all” under applicable law. Accordingly, 
your ability to require us to purchase your 2030 Notes as a result of the sale, transfer, conveyance 
or other disposition of less than all of our assets may be uncertain. 

Certain Covenants 

The  indenture  contains,  among  others,  restrictive  covenants  regarding  (i)  our  ability  to 
consolidate or merge with another entity or to sell, transfer or otherwise convey all or substantially 
all of our assets to another entity, (ii) create or permit certain significant subsidiaries to create or 
permit  to  exist  certain  liens  and  (iii)  certain  sale  and  lease-back  transactions  involving  certain 
subsidiaries.  

Events of Default 

Holders of the 2030 Notes will have specified rights if an Event of Default (as defined below) 

occurs. The term “Event of Default” in respect of the 2030 Notes means any of the following: 

9

  
(1) we do not pay interest on any of the 2030 Notes within 30 days of its due date;

(2) we fail to pay the principal (or premium, if any) of any 2030 Note, when such principal 
becomes due and payable, at maturity, upon acceleration, upon redemption or otherwise;

(3) we fail to comply with certain covenants under the indenture;

(4) we remain in breach of a covenant or warranty in respect of the indenture or 2030 Notes 
(other than a covenant included in the indenture solely for the benefit of debt securities 
of another series) for 90 days after we receive a written notice of default, which notice 
must be sent by either the trustee or holders of at least 25% in principal amount of the 
outstanding 2030 Notes; 

(5) we  file  for  bankruptcy,  or  other  events  of  bankruptcy,  insolvency  or  reorganization 

specified in the indenture;

(6) we default on any indebtedness of ours or of a significant subsidiary having an aggregate 
amount of at least $150,000,000, constituting a default either of payment of principal 
when due and payable or which results in acceleration of the indebtedness unless the 
default has been cured or waived or the indebtedness discharged in full within 60 days 
after we have been notified of the default by the trustee or holders of at least 25% of the 
outstanding 2030 Notes; or

(7) one or more final judgments for the payment of money in an aggregate amount in excess 
of  $150,000,000  above  available insurance  or  indemnity coverage  shall  be  rendered 
against us or any significant subsidiary and the same shall remain undischarged for a 
period of 60 consecutive days during which execution shall not be effectively stayed.

If an Event of Default (other than an Event of Default specified in clause (5) above) with respect 
to the 2030 Notes has occurred, the trustee or the holders of at least 25% in principal amount of the 
2030 Notes may declare the entire unpaid principal amount of (and premium, if any), and all the 
accrued interest on, the Notes to be due and immediately payable. This is called a declaration of 
acceleration of maturity. There is no action on the part of the trustee or any holder of the 2030 Notes 
required for such declaration if the Event of Default is the Company’s bankruptcy, insolvency or 
reorganization. Holders of a majority in principal amount of the 2030 Notes may also waive certain 
past defaults under the indenture with respect to the 2030 Notes on behalf of all of the holders of 
the  2030  Notes.  A  declaration  of  acceleration  of  maturity  may  be  canceled,  under  specified 
circumstances, by the holders of at least a majority in principal amount of the 2030 Notes and the 
trustee. 

Except in cases of default, where the trustee has special duties, the trustee is not required to take 
any action under the indenture at the request of holders unless the holders offer the trustee protection 
from expenses and liability satisfactory to the trustee. If an indemnity satisfactory to the trustee is 
10

 
 
provided, the holders of a majority in principal amount of 2030 Notes may direct the time, method 
and place of conducting any lawsuit or other formal legal action seeking any remedy available to 
the trustee. The trustee may refuse to follow those directions in certain circumstances specified in 
the indenture. No delay or omission in exercising any right or remedy will be treated as a waiver 
of the right, remedy or Event of Default. 

Modification of the Indenture and Waiver of Rights of Holders 

Under certain circumstances, we can make changes to the indenture and the 2030 Notes. Some 
types of changes require the approval of each holder of 2030 Notes, some require approval by a 
vote of a majority of the holders of the 2030 Notes, and some changes do not require any approval 
at all. 

11

Description of the 1.75% Senior Notes Due 2029

The 1.75% Senior Notes due 2029 (the “2029 Notes”) were issued under an indenture, dated 
as of June 7, 2013 (the “base indenture”) between Nasdaq, Inc. and Wells Fargo Bank, National 
Association, as trustee (the “Trustee”) and a sixth supplemental indenture dated as of April 1, 2019 
(the “supplemental indenture” and, together with the base indenture, the “indenture”). The indenture 
is publicly available at www.sec.gov.

We issued €600  million aggregate principal amount of the 2029 Notes on April 1, 2019.

This summary is subject to, and qualified in its entirety by reference to, all the provisions of 

the 2029 Notes and the indenture, including definitions of certain terms used therein.  

General 

The 2029 Notes: 

• 

• 

• 

• 

are senior unsecured obligations;

rank equally in right of payment with all of our other senior unsecured indebtedness 
from time to time outstanding, commercial paper issuances and indebtedness under 
our 2017 credit facility;

are structurally subordinated in right of payment to all existing and future obligations 
of our subsidiaries, including claims with respect to trade payables; and

are effectively subordinated in right of payment to all of our existing and future secured 
indebtedness and other secured obligations to the extent of the value of the collateral 
securing any such indebtedness and other obligations.

The 2029 Notes were issued in minimum denominations of €100,000  and integral multiples 

of €1,000  in excess thereof. 

Principal, Maturity and Interest 

The 2029 Notes bear interest at a rate of 1.75% per year. Interest on the 2029 Notes is  payable 
annually in arrears on of each year, beginning on March 28, 2020, and is computed on the basis of 
the actual number of days in the period for which interest is being calculated and the actual number 
of days from and including the last date on which interest was paid on the 2029 Notes (or the 
settlement date if no interest has been paid or duly provided for on the 2029 Notes), to but excluding 
the next date on which interest is paid or duly provided for. This payment convention is referred to 
as ACTUAL/ACTUAL  (ICMA)  as  defined  in  the  rulebook  of  the  International  Capital  Market 
Association. Interest on the 2029 Notes accrues from and including the settlement date and will be 
paid to holders of record on the day immediately prior to the applicable interest payment date. 

The 2029 Notes will mature on March 28, 2029. On the maturity date of the 2029 Notes, the 
holders will be entitled to receive 100% of the principal amount of such 2029 Notes. The 2029 
Notes will not have the benefit of any sinking fund. 

12

If any interest payment date, redemption date or maturity date falls on a day that is not a 
business day, then the relevant payment may be made on the next succeeding business day and no 
interest will accrue because of such delayed payment. With respect to the 2029 Notes, when we use 
the term “business day” we mean any day except a Saturday, a Sunday or a day on which banking 
institutions  in  the  applicable  place  of  payment  are  authorized  or  required  by  law,  regulation  or 
executive order to close. 

Claims against the Company for payment of principal, interest and additional amounts, if any, 
on the 2029 Notes will become void unless presentment for payment is made (where so required 
under the indenture) within, in the case of principal and additional amounts, if any, a period of ten 
years or, in the case of interest, a period of five years, in each case from the applicable original date 
of payment therefor. 

Euro Notes—Issuance in Euros 

Initial holders of the 2029 Notes paid for the 2029 Notes in euros, and principal, premium, 
if any, and interest payments and additional amounts, if any, in respect of the Notes will be payable 
in  euros.  If  the  euro  is  unavailable  to  us  due  to  the  imposition  of  exchange  controls  or  other 
circumstances beyond our control or the euro is no longer used by the then member states of the 
European Monetary Union that have adopted the euro as their currency or for the settlement of 
transactions by public institutions within the international banking community, then all payments 
in respect of the 2029 Notes will be made in U.S. dollars until the euro is again available to us or 
so used. 

The amount payable on any date in euros will be converted to U.S. dollars on the basis of 
the most recently available market exchange rate for euros as determined by us in our sole discretion. 
Any payment in respect of the 2029 Notes so made in U.S. dollars will not constitute an event of 
default under the indenture or the 2029 Notes. Neither the trustee nor the paying agent will be 
responsible  for  obtaining  exchange  rates,  effecting  conversions  or  otherwise  handling 
redenominations. 

Interest Rate Adjustment 

The interest rate payable on the 2029 Notes will be subject to adjustment from time to time if 
either Moody’s or S&P, or, in either case, any substitute rating agency downgrades (or subsequently 
upgrades) the credit rating assigned to the 2029 Notes. 

Ranking 

The 2029 Notes are general unsecured obligations of ours and rank equally with all of our 

existing and future unsubordinated obligations. 

Holders of any secured indebtedness and other secured obligations of the Company will have 
claims that are prior to claims as holders of the 2029 Notes, to the extent of the value of the assets 
securing such indebtedness and other obligations, in the event of any bankruptcy, liquidation or 
similar proceeding. 

Further Issues 

13

The 2029 Notes constituted a separate series of debt securities under the indenture, limited to 
€600  million. Under the indenture, we may, without the consent of the holders of the 2029 Notes, 
issue additional 2029 Notes of the same or a different series from time to time in the future in an 
unlimited aggregate principal amount; provided, that, if any such additional 2029 Notes are not 
fungible with the 2029 Notes (or any other tranche of additional 2029 Notes) for U.S. federal income 
tax  purposes,  then  such  additional  2029  Notes  will  have  different  ISIN  and/or  Common  Code 
numbers than the 2029 Notes (and any such other tranche of additional 2029 Notes). The 2029 
Notes and any additional 2029 Notes of the same series would rank equally and ratably and would 
be treated as a single class for all purposes under the indenture. This means that, in circumstances 
where the indenture provides for the holders of debt securities of any series to vote or take any 
action, any of the outstanding 2029 Notes, as well as any additional 2029 Notes that we may issue 
by reopening such series, will vote or take action as a single class. 

Redemption 

Optional Redemption 

The 2029 Notes will be redeemable, in whole at any time or in part from time to time, at our 
option, at a redemption price (the “make-whole redemption price”) equal to the greater of (i) 100% 
of the principal amount of the 2029 Notes, and (ii) as determined by the Quotation Agent (as defined 
below), the sum of the present values of the remaining scheduled payments of principal and interest 
on the 2029 Notes (exclusive of interest accrued and unpaid as of the date of redemption), discounted 
to the date of redemption on an annual basis (ACTUAL/ACTUAL (ICMA)) at the Bund Rate (as 
defined  below),  plus  30  basis  points,  plus  accrued  and  unpaid  interest  thereon  to  the  date  of 
redemption. However, if the redemption date is after a record date and on or prior to a corresponding 
interest payment date, the interest will be paid on the redemption date to the holder of record on 
the record date. 

Notwithstanding the foregoing, at any time on or after December 28, 2028 (three months before 
their maturity date), the 2029 Notes will be redeemable, in whole or in part, at our option and at 
any time or from time to time, at a redemption price equal to 100% of the principal amount of the 
2029 Notes to be redeemed plus accrued and unpaid interest thereon to, but excluding, the date of 
redemption. 

