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FY2021 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, 2021

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
(Address of Principal Executive Offices)

10036
(Zip Code)

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

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

Title of each class
Common Stock, $0.01 par value per share
0.900% Senior Notes due 2033
0.875% Senior Notes due 2030
1.75% Senior Notes due 2029

Trading Symbol(s)
NDAQ
NDAQ33
NDAQ30
NDAQ29

Name of each exchange on which registered
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  ☒    No  ☐
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  ☐    No   ☒ 
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 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 been subject to such filing requirements for 
the past 90 days.    Yes  ☒    No  ☐

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 has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control 
over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit 
report. ☒

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 30, 2021, the aggregate market value of the registrant’s common stock held by non-affiliates of the registrant was approximately $21.0 billion 

(this amount represents approximately 119.3 million shares of Nasdaq, Inc.’s common stock based on the last reported sales price of $175.80 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 14, 2022

164,412,114  shares

Documents  Incorporated  by  Reference:  Certain  portions  of  the  Definitive  Proxy  Statement  for  the  2022  Annual  Meeting  of  Shareholders  are  incorporated  by 
reference into Part III of this Form 10-K.

 
 
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.

[Reserved]

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

Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections

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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About this Form 10-K

Throughout this Form 10-K, unless otherwise specified:

“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.

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% senior unsecured notes due June 30, 2026

2029  Notes:  €600  million  aggregate  principal  amount  of 

1.75% senior unsecured notes due March 28, 2029

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

2030  Notes:  €600  million  aggregate  principal  amount  of 

0.875% senior unsecured notes due February 13, 2030

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

2031  Notes:  $650  million  aggregate  principal  amount  of 

1.650% senior unsecured notes due January 15, 2031

“Nasdaq CXC” and “Nasdaq CX2” refer to the Canadian 
cash  equity  trading  books  operated  by  Nasdaq  CXC 
Limited.

“Nasdaq  First  North” 
marketplaces 
companies in the Nordic and Baltic regions.

to  our  alternative 
for  smaller  companies  and  growth 

refers 

“Nasdaq  GEMX”  refers 
operated by Nasdaq GEMX, LLC.

to 

the  options  exchange 

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

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

2033  Notes:  €615  million  aggregate  principal  amount  of 

0.900% senior unsecured notes due July 30, 2033

2040  Notes:  $650  million  aggregate  principal  amount  of 
2.500% senior unsecured notes due December 21, 2040

2050  Notes:  $500  million  aggregate  principal  amount  of 

3.25% senior unsecured notes due April 28, 2050

ARR: Annualized Recurring Revenue

ASU: Accounting Standards Update

ASU  2016-13:  Measurement  of  Credit  Losses  on  Financial 

Instruments

ASR: Accelerated Share Repurchase

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

ATS: Alternative Trading System

AUM: Assets Under Management

“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.

401(k) Plan: Voluntary Defined Contribution Savings Plan

2020  Credit  Facility:  $1.25  billion  senior  unsecured 
revolving  credit  facility,  which  matures  on  December  22, 
2025

2022  Notes:  $600  million  aggregate  principal  amount  of 
0.445% senior unsecured notes due December 21, 2022

2023  Notes:  €600  million  aggregate  principal  amount  of 
1.75% senior unsecured notes; repaid in full and terminated 
in August 2021 

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

CCP: Central Counterparty

CFTC: U.S. Commodity Futures Trading Commission

EMIR: European Market Infrastructure Regulation

Equity Plan: Nasdaq Equity Incentive Plan

ESG: Environmental, Social and Governance

ESPP: Nasdaq Employee Stock Purchase Plan

ETF: Exchange Traded Fund

ETP: Exchange Traded Product

Exchange Act: Securities Exchange Act of 1934, as amended

FASB: Financial Accounting Standards Board

FICC: Fixed Income and Commodities Trading and Clearing

FINRA: Financial Industry Regulatory Authority

IPO: Initial Public Offering

LIBOR: London Interbank Offered Rate

MiFID  II:  Update  to  the  Markets  in  Financial  Instruments 

Directive

ii

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 
Industry  publications  and  surveys 
company  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;  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 
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 
risks  and 
uncertainties  and  are  subject  to  change  based  on  various 
factors,  including  those  discussed  in  the  “Item  1A.  Risk 
Factors” section in this Annual Report on Form 10-K. 

involve 

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.

MiFIR: Markets in Financial Instruments Regulation

MTF: Multilateral Trading Facility

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 

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 2022 Annual Meeting of Shareholders

PSU: Performance Share Unit

Regulation NMS: Regulation National Market System

Regulation  SCI:  Regulation  Systems  Compliance  and 

Integrity

SaaS: Software as a Service

SEC: U.S. Securities and Exchange Commission

SERP: Supplemental Executive Retirement Plan

SFSA: Swedish Financial Supervisory Authority

S&P: Standard & Poor’s

S&P 500: S&P 500 Stock Index

SPAC: Special Purpose Acquisition Company

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

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.

iii

Forward-Looking Statements

“anticipates,” 

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,” 
“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:

“envisions,” 

• our strategic direction;

• the 

integration  of  acquired  businesses, 

including 

accounting decisions relating thereto;

• the  scope,  nature  or  impact  of  acquisitions,  divestitures, 
transactional 
joint  ventures  or  other 

investments, 
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 and services;

• the impact of pricing changes;

• tax matters;

• the cost and availability of liquidity and capital;

• any 

litigation,  or  any 

regulatory  or  government 
investigation or action, to which we are or could become a 
party or which may affect us; and

• the  ongoing  impact  of  the  COVID-19  pandemic  and  the 
response  of  governments  and  other  third  parties  on  our 
business,  operations,  results  of  operations, 
financial 
condition, workforce or the operations or decisions of our 
customers, suppliers or business partners.

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:

• our operating results may be lower than expected;

• our  ability  to  keep  up  with  rapid  technological  advances 

and adequately address cybersecurity risks;

• economic, political and market conditions and fluctuations, 
including inflation, 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 
or 
internationally.

domestically 

regulatory 

oversight 

to 

Most  of  these  factors  are  difficult  to  predict  accurately  and 
are  generally  beyond  our  control.  You  should  consider  the 
forward-looking 
uncertainty  and  any  risk  related 
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 
the 
protection of the safe harbor for forward-looking statements 
contained  in  the  Private  Securities  Litigation  Reform  Act  of 
1995.

in  any  document,  we  claim 

• 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 
from  business  combinations, 
acquisitions, divestitures or other transactional activities;

synergies 

realize 

• loss of significant trading and clearing volumes or values, 
listed  companies,  market  data 

fees,  market  share, 
customers or other customers;

• our  ability 
businesses, 
offerings;

to  develop  and  grow  our  non-trading 
technology  and  analytics 
including  our 

iv

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  Technology,  Investment 
Intelligence, Corporate Platforms and Market Services.

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 an independent registered 
national securities exchange in 2007.

Inc.  This 

In  February  2008,  Nasdaq  and  OMX  AB  combined  their 
businesses,  and  we  changed  our  corporate  name  to  The 
NASDAQ  OMX  Group, 
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.  We  operated  as  the  NASDAQ  OMX  Group  until  we 
rebranded our business as Nasdaq, Inc. in 2015. 

Growth Strategy

To  ensure  our  continued  success  in  the  evolving  business 
environment,  we  have  established  a  clear  and  consistent 
vision, mission, purpose and strategy:

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

Our  Mission:  To  provide 
the  premier  platform  and 
ecosystem  for  global  capital  markets  and  beyond  with 
unmatched technology, insights and markets expertise.

Our Purpose: To champion inclusive growth and prosperity. 
We  power  stronger  economies,  create  more  equitable 
opportunities  and  contribute  to  a  more  sustainable  world  to 
help  our  communities,  clients,  employees  and  people  of  all 
backgrounds reach their full potential.

Our Strategy: 

infrastructure 

Under the strategic direction that we have been implementing 
over the past five years, we have focused on maximizing the 
resources, people and capital allocated to our largest growth 
include  anti-
opportunities.  These  opportunities,  which 
financial  crime  and  market 
technology 
solutions,  analytics  and  workflows  for  investment  managers 
and  asset  owners,  and  ESG  solutions,  constitute  large  and 
growing  opportunities  where  we  feel  our  strengths  in 
technology,  analytics  and  capital  markets  expertise, 
combined  with  our  expansive  client  network,  position  us  to 
meet  our  clients’  evolving  needs.  We  are  also  committed  to 
investing  to  maintain  the  strong  competitive  positioning  of 
our  foundational  marketplace  and  corporate  businesses,  as 
well as over time reducing capital allocated to areas that we 
believe  are  less  strategic  to  our  clients  and  which  have  less 
long-term growth potential within Nasdaq.

Our  four  business  segments  reflect  our  broad  capabilities, 
Intelligence 
with  Market  Technology  and 
providing our technology and analytics growth platform, and 
Corporate  Platforms  and  Market  Services  serving  as  our 
foundational marketplace core. 

Investment 

• Increasing  Investment  in  Businesses  Where  We  See  the 
Highest  Growth  Opportunity.  We  have 
increased 
investment  in  fast-growing  markets  that  we  believe  help 
solve  our  clients’  biggest  challenges  and  are  likely  to 
generate growth for our stockholders. These areas include: 
the  index  and  analytics  business  within  our  Investment 
Intelligence  segment;  broader  governance  technology  and 
consultative  solutions,  including  ESG-focused  solutions, 
within our Corporate Platforms segment; and anti-financial 
crime  solutions  and  trade  surveillance  in  our  Market 
Technology segment. 

1

Products and Services

Market Technology

Powering  over  130  market  infrastructure  operators  and  new 
market  clients  in  more  than  55  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  markets  customers, 
including 
liabilities  securitization, 
cryptocurrencies and sports wagering.

insurance 

those 

in 

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  220  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.

During  2021,  we  continued  to  build  out  our  SaaS  business 
portfolio by extending and migrating our current offerings to 
SaaS.  Across  our  product  portfolio,  ranging  from  our 
Marketplace  Service  Platform  to  our  Surveillance  offerings, 
we  added  more  than  25  new  SaaS  customers.  Additionally, 
our Verafin solutions are offered to our clients entirely on a 
SaaS basis.

Our Market Technology segment has evolved from its origins 
serving  the  capital  markets,  as  we  have  leveraged  NFF  to 
develop  our  SaaS  platform  and  offerings.  We  expect  to 
continue  to  expand  adoption  by  our  clients  of  this  SaaS 
model in the future.

In February 2021, we completed the acquisition of Verafin, 
a  provider  of  anti-financial  crime  management  solutions, 
which  is  part  of  our  Market  Technology  segment.  We  are 
continuing  to  invest  in  the  Market  Technology  segment 
through the expansion, enhancement, and flexibility of our 
technology  platform,  in  addition  to  leveraging  emerging 
technologies  such  as  machine  intelligence  in  our  Trade 
Surveillance offering. 

In  December  2021,  we  completed  the  acquisition  of 
QDiligence,  a  provider  of  software  that  facilitates  digital 
director and officer questionnaires and self-evaluations for 
directors  and  corporate  secretaries.  We  plan  to  integrate 
QDiligence  as  part  of  the  Nasdaq  Governance  Solutions 
business. 

• Enhancing  Our  Foundation.  As  we  strive  to  grow  our 
business,  we  have  also  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. In December 
2021, we announced a multi-year partnership with Amazon 
Web  Services,  or  AWS,  to  migrate  our  North  American 
exchanges  to  the  cloud.  Nasdaq  will  utilize  a  new  edge 
computing  solution  that  was  co-designed  by  Nasdaq  and 
AWS for market infrastructure. The partnership with AWS 
will also further our strategy with our market infrastructure 
clients, including banks, clearing houses, central securities 
depositories  and  regulators  that  rely  on  us  for  their  core 
surveillance 
trading, 
technology.  We  believe  these  offerings  can  provide  such 
clients with added agility in adjusting to changing industry 
dynamics.  We  plan  to  work  with  AWS  to  develop  viable 
cloud choices that include public-cloud and hybrid models. 
The collaboration with AWS also includes opportunities to 
explore  other  ways  to  leverage  AWS’s  cloud  capabilities 
across  our  other  businesses,  including  our  anti-financial 
crime and data and analytics businesses. 

settlement 

clearing 

and 

and 

• Optimizing  Slower  Growth  Businesses.  We  continually 
review areas that are not critical to our core. In June 2021, 
we  sold  our  U.S.  Fixed  Income  business.  This  transaction 
aligns  with  our  strategy  to  concentrate  our  resources  and 
capital  in  order  to  maximize  our  potential  as  a  major 
technology  and  analytics  provider  to  the  global  capital 
markets. See “2021 Divestiture,” of Note 4, “Acquisitions 
and  Divestiture,”  to  the  consolidated  financial  statements 
for further discussion of this transaction.

2

Anti Financial Crime Technology

Integrity  of  markets  is  core  to  everything  we  do  at  Nasdaq. 
As  such,  we  continue  to  extend  our  anti-financial  crime 
strategy in the Market Technology segment. We have seen a 
growing  demand  globally  for  our  products  and  services 
within  the  Anti  Financial  Crime  Technology  business.  Our 
Nasdaq  Trade  Surveillance  solution  is  a  SaaS  solution 
designed  for  brokers  and  other  market  participants  to  assist 
them in complying with market rules, regulations and internal 
market  surveillance  policies.  We  provide  an  anti-money 
laundering  offering  with  an  automated  investigator  tool  for 
retail  banks,  the  Nasdaq  Automated  Investigator.  Verafin 
provides  a  cloud-based  platform  to  help  detect,  investigate, 
and report money laundering and financial fraud to more than 
2,100 financial institutions in North America. 

Market Infrastructure Technology

For Market Infrastructure Operators, 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. 

Recently,  we  have  seen  a  growing  demand  for  our  products 
and service outside of the traditional capital markets. Market 
Technology  currently  offers  its  services  to  several  digital 
assets  exchanges,  two  commercial  real  estate  markets,  the 
reinsurance  market,  and  several  sports  wagering  operators. 
Our  Marketplaces  Services  Platform  provides  next-
generation  marketplace  capabilities  spanning  the  transaction 
lifecycle  to  facilitate  the  exchange  of  assets,  services  and 
information  across  various  types  of  market  ecosystems  and 
machine-to-machine transactions. The Marketplaces Services 
Platform  is  targeted  at  new  markets  and  enables  end-to-end 
marketplace  implementation  without  the  resources  required 
with on-premise solutions.

involve  complex 
Many  Market  Infrastructure  projects 
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.

Investment Intelligence

Our  Investment  Intelligence  segment  provides  the  global 
investing  community  with  access  to  the  financial  markets 
together with strong investment insights. 

Our  Investment  Intelligence  segment  includes  our  Market 
Data, Index and Analytics businesses.

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 
analytics.

Market Data

Our Market Data business sells and distributes historical and 
real-time  market  data  to  the  sell-side,  the  institutional 
investing  community,  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  provide  varying  levels  of  quote  and  trade 
information 
turn  provide 
subscriptions  for  this  information.  Our  systems  enable 
distributors  to  gain  access  to  our  market  depth,  fund 
valuation,  order  imbalances,  market  sentiment  and  other 
analytical data.

to  our  customers  who 

in 

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, and Nordic commodities.

transactions 

information  for  all 

Our  Market  Data  business  also  includes  revenues  from  U.S. 
tape  plans.  The  plan  administrators  sell  quotation  and  last 
in  Nasdaq-listed 
sale 
securities,  whether  traded  on  The  Nasdaq  Stock  Market  or 
other  exchanges, 
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.

to  market  participants  and 

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.

3

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 
Derivatives TotalView, and Nordic Fixed Income TotalView, 
Level 2 and Analytics.

Index 

Our  Index  business  develops  and  licenses  Nasdaq-branded 
indexes  and  financial  products.  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.

As of December 31, 2021, 362 ETPs listed on 25 exchanges 
in  over  20  countries  tracked  a  Nasdaq  index  and  accounted 
for  $424  billion  in  AUM.  This  includes  approximately  $94 
billion in ETP AUM, or 22% of the total AUM that tracked 
our  smart  beta  indexes  during  this  same  time  period.  Our 
flagship  index,  the  Nasdaq-100  Index,  includes  the  top  100 
non-financial companies listed on The Nasdaq Stock Market, 
and  is  tracked  by  more  than  100  ETPs  worldwide,  and  had 
nearly  $300  billion  in  assets  tracking  the  index  as  of 
December 31, 2021. 

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 the indexes that we operate. 

Nasdaq Dorsey Wright, or NDW, provides passive indexing 
and  smart  beta  strategies  to  support  the  financial  advisor 
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. 

Analytics

Our  Analytics  business  provides  asset  managers,  investment 
consultants  and  institutional  asset  owners  with  information 
and  analytics  to  make  data-driven  investment  decisions, 
deploy  their  resources  more  productively,  and  provide 
liquidity solutions for private funds. Through our eVestment 
and  Solovis  solutions,  we  provide  a  suite  of  cloud-based 
solutions  that  help  institutional  investors  and  consultants 
conduct  pre-investment  due  diligence,  and  monitor  their 
portfolios  post-investment.  The  eVestment  platform  also 
enables  asset  managers  to  efficiently  distribute  information 
about  their  firms  and  funds  to  asset  owners  and  consultants 
worldwide.

Additionally,  our  Nasdaq  Cloud  Data  Service  provides  a 
flexible  and  efficient  method  of  delivery  for  real-time 
exchange data and other financial information. Data is made 
through  a  suite  of  application  programming 
available 
interfaces, or APIs, allowing for the integration of data from 
disparate  sources  and  a  reduction  in  time  to  market  for 
customer-designed  applications.  The  API  is  highly  scalable 
and can support the delivery of real-time exchange data.

Through  the  Solovis  platform,  endowments,  foundations, 
pensions  and  family  offices  transform  how  they  collect  and 
aggregate  investment  data,  analyze  portfolio  performance, 
model  and  predict  future  outcomes,  and  share  meaningful 
portfolio  insights  with  key  stakeholders.  The  Nasdaq  Fund 
Network  and  Nasdaq  Data  Link  are  additional  platforms  in 
our  suite  of  investment  data  analytics  offerings  and  data 
management  tools.  Nasdaq  Fund  Network  gathers  and 
distributes daily net asset values from over 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. Nasdaq Data 
Link  strengthens  our  position  as  a  leading  source  for 
financial, economic, and alternative datasets. For investment 
management firms, investment banks and other investors, the 
platform  powers  data-driven  decision-making  for  users 
across the globe via universal APIs, and provides for highly 
efficient data discovery and delivery. Additionally, our Data 
Fabric  solution,  launched  in  2021,  enables  investment  firms 
to leverage the technology and team that powers Nasdaq Data 
Link  to  manage  their  own  internal  data  with  greater  speed 
and efficiency. 