Notice of any redemption will be mailed at least 30 days, but not more than 60 days, before 
the  redemption  date  to  each  registered  holder  of  2029  Notes  to  be  redeemed.  Once  notice  of 
redemption is mailed, the 2029 Notes called for redemption will become due and payable on the 
redemption date and at the applicable redemption price, plus accrued and unpaid interest to, but not 
including, the redemption date. Unless we default in payment of the redemption price, on and after 
the  redemption  date,  interest  will  cease  to  accrue  on  the  2029  Notes  (or  portion  thereof)  to  be 
redeemed on such redemption date. 

“Bund Rate” means, with respect to any redemption date, the rate per annum equal to the 
annual equivalent yield to maturity of the Comparable German Bund Issue, assuming a price for 
the Comparable German Bund Issue (expressed as a percentage of its principal amount) equal to 
the Comparable German Bund Price for such redemption date. 

14

“Comparable German Bund Issue” means that German Bundesanleihe security selected by 
the Quotation Agent as having a maturity comparable to the remaining term of the Notes to be 
redeemed that would be utilized, at the time of selection and in accordance with customary financial 
practice, in pricing new issues of corporate notes of comparable maturity to the remaining term of 
the Notes. 

“Comparable German Bund Price” means, with respect to any redemption date, (i) the average 
of four Reference German Bund Dealer Quotations for such redemption date, after excluding the 
highest and lowest such Reference German Bund Dealer Quotations, or (ii) if the Quotation Agent 
obtains fewer than four such Reference German Bund Dealer Quotations, the average of all such 
quotations. 

“Quotation Agent” means a Reference German Bund Dealer appointed by us. 

“Reference  German  Bund  Dealer”  means  any  dealer  of  German  Bundesanleihe  securities 

selected by us in good faith. 

“Reference German Bund Dealer Quotations” means, with respect to each Reference German 
Bund Dealer and any redemption date, the average, as determined by us, of the bid and asked prices 
for the Comparable German Bund Issue (expressed in each case as a percentage of its principal 
amount) quoted in writing to the Quotation Agent by such Reference German Bund Dealer at 3:30 
p.m., Frankfurt, Germany time, on the third business day preceding such redemption date. 

If we elect to redeem less than all of the 2029 Notes, and such 2029 Notes are at the time 
represented by a global note, then the depositary will select by lot the particular interests to be 
redeemed. If we elect to redeem less than all of the 2029 Notes, and any of such 2029 Notes are 
not represented by a global note, then the trustee will select the particular 2029 Notes to be redeemed 
in a manner it deems appropriate and fair (and the depositary will select by lot the particular interests 
in any global note to be redeemed). 

We may at any time, and from time to time, purchase the 2029 Notes at any price or prices in 

the open market or otherwise. 

Repurchase upon Change of Control Triggering Event 

If a Change of Control Triggering Event (as defined below) occurs with respect to the 2029 
Notes, unless we have exercised our right to redeem the 2029 Notes, we are required to make an 
offer to repurchase all or, at the holder’s option, any part (equal to €100,000  or any integral multiple 
of €1,000  in excess thereof) of each holder’s 2029 Notes pursuant to the offer described below (the 
“Change of Control Offer”). 

In the Change of Control Offer, we will be required to offer payment in cash equal to 101% 
of the aggregate principal amount of 2029 Notes repurchased plus accrued and unpaid interest, if 
any, on the Notes repurchased to, but not including, the date of purchase (the “Change of Control 
Payment”). 

15

 
“Change of Control” means the occurrence of any of the following: (1) the direct or indirect 
sale, transfer, conveyance or other disposition (other than by way of merger or consolidation), in 
one or a series of related transactions, of all or substantially all of the assets of us and our Subsidiaries 
taken as a whole to any Person or group of related Persons for purposes of Section 13(d) of the 
Exchange Act (a “Group”) other than us or one of our subsidiaries; (2) the approval by the holders 
of our common stock of any plan or proposal for our liquidation or dissolution; (3) the consummation 
of any transaction (including, without limitation, any merger or consolidation) the result of which 
is that any Person or Group becomes the beneficial owner, directly or indirectly, of more than 50% 
of the then outstanding number of shares of our Voting Stock; or (4) the first day on which a majority 
of the members of our board of directors are not Continuing Directors. 

Notwithstanding the foregoing, a transaction will not be deemed to involve a Change of Control 
if (1) we become a direct or indirect wholly owned Subsidiary of a holding company and (2)(A) 
the direct or indirect holders of the Voting Stock of such holding company immediately following 
that transaction are substantially the same as the holders of our Voting Stock immediately prior to 
that transaction or (B) immediately following that transaction no Person or Group (other than a 
holding company satisfying the requirements of this sentence) is the beneficial owner, directly or 
indirectly of more than 50% of the Voting Stock of such holding company. 

“Change of Control Triggering Event” means the occurrence of both a Change of Control and 
a Below Investment Grade Rating Event (as such term is defined in the indenture) occurring in 
respect of that Change of Control. 

“Continuing Directors” means, as of any date of determination, any member of our board of 
directors who (1) was a member of our board of directors on the date of the issuance of the Notes; 
or (2) was nominated or approved for election, elected or appointed to our board of directors with 
the approval of a majority of the Continuing Directors who were members of our board of directors 
at the time of such nomination, approval, election or appointment (either by a specific vote or by 
approval of the proxy statement issued by us in which such member was named as a nominee for 
election as a director). 

  “Person”  means  any  individual,  firm,  limited  liability  company,  corporation,  partnership, 
association,  joint  venture,  tribunal,  trust,  government  or  political  subdivision  or  agency  or 
instrumentality  thereof,  or  any  other  entity  or  organization  and  includes  a  “person”  as  used  in 
Section 13(d)(3) of the Exchange Act. 

“Voting Stock” of any specified Person as of any date means the capital stock of such Person 
that is at the time entitled to vote generally in the election of the board of directors of such Person. 

The  definition  of  “Change  of  Control”  includes  a  phrase  relating  to  the  sale,  transfer, 
conveyance or other disposition of “all or substantially all” of our consolidated assets. There is no 
precise, established definition of the phrase “substantially all” under applicable law. Accordingly, 
the ability to require us to purchase 2029 Notes as a result of the sale, transfer, conveyance or other 
disposition of less than all of our assets may be uncertain. 

16

Certain Covenants 

The  indenture  contains,  among  others,  restrictive  covenants  regarding  (i)  our  ability  to 
consolidate or merge with another entity or to sell, transfer or otherwise convey all or substantially 
all of our assets to another entity; (ii) create or permit certain significant subsidiaries to create or 
permit  to  exist  certain  liens  and  (iii)  certain  sale  and  lease-back  transactions  involving  certain 
subsidiaries. 

Events of Default 

Holders of the 2029 Notes will have specified rights if an Event of Default (as defined below) 

occurs.  The term “Event of Default” in respect of the Notes means any of the following: 

(1) we do not pay interest on any of the Notes within 30 days of its due date;

(2) we fail to pay the principal (or premium, if any) of any Note, when such principal becomes 

due and payable, at maturity, upon acceleration, upon redemption or otherwise;

(3) failure by us to comply with the covenants under the indenture; 

(4) we remain in breach of a covenant or warranty in respect of the indenture or 2029 Notes 
(other than a covenant included in the indenture solely for the benefit of debt securities of 
another series) for 90 days after we receive a written notice of default, which notice must 
be sent by either the trustee or holders of at least 25% in principal amount of the outstanding 
2029 Notes;

(5) we file for bankruptcy, or other events of bankruptcy, insolvency or reorganization specified 

in the indenture;

(6) we default on any indebtedness of ours or of a significant subsidiary having an aggregate 
amount of at least $150,000,000, constituting a default either of payment of principal when 
due and payable or which results in acceleration of the indebtedness unless the default has 
been cured or waived or the indebtedness discharged in full within 60 days after we have 
been notified of the default by the trustee or holders of at least 25% of the outstanding 
2029 Notes; or

(7) one or more final judgments for the payment of money in an aggregate amount in excess 
of $150,000,000 above available insurance or indemnity coverage shall be rendered against 
us or any significant subsidiary and the same shall remain undischarged for a period of 60 
consecutive days during which execution shall not be effectively stayed.

If an Event of Default (other than an Event of Default specified in clause (5) above) with respect 
to the 2029 Notes has occurred, the Trustee or the holders of at least 25% in principal amount of 
17

 
 
 
 
 
the 2029 Notes may declare the entire unpaid principal amount of (and premium, if any), and all 
the accrued interest on, the Notes to be due and immediately payable. This is called a declaration 
of acceleration of maturity. There is no action on the part of the trustee or any holder of the 2029 
Notes required for such declaration if the Event of Default is the Company’s bankruptcy, insolvency 
or reorganization. Holders of a majority in principal amount of the Notes may also waive certain 
past defaults under the indenture with respect to the 2029 Notes on behalf of all of the holders of 
the  2029  Notes.  A  declaration  of  acceleration  of  maturity  may  be  canceled,  under  specified 
circumstances, by the holders of at least a majority in principal amount of the 2029 Notes and the 
trustee. 

Except in cases of default, where the trustee has special duties, the trustee is not required to 
take any action under the indenture at the request of holders unless the holders offer the trustee 
protection from expenses and liability satisfactory to the trustee. If an indemnity satisfactory to the 
trustee is provided, the holders of a majority in principal amount of 2029 Notes may direct the time, 
method  and  place  of  conducting  any  lawsuit  or  other  formal  legal  action  seeking  any  remedy 
available to the trustee. The trustee may refuse to follow those directions in certain circumstances 
specified in the indenture. No delay or omission in exercising any right or remedy will be treated 
as a waiver of the right, remedy or Event of Default. 

Before holders of the 2029 Notes are allowed to bypass the trustee and bring a lawsuit or other 
formal legal action or take other steps to enforce their rights or protect their interests relating to the 
2029 Notes, the following must occur: 

• 

such holders must give the trustee written notice that an Event of Default has occurred and 
remains uncured;

•  holders of at least 25% in principal amount of the 2029 Notes must make a written request 
that  the  trustee  take  action  because  of  the  default  and  must  offer  the Trustee  indemnity 
satisfactory to the trustee against the cost and other liabilities of taking that action; and

• 

the trustee must have failed to take action for 60 days after receipt of the notice and offer 
of indemnity.

Holders are, however, entitled at any time to bring a lawsuit for the payment of money due on 

the 2029 Notes on or after the due date. 

Modification of the Indenture and Waiver of Rights of Holders 

Under certain circumstances, we can make changes to the indenture and the 2029 Notes. Some 
types of changes require the approval of each holder of 2029 Notes, some require approval by a 
vote of a majority of the holders of the 2029 Notes, and some changes do not require any approval 
at all. 

18

Description of the 1.750% Senior Notes Due 2023

The 1.750% Senior Notes due 2023 (the “2023 Notes”) were issued under an indenture, dated 
as of June 7, 2013 (the “base indenture”) between Nasdaq, Inc. and Wells Fargo Bank, National 
Association, as trustee (the “Trustee”) and a third supplemental indenture dated as of May 20, 2016 
(the “supplemental indenture” and, together with the base indenture, the “indenture”). 