Corporate Platforms

Our  Corporate  Platforms  segment  includes  our  Listing 
Services  and  IR  &  ESG  Services  businesses.  These 
businesses  deliver  critical  capital  market  and  ESG  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  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  may  do  so  on  one  of  the  three  market  tiers:  The 
Nasdaq Global Select Market, The Nasdaq Global Market, or 
The  Nasdaq  Capital  Market.  To  qualify,  companies  must 
meet  minimum  listing  requirements,  including  specified 
financial  and  corporate  governance  criteria.  Once  listed, 
companies  must  maintain  rigorous  listing  and  corporate 
governance  standards.  We  offer  a  suite  of  products  to  assist 
companies  manage 
standards, 
discussed below in “IR & ESG Services.”

corporate  governance 

4

As of December 31, 2021, a total of 4,178 companies listed 
securities  on  The  Nasdaq  Stock  Market,  with  1,632  listings 
on The Nasdaq Global Select Market, 1,169 on The Nasdaq 
Global Market and 1,377 on The Nasdaq Capital Market.

We  seek  new  listings  from  companies  conducting  IPOs, 
including  SPACs,  and  direct  listings  as  well  as  companies 
looking  to  switch  from  alternative  exchanges.  In  2021,  The 
Nasdaq Stock Market attracted 1,000 new listings, including 
752 IPOs, representing 73% of U.S. IPOs in 2021. Of the 752 
IPOs  that  listed  on  The  Nasdaq  Stock  Market,  319  were 
operating  companies,  representing  76%  of  all  operating 
company  IPOs  in  2021  and  71%  of  SPACs  IPOs.  Nasdaq 
featured  the  year's  largest  IPO  as  well  as  the  largest  direct 
listing  by  first  trade  volume.  The  new  listings  were 
comprised of the following:

IPOs

Switches from the New York Stock Exchange 
LLC, or NYSE and the NYSE American LLC, or 
NYSE American
Upgrades from OTC
ETPs and Other Listings

Total

752 

33 
112 
103 
  1,000 

During  2021,  we  had  33  new  listings  resulting  from 
companies  switching  their  listings  from  NYSE  or  NYSE 
American  to  join  Nasdaq.  Together  with  companies  that 
transferred  additional  securities  to  Nasdaq  during  2021,  an 
aggregate  of  $361  billion 
in  global  equity  market 
capitalization switched to Nasdaq. Notable switches in 2021 
included Honeywell, Palo Alto Networks and Lucid Group. 

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,  2021,  a  total  of  1,235  companies  listed 
securities on our Nordic and Baltic exchanges.

equities,  depository 

Our  European  listing  customers  include  companies,  funds 
and  governments.  Customers  issue  securities  in  the  form  of 
cash 
receipts,  warrants,  ETPs, 
convertibles,  rights,  options,  bonds  or  fixed-income  related 
products. In 2021, a total of 207 new companies listed on our 
Nordic  and  Baltic  exchanges.  In  addition,  12  companies 
upgraded  their  listings  from  Nasdaq  First  North  to  Nasdaq 
Main Market.

During  2021,  we  announced  a  joint  venture  with  several 
financial  institutions  to  establish  an  institutional-grade, 
centralized  secondary  trading  venue  for  issuers,  brokers, 
shareholders  and  prospective  investors  of  private  company 
stock. We contributed our Nasdaq Private Market platform to 
this  new,  standalone,  independent  company,  of  which  we 
own  the  largest  minority  interest.  Nasdaq  Private  Market’s 
existing  technology,  client  relationships  and  regulatory 
infrastructure  will  provide  the  foundation  for  the  joint 
venture  to  develop  a  full  suite  of  liquidity  solutions  for 
private companies. Private companies, brokers and investors 

5

transactions 

will  be  able  to  access,  connect,  manage  and  execute  their 
private  company  stock 
through  a  global 
marketplace  and  customized  technology  solutions.  The 
platform  will  continue  to  manage  and  support  private 
company stock transactions including tender offers, buy-side 
book-building,  auctions,  investor  block  trades,  company 
directed  windows  of 
listing 
continuous  trading.  In  addition,  the  platform  will  provide 
end-to-end  settlement  process  management  and  an  inter-
broker  global  marketplace  through  its  existing  ATS  for  all 
customers,  from  employees  to  institutions,  to  access  and 
transact.

liquidity  and  pre-direct 

We  are  continuing  to  grow  our  U.S.  Corporate  Bond 
exchange  for  the  listing  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,  2021,  107 
corporate bonds were listed on the Corporate Bond exchange. 
Our U.S. corporate bond listing offering won 23 new issues 
and we added five existing bond listings that transferred from 
the NYSE.

IR & ESG Services

Our  IR  &  ESG  Services  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 
their  global 
to  understand  and  expand 
shareholder  base, 
improve  corporate  governance,  and 
navigate  the  evolving  ESG  landscape  through  our  suite  of 
advanced  technology,  analytics,  and  consultative  services. 
We  also  provide  clients  with  counsel  on  a  range  of 
governance and sustainability-related issues.

As of December 31, 2021, we provided IR & ESG Services 
offerings in the following key areas:

that  deliver  advisory 

• Investor Relations Intelligence. We offer a global team of 
consultative  experts 
services 
including  Equity  Surveillance  &  Shareholder  Analysis, 
Investor Engagement and Perception Studies, as well as an 
industry-leading platform, Nasdaq IR Insight®, to investor 
relations  professionals  and  executive 
teams.  These 
solutions allow investor relations officers and executives to 
better manage their investor relations programs, understand 
their investor base, target new investors, manage meetings 
and  consume  key  data  such  as  investor  profiles,  equity 
research, consensus estimates and news.

• Environmental,  Social  and  Governance  Solutions.  Our 
ESG  Advisory  practice  helps  companies  analyze,  assess 
and  action  best  practices  to  attract  long-term  capital. 
to 
OneReport,  a  SaaS  solution,  helps  organizations 
navigate  corporate  responsibility  frameworks,  manage 
information capture and response process, and deliver ESG 
data to ratings agencies and other stakeholders.

 
 
 
 
We  also  provide  a  global 
technology  offering  and 
consultative  services  that  streamline  the  meeting  process 
for  board  of  directors  and  executive  leadership  teams  and 
help  them  accelerate  decision  making  and  strengthen 
governance.  Our  solutions  protect  sensitive  data  and 
facilitate  productive  collaboration,  which  enables  board 
members and teams to work faster and more effectively. In 
December 2021, we enhanced our position as a provider of 
governance technology and consultative solutions with the 
acquisition  of  QDiligence,  a  provider  of  software  that 
facilitates  digital  director  and  officer  questionnaires  and 
self-evaluations  for  boards  of  directors  and  corporate 
secretaries.

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,  and 
Denmark  via  the  local  central  securities  depositories.  In 
addition,  Nasdaq  owns  a  central  securities  depository  that 
provides  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  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 2021 represented the largest share of the U.S. 
market  for  all  categories,  including  single-exchange-listed 
options  products.  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 
require high touch services to execute their trades, which are 
often performed on our trading floor in Philadelphia. 

In Europe, Nasdaq offers trading in derivatives, such as stock 
options  and  futures  and  index  options  and  futures.  Nasdaq 
Clearing  offers  central  counterparty  clearing  services  for 
stock options and futures and index options and futures.

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,  institutional  investors,  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  Stockholm 
In  Europe,  Nasdaq  operates  exchanges 
(Sweden),  Copenhagen  (Denmark),  Helsinki  (Finland),  and 
Reykjavik  (Iceland)  as  well  as  the  clearing  operations  of 
Nasdaq  Clearing,  as  Nasdaq  Nordic.  We  also  operate 
exchanges  in  Tallinn  (Estonia),  Riga  (Latvia)  and  Vilnius 
(Lithuania) as Nasdaq Baltic. 

6

Our  FICC  business  includes  Nasdaq  Fixed  Income,  or  NFI, 
offering  trading  and  clearing  services  for  fixed  income 
products in Europe and Nasdaq Commodities. 

NFI provides a wide range of products and services, such as 
trading  and  clearing,  for  fixed  income  products  in  Sweden, 
Denmark,  Finland,  Iceland,  Estonia,  Lithuania  and  Latvia. 
Nasdaq is the largest bond listing venue in the Nordics, with 
more  than  5,600  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. Nasdaq Clearing offers central counterparty 
clearing  services  for  fixed-income  options  and  futures  and 
interest rate swaps. Nasdaq Clearing also operates a clearing 
service for the resale and repurchase agreement market.

Nasdaq  Commodities  is  the  brand  name  for  Nasdaq’s 
European  commodity-related  products  and  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 is the commodity derivatives exchange for 
European  products.  All  trades  with  Nasdaq  Oslo  ASA  are 
subject  to  clearing  with  Nasdaq  Clearing,  which  offers 
central  counterparty  clearing  services  for  commodities 
options and futures.

In June 2021, we sold our U.S. Fixed Income business, which 
included  an  electronic  platform  for  the  trading  of  U.S. 
Treasuries. 

in  Puro.earth,  a  Finnish-based 

Additionally, in June 2021, we completed the acquisition of a 
leading 
majority  stake 
marketplace  for  carbon  removal.  Puro.earth  offers  industrial 
carbon  removal  instruments  that  are  verifiable  and  tradable 
through  an  open,  online  platform.  The  addition  of 
Puro.earth’s  marketplace  capabilities  to  our  suite  of  ESG-
focused  technologies  and  workflow  solutions  gives  our 
clients  further  resources  to  successfully  achieve  their  ESG 
objectives. 

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.  In  April 
2021,  we  launched  WorkX,  an  upgraded  version  of  Nasdaq 
Workstation, a browser-based, front-end interface that allows 
market participants to view data and enter orders, quotes and 
trade  reports.  WorkX  enables  a  seamless  workflow  and 
enhanced trade intelligence. All current Workstation users are 
expected  to  migrate  to  WorkX  by  the  end  of  2022.  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 
offerings  between  select  data  centers  using  millimeter  wave 
and microwave technology. 

enables 
developments. 

end  users 

Competitive Strengths

to 

leverage 

recent 

technology 

trusted, 

We  are  a  global  technology  company  and  we  continue  to 
diversify  our  product  and  service  offerings  by  having  a 
client-first  focus  and  orientation;  unparalleled  expertise  in 
independent,  global  brand;  unique 
markets;  a 
technology  capabilities  and  reputation;  and  fostering  a 
leading issuer community and investor intelligence platform. 
Our  business  segments  complement  each  other.  We  believe 
that  our  strong  competitive  position  in  large,  high-growth 
markets positions us for sustained growth.

and 

securities 

customized 

Our  broker  services  operations  business  primarily  offers 
technology 
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  business.  We  expect  this 
wind-down to continue through the second quarter of 2022.
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  identifying  areas 
for improvement in systems, and 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  to  market  infrastructure 
operators,  buy-side  firms,  sell-side  firms  and  other  non-
financial markets in addition to also supporting Nasdaq's own 
internal trading systems. The framework consists of a single 
operational  core  platform 
together  Nasdaq’s 
portfolio of functionality across the trade lifecycle, in an open 
framework  whereby  exchanges,  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 

that 

ties 

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

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 including:

• 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.

7

Our  surveillance  and  anti-financial  crime  offerings  must 
demonstrate  the  ability  to  decrease  false-positives,  provide 
in-depth views into potential abuses and risks that stem from 
those  cases  and  help  firms  reduce  both  the  reputational  and 
regulatory risk, and complexity in efforts to keep markets and 
financial institutions safe.

Investment Intelligence

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 
systems.  Consolidated  data  products  are 
exchange’s 
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 is under competitive 
threat globally from alternative exchanges and trading venues 
that offer similar products. Our data business competes with 
to  provide 
other  exchanges  and 
third  party  vendors 
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,  including  S&P  Dow  Jones  Indices,  MSCI  and 
FTSE Russell.

Our 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 and any number of smaller firms along with start-up 
data  providers  and  aggregators.  Our  Solovis  offering 
competes  with  other  analytics  providers,  including  Addepar 
and  Caissa.  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.

• Investors  and  Asset  Managers  -  Offering  products  and 
in 

investors  and  asset  managers 

services 
optimizing their portfolios and offerings.

to  assist 

• Listed  Companies  -  Promoting  the  capital  health  of  our 

listed companies.

• 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 

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

-  Delivering  efficiencies 

• Banks  and  Financial  Institutions  -  Providing  a  suite  of 
trade  surveillance  and  anti-financial  crime  management 
solutions. 

Competition

Market Technology

Traditionally,  exchanges  and  exchange-related  businesses 
would  internally  develop  technology,  sometimes  aided  by 
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.  Our  partnership  with  AWS  to 
migrate  our  exchanges,  in  a  phased  approach,  to  the  cloud 
enables  us  to  compete  with  other  companies  that  are 
developing  cloud-based  exchanges  and  market  technology 
offerings. 

A  wide  range  of  providers  compete  with  us  in  surveillance, 
where standardization of products and budget pressures drive 
customers  to  focus  on  pricing.  Our  competitors  range  from 
large  enterprise  software  providers  that  cover  the  broader 
compliance lifecycle to smaller vendors focusing on a single 
silo of the compliance workflow. Recently, an influx of start-
ups have entered the space from the FinTech landscape, often 
shifting from data and analytics, or a complementary silo like 
electronic  communications,  to  surveillance.  For  our  anti-
financial  crime  offering,  competitors  include  core  banking 
solution  providers, 
independent  fraud  and  anti-money 
laundering solution providers and FinTech start-ups. We also 
compete  against  enterprise  solution  providers  and  point 
solutions  for  clients  with  larger  AUM.  The  anti-financial 
crime  offering  competes  on  a  number  of  factors,  including 
but  not  limited  to,  increased  workflow  efficiency,  quality  of 
the data output and pricing.

8

Corporate Platforms

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  our  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.  Additionally,  we 
face competition from private equity firms that may elect to 
keep their portfolio companies as private companies.

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 AG. 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 IR & ESG Services business, competition is varied and 
can  be  fragmented.  For  our  Investor  Relations  Intelligence 
solutions, 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 to customers alongside listing services. The 
competitive landscape for our Governance Solutions business 
varies  by  customer 
segment  and  geography.  Most 
competitors offer SaaS solutions that are supported by a data 
centered  strategy.  Some  firms  offer  specialized  services  that 
focus  on  a  single  niche  segment.  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.  Our  ESG-focused  services, 
including  Nasdaq  OneReport  and  ESG  Advisory,  are 
positioned  in  evolving  markets  with  competitors  offering 
multiple  point  solutions  providing  software,  data  or 
consulting services.

Market Services

We face intense competition in North America and Europe in 
businesses  that  comprise  our  Market  Services  segment.  We 
seek to provide market participants with greater functionality, 
trading  system  stability  and  performance,  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  MIAX,  Intercontinental 
Exchange, Inc., or ICE, and Boston Options Market. In cash 
equities in the U.S., we compete with exchanges operated by 
Cboe, ICE, MIAX, The Investors Exchange, and the recently 
launched  Members  Exchange  and  the  Long  Term  Stock 
Exchange.  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  Euronext  N.V.,  Deutsche  Börse  AG  and  London 
Stock Exchange Group plc, or LSE, and many MTFs such as 
Cboe,  Turquoise  and  Aquis.  Our  competitors  in  the  trading 
and  clearing  of  options  and  futures  on  European  equities 
include  Eurex,  Cboe,  ICE  Futures  Europe  and  London 
Clearing  House,  or  LCH.  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 
exchange-based 
competition,  we  face  competition  from  OTC  derivative 
markets.

equities. 

addition 

In 

to 

The  implementation  of  MiFID  II  and  MiFIR  has  resulted  in 
further  competitive  pressure  on  our  European 
trading 
business.  SIs  are  already  attracting  a  significant  share  of 
electronically matched volume and 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.  Regulators  are  continuously  monitoring  the 
market structure and have, in a series of consultations, asked 
for input regarding suggested changes to MiFID II. 

Our  European  fixed  income  and  commodities  products  and 
services  are  subject  to  competitive  pressure  from  European 
exchanges and clearinghouses. 

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

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 

9

innovations, products and services; trademarks related to our 
brands,  products  and  services;  copyrights  in  software  and 
creative content; trade secrets; and through other intellectual 
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 
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.

innovative  skills, 

the 

Corporate Venture Practice

in  emerging  growth 

We  operate  a  corporate  venture  program  to  make  minority 
investments  primarily 
financial 
technology  companies  that  are  strategically  relevant  to,  and 
aligned  with,  Nasdaq.  Investments  are  made  through  the 
venture  program  to  further  our  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 
investments  of 
approximately  $90  million  in  19  companies  in  various 
sectors, including data, analytics and workflow, digital assets, 
market infrastructure, anti-financial crime, new marketplaces, 
and ESG.

initial  and 

follow-on 

Environmental, Social and Governance Matters

Nasdaq  is  committed  to  further  advancing  our  longer-term 
ESG  strategy,  advocacy  and  oversight.  We  continue  to 
engage with internal and external stakeholders at all levels on 
ESG  matters.  During  2021,  we  deepened  our  corporate  and 
community ESG efforts, including expanding ESG oversight 
of  our  own  operations  and  furthering  our  commitment  to 
greater sustainability and climate change awareness.