We issued €600  million aggregate principal amount of the 2023 Notes on May 17, 2016.

This summary is subject to, and qualified in its entirety by reference to, all the provisions of 

the 2023 Notes and the indenture, including definitions of certain terms used therein.  

 General 

The 2023 Notes: 

• 

• 

• 

• 

are senior unsecured obligations of ours;

rank equally with all of our other senior unsecured indebtedness from time to time 
outstanding, all indebtedness under our senior credit facility and our term loan credit 
agreement;

are structurally subordinated to all existing and future obligations of our subsidiaries, 
including claims with respect to trade payables; and

are effectively subordinated in right of payment to all of our existing and future secured 
indebtedness and other secured obligations to the extent of the collateral securing any 
such indebtedness and other obligations.

The 2023 Notes were issued in minimum denominations of €100,000  and integral multiples 

of €1,000  in excess thereof. 

Principal, Maturity and Interest 

The 2023 Notes bear interest at a rate of 1.750% per year. Interest on the 2023 Notes is payable 
annually in arrears on May 19 of each year, beginning on May 19, 2017, and is computed on the 
basis of the actual number of days in the period for which interest is being calculated and the actual 
number of days from and including the last date on which interest was paid on the 2023 Notes (or 
the settlement date if no interest has been paid or duly provided for on the 2023 Notes), to but 
excluding the next date on which interest is paid or duly provided for. This payment convention is 
referred to as ACTUAL/ACTUAL (ICMA) as defined in the rulebook of the International Capital 
Market Association. Interest on the 2023 Notes accrues from and including the settlement date and 
will be paid to holders of record on the day immediately prior to the applicable interest payment 
date. 

The 2023 Notes mature on May 19, 2023. On the maturity date of the 2023 Notes, the holders 
will be entitled to receive 100% of the principal amount of such 2023 Notes. The 2023 Notes will 
not have the benefit of any sinking fund. 

19

If any interest payment date, redemption date or maturity date falls on a day that is not a 
business day, then the relevant payment may be made on the next succeeding business day and no 
interest will accrue because of such delayed payment. With respect to the Notes, when we use the 
term “business day” we mean any day except a Saturday, a Sunday or a day on which banking 
institutions  in  the  applicable  place  of  payment  are  authorized  or  required  by  law,  regulation  or 
executive order to close. 

Claims against the Company for payment of principal, interest and additional amounts, if any, 
on the 2023 Notes will become void unless presentment for payment is made (where so required 
under the indenture) within, in the case of principal and additional amounts, if any, a period of ten 
years or, in the case of interest, a period of five years, in each case from the applicable original date 
of payment therefor. 

Interest Rate Adjustment 

The interest rate payable on the 2023 Notes will be subject to adjustment from time to time if 
either Moody’s or S&P, or, in either case, any substitute rating agency downgrades (or subsequently 
upgrades) the credit rating assigned to the 2023 Notes. 

Ranking 

The 2023 Notes are general unsecured obligations of ours and rank equally with all of our 

existing and future unsubordinated obligations. 

Holders of any secured indebtedness and other secured obligations of the Company will have 
claims that are prior to claims as holders of the 2023 Notes, to the extent of the value of the assets 
securing such indebtedness and other obligations, in the event of any bankruptcy, liquidation or 
similar proceeding. 

Further Issues 

The Notes constitute a separate series of debt securities under the indenture, initially limited 
to €600  million. Under the indenture, we may, without the consent of the holders of the 2023 Notes, 
issue additional 2023 Notes of the same or a different series from time to time in the future in an 
unlimited aggregate principal amount; provided, that, if any such additional 2023 Notes are not 
fungible with the 2023 Notes offered hereby (or any other tranche of additional Notes) for U.S. 
federal  income  tax  purposes,  then  such  additional  2023  Notes  will  have  different  ISIN  and/or 
Common Code numbers than the 2023 Notes (and any such other tranche of additional 2023 Notes). 
The 2023 Notes and any additional 2023 Notes of the same series would rank equally and ratably 
and would be treated as a single class for all purposes under the indenture. This means that, in 
circumstances where the indenture provides for the holders of debt securities of any series to vote 
or take any action, any of the outstanding 2023 Notes, as well as any additional 2023 Notes that we 
may issue by reopening such series, will vote or take action as a single class. 

20

 
Redemption 

Optional Redemption 

The 2023 Notes will be redeemable, in whole or in part from time to time, at our option, at a 
redemption  price  (the  “make-whole  redemption  price”)  equal  to  the  greater  of  (i) 100%  of  the 
principal amount of the 2023 Notes, and (ii) as determined by the Quotation Agent (as defined 
below), the sum of the present values of the remaining scheduled payments of principal and interest 
on the Notes (exclusive of interest accrued and unpaid as of the date of redemption), discounted to 
the date of redemption on an annual basis (ACTUAL/ACTUAL (ICMA)) at the Bund Rate (as 
defined  below),  plus  30  basis  points,  plus  accrued  and  unpaid  interest  thereon  to  the  date  of 
redemption. However, if the redemption date is after a record date and on or prior to a corresponding 
interest payment date, the interest will be paid on the redemption date to the holder of record on 
the record date. \

Notwithstanding the foregoing, at any time on or after February 19, 2023 (three months before 
their maturity date), the 2023 Notes will be redeemable, as a whole or in part, at our option and at 
any time or from time to time, at a redemption price equal to 100% of the principal amount of the 
2023 Notes to be redeemed plus accrued and unpaid interest thereon to, but excluding, the date of 
redemption. 

Notice of any redemption will be mailed at least 30 days, but not more than 60 days, before 
the  redemption  date  to  each  registered  holder  of  2023  Notes  to  be  redeemed.  Once  notice  of 
redemption is mailed, the 2023 Notes called for redemption will become due and payable on the 
redemption date and at the applicable redemption price, plus accrued and unpaid interest to, but not 
including, the redemption date. Unless we default in payment of the redemption price, on and after 
the  redemption  date,  interest  will  cease  to  accrue  on  the  2023  Notes  (or  portion  thereof)  to  be 
redeemed on such redemption date. 

“Bund Rate” means, with respect to any redemption date, the rate per annum equal to the 
annual equivalent yield to maturity of the Comparable German Bund Issue, assuming a price for 
the Comparable German Bund Issue (expressed as a percentage of its principal amount) equal to 
the Comparable German Bund Price for such redemption date. 

“Comparable German Bund Issue” means that German Bundesanleihe security selected by 
the Quotation Agent as having a maturity comparable to the remaining term of the 2023 Notes to 
be redeemed that would be utilized, at the time of selection and in accordance with customary 
financial practice, in pricing new issues of corporate notes of comparable maturity to the remaining 
term of the Notes. 

“Comparable German Bund Price” means, with respect to any redemption date, (i) the average 
of four Reference German Bund Dealer Quotations for such redemption date, after excluding the 
highest and lowest such Reference German Bund Dealer Quotations, or (ii) if the Quotation Agent 
obtains fewer than four such Reference German Bund Dealer Quotations, the average of all such 
quotations. 

“Quotation Agent” means a Reference German Bund Dealer appointed by us. 

21

“Reference  German  Bund  Dealer”  means  any  dealer  of  German  Bundesanleihe  securities 

selected by us in good faith. 

“Reference German Bund Dealer Quotations” means, with respect to each Reference German 
Bund Dealer and any redemption date, the average, as determined by us, of the bid and asked prices 
for the Comparable German Bund Issue (expressed in each case as a percentage of its principal 
amount) quoted in writing to the Quotation Agent by such Reference German Bund Dealer at 3:30 
p.m., Frankfurt, Germany time, on the third business day preceding such redemption date. 

If we elect to redeem less than all of the 2023 Notes, and such 2023 Notes are at the time 
represented by a global note, then the depositary will select by lot the particular interests to be 
redeemed. If we elect to redeem less than all of the 2023 Notes, and any of such 2023 Notes are 
not represented by a global note, then the trustee will select the particular 2023 Notes to be redeemed 
in a manner it deems appropriate and fair (and the depositary will select by lot the particular interests 
in any global note to be redeemed). 

We may at any time, and from time to time, purchase the 2023 Notes at any price or prices in 

the open market or otherwise. 

Repurchase upon Change of Control Triggering Event 

If a Change of Control Triggering Event (as defined below) occurs with respect to the 2023 
Notes, unless we have exercised our right to redeem the 2023 Notes, we will be required to make 
an offer to repurchase all or, at the holder’s option, any part (equal to €100,000  or any integral 
multiple of €1,000  in excess thereof) of each holder’s 2023 Notes pursuant to the offer described 
below (the “Change of Control Offer”). 

In the Change of Control Offer, we will be required to offer payment in cash equal to 101% 
of the aggregate principal amount of 2023 Notes repurchased plus accrued and unpaid interest, if 
any, on the 2023 Notes repurchased to, but not including, the date of purchase (the “Change of 
Control Payment”). 

 “Change of Control” means the occurrence of any of the following: (1) the direct or indirect 
sale, transfer, conveyance or other disposition (other than by way of merger or consolidation), in 
one or a series of related transactions, of all or substantially all of the assets of us and our Subsidiaries 
taken as a whole to any Person or group of related Persons for purposes of Section 13(d) of the 
Exchange Act (a “Group”) other than us or one of our Subsidiaries; (2) the approval by the holders 
of our common stock of any plan or proposal for our liquidation or dissolution; (3) the consummation 
of any transaction (including, without limitation, any merger or consolidation) the result of which 
is that any Person or Group becomes the beneficial owner, directly or indirectly, of more than 50% 
of the then outstanding number of shares of our Voting Stock; or (4) the first day on which a majority 
of the members of our board of directors are not Continuing Directors. 

Notwithstanding the foregoing, a transaction will not be deemed to involve a Change of Control 
if (1) we become a direct or indirect wholly owned Subsidiary of a holding company and (2)(A) the 
direct or indirect holders of the Voting Stock of such holding company immediately following that 

22

transaction are substantially the same as the holders of our Voting Stock immediately prior to that 
transaction or (B) immediately following that transaction no Person or Group (other than a holding 
company satisfying the requirements of this sentence) is the beneficial owner, directly or indirectly 
of more than 50% of the Voting Stock of such holding company. 

“Change of Control Triggering Event” means the occurrence of both a Change of Control and 
a Below Investment Grade Rating (as such term is defined in the indenture) event occurring in 
respect of that Change of Control. 

“Continuing Directors” means, as of any date of determination, any member of our board of 
directors who (1) was a member of our board of directors on the date of the issuance of the 2023 
Notes; or (2) was nominated or approved for election, elected or appointed to our board of directors 
with the approval of a majority of the Continuing Directors who were members of our board of 
directors at the time of such nomination, approval, election or appointment (either by a specific 
vote or by approval of the proxy statement issued by us in which such member was named as a 
nominee for election as a director). 