For  the  fourth  consecutive  year,  Nasdaq  achieved  its 
continued  commitment  to  be  carbon  neutral  across  all 
business  operations  through  the  purchase  of  green  power, 
carbon  removal  offsets,  and  renewable  energy  certificates. 
We  were  named  to  the  Dow  Jones  Sustainability  North 
America  Index  for  the  sixth  consecutive  year  and  have  seen 

10

positive  progress  on  our  ESG  scores  across  multiple  rating 
agencies.  Nasdaq  is  also  a  signatory  to  the  United  Nations 
Global  Compact  and  the  United  Nations  Principles  of 
Responsible Investment.

to 

impact,  we  are  able 

While  our  business  operations  account  for  a  comparatively 
small  environmental 
focus 
environmental efforts on several key areas, including the way 
we  use  energy  resources,  manage  our  workspaces,  and 
conduct  business  travel.  Through  these  efforts,  we  seek  to 
lessen  the  environmental  impact  of  our  organization  by 
reducing  atmospheric  carbon  emissions  and  managing  water 
and  waste  associated  with  business  operations.  Our 
commitment  to  implement  Science-Based  targets  as  part  of 
the  Science-Based  Targets  Initiative  further  emphasizes  our 
ambition  to  drive  to  a  net-zero  economy.  For  the  first  time, 
Nasdaq obtained a Platinum LEED certification for our New 
York Headquarters and we continue to look for opportunities 
to transition to green offices across the globe.

We also expanded our ESG services and solutions with new 
offerings for our clients, including: 

• the  Nasdaq  ESG  Advisory  Program,  which  pairs 
companies  with  consultative  ESG  expertise  to  help  them 
analyze, assess and enact ESG program best practices with 
the  goals  of  attracting  long-term  capital  and  enhancing 
value;

• the  Nasdaq  OneReport  platform,  which  helps  clients 
streamline  the  data  gathering  process  under  various 
frameworks for sustainability reporting and to provide data 
to ratings agencies; 

• the  Nasdaq  Sustainable  Bond  Network,  which  connects 
issuers  and  investors  in  sustainable,  green  and  social 
bonds,  and  provides  access  to  detailed  information  and 
impact  data  allowing  investors  to  make  more  informed 
decisions;

• the Nasdaq ESG Data Hub, which connects investors with 
expert-led  ESG  data  sets  from  leading  providers  across  a 
wide spectrum of areas, including gender diversity, carbon 
emissions and climate risk, providing detailed and tangible 
intelligence on companies’ ESG profiles;

• the Nasdaq ESG Data Portal, which now includes ESG-

related data from more than 630 companies;

• the Nasdaq ESG Footprint, a tool to help both institutional 
their 

investors  understand 

impact  of 

the 

and  retail 
portfolios; and

• the acquisition of a majority stake in Puro.earth, a leading 
marketplace  for  carbon  removal,  which  we  believe  will 
address  the  growing  demand  for  carbon  removal  by 
corporations,  as  well  as  enable  new  carbon  removal 
methodologies as technologies evolve. 

In  2021,  we  also  adopted  a  new  Supplier  Code  of  Ethics, 
which  encourages  our  suppliers  and  vendors  to  adopt 
sustainability  and  environmental  practices  in  line  with  our 
published Environmental Practices Statement. This code asks 
our  suppliers  to  measure,  report,  and  mitigate  any  potential 
negative  climate  change  and  biodiversity  impacts  associated 
with their operations, products and services including energy 
and water consumption, greenhouse gas emissions, waste, air 
and water pollution, nature loss and hazardous materials. Our 
policy  asks  suppliers  to  provide  us  with  information  to 
support our reporting and transparency commitments related 
to  environmental  sustainability  and  supply  chain  emissions. 
Additionally, the Supplier Code of Ethics expects suppliers to 
promote  a  diverse  and  inclusive  workforce  and  encourages 
suppliers  to  engage  diverse-owned  business  in  their  supply 
chain. Our Supplier Code of Ethics is available on Nasdaq’s 
website.

During 2021, the SEC adopted Nasdaq’s new listings rule for 
companies  listed  on  our  U.S.  exchange  to  publicly  disclose 
consistent,  transparent  diversity  statistics  regarding  their 
board of directors and choose whether to meet recommended 
board  diversity  objectives  or  disclose  their  reasons  for  not 
doing so. The diversity rule is currently being challenged by 
two  advocacy  groups  in  the  U.S.  Court  of  Appeals  for  the 
Fifth Circuit.

Nasdaq  also  was  included  in  the  2021  Bloomberg  Gender-
Equality  Index  in  recognition  for  advancing  equality  across 
its global workforce, and earned a perfect score for the third 
consecutive  year  by 
the  Human  Rights  Campaign 
Foundation’s  2021  Corporate  Equality  Index  regarding 
LGBTQ+ workplace equality.

For  more  information  regarding  our  ESG  efforts  in  2021, 
both internally and externally, please see the section entitled 
“Human  Capital  Management”  below  and  our  Proxy 
Statement.

Regulation

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

U.S. Regulation

SROs 

companies. 

U.S. federal securities laws establish a system of cooperative 
regulation  of  securities  markets,  market  participants  and 
listed 
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.

conduct 

the 

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.

11

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, operating results and financial 
condition.

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,  after  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.

Nasdaq’s 

regulation. 

Broker-dealer 
broker-dealer 
subsidiaries  are  subject  to  regulation  by  the  SEC,  the  SROs 
and various state securities regulators. Nasdaq operates three 
broker-dealers:  Nasdaq  Execution  Services,  LLC,  NFSTX, 
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. In addition, we own 
a minority interest in NPM Securities.

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.  NFSTX  is  a 
registered  ATS  and  acts  as  an  intermediary  to  facilitate 
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.  Nasdaq  Capital 
Markets  Advisory  acts  as  a  third-party  advisor  to  privately-
held  or  publicly-traded  companies  during  IPOs  and  various 
other offerings.

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 

12

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, 
2021, 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  activities 
regulatory 
performed under these agreements by FINRA.

responsibility 

for  all 

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 
regulatory  responsibility  for  specifics  covered  by 
the 
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;

• joint 

industry 

agreements  with  FINRA 

covering 

responsibility for enforcement of insider trading rules;

• joint 

industry 

covering 
enforcement  of  rules  related  to  cash  equity  sales  practices 
and certain other non-market related rules; and

agreement  with  FINRA 

• 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 
for  an 
dissemination  of  all  consolidated 
individual NMS stock through a single plan processor.

information 

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  recently  extended  for  a  two-year  term  through  October 
2023.  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 
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.

hardware, 

software 

system, 

In May 2020, the SEC adopted an order to require changes to 
the  governance  of  securities  information  processors.  In  June 
2020,  we  and  several  other  exchanges  petitioned  the  U.S. 
Court of Appeals for the District of Columbia Circuit, or the 
Court of Appeals, to review the SEC’s governance order. In 
June  2021,  the  Court  of  Appeals  dismissed  our  petition  as 
premature,  but  gave  us  leave  to  challenge  the  governance 
order after the SEC acted pursuant to the order to approve a 
national  market  system  plan  implementing  it.  Accordingly, 
we refiled our challenge in August 2021, and also asked the 
Court  of  Appeals  to  stay  the  operation  of  the  new  national 
market  system  plan.  In  October  2021,  the  Court  of  Appeals 
granted  our  stay  request.  This  case  is  scheduled  for  oral 
argument on March 24, 2022.

for 

the 

collection, 

consolidation 

In  December  2020,  the  SEC  adopted  a  rule  to  modify  the 
and 
infrastructure 
dissemination  of  market  data  for  exchange-listed  national 
market  stocks,  or  NMS  data.  The  rule  changes  include, 
among  other  things,  requiring  exchanges  to  add  more  “core 
data”  to  the  securities  information  processors,  including 
partial depth-of-book, certain odd-lot quotations/transactions, 
auction,  regulatory,  and  administrative  data;  eliminating 
central,  official  consolidators  of  tape  plans  and  enabling 
multiple competing consolidators to register to aggregate and 
disseminate  core  data;  and  authorizing  persons  to  purchase 
and aggregate core data directly from the exchanges for their 
own use. The rule implementation schedule has not yet been 
finalized by the SEC, and we are not certain of the timing, or 
the  impact,  of  these  new  rules  on  our  business  or  role  as  a 

securities  information  processor.  In  February  2021,  we 
petitioned  the  U.S.  Court  of  Appeals  for  the  District  of 
Columbia Circuit to review the SEC’s rulemaking. This case 
is scheduled for oral argument on March 18, 2022.

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 
inter-
disciplinary  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.

implemented  an 

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. 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  also 
comply with the terms and conditions of an exemption order 
granted  by  the  other  jurisdictions  in  order  to  maintain  its 
exemptive status. Oversight of the exchange is performed by 
Nasdaq  Canada’s  lead  regulator,  the  Ontario  Securities 
Commission. 

instruments  which  set  out 

Nasdaq  Canada  is  subject  to  several  national  marketplace 
requirements 
related 
for 
marketplace  operations, 
rules  and  managing 
trading 
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.