  “Person”  means  any  individual,  firm,  limited  liability  company,  corporation,  partnership, 
association,  joint  venture,  tribunal,  trust,  government  or  political  subdivision  or  agency  or 
instrumentality  thereof,  or  any  other  entity  or  organization  and  includes  a  “person”  as  used  in 
Section 13(d)(3) of the Exchange Act. 

 “Voting Stock” of any specified Person as of any date means the capital stock of such Person 
that is at the time entitled to vote generally in the election of the board of directors of such Person. 

The  definition  of  “Change  of  Control”  includes  a  phrase  relating  to  the  sale,  transfer, 
conveyance or other disposition of “all or substantially all” of our consolidated assets. There is no 
precise, established definition of the phrase “substantially all” under applicable law. Accordingly, 
the ability to require us to purchase 2023 Notes as a result of the sale, transfer, conveyance or other 
disposition of less than all of our assets may be uncertain. 

Certain Covenants 

The  indenture  contains,  among  others,  restrictive  covenants  regarding  (i)  our  ability  to 
consolidate or merge with another entity or to sell, transfer or otherwise convey all or substantially 
all of our assets to another entity; (ii) create or permit certain significant subsidiaries to create or 
permit  to  exist  certain  liens  and  (iii)  certain  sale  and  lease-back  transactions  involving  certain 
subsidiaries. 

Events of Default 

Holders of the 2023 Notes will have specified rights if an Event of Default (as defined below) 

occurs. 

The term “Event of Default” in respect of the 2023 Notes means any of the following: 

(1) we do not pay interest on any of the 2023 Notes within 30 days of its due date; 

23

(2) we fail to pay the principal (or premium, if any) of any 2023 Note, when such principal 

becomes due and payable, at maturity, upon acceleration, upon redemption or otherwise; 

(3) failure by us to comply with our covenant obligations;

(4) we remain in breach of a covenant or warranty in respect of the indenture or 2023 
Notes (other than a covenant included in the indenture solely for the benefit of debt securities 
of another series) for 90 days after we receive a written notice of default, which notice must 
be sent by either the trustee or holders of at least 25% in principal amount of the outstanding 
2023 Notes; 

(5) we file for bankruptcy, or other events of bankruptcy, insolvency or reorganization 

specified in the indenture; 

(6)  we  default  on  any  indebtedness  of  ours  or  of  a  significant  subsidiary  having  an 
aggregate amount of at least $150,000,000, constituting a default either of payment of principal 
when due and payable or which results in acceleration of the indebtedness unless the default 
has been cured or waived or the indebtedness discharged in full within 60 days after we have 
been notified of the default by the trustee or holders of at least 25% of the outstanding 2023 
Notes; or 

(7) one or more final judgments for the payment of money in an aggregate amount in 
excess of $150,000,000 above available insurance or indemnity coverage shall be rendered 
against us or any significant subsidiary and the same shall remain undischarged for a period 
of 60 consecutive days during which execution shall not be effectively stayed. 

If an Event of Default (other than an Event of Default specified in clause (5) above) with 
respect to the 2023 Notes has occurred, the trustee or the holders of at least 25% in principal amount 
of the 2023 Notes may declare the entire unpaid principal amount of (and premium, if any), and all 
the accrued interest on, the Notes to be due and immediately payable. This is called a declaration 
of acceleration of maturity. There is no action on the part of the trustee or any holder of the 2023 
Notes required for such declaration if the Event of Default is the Company’s bankruptcy, insolvency 
or reorganization. Holders of a majority in principal amount of the 2023 Notes may also waive 
certain past defaults under the indenture with respect to the 2023 Notes on behalf of all of the holders 
of  the  Notes.  A  declaration  of  acceleration  of  maturity  may  be  canceled,  under  specified 
circumstances, by the holders of at least a majority in principal amount of the 2023 Notes and the 
trustee. 

Except in cases of default, where the trustee has special duties, the trustee is not required to 
take any action under the indenture at the request of holders unless the holders offer the trustee 
protection from expenses and liability satisfactory to the trustee. If an indemnity satisfactory to the 
Trustee is provided, the holders of a majority in principal amount of 2023 Notes may direct the 
time, method and place of conducting any lawsuit or other formal legal action seeking any remedy 
available to the trustee. The trustee may refuse to follow those directions in certain circumstances 
specified in the indenture. No delay or omission in exercising any right or remedy will be treated 
as a waiver of the right, remedy or Event of Default. 

24

Before holders of the 2023 Notes are allowed to bypass the trustee and bring a lawsuit or other 
formal legal action or take other steps to enforce their rights or protect their interests relating to the 
Notes, the following must occur: 

• 

such holders must give the trustee written notice that an Event of Default has occurred and 
remains uncured;

•  holders of at least 25% in principal amount of the 2023 Notes must make a written request 
that  the  trustee  take  action  because  of  the  default  and  must  offer  the  trustee  indemnity 
satisfactory to the trustee against the cost and other liabilities of taking that action; and

• 

the trustee must have failed to take action for 60 days after receipt of the notice and offer 
of indemnity.

Holders are, however, entitled at any time to bring a lawsuit for the payment of money due on 

the 2023 Notes on or after the due date. 

Modification of the Indenture and Waiver of Rights of Holders 

Under certain circumstances, we can make changes to the indenture and the 2023 Notes. Some 
types of changes require the approval of each holder of 2023 Notes, some require approval by a 
vote of a majority of the holders of the 2023 Notes, and some changes do not require any approval 
at all. 

25

 
Description of the 3.875% Senior Notes due 2021

The 3.875% Senior Notes due 2021 (the “2021 Notes”) were issued under an indenture, dated 
as of June 7, 2013 (the “base indenture”) between Nasdaq, Inc. and Wells Fargo Bank, National 
Association, as trustee (the “Trustee”) and a supplemental indenture to be dated as of June 7, 2013 
(the “supplemental indenture” and, together with the base indenture, the “indenture”).

We issued €600  million aggregate principal amount of the 2021 Notes on June 4, 2013.

This summary is subject to, and qualified in its entirety by reference to, all the provisions of 

the 2021 Notes and the indenture, including definitions of certain terms used therein.  

General 

The 2021 Notes: 

• 

are senior unsecured obligations of ours;

•  will rank equally with all of our other senior unsecured indebtedness from time to time 

outstanding and all indebtedness under our senior credit facility;

• 

• 

structurally subordinated to all existing and future obligations of our subsidiaries including 
claims with respect to trade payables;

are effectively subordinated in right of payment to all of our existing and future secured 
indebtedness to the extent of the collateral securing any such indebtedness.

The 2021 Notes were issued in minimum denominations of €100,000  and integral multiples of 

€1,000  in excess thereof. 

Principal, Maturity and Interest 

The 2021 Notes bear interest at a rate of 3.875% per year. Interest on the 2021 Notes will 
be  payable  annually  in  arrears  on  June 7  of  each  year,  beginning  on  June 7,  2014,  and  will  be 
computed on the basis of the actual number of days in the period for which interest is being calculated 
and the actual number of days from and including the last date on which interest was paid on the 
2021 Notes (or the settlement date if no interest has been paid or duly provided for on the 2021 
Notes), to but excluding the next date on which interest is paid or duly provided for. Interest on the 
2021 Notes will accrue from and including the settlement date and will be paid to holders of record 
on the June 6 immediately before the applicable interest payment date. 

The 2021 Notes will mature on June 7, 2021. On the maturity date of the 2021 Notes, the 
holders will be entitled to receive 100% of the principal amount of such Notes. The 2021 Notes 
will not have the benefit of any sinking fund. 

If any interest payment date falls on a day that is not a business day, then payment of interest 
may be made on the next succeeding business day and no interest will accrue because of such 
delayed payment. With respect to the 2021 Notes, when we use the term “business day” we mean 

26

any day except a Saturday, a Sunday or a day on which banking institutions in the applicable place 
of payment are authorized or required by law, regulation or executive order to close. 

Claims against the Company for payment of principal, interest and additional amounts, if any, on 
the 2021 Notes will become void unless presentment for payment is made (where so required under 
the indenture) within, in the case of principal and additional amounts, if any, a period of ten years 
or, in the case of interest, a period of five years, in each case from the applicable original date of 
payment therefor. 

Interest Rate Adjustment 

The interest rate payable on the 2021 Notes will be subject to adjustment from time to time 
if either Moody’s or S&P or, in either case, any substitute rating agency downgrades (or subsequently 
upgrades) the credit rating assigned to such 2021 Notes. 

Ranking 

The 2021 Notes are general unsecured obligations of ours and rank equally with all of our 

existing and future unsubordinated obligations. 

Holders of any secured indebtedness will have claims that are prior to your claims as holders 
of the 2021 Notes, to the extent of the value of the assets securing such indebtedness, in the event 
of any bankruptcy, liquidation or similar proceeding. 

Further Issues 

The 2021 Notes constitute a separate series of debt securities under the indenture. Under 
the indenture, we may, without the consent of the holders of the 2021 Notes, “reopen” such series 
and issue additional 2021 Notes from time to time in the future, but only if such additional 2021 
Notes are issued with less than a de minimis amount of original issue discount or are issued as part 
of a “qualified reopening” for U.S. federal income tax purposes. This means that, in circumstances 
where the indenture provides for the holders of debt securities of any series to vote or take any 
action, any of the outstanding 2021 Notes, as well as any additional 2021 Notes that we may issue 
by reopening such series, will vote or take action as a single class. 

Redemption 

Optional Redemption 

The 2021 Notes will be redeemable, in whole or in part from time to time, at our option, at 
a redemption price (the “make-whole redemption price”) equal to the greater of (i) 100% of the 
principal amount of the 2021 Notes, and (ii) as determined by the Quotation Agent (as defined 
below), the sum of the present values of the remaining scheduled payments of principal and interest 
on the 2021 Notes (exclusive of interest accrued and unpaid as of the date of redemption), discounted 
to the date of redemption on an annual basis (Actual/Actual (ICMA)) at the Bund Rate (as defined 
below), plus 40 basis points, plus accrued and unpaid interest thereon to the date of redemption. 
However, if the redemption date is after a record date and on or prior to a corresponding interest 
payment date, the interest will be paid on the redemption date to the holder of record on the record 
date. 

27

Notice of any redemption will be mailed at least 30 days, but not more than 60 days, before 
the  redemption  date  to  each  registered  holder  of  2021  Notes  to  be  redeemed.  Once  notice  of 
redemption is mailed, the 2021 Notes called for redemption will become due and payable on the 
redemption date and at the applicable redemption price, plus accrued and unpaid interest to, but not 
including, the redemption date. Unless we default in payment of the redemption price, on and after 
the redemption date, interest will cease to accrue on the 2021 Notes (or portion thereof). 

If money sufficient to pay the redemption price of all of the Notes (or portions thereof) to 
be redeemed on the redemption date is deposited with the trustee or paying agent on or before the 
redemption date and certain other conditions are satisfied, then on and after such redemption date, 
interest will cease to accrue on the 2021 Notes (or such portion thereof) called for redemption. 