13

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  2016, 

the  European  Union’s  Market  Abuse 
In  July  2016, 
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, 
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, 2024, 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  clearinghouse  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 
initial 
registration must be approved by the SFSA. Nasdaq Clearing 
holds the license as a CCP under EMIR.

articles  of 

association 

following 

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 

14

in 

to  all 

that  each  person  which  meets 

confidence  in  the  securities  markets.  When  operating  a 
regulated  market,  an  exchange  must  apply  the  principles  of 
free  access  (i.e., 
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 
trading)  and 
those  who  participate 
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 
financial 
trading  participation 
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.

rules, 

there  has  been  cooperation  between 

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, 
the 
supervisory  authorities  in  Sweden,  Iceland,  Denmark  and 
Finland,  which 
and 
to 
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.

safeguard 

effective 

looks 

Nasdaq  owns  a  central  securities  depository  known  as 
Nasdaq  CSD  SE  (Societas  Europaea)¸  that  provides  notary, 
settlement,  central  maintenance  and  other  services  in  the 
Baltic  countries  and  in  Iceland.  Nasdaq  CSD  SE  is  licensed 
under 
the  European  Central  Securities  Depositories 
Regulation  and  is  supervised  by  the  respective  regulatory 
institutions.

that 

trades  and 

We  operate  a  licensed  exchange,  Nasdaq  Oslo  ASA,  in 
Norway 
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  Financial  Supervisory  Authority  of  Norway  supervises 
the  Norwegian  exchange  on  an  autonomous  basis  and  the 
Norwegian exchange also has a separate market surveillance 
function overseen by the Financial Supervisory Authority.

surveillance  work 

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 
is 
conceptually organized into two functions: one for the review 
and  admission  of  listing  applications  and  surveillance 
activities  related  to  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  the  three  Baltic 
exchanges. In Finland, Sweden and Estonia, 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  either  by  the  respective 
president of the exchange or by the executive board.

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,  Sweden  and  Norway.  Suspected 
insider trading is reported to the appropriate authorities in the 
respective country.

In  the  United  Kingdom,  The  Nasdaq  Stock  Market,  Nasdaq 
Oslo ASA, Nasdaq Stockholm AB, Nasdaq Copenhagen A/S, 
and Nasdaq Helsinki Ltd 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 
became  effective  on  December  31,  2020,  and  lasts  for  three 
years. We will be applying for permanent recognition within 
eighteen months of the end of this implementation period.

Human Capital Management 

Nasdaq  deepened  its  commitment  to,  and  investment  in, 
attracting, retaining, developing and motivating its employees 
during  2021,  and  while  the  COVID-19  pandemic  has 
continued to create certain challenges for our employees, we 
have  bolstered  our  human  capital  management  efforts 
throughout  the  past  year.  The  cultural  foundation  at  Nasdaq 
is  based  on  our  core  values:  Act  as  an  Owner,  Play  as  a 
Team, Fuel Client Success, Lead with Integrity, Expand Your 
Expertise,  and  Drive  Innovation.  We  believe  these  cultural 
values energize and align employees with our most important 
priorities,  and  encourage  and  reward  high 
levels  of 
performance,  innovation  and  growth,  while  not  promoting 
undue risk.

15

During  2021,  we  continued  to  bolster  our  efforts  to  create  a 
diverse and inclusive work environment of equal opportunity, 
where  employees  feel  respected  and  valued  for 
their 
contributions,  and  where  Nasdaq  and  its  employees  have 
opportunities  to  make  positive  contributions  to  our  local 
communities.  Nasdaq  held  its  first  annual  Purpose  Week  in 
2021,  a  week-long  internal  series  showcasing  Nasdaq’s 
inclusive  growth  initiatives  and  leveraging  Nasdaq’s  unique 
position  at  the  center  of  capital  markets.  The  week  featured 
online  events,  volunteer  activities,  expert  discussions  and 
business  innovation  challenges  for  the  entire  global  Nasdaq 
workforce.

As  of  December  31,  2021,  Nasdaq  had  5,814  full  and  part-
time employees. Our total headcount includes 776 employees 
from Verafin, which we acquired in February 2021. 

ESG Oversight

The Nominating & ESG Committee has formal responsibility 
and  oversight  for  ESG  policies  and  programs  and  receives 
regular  reporting  on  key  ESG  matters  and  initiatives.  Our 
Corporate  ESG  Steering  Committee  serves  as  the  central 
coordinating  body  for  our  ESG  strategy;  it  is  co-chaired  by 
executive  leaders  and  comprised  of  geographically  diverse 
representatives from multiple business units. 

COVID-19 and Employee Safety 

As  the  COVID-19  pandemic  continues  around  the  world, 
affecting all of our offices, we are committed to ensuring the 
safety and well-being of our employees and stakeholders, and 
complying with local government regulations in the areas in 
which we operate. This includes having the vast majority of 
our  employees  work  from  home,  while 
implementing 
additional  safety  measures  and  precautions  for  employees 
continuing  critical  on-site  work  in  certain  of  our  offices  or 
returning to the office. We currently expect to transition to a 
hybrid  work  environment  during  2022  as  we  reopen  our 
global  offices  and  will  continue  to  evaluate  local  conditions 
and regulations

We  also  continued  benefits  for  our  employees  that  were 
introduced in 2020 as a result of COVID-19, and introduced 
additional  new  benefits  this  year  in  an  effort  to  help  our 
employees  balance  their  work  and  personal  commitments. 
These  benefits  include  providing  “flex  days”  for  additional 
time  away  from  the  office  without  requiring  the  usage  of 
vacation  or  personal  leave  days,  additional  family  care 
resources and benefits, including back-up childcare and other 
caregiver  support,  subsidized  distance-learning  enrichment 
programs and free home workout programs through different 
wellness and fitness providers. We also added new programs 
to  help  employees  coordinate  care  for  chronically  ill  family 
members  and 
family 
experienced  the  death  of  a  loved  one.  Our  managers 
participated in additional training programs to help them lead 
their teams through COVID-19 concerns and challenges.

support  employees  whose 

to 

Talent Management and Development

We  continued  to  increase  our  efforts  in  attracting  and 
retaining  our  employees.  Nasdaq  seeks  to  hire  world-class, 
innovative, and diverse talent across the globe. We created a 
Talent  Attraction  Team  focused  on  strategic  marketing  and 
branding to position Nasdaq as a top employer of choice for 
talent  in  our  industry,  helping  to  increase  our  pool  of  top 
candidates for open positions, particularly diverse candidates.
We continued to strengthen our diversity recruiting efforts to 
help  us  attract  talent  using  innovative  new  techniques  and 
channels,  enabling  us  to  successfully  launch  partnerships 
with  diverse  talent  organizations,  such  as  the  National 
Society  of  Black  Engineers, 
the  Society  of  Women 
Engineers,  Women  in  Technology,  Grace  Hopper  and  the 
Society of Hispanic Professional Engineers, improving brand 
awareness  of  Nasdaq  and  helping  us  to  attract  more  diverse 
candidates in our recruiting campaigns.

During  2021,  we  launched  a  year-long  campaign  called 
“Your Career Journey” to engage employees and managers in 
sustained  professional  development,  and  established  a  core 
curriculum  to  customize  curated  development  training  for 
employees at each level of seniority. We created performance 
objectives  for  each  our  managers  measuring  them  on 
managerial effectiveness, and the outcomes were included in 
each manager’s year-end performance evaluation. We further 
refined our onboarding and exit surveys to better understand 
why  employees  join,  and  leave,  Nasdaq.  Our  internal 
employee engagement score, based on our biannual employee 
engagement  surveys,  increased  year-over-year  from  2020. 
Additionally, our peer-to-peer employee recognition program 
rewards  employees  and  highlights  recognized  employees  on 
our  internal  social  media  channels,  further  amplifying  the 
recognition.  Our  workforce  voluntary  attrition  rate  during 
2021  was  11.5%.  This  voluntary  attrition  rate  is  lower  than 
averages  in  the  financial  services  and  technology  sectors,  as 
well as for all industries, based on a study for the U.S. for the 
period June 1, 2020 to June 1, 2021.

Our  internship  program  welcomed  157  interns  remotely  to 
Nasdaq,  and  64%  of  graduating  interns  were  converted  into 
full-time hires.

We  have  invested  in  professional  development  for  our 
employees,  including  offering  access  to  more  than  18,000 
tuition 
professional  development  programs;  providing 
assistance to employees enrolled in degree-granting academic 
fairs  and  career 
programs;  holding 
internal  career 
development  programs;  establishing 
formal  mentoring 
programs  and  providing  one-on-one  professional  coaching 
opportunities. We also launched a new internal platform, the 
Talent  Marketplace,  to  enable  our  employees  to  find  short-
term on-the-job development “gigs” throughout the company, 
as  well  as  search  for  and  apply  for  internal  full-time  job 
opportunities.  This  program  provides  greater  exposure  and 
professional  development  for  our  employees  to  learn  about 
different  organizations  in  the  company  and  expand  their 
professional network at Nasdaq, which we believe is a highly 
effective employee retention technique. 

16

Finally,  to  reward  our  employees  at  various  stages  of  their 
tenure  with  Nasdaq,  we  introduced  a  new  anniversary 
recognition  program  that  includes,  depending  on  the  work 
charitable 
anniversary,  Nasdaq-branded  merchandise, 
donations 
the  name  of  an  employee,  personalized 
messages  from  our  Chief  Executive  Officer  and  recognition 
on our Nasdaq Tower in New York City.

in 

Diversity, Equity and Inclusion

We  have  established  three  pillars  to  guide  our  diversity, 
equity and inclusion efforts with our employees: Workforce, 
to  ensure  our  employee  population  is  representative  of  the 
communities  in  which  we  operate;  Workplace,  to  ensure  a 
positive, equitable workplace experience for all employees of 
Nasdaq; and Marketplace, to positively influence our peers in 
the  capital  market  space  and  to  invest  in  our  local 
communities in which we operate.

Nasdaq  sponsors  eleven  employee-led 
internal  affinity 
networks. These networks include more than 1,900 employee 
members, representing 39% of our employees, to support the 
diverse communities that comprise our workforce, including 
networks 
for  our  Black,  Asian  American,  Hispanic, 
LGBTQ+,  female,  disabled,  veteran,  and  parent/caregiver 
employees  and  those  that  support  these  employees.  The 
networks  provide  both  formal  and  informal  development 
programs  and  guidance  for  their  members,  and  benefit  the 
entire  Nasdaq  workforce  through  educational  events,  guest 
speakers, and volunteering opportunities.

for  underrepresented 

In order to monitor our diversity efforts on an ongoing basis, 
each business unit has a dashboard reflecting the diversity of 
their  employee  population  and  leaders  can  track  diverse 
including  hires, 
representation  on  a  monthly  basis, 
departures, and employee sentiment. During 2021, more than 
80%  of  our  global  managers,  and  100%  of  our  executive 
team,  participated  in  a  “conscious  inclusion”  leadership 
development  program  that  offered  training  and  increased 
awareness  on  inclusion  issues.  We  also  added  customized 
developmental  programs 
talent, 
including  executive  mentoring  and  accelerated  leadership 
development  programs.  In  2021,  we  launched  a  high-
potential  leadership  program  for  our  Black  employees  to 
hone  their  skills  and  increase  advancement  opportunities; 
50% of participants in this program were promoted in 2021, 
while  100%  of  participants  have  remained  with  Nasdaq  to 
date.  During  our  annual  executive  succession  planning 
exercise  with  our  Board  of  Directors,  we  achieved  a  34% 
increase  in  the  diversity  of  our  succession  candidates 
(considering gender, race and LGBTQ+ status) due to a focus 
by our senior executives on identifying and cultivating talent 
deeper in their organizations. Additionally, as a signatory to 
the  Parity  Pledge,  we  fulfilled  our  commitment  to  interview 
female  candidates  for  all  externally  advertised  roles  at  the 
Vice President level and above.

Workplace Demographics

During  2021,  we  continued  our  progress  to  increase  the 
diversity of our global workforce. Our global employee base 
of women grew from 35% to 36%, and in the United States, 
we  increased  our  under-represented  minority  representation 
from 15% to 16%. In the United States, Nasdaq has increased 
by 
representation 
approximately 10% since 2019.

under-represented  minorities 

of 

Gender and Ethnicity Performance Data as of December 
31, 2021 and 2020

Gender:

* In the charts above, totals may not add up to 100% due to 
rounding  and  the  omission  of  race  and  ethnicities  that  are 
less than 0.3%. 

Additionally,  in  order  to  better  understand  our  pay  equity 
performance, we are currently conducting a global pay equity 
analysis, which is expected to be completed in the beginning 
of  the  second  quarter  of  2022.  As  a  first  step,  we  plan  to 
review  the  conclusions  internally  and  evaluate  any  potential 
gaps in pay equity. 

Finally,  to  increase  transparency  of  our  workforce,  Nasdaq 
publishes  statistics  on  the  composition  of  its  own  global 
workforce  by  gender,  and  of  its  U.S.  workforce  by  gender, 
race  and  ethnicity,  in  our  U.S.  EEO-1  report  and  our 
Sustainability Report, which are available on our website.

Compensation and Benefits 

Our  Total  Rewards  compensation  program  is  designed  to 
attract,  retain,  and  empower  employees  to  successfully 
execute  our  growth  strategy.  Our  comprehensive  Total 
Rewards program reflects our commitment to protecting our 
employees’ health, well-being and financial security.

Our  talented  employees  are  our  greatest  asset,  and  we  offer 
competitive  compensation  to  attract  and  retain  the  best 
employees. Our pay-for-performance compensation programs 
includes market-competitive base salaries, annual bonuses or 
sales  commissions,  and  equity.  The  majority  of  our 
employees  are  granted  annual  long-term  equity  awards, 
enabling  them  to  be  owners  of  the  company,  committed  to 
our  long-term  success  and  aligning  their  interests  with  the 
short-term and long-term interests of our shareholders.

17

2021*Male:64.1%Female:35.9%Undisclosed:<1%2020*Male:64.9%Female:34.9%Undisclosed:<1%Race and Ethnicity (U.S. only) in 2021*65.4%16.5%7.5%5.8%2.1%2.4%WhiteAsianBlackHispanicTwo or moreNot disclosedRace and Ethnicity (U.S. only) in 2020*66.6%16.2%7.4%5.1%2.0%2.3%WhiteAsianBlackHispanicTwo or moreNot disclosed 
Our  Total  Rewards  program  extends  beyond  compensation, 
offering  a  suite  of  programs,  benefits,  perquisites  and 
resources to support employee priorities. In addition to cash 
and  equity  compensation,  we  also  offer  employee  benefits 
such  as  health  (medical,  dental,  vision  and  telehealth) 
insurance, fertility benefits, paid time off, paid parental leave, 
adoption  assistance,  an  employee  stock  purchase  plan, 
student  loan  repayment  benefits,  charitable  contribution 
matching  and  a  U.S.  401(k)  Plan  with  company  matching. 
Since  the  start  of  the  pandemic,  we  have  introduced 
additional  benefits  to  support  our  employees,  as  described 
above  under  “COVID-19  and  Employee  Safety.”  We  also 
provide  additional  benefits  to  our  international  employees 
based  on  local  regulations  and  practice  to  address  market-
specific needs. 
Community Involvement

We are committed to creating lasting, positive change within 
our Company and the communities we serve.

Our employees take pride in being active in our communities. 
Through  our  Nasdaq  GoodWorks  Corporate  Responsibility 
Program, we have committed to supporting the communities 
in which we live and work by providing eligible full and part-
time employees two paid days off per year to volunteer. We 
also match charitable donations of all Nasdaq employees and 
contractors  up  to  $1,000,  or  more  in  certain  circumstances, 
per  calendar  year.  While  most  of  our  volunteer  efforts  in 
2021  continued  to  remain  virtual  due  to  the  pandemic,  we 
organized  more  than  100  employee  volunteer  events  around 
the world.

to  advance 

is  designed 

As  part  of  Nasdaq’s  ongoing  commitment  to  diversity, 
equity,  inclusion  and  culture,  we  have  continued  our  series, 
Amplifying  Black  Voices,  which  we  initiated  in  2020.  This 
year,  the  program  is  a  multimedia  retrospective  featuring 
works of art and photography documenting Black culture and 
life.  These  works  are  displayed  on  the  Nasdaq  MarketSite 
tower  in  Times  Square  throughout  the  year,  enabling  the 
entire community to view and celebrate the exhibits.
In  September  2020,  we  launched  the  “Purpose  Initiative,” 
which 
inclusive  growth  and 
prosperity,  and  we  continued  to  expand  this  initiative 
throughout  2021.  The  Purpose  Initiative  comprises  our 
philanthropic,  community  outreach,  corporate  sustainability, 
and  employee  volunteerism  programs,  all  designed 
to 
leverage  our  unique  place  at  the  center  of  capital  creation, 
markets, and technology and drive stronger economies, more 
equitable  opportunities  and  contribute  to  a  more  sustainable 
world.  During  2021, 
two 
company-wide  roundtables,  which  explored  topics  such  as 
advancing  inclusive  growth  and  prosperity,  particularly  for 
women of color, and investor and community engagement to 
increase  market  accessibility  across  race,  ethnicity,  gender 
and  class.  Nasdaq  also  held  its  first  “Purpose  Week”  to 
further  the  initiative,  which  included  six  company-wide 
webinars,  volunteer  opportunities,  an  innovation  challenge 
and  other  events 
involving  and  recognizing  company 
employees.

the  Purpose  Initiative  held 

The  mission  of 
the  Nasdaq  Foundation,  which  was 
relaunched  in  2020,  is  focused  on  two  primary  goals:  (i) 
reimagining investor engagement to equip under-represented 
communities  with  the  financial  knowledge  to  share  in  the 
wealth that markets create; and (ii) leveraging our investment 
in the Nasdaq Entrepreneurial Center alongside new strategic 
partnerships with organizations that can help build a deeper, 
data-led  understanding  of  where  the  challenges  are  greatest, 
what existing efforts could be amplified, and how the Nasdaq 
Foundation can make new and distinctive contributions.

The  Nasdaq  Foundation  provided  six  grants  during  2021  to 
organizations  that  seek  to  fulfill  that  mission.  These  grants 
were  awarded  to,  among  others,  Wall  Street  Bound,  an 
organization  to  increase  diversity  on  Wall  Street;  1863 
Ventures,  a  start-up  accelerator  fund  assisting  minority 
entrepreneurs  throughout  the  growth  lifecycle;  and  The 
Leave No Women Behind program, which seeks to advance 
female  entrepreneurship  in  Utah  by  offering  a  suite  of 
programs 
the 
knowledge to start or scale up a business. 
Nasdaq Website and Availability of SEC Filings

female  entrepreneurs  with 

to  provide 

We  file  periodic  reports,  proxy  statements  and  other 
information with the SEC. The SEC maintains a website that 
contains reports, proxy and information statements, and other 
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 our 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  ongoing  COVID-19  pandemic  could  have  an  adverse 
effect  on  our  business,  financial  condition,  liquidity  or 
results of operations.