“Bund Rate” means, with respect to any redemption date, the rate per annum equal to the 
annual equivalent yield to maturity of the Comparable German Bund Issue, assuming a price for 
the Comparable German Bund Issue (expressed as a percentage of its principal amount) equal to 
the Comparable German Bund Price for such redemption date. 

“Comparable German Bund Issue” means that German Bundesanleihe security selected by 
the Quotation Agent as having a maturity comparable to the remaining term of the Notes to be 
redeemed that would be utilized, at the time of selection and in accordance with customary financial 
practice, in pricing new issues of corporate notes of comparable maturity to the remaining term of 
the 2021 Notes. 

“Comparable  German  Bund  Price”  means,  with  respect  to  any  redemption  date,  (i) the 
average of four Reference German Bund Dealer Quotations for such redemption date, after excluding 
the highest and lowest such Reference German Bund Dealer Quotations, or (ii) if the Quotation 
Agent obtains fewer than four such Reference German Bund Dealer Quotations, the average of all 
such quotations. 

“Quotation Agent” means a Reference German Bund Dealer appointed by us. 

“Reference German Bund Dealer” means any dealer of German Bundesanleihe securities 

selected by us in good faith. 

“Reference  German  Bund  Dealer  Quotations”  means,  with  respect  to  each  Reference 
German Bund Dealer and any redemption date, the average, as determined by us, of the bid and 
asked prices for the Comparable German Bund Issue (expressed in each case as a percentage of its 
principal amount) quoted in writing to the Quotation Agent by such Reference German Bund Dealer 
at 3:30 p.m., Frankfurt, Germany time, on the third business day preceding such redemption date. 

If we elect to redeem less than all of the 2021 Notes, and such 2021 Notes are at the time 
represented by a global note, then the depositary will select by lot the particular interests to be 
redeemed. If we elect to redeem less than all of the 2021 Notes, and any of such 2021 Notes are 
not represented by a global note, then the trustee will select the particular 2021 Notes to be redeemed 
in a manner it deems appropriate and fair (and the depositary will select by lot the particular interests 
in any global note to be redeemed). 

28

We may at any time, and from time to time, purchase the 2021 Notes at any price or prices 

in the open market or otherwise. 

Repurchase upon Change of Control Triggering Event 

If a Change of Control Triggering Event (as defined below) occurs with respect to the 2021 
Notes, unless we have exercised our right to redeem the Notes, we will be required to make an offer 
to repurchase all or, at the holder’s option, any part (equal to €100,000  or any integral multiple of 
€1,000  in excess thereof) of each holder’s 2021 Notes pursuant to the offer described below (the 
“Change of Control Offer”). 

In the Change of Control Offer, we will be required to offer payment in cash equal to 101% 
of the aggregate principal amount of 2021 Notes repurchased plus accrued and unpaid interest, if 
any, on the Notes repurchased to, but not including, the date of purchase (the “Change of Control 
Payment”). 

“Change of Control” means the occurrence of any of the following: (1) the direct or indirect 
sale, transfer, conveyance or other disposition (other than by way of merger or consolidation), in 
one or a series of related transactions, of all or substantially all of the assets of us and our subsidiaries 
taken as a whole to any Person or group of related Persons for purposes of Section 13(d) of the 
Exchange Act (a “Group”) other than us or one of our subsidiaries; (2) the approval by the holders 
of our common stock of any plan or proposal for our liquidation or dissolution; (3) the consummation 
of any transaction (including, without limitation, any merger or consolidation) the result of which 
is that any Person or Group becomes the beneficial owner, directly or indirectly, of more than 50% 
of the then outstanding number of shares of our Voting Stock; or (4) the first day on which a majority 
of the members of our board of directors are not Continuing Directors. 

Notwithstanding the foregoing, a transaction will not be deemed to involve a Change of 
Control if (1) we become a direct or indirect wholly owned subsidiary of a holding company and 
(2)(A) the direct or indirect holders of the Voting Stock of such holding company immediately 
following that transaction are substantially the same as the holders of our Voting Stock immediately 
prior to that transaction or (B) immediately following that transaction no Person or Group (other 
than a holding company satisfying the requirements of this sentence) is the beneficial owner, directly 
or indirectly of more than 50% of the Voting Stock of such holding company. 

“Change of Control Triggering Event” means the occurrence of both a Change of Control 
and a Below Investment Grade Rating Event (as such term is defined in the indenture) occurring 
in respect of that Change of Control. 

“Continuing Directors” means, as of any date of determination, any member of our board 
of directors who (1) was a member of our board of directors on the date of the issuance of the 2021 
Notes; or (2) was nominated for election, elected or appointed to our board of directors with the 
approval of a majority of the Continuing Directors who were members of our board of directors at 
the time of such nomination, election or appointment (either by a specific vote or by approval of 
the proxy statement issued by us in which such member was named as a nominee for election as a 
director). 

29

 “Person” means any individual, firm, corporation, partnership, association, joint venture, 
tribunal, trust, government or political subdivision or agency or instrumentality thereof, or any other 
entity or organization and includes a “person” as used in Section 13(d)(3) of the Exchange Act. 

 “Voting Stock” of any specified Person as of any date means the capital stock of such Person 
that is at the time entitled to vote generally in the election of the board of directors of such Person. 

The  definition  of  Change  of  Control  includes  a  phrase  relating  to  the  sale,  transfer, 
conveyance or other disposition of “all or substantially all” of our consolidated assets. There is no 
precise, established definition of the phrase “substantially all” under applicable law. Accordingly, 
your ability to require us to purchase your Notes as a result of the sale, transfer, conveyance or other 
disposition of less than all of our assets may be uncertain. 

Certain Covenants 

The  indenture  contains,  among  others,  restrictive  covenants  regarding  (i)  our  ability  to 
consolidate or merge with another entity or to sell, transfer or otherwise convey all or substantially 
all of our assets to another entity; (ii) create or permit certain significant subsidiaries to create or 
permit  to  exist  certain  liens  and  (iii)  certain  sale  and  lease-back  transactions  involving  certain 
subsidiaries. 

Events of Default 

Holders of the 2021 Notes will have specified rights if an Event of Default (as defined below) 

occurs. 

The term “Event of Default” in respect of the 2021 Notes means any of the following: 

(1) we do not pay interest on any of the 2021 Notes within 30 days of its due date; 

(2) we fail to pay the principal (or premium, if any) of any 2021 Note, when such principal 

becomes due and payable, at maturity, upon acceleration, upon redemption or otherwise; 

(3) failure by us to comply with our covenant obligations;

(4) we remain in breach of a covenant or warranty in respect of the indenture or 2021 
Notes (other than a covenant included in the indenture solely for the benefit of debt securities 
of another series) for 90 days after we receive a written notice of default, which notice must 
be sent by either the trustee or holders of at least 25% in principal amount of the outstanding 
2021 Notes; 

(5) we file for bankruptcy, or other events of bankruptcy, insolvency or reorganization 

specified in the indenture; 

(6)  we  default  on  any  indebtedness  of  ours  or  of  a  significant  subsidiary  having  an 
aggregate amount of at least $150,000,000, constituting a default either of payment of principal 
when due and payable or which results in acceleration of the indebtedness unless the default 
has been cured or waived or the indebtedness discharged in full within 60 days after we have 
been notified of the default by the trustee or holders of at least 25% of the outstanding 2021 
Notes; or 

30

 
(7) one or more final judgments for the payment of money in an aggregate amount in 
excess of $150,000,000 above available insurance or indemnity coverage shall be rendered 
against us or any significant subsidiary and the same shall remain undischarged for a period 
of 60 consecutive days during which execution shall not be effectively stayed. 

If an Event of Default (other than an Event of Default specified in clause (5) above) with 
respect to the 2021 Notes has occurred, the trustee or the holders of at least 25% in principal amount 
of the 2021 Notes may declare the entire unpaid principal amount of (and premium, if any), and all 
the  accrued  interest  on,  such  2021  Notes  to  be  due  and  immediately  payable.  This  is  called  a 
declaration of acceleration of maturity. There is no action on the part of the trustee or any holder 
of the 2021 Notes required for such declaration if the Event of Default is the Company’s bankruptcy, 
insolvency or reorganization. Holders of a majority in principal amount of the 2021 Notes may also 
waive certain past defaults under the indenture with respect to the 2021 Notes on behalf of all of 
the holders of the 2021 Notes. A declaration of acceleration of maturity may be canceled, under 
specified circumstances, by the holders of at least a majority in principal amount of the 2021 Notes 
and the trustee. 

Except in cases of default, where the trustee has special duties, the trustee is not required to 
take any action under the indenture at the request of holders unless the holders offer the trustee 
protection from expenses and liability satisfactory to the trustee. If an indemnity satisfactory to the 
trustee is provided, the holders of a majority in principal amount of 2021 Notes may direct the time, 
method  and  place  of  conducting  any  lawsuit  or  other  formal  legal  action  seeking  any  remedy 
available to the trustee. The trustee may refuse to follow those directions in certain circumstances 
specified in the indenture. No delay or omission in exercising any right or remedy will be treated 
as a waiver of the right, remedy or Event of Default. 

Before holders are allowed to bypass the trustee and bring a lawsuit or other formal legal action 
or take other steps to enforce their rights or protect their interests relating to the 2021 Notes, the 
following must occur: 

• 

such holders must give the trustee written notice that an Event of Default has occurred and 
remains uncured;

•  holders of at least 25% in principal amount of the 2021 Notes must make a written request 
that  the  trustee  take  action  because  of  the  default  and  must  offer  the  trustee  indemnity 
satisfactory to the trustee against the cost and other liabilities of taking that action; and

• 

the Trustee must have failed to take action for 60 days after receipt of the notice and offer 
of indemnity.

Modification of the Indenture and Waiver of Rights of Holders 

Under certain circumstances, we can make changes to the indenture and the 2021 Notes. 
Some types of changes require the approval of each holder of 2021 Notes affected, some require 
approval by a vote of a majority of the holders of the 2021 Notes, and some changes do not require 
any approval at all. 

31

 
Exhibit 21.1

Subsidiaries and Affiliates of Nasdaq, Inc.*

As of February 14, 2020

U.S. Entities

1.  A.S.A.P. Advisor Services, Inc (organized in New York)  
2.  BoardVantage, Inc (organized in Delaware)  
3.  Boston Stock Exchange Clearing Corporation (organized in Massachusetts)  
4.  Channel Capital Group Inc. (organized in Delaware)  
5.  Cinnober Americas Inc. (organized in New York)  
6.  Consolidated Securities Source LLC (organized in Delaware)  
7.  Content Services, LLC (organized in Delaware) -  
8.  Curzon Street Acquisition, LLC (organized in Delaware) 
9.  Directors Desk, LLC (organized in Delaware) 
10.  Dorsey, Wright & Associates, LLC (organized in Virginia)  
11.  ETC Acquisition Corp. (organized in Delaware)  
12.  eVestment Alliance Holdings, Inc. (organized in Delaware) 
13.  eVestment Alliance Holdings, LLC (organized in Georgia) 
14.  eVestment Alliance, LLC (organized in Georgia)  
15.  eVestment, Inc. (organized in Delaware)  
16.  ExactEquity, LLC (organized in Delaware)  
17.  Execution Access, LLC (organized in Delaware) 
18.  FinQloud LLC (organized in Delaware) 
19.  FINRA/Nasdaq Trade Reporting Facility LLC (organized in Delaware) 
20.  FTEN, Inc. (organized in Delaware) 
21.  Fundspire, Inc. (organized in Delaware) 
22.  Global Network Content Services, LLC (organized in Florida) 
23.  GlobeNewswire, Inc. (organized in California) 
24.  Granite Redux, Inc. (organized in Delaware) 
25.  GraniteBlock, Inc. (organized in Delaware) 
26.  Inet Futures Exchange, LLC (organized in Delaware) 
27.  International Securities Exchange Holdings, Inc. (organized in Delaware) 
28.  ISE ETF Ventures LLC (organized in Delaware)  
29.  Kleos Managed Services Holdings, LLC (organized in Delaware)  
30.  Kleos Managed Services, L.P. (organized in Delaware)  
31.  Longitude LLC (organized in Delaware)  
32.  Nasdaq BX, Inc. (organized in Delaware)  
33.  Nasdaq Capital Markets Advisory LLC (organized in Delaware)  
34.  Nasdaq Commodities Clearing LLC (organized in Delaware)  
35.  Nasdaq Corporate Services, LLC (organized in Delaware)  
36.  Nasdaq Corporate Solutions, LLC (organized in Delaware)  
37.  NASDAQ Energy Futures, LLC (organized in Delaware)  
38.  Nasdaq Execution Services, LLC (organized in Delaware)  
39.  NASDAQ Futures, Inc. (organized in Delaware)  
40.  Nasdaq GEMX, LLC (organized in Delaware)  
41.  NASDAQ Global, Inc. (organized in Delaware) 
42.  Nasdaq Governance Solutions, Inc. (organized in Delaware)
43.  Nasdaq Information, LLC (organized in Delaware) 
44.  Nasdaq International Market Initiatives, Inc. (organized in Delaware) 
45.  Nasdaq ISE, LLC (organized in Delaware)  
46.  Nasdaq MRX, LLC (organized in Delaware) 
47.  NASDAQ OMX (San Francisco) Insurance LLC (organized in Delaware) 

48.  NASDAQ OMX BX Equities LLC (organized in Delaware) 
49.  Nasdaq PHLX LLC (organized in Delaware) 
50.  Nasdaq Technology Services, LLC (organized in Delaware) 
51.  Norway Acquisition LLC (organized in Delaware) 
52.  NPM Securities, LLC (organized in Delaware) 
53.  OneReport, Inc, (organized in Vermont)
54.  Operations & Compliance Network, LLC (organized in Delaware)  
55.  Public Plan IQ Limited Liability Company (organized in New Jersey)  
56.  SecondMarket Labs, LLC (organized in Delaware)  
57.  SecondMarket Solutions, Inc. (organized in Delaware)  
58.  SMTX, LLC (organized in Delaware)  
59.  Strategic Financial Solutions, LLC (organized in Nevada)  
60.  Sybenetix Inc. (organized in Delaware)  
61.  The Center for Board Evaluations, Inc. (organized in North Carolina)
62.  The Nasdaq Options Market LLC (organized in Delaware)  
63.  The NASDAQ Private Market, LLC (organized in Delaware)  
64.  The Nasdaq Stock Market LLC (organized in Delaware)  
65.  The Stock Clearing Corporation of Philadelphia (organized in Pennsylvania)  
66.  U.S. Exchange Holdings, Inc. (organized in Delaware)  

Non-U.S. Subsidiaries

1.  2157971 Ontario Ltd. (organized in Canada)  
2.  AB Nasdaq Vilnius (organized in Lithuania) (96.35% owned, directly or indirectly, by Nasdaq, Inc.)  
3.  AS eCSD Expert (organized in Estonia)  
4.  AS Pensionikeskus AS (organized in Estonia)  
5.  BoardVantage (UK) Limited (organized in the United Kingdom)  
6.  Cinetics AB (organized in Sweden)  
7.  Cinnober AB (organized in Sweden)  
8.  Cinnober Financial Technology AB (organized in Sweden)  
9.  Cinnober Financial Technology North AB (organized in Sweden)  
10.  Curzon Street Holdings Limited (organized in the United Kingdom)  
11.  Ensoleillement Inc. (organized in Canada) 
12.  eVestment Alliance (UK) Limited (organized in the United Kingdom)  
13.  eVestment Alliance Australia Pty Ltd (organized in Australia)  
14.  eVestment Alliance Hong Kong Limited (organized in Hong Kong)  
15.  Indxis Ltd (organized in the United Kingdom) 
16.  Irisium AB (organized in Sweden)  
17.  LLC "SYBENETIX UKRAINE" (organized in Ukraine) 
18.  Longitude S.A. (organized in Luxembourg)  
19.  Marketwire China Holding (HK) Ltd. (organized in Hong Kong)  
20.  Minium Financial Technology AB (organized in Sweden) 
21.  Minium Financial Technology Ltd (organized in the United Kingdom)  
22.  Nasdaq (Asia Pacific) Pte. Ltd. (organized in Singapore)  
23.  Nasdaq AB (organized in Sweden)  
24.  Nasdaq Australia Holding Pty Ltd (organized in Australia)  
25.  Nasdaq Broker Services AB (organized in Sweden)  
26.  Nasdaq Canada Inc. (organized in Canada)  
27.  Nasdaq Clearing AB (organized in Sweden)  
28.  Nasdaq Copenhagen A/S (organized in Denmark)  
29.  Nasdaq Corporate Solutions (India) Private Limited (organized in India)  
30.  Nasdaq Corporate Solutions International Limited (organized in the United Kingdom)  
31.  Nasdaq CSD Iceland hf. (organized in Iceland)  
32.  Nasdaq CSD SE (organized in Latvia)  
33.  Nasdaq CXC Limited (organized in Canada)  
34.  Nasdaq Exchange and Clearing Services AB (organized in Sweden)  
35.  Nasdaq France SAS (organized in France)  
36.  Nasdaq Germany GmbH (organized in Germany)  
37.  Nasdaq Helsinki Ltd (organized in Finland)  
38.  Nasdaq Holding AB (organized in Sweden)  
39.  Nasdaq Holding Denmark A/S (organized in Denmark)  
40.  Nasdaq Holding Luxembourg Sárl (organized in Luxembourg)  
41.  Nasdaq Iceland hf. (organized in Iceland)  
42.  Nasdaq International Ltd (organized in the United Kingdom)  
43.  Nasdaq Korea Ltd. (organized in South Korea)  
44.  Nasdaq Ltd (organized in Hong Kong) 
45.  Nasdaq NLX Ltd (organized in the United Kingdom)  
46.  Nasdaq Nordic Ltd (organized in Finland)  
47.  NASDAQ OMX Europe Ltd (organized in the United Kingdom) 
48.  Nasdaq Oslo ASA (organized in Norway)  
49.  Nasdaq Pty Ltd (organized in Australia) 
50.  Nasdaq Riga, AS (organized in Latvia) (92.98% owned, directly or indirectly, by Nasdaq, Inc.) 

51.  Nasdaq Stockholm AB (organized in Sweden)  
52.  Nasdaq Tallinn AS (organized in Estonia)  
53.  Nasdaq Technology (Japan) Ltd (organized in Japan)  
54.  Nasdaq Technology AB (organized in Sweden)  
55.  Nasdaq Technology Canada Inc. (organized in Canada)  
56.  Nasdaq Technology Energy Systems AS (organized in Norway)  
57.  Nasdaq Technology Italy Srl (organized in Italy)  
58.  Nasdaq Teknoloji Servisi Limited Sirketi (organized in Turkey) 
59.  Nasdaq Treasury AB (organized in Sweden) 
60.  Nasdaq Vilnius Services UAB (organized in Lithuania) 
61.  Nasdaq Wizer Solutions AB (organized in Sweden)
62.  Nasdaq Wizer Vilnius UAB (organized in Lithuania)
63.  OMX Netherlands B.V. (organized in the Netherlands)  
64.  OMX Netherlands Holding B.V. (organized in the Netherlands)  
65.  OMX Treasury Euro AB (organized in Sweden) (99.9% owned, directly or indirectly, by Nasdaq, Inc.) 
66.  OMX Treasury Euro Holding AB (organized in Sweden) 
67.  PerTrac Financial Solutions Hong Kong Limited (organized in Hong Kong) 
68.  Quandl, Inc.(organized in Canada)
69.  RF Nordic Express AB (organized in Sweden) (50.1% owned, directly or indirectly, by Nasdaq, Inc.) 
70.  Shareholder.com B.V. (organized in the Netherlands)  
71.  Simplitium Ltd (organized in the United Kingdom) 
72.  SMARTS (Asia) Ltd (organized in China)  
73.  SMARTS Broker Compliance Pty Ltd (organized in Australia)  
74.  SMARTS Market Surveillance Pty Ltd (organized in Australia) 
75.  Sybenetix Limited (organized in the United Kingdom) 
76.  TopQ Software Limited (organized in the United Kingdom) 
77.  Whittaker & Garnier Limited (organized in the United Kingdom) 

* The list of subsidiaries does not include not-for-profit entities or foreign branches of particular subsidiaries

Exhibit 23.1

Consent of Independent Registered Public Accounting Firm

We consent to the incorporation by reference in the following Registration Statements:
(1) 

Registration Statement (Form S-3 No. 333-224489) of Nasdaq, Inc.,

(2) 

(3) 

(4) 

(5) 

(6) 

(7) 

(8) 

(9) 

Registration  Statement  (Form  S-8  No.  333-225218)  pertaining  to  Nasdaq,  Inc.  Equity 
Incentive Plan, 

Registration Statement (Form S-8 No. 333-196838) pertaining to Nasdaq, Inc. (f/k/a The 
NASDAQ OMX Group, Inc.) Equity Incentive Plan, 

Registration Statement (Form S-8 No. 333-167724) pertaining to Nasdaq, Inc. (f/k/a The 
NASDAQ OMX Group, Inc.) Employee Stock Purchase Plan,

Registration Statement (Form S-8 No. 333-167723) pertaining to Nasdaq, Inc. (f/k/a The 
NASDAQ OMX Group, Inc.) Equity Incentive Plan,

Registration Statement (Form S-8 No. 333-110602) pertaining to The Nasdaq Stock Market, 
Inc. Equity Incentive Plan,

Registration  Statement  (Form  S-8  No.  333-106945)  pertaining  to  the  Employment 
Agreement with Robert Greifeld of The Nasdaq Stock Market, Inc., 

Registration Statement (Form S-8 No. 333-76064) pertaining to The Nasdaq Stock Market, 
Inc. 2000 Employee Stock Purchase Plan, 

Registration Statement (Form S-8 No. 333-72852) pertaining to The Nasdaq Stock Market, 
Inc. 2000 Employee Stock Purchase Plan, and

(10)  Registration Statement (Form S-8 No. 333-70992) pertaining to The Nasdaq Stock Market, 

Inc. Equity Incentive Plan;

of our reports dated February 25, 2020, with respect to the consolidated financial statements of 
Nasdaq,  Inc.  and  the  effectiveness  of  internal  control  over  financial  reporting  of  Nasdaq,  Inc. 
included in this Annual Report (Form 10-K) of Nasdaq, Inc. for the year ended December 31, 2019.