We  are  closely  monitoring  the  continuing  impact  of  the 
COVID-19  pandemic  on  our  industry  and  business  in  the 
United  States  and  worldwide,  including  its  effect  on  our 
customers,  employees,  vendors  and  other  stakeholders.  The 
COVID-19  pandemic  has  created  significant  volatility, 
uncertainty  and  economic  disruption,  which  may  adversely 
affect our business, financial condition, liquidity or results of 
operations.

18

Throughout  the  pandemic,  we  have  shifted  to  having  a 
majority  of  our  staff  work  from  home  and  have  added 
additional  network  capacity  and  monitoring.  However,  such 
remote  work  may  cause  heightened  cybersecurity  and 
operational  risks.  Certain  of  our  global  offices  have  re-
opened on a limited basis, with applicable safety protocols in 
place, or expect to re-open subject to limitations during 2022. 
We  could  face  disruption  to  our  business  or  operations  if  a 
significant  number  of  our  employees  or  any  of  our  key 
employees becomes ill due to the virus. Any disruption to our 
ability  to  deliver  services  to  our  clients  could  result  in 
liability to our customers, regulatory fines, penalties or other 
sanctions,  increased  operational  costs  or  harm  to  our 
reputation  and  brand.  This,  in  turn,  may  have  an  adverse 
effect on our business, financial condition, liquidity or results 
of operations.

The  reopening  of  our  global  offices  has  created  and  may 
continue to create additional risks and operational challenges 
and  may  require  us  to  make  additional  investments  in  the 
design,  implementation  and  enforcement  of  new  workplace 
health and safety protocols. Even if we follow governmental 
guidance and what we believe to be best practices, our efforts 
to reopen our offices safely may not be successful and could 
expose  our  customers,  employees,  vendors  and  other 
stakeholders  to  health  risks,  and  we  could  be  exposed  to 
associated  liability.  Furthermore,  additional  and/or  extended 
governmental restrictions, new regulations or other changing 
conditions  could  cause  us  to  temporarily  re-close  certain 
offices. 

The  extent  to  which  the  COVID-19  pandemic  impacts  our 
business, financial condition, liquidity or results of operations 
will depend on future developments, which are uncertain and 
cannot be predicted, including the scope and duration of the 
COVID-19 pandemic, the length of time of any commercial 
and  travel  limitations,  the  continued  effectiveness  of  our 
remote  work  arrangements,  actions  taken  by  governmental 
authorities,  regulators  and  other  third  parties  in  response  to 
the pandemic, as well as other direct and indirect impacts on 
us,  our  exchanges,  our  customers,  our  vendors  and  other 
stakeholders. 

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,  current  or 
expected inflation, interest rate fluctuations, market volatility, 
changes  in  investment  patterns  and  priorities,  pandemics 
(such  as  COVID-19)  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 
including  our  market 
for  our  products  and  services, 
technology, data, indexes and IR & ESG Services, 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, including SPACs, and direct listings.

Investment  Intelligence  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  as  well  as  trading  in  futures  linked  to  Nasdaq 
indexes.

There  may  be  less  demand  for  our  IR  &  ESG  Services  or 
Market  Technology  products  if  global  economic  conditions 
are  weak.  Our  customers  historically  reduce  purchases  of 
new  services  and  technology  when  growth  rates  decline, 
thereby  diminishing  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 
Investment  Intelligence,  Market  Technology  or  Corporate 
Platforms  products  and  services  due  to  economic  conditions 
or  other  market  factors  could  adversely  affect  our  business, 
financial condition and operating results.

The industries we operate in are highly competitive.

We  face  significant  competition  in  our  Market  Technology, 
Investment  Intelligence  and  Corporate  Platforms  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.

19

in  Europe, 

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 
this 
U.S.  and 
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.

is  structured 

to  maintain 

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 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 
listings,  clearing,  data  or 
trading, 
technology businesses more competitive than ours.

their 

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, or due to new SEC regulations, 
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 Platforms, 
Investment Intelligence and Market Technology segments are 
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  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.

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 
the 
in 
causes 
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.

services,  decreases 

interruption 

an 

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  delay  purchases  in  anticipation  of  new  products 
or  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 
the 
than  anticipated. 
introduction of new products by competitors, the emergence 
of new industry standards or the development of entirely new 
technologies  to  replace  existing  product  offerings  could 
render our existing or future products obsolete.

In  addition, 

lower 

is 

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

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 

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 

20

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, and particularly 
in  2020  and  2021  as  the  pandemic  continued,  trading  and 
clearing  volumes  and  values  across  our  markets  have 
fluctuated  significantly  depending  on  market  conditions  and 
other  factors  beyond  our  control.  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  and  depository 
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  recently  adopted  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. Due to COVID-19, most 
of our workforce has, and may continue to, work from home 
the  majority  of  each  week,  creating  a  broader  and  more 
distributed  network  footprint  and  increased  reliance  on  the 
home networks of employees. 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.  Further, 
cybersecurity  incidents  that  impact  our  vendors  and  other 
third parties that support our organization and industry could 
directly  or  indirectly  impact  us.  For  example,  in  December 
2021, the Log4j security vulnerability was widely publicized. 
It  did  not  have  an  impact  to  our  business  or  operations, 
including our core market system environment. There can be 
no  assurance  we  will  be  able  to  identify  and  mitigate  every 
incident 
involving  cybersecurity  attacks,  breaches  or 
incidents.

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 
functionality,  performance, 
capacity, reliability and speed required by our business and 
our regulators, as well as by our customers.

that  have 

the 

technology,  evolving 

The  markets  in  which  we  compete  are  characterized  by 
rapidly  changing 
industry  and 
regulatory  standards,  frequent  enhancements  to  existing 
products  and  services,  the  adoption  of  new  services  and 
products and changing customer demands. We are reliant on 
our  customers  that  purchase  our  on-premise  solutions  to 
maintain  a  certain  level  of  network  infrastructure  for  our 
products  to  operate  and  to  allow  for  our  support  of  those 
products,  and  there  is  no  assurance  that  a  customer  will 
implement  such  measures.  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.

21

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.  In 
the current tight labor market, we have intensified our efforts 
to recruit and retain talent. Competition for key personnel in 
the  various  localities  and  business  segments  in  which  we 
operate is intense. We have, and may continue to, experience 
higher compensation costs to retain personnel, and hire new 
talent,  that  may  not  be  offset  by  improved  productivity, 
higher revenues or increased sales. 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, office/remote 
working  arrangements  and  compensation  and  benefit 
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 
identify  and  pursue  strategic 
business  strategy  and 
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 or at all.

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 15, “Clearing Operations,” 
to  the  consolidated  financial  statements.  There  are  no 
assurances  that  similar  defaults  will  not  occur  again,  which 
could result in losses. 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  the  effects  of 
COVID-19  on  their  business,  bankruptcy,  lack  of  liquidity, 
operational failure or other reasons.

We  clear  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 Nasdaq Clearing on 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 also may 
not be sufficient.

financial 

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

to 

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

issues  relating 

Technology 
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 
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,  or  an  increase  in  the 
number  of  delistings,  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  IR  & 
ESG  Services  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.

22

RISKS 
ACTIVITIES AND STRATEGIC RELATIONSHIPS 

RELATED 

TRANSACTIONAL 

TO 

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, 
and 

business 

policies, 

cultures 

and 

procedures 
compensation structures;

• 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 

23

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

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  or  experience  service 
interruptions affecting our operations.

We  rely  on  third  parties  for  regulatory,  data  center,  cloud, 
data storage and processing, data content, clearing and other 
services.  Interruptions  or  delays  in  services  from  our  third-
party  data  center  hosting  facilities  or  cloud  computing 
platform  providers  could  impair  the  delivery  of  our  services 
and harm our business. To the extent that any of our vendors 
or other third-party service providers experiences difficulties 
or  a  significant  disruption,  breach  or  outage,  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.  Our  access 
to cloud service provider infrastructure could be limited by a 
number  of  events,  including  technical  or  infrastructure 
failures,  natural  disasters  or  cybersecurity  attacks.  As  we 
continue to grow our SaaS businesses, our dependency on the 
continuing  operation  and  availability  of  these  cloud  service 
providers  increases.  If  our  cloud  services  from  third  party 
providers  are  unavailable  to  us  for  any  reason,  our  clients 
may  not  be  able  to  access  our  exchanges  or  certain  of  our 
cloud  products  or  features,  which  could  significantly  impact 
our reputation, operations, business, and financial results.

For example, in 2022, we will begin to use AWS to migrate 
our North American markets to AWS in a phased approach, 
starting with Nasdaq MRX. AWS operates a platform that we 
use  to  provide  services  to  our  clients,  and  therefore  we  are 
vulnerable  to  Nasdaq-specific  service  outages  on  the  AWS 
platform.  If  AWS  does  not  deliver  our  system  requirements 
on  time,  fails  to  provide  maintenance  and  support  to  our 
specifications  or 
integration 
challenges, the successful migration of our exchanges to the 
AWS  cloud  platform  may  be  significantly  delayed,  which 
may adversely affect our reputation and financial results.

the  migration  experiences 

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.

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,  2021,  goodwill