New York, New York
February 25, 2020

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Exhibit 24.1

Know all men by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware 
corporation, hereby constitutes and appoints John A. Zecca and Joan C. Conley, and each of them 
acting individually, the undersigned’s true and lawful attorneys-in-fact and agents, each with full 
power and substitution and resubstitution, for him and in his name, place, and stead, in any case 
and all capacities to:

(1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, 
Inc. for the fiscal year ended December 31, 2019, including any and all amendments and additions 
thereto (collectively, the “Annual Report”) in accordance with the Securities Exchange Act of 1934, 
as amended, and the rules thereunder;

(2) do and perform any and all acts for and on behalf of the undersigned which may be 
necessary  or  desirable  to  file,  or  cause  to  be  filed,  the Annual  Report  with  all  exhibits  thereto 
(including this Power of Attorney), and other documents in connection therewith, with the United 
States Securities and Exchange Commission; and

(3) take any other action or any type whatsoever in connection with the foregoing which, 
in the opinion of such attorneys-in-fact, may be of benefit to, in the best interest of, or legally 
required by, the undersigned, it being understood that the documents executed by such attorneys-
in-fact on behalf of the undersigned pursuant to this Power of Attorney shall be in such form and 
shall contain such terms and conditions as such attorneys-in-fact may approve in such attorneys-
in-fact’s discretion.

The undersigned hereby grants to each attorney-in-fact full power and authority to do and 
perform any and every act and thing whatsoever requisite, necessary or proper to be done in the 
exercise of any of the rights and powers herein granted, as fully to all intents and purposes as the 
undersigned might or could do if personally present, with full power of substitution or revocation, 
hereby ratifying and confirming all that such shall lawfully do or cause to be done by virtue of this 
Power of Attorney and the rights and powers herein granted.

IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed 

as of February 24, 2020.

/s/ Melissa M. Arnoldi
Signature

 
 
 
 
 
 
 
 
 
 
 
 
POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Know all men by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware 
corporation, hereby constitutes and appoints John A. Zecca and Joan C. Conley, and each of them 
acting individually, the undersigned’s true and lawful attorneys-in-fact and agents, each with full 
power and substitution and resubstitution, for him and in his name, place, and stead, in any case 
and all capacities to:

(1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, 
Inc. for the fiscal year ended December 31, 2019, including any and all amendments and additions 
thereto (collectively, the “Annual Report”) in accordance with the Securities Exchange Act of 1934, 
as amended, and the rules thereunder;

(2) do and perform any and all acts for and on behalf of the undersigned which may be 
necessary  or  desirable  to  file,  or  cause  to  be  filed,  the Annual  Report  with  all  exhibits  thereto 
(including this Power of Attorney), and other documents in connection therewith, with the United 
States Securities and Exchange Commission; and

(3) take any other action or any type whatsoever in connection with the foregoing which, 
in the opinion of such attorneys-in-fact, may be of benefit to, in the best interest of, or legally 
required by, the undersigned, it being understood that the documents executed by such attorneys-
in-fact on behalf of the undersigned pursuant to this Power of Attorney shall be in such form and 
shall contain such terms and conditions as such attorneys-in-fact may approve in such attorneys-
in-fact’s discretion.

The undersigned hereby grants to each attorney-in-fact full power and authority to do and 
perform any and every act and thing whatsoever requisite, necessary or proper to be done in the 
exercise of any of the rights and powers herein granted, as fully to all intents and purposes as the 
undersigned might or could do if personally present, with full power of substitution or revocation, 
hereby ratifying and confirming all that such shall lawfully do or cause to be done by virtue of this 
Power of Attorney and the rights and powers herein granted.

IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed 

as of February 24, 2020.

/s/ Charlene T. Begley
Signature

 
 
 
 
 
 
 
 
 
 
 
 
POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Know all men by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware 
corporation, hereby constitutes and appoints John A. Zecca and Joan C. Conley, and each of them 
acting individually, the undersigned’s true and lawful attorneys-in-fact and agents, each with full 
power and substitution and resubstitution, for him and in his name, place, and stead, in any case 
and all capacities to:

(1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, 
Inc. for the fiscal year ended December 31, 2019, including any and all amendments and additions 
thereto (collectively, the “Annual Report”) in accordance with the Securities Exchange Act of 1934, 
as amended, and the rules thereunder;

(2) do and perform any and all acts for and on behalf of the undersigned which may be 
necessary  or  desirable  to  file,  or  cause  to  be  filed,  the Annual  Report  with  all  exhibits  thereto 
(including this Power of Attorney), and other documents in connection therewith, with the United 
States Securities and Exchange Commission; and

(3) take any other action or any type whatsoever in connection with the foregoing which, 
in the opinion of such attorneys-in-fact, may be of benefit to, in the best interest of, or legally 
required by, the undersigned, it being understood that the documents executed by such attorneys-
in-fact on behalf of the undersigned pursuant to this Power of Attorney shall be in such form and 
shall contain such terms and conditions as such attorneys-in-fact may approve in such attorneys-
in-fact’s discretion.

The undersigned hereby grants to each attorney-in-fact full power and authority to do and 
perform any and every act and thing whatsoever requisite, necessary or proper to be done in the 
exercise of any of the rights and powers herein granted, as fully to all intents and purposes as the 
undersigned might or could do if personally present, with full power of substitution or revocation, 
hereby ratifying and confirming all that such shall lawfully do or cause to be done by virtue of this 
Power of Attorney and the rights and powers herein granted.

IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed 

as of February 24, 2020.

/s/ Steven D. Black
Signature

 
 
 
 
 
 
 
 
 
 
 
 
POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Know all men by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware 
corporation, hereby constitutes and appoints John A. Zecca and Joan C. Conley, and each of them 
acting individually, the undersigned’s true and lawful attorneys-in-fact and agents, each with full 
power and substitution and resubstitution, for him and in his name, place, and stead, in any case 
and all capacities to:

(1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, 
Inc. for the fiscal year ended December 31, 2019, including any and all amendments and additions 
thereto (collectively, the “Annual Report”) in accordance with the Securities Exchange Act of 1934, 
as amended, and the rules thereunder;

(2) do and perform any and all acts for and on behalf of the undersigned which may be 
necessary  or  desirable  to  file,  or  cause  to  be  filed,  the Annual  Report  with  all  exhibits  thereto 
(including this Power of Attorney), and other documents in connection therewith, with the United 
States Securities and Exchange Commission; and

(3) take any other action or any type whatsoever in connection with the foregoing which, 
in the opinion of such attorneys-in-fact, may be of benefit to, in the best interest of, or legally 
required by, the undersigned, it being understood that the documents executed by such attorneys-
in-fact on behalf of the undersigned pursuant to this Power of Attorney shall be in such form and 
shall contain such terms and conditions as such attorneys-in-fact may approve in such attorneys-
in-fact’s discretion.

The undersigned hereby grants to each attorney-in-fact full power and authority to do and 
perform any and every act and thing whatsoever requisite, necessary or proper to be done in the 
exercise of any of the rights and powers herein granted, as fully to all intents and purposes as the 
undersigned might or could do if personally present, with full power of substitution or revocation, 
hereby ratifying and confirming all that such shall lawfully do or cause to be done by virtue of this 
Power of Attorney and the rights and powers herein granted.

IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed 

as of February 24, 2020.

/s/ Essa Kazim
Signature

 
 
 
 
 
 
 
 
 
 
 
 
POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Know all men by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware 
corporation, hereby constitutes and appoints John A. Zecca and Joan C. Conley, and each of them 
acting individually, the undersigned’s true and lawful attorneys-in-fact and agents, each with full 
power and substitution and resubstitution, for him and in his name, place, and stead, in any case 
and all capacities to:

(1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, 
Inc. for the fiscal year ended December 31, 2019, including any and all amendments and additions 
thereto (collectively, the “Annual Report”) in accordance with the Securities Exchange Act of 1934, 
as amended, and the rules thereunder;

(2) do and perform any and all acts for and on behalf of the undersigned which may be 
necessary  or  desirable  to  file,  or  cause  to  be  filed,  the Annual  Report  with  all  exhibits  thereto 
(including this Power of Attorney), and other documents in connection therewith, with the United 
States Securities and Exchange Commission; and

(3) take any other action or any type whatsoever in connection with the foregoing which, 
in the opinion of such attorneys-in-fact, may be of benefit to, in the best interest of, or legally 
required by, the undersigned, it being understood that the documents executed by such attorneys-
in-fact on behalf of the undersigned pursuant to this Power of Attorney shall be in such form and 
shall contain such terms and conditions as such attorneys-in-fact may approve in such attorneys-
in-fact’s discretion.

The undersigned hereby grants to each attorney-in-fact full power and authority to do and 
perform any and every act and thing whatsoever requisite, necessary or proper to be done in the 
exercise of any of the rights and powers herein granted, as fully to all intents and purposes as the 
undersigned might or could do if personally present, with full power of substitution or revocation, 
hereby ratifying and confirming all that such shall lawfully do or cause to be done by virtue of this 
Power of Attorney and the rights and powers herein granted.

IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed 

as of February 24, 2020.

/s/ Thomas A. Kloet
Signature

 
 
 
 
 
 
 
 
 
 
 
 
POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Know all men by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware 
corporation, hereby constitutes and appoints John A. Zecca and Joan C. Conley, and each of them 
acting individually, the undersigned’s true and lawful attorneys-in-fact and agents, each with full 
power and substitution and resubstitution, for him and in his name, place, and stead, in any case 
and all capacities to:

(1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, 
Inc. for the fiscal year ended December 31, 2019, including any and all amendments and additions 
thereto (collectively, the “Annual Report”) in accordance with the Securities Exchange Act of 1934, 
as amended, and the rules thereunder;

(2) do and perform any and all acts for and on behalf of the undersigned which may be 
necessary  or  desirable  to  file,  or  cause  to  be  filed,  the Annual  Report  with  all  exhibits  thereto 
(including this Power of Attorney), and other documents in connection therewith, with the United 
States Securities and Exchange Commission; and

(3) take any other action or any type whatsoever in connection with the foregoing which, 
in the opinion of such attorneys-in-fact, may be of benefit to, in the best interest of, or legally 
required by, the undersigned, it being understood that the documents executed by such attorneys-
in-fact on behalf of the undersigned pursuant to this Power of Attorney shall be in such form and 
shall contain such terms and conditions as such attorneys-in-fact may approve in such attorneys-
in-fact’s discretion.

The undersigned hereby grants to each attorney-in-fact full power and authority to do and 
perform any and every act and thing whatsoever requisite, necessary or proper to be done in the 
exercise of any of the rights and powers herein granted, as fully to all intents and purposes as the 
undersigned might or could do if personally present, with full power of substitution or revocation, 
hereby ratifying and confirming all that such shall lawfully do or cause to be done by virtue of this 
Power of Attorney and the rights and powers herein granted.

IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed 

as of February 24, 2020.

/s/ John D. Rainey
Signature

 
 
 
 
 
 
 
 
 
 
 
 
POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Know all men by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware 
corporation, hereby constitutes and appoints John A. Zecca and Joan C. Conley, and each of them 
acting individually, the undersigned’s true and lawful attorneys-in-fact and agents, each with full 
power and substitution and resubstitution, for him and in his name, place, and stead, in any case 
and all capacities to:

(1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, 
Inc. for the fiscal year ended December 31, 2019, including any and all amendments and additions 
thereto (collectively, the “Annual Report”) in accordance with the Securities Exchange Act of 1934, 
as amended, and the rules thereunder;

(2) do and perform any and all acts for and on behalf of the undersigned which may be 
necessary  or  desirable  to  file,  or  cause  to  be  filed,  the Annual  Report  with  all  exhibits  thereto 
(including this Power of Attorney), and other documents in connection therewith, with the United 
States Securities and Exchange Commission; and

(3) take any other action or any type whatsoever in connection with the foregoing which, 
in the opinion of such attorneys-in-fact, may be of benefit to, in the best interest of, or legally 
required by, the undersigned, it being understood that the documents executed by such attorneys-
in-fact on behalf of the undersigned pursuant to this Power of Attorney shall be in such form and 
shall contain such terms and conditions as such attorneys-in-fact may approve in such attorneys-
in-fact’s discretion.

The undersigned hereby grants to each attorney-in-fact full power and authority to do and 
perform any and every act and thing whatsoever requisite, necessary or proper to be done in the 
exercise of any of the rights and powers herein granted, as fully to all intents and purposes as the 
undersigned might or could do if personally present, with full power of substitution or revocation, 
hereby ratifying and confirming all that such shall lawfully do or cause to be done by virtue of this 
Power of Attorney and the rights and powers herein granted.

IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed 

as of February 24, 2020.

/s/ Michael R. Splinter
Signature

 
 
 
 
 
 
 
 
 
 
 
 
POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Know all men by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware 
corporation, hereby constitutes and appoints John A. Zecca and Joan C. Conley, and each of them 
acting individually, the undersigned’s true and lawful attorneys-in-fact and agents, each with full 
power and substitution and resubstitution, for him and in his name, place, and stead, in any case 
and all capacities to:

(1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, 
Inc. for the fiscal year ended December 31, 2019, including any and all amendments and additions 
thereto (collectively, the “Annual Report”) in accordance with the Securities Exchange Act of 1934, 
as amended, and the rules thereunder;

(2) do and perform any and all acts for and on behalf of the undersigned which may be 
necessary  or  desirable  to  file,  or  cause  to  be  filed,  the Annual  Report  with  all  exhibits  thereto 
(including this Power of Attorney), and other documents in connection therewith, with the United 
States Securities and Exchange Commission; and

(3) take any other action or any type whatsoever in connection with the foregoing which, 
in the opinion of such attorneys-in-fact, may be of benefit to, in the best interest of, or legally 
required by, the undersigned, it being understood that the documents executed by such attorneys-
in-fact on behalf of the undersigned pursuant to this Power of Attorney shall be in such form and 
shall contain such terms and conditions as such attorneys-in-fact may approve in such attorneys-
in-fact’s discretion.

The undersigned hereby grants to each attorney-in-fact full power and authority to do and 
perform any and every act and thing whatsoever requisite, necessary or proper to be done in the 
exercise of any of the rights and powers herein granted, as fully to all intents and purposes as the 
undersigned might or could do if personally present, with full power of substitution or revocation, 
hereby ratifying and confirming all that such shall lawfully do or cause to be done by virtue of this 
Power of Attorney and the rights and powers herein granted.

IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed 

as of February 24, 2020.

/s/ Jacob Wallenberg
Signature

 
 
 
 
 
 
 
 
 
 
 
 
POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Know all men by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware 
corporation, hereby constitutes and appoints John A. Zecca and Joan C. Conley, and each of them 
acting individually, the undersigned’s true and lawful attorneys-in-fact and agents, each with full 
power and substitution and resubstitution, for him and in his name, place, and stead, in any case 
and all capacities to:

(1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, 
Inc. for the fiscal year ended December 31, 2019, including any and all amendments and additions 
thereto (collectively, the “Annual Report”) in accordance with the Securities Exchange Act of 1934, 
as amended, and the rules thereunder;

(2) do and perform any and all acts for and on behalf of the undersigned which may be 
necessary  or  desirable  to  file,  or  cause  to  be  filed,  the Annual  Report  with  all  exhibits  thereto 
(including this Power of Attorney), and other documents in connection therewith, with the United 
States Securities and Exchange Commission; and

(3) take any other action or any type whatsoever in connection with the foregoing which, 
in the opinion of such attorneys-in-fact, may be of benefit to, in the best interest of, or legally 
required by, the undersigned, it being understood that the documents executed by such attorneys-
in-fact on behalf of the undersigned pursuant to this Power of Attorney shall be in such form and 
shall contain such terms and conditions as such attorneys-in-fact may approve in such attorneys-
in-fact’s discretion.

The undersigned hereby grants to each attorney-in-fact full power and authority to do and 
perform any and every act and thing whatsoever requisite, necessary or proper to be done in the 
exercise of any of the rights and powers herein granted, as fully to all intents and purposes as the 
undersigned might or could do if personally present, with full power of substitution or revocation, 
hereby ratifying and confirming all that such shall lawfully do or cause to be done by virtue of this 
Power of Attorney and the rights and powers herein granted.

IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed 

as of February 24, 2020.

/s/ Lars R. Wedenborn
Signature

 
 
 
 
 
 
 
 
 
 
 
 
POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Know all men by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware 
corporation, hereby constitutes and appoints John A. Zecca and Joan C. Conley, and each of them 
acting individually, the undersigned’s true and lawful attorneys-in-fact and agents, each with full 
power and substitution and resubstitution, for him and in his name, place, and stead, in any case 
and all capacities to:

(1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, 
Inc. for the fiscal year ended December 31, 2019, including any and all amendments and additions 
thereto (collectively, the “Annual Report”) in accordance with the Securities Exchange Act of 1934, 
as amended, and the rules thereunder;

(2) do and perform any and all acts for and on behalf of the undersigned which may be 
necessary  or  desirable  to  file,  or  cause  to  be  filed,  the Annual  Report  with  all  exhibits  thereto 
(including this Power of Attorney), and other documents in connection therewith, with the United 
States Securities and Exchange Commission; and

(3) take any other action or any type whatsoever in connection with the foregoing which, 
in the opinion of such attorneys-in-fact, may be of benefit to, in the best interest of, or legally 
required by, the undersigned, it being understood that the documents executed by such attorneys-
in-fact on behalf of the undersigned pursuant to this Power of Attorney shall be in such form and 
shall contain such terms and conditions as such attorneys-in-fact may approve in such attorneys-
in-fact’s discretion.

The undersigned hereby grants to each attorney-in-fact full power and authority to do and 
perform any and every act and thing whatsoever requisite, necessary or proper to be done in the 
exercise of any of the rights and powers herein granted, as fully to all intents and purposes as the 
undersigned might or could do if personally present, with full power of substitution or revocation, 
hereby ratifying and confirming all that such shall lawfully do or cause to be done by virtue of this 
Power of Attorney and the rights and powers herein granted.

IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed 

as of February 24, 2020.

/s/ Alfred W. Zollar
Signature

 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 31.1

I, Adena T. Friedman, certify that:

1. I have reviewed this Annual Report on Form 10-K of Nasdaq, Inc.;

CERTIFICATION

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material 

fact necessary to make the statements made, in light of the circumstances under which such statements were made, not 
misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present 

in all material respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods 
presented in this report;

4. The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and 

procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as 
defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be 

designed under our supervision, to ensure that material information relating to the registrant, including its consolidated 
subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is 
being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting 
to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and 
the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our 

conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this 
report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred 
during the registrant’s most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that 
has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial 
reporting; and

5. The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control 
over financial reporting, to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons 
performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial 
reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report 
financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in 

the registrant’s internal control over financial reporting.

 /s/    Adena T. Friedman

Name: Adena T. Friedman
Title:

President and Chief Executive Officer

Date: February 25, 2020 

 
 
 
 
 
 
 
 
 
CERTIFICATION

Exhibit 31.2

I, Michael Ptasznik, certify that:

1. I have reviewed this Annual Report on Form 10-K of Nasdaq, Inc.;

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material 

fact necessary to make the statements made, in light of the circumstances under which such statements were made, not 
misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present 

in all material respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods 
presented in this report;

4. The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and 

procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as 
defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be 

designed under our supervision, to ensure that material information relating to the registrant, including its consolidated 
subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is 
being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting 
to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and 
the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our 

conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this 
report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred 
during the registrant’s most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that 
has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial 
reporting; and

5. The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control 
over financial reporting, to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons 
performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial 
reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report 
financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in 

the registrant’s internal control over financial reporting.

 /s/ Michael Ptasznik 

Name: Michael Ptasznik
Title:

Executive Vice President, Corporate Strategy and
Chief Financial Officer

Date: February 25, 2020 

 
 
 
Certification of CEO and CFO Pursuant to
18 U.S.C. Section 1350
as Adopted Pursuant to
Section 906 of the Sarbanes-Oxley Act of 2002

Exhibit 32.1

In connection with the Annual Report on Form 10-K of Nasdaq, Inc. (the “Company”) for the period ended December 31, 
2019 as filed with the Securities and Exchange Commission on the date hereof (the “Report”), Adena T. Friedman, as President 
and Chief Executive Officer of the Company, and Michael Ptasznik, as Executive Vice President, Corporate Strategy and Chief 
Financial Officer of the Company, each hereby certifies, pursuant to 18 U.S.C. § 1350, as adopted pursuant to § 906 of the 
Sarbanes-Oxley Act of 2002, that, to the best of her or his knowledge:

(1) The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 

1934; and

(2) The information contained in the Report fairly presents, in all material respects, the financial condition and 

results of the operations of the Company.

/s/   Adena T. Friedman

Name: Adena T. Friedman
Title:
Date:

President and Chief Executive Officer
February 25, 2020

/s/    Michael Ptasznik

Name: Michael Ptasznik
Title:

Executive Vice President, Corporate Strategy and
Chief Financial Officer
February 25, 2020

Date:

This certification accompanies the Report pursuant to § 906 of the Sarbanes-Oxley Act of 2002 and shall not, except to the 
extent required by the Sarbanes-Oxley Act of 2002, be deemed filed by the Company for purposes of § 18 of the Securities 
Exchange Act of 1934, as amended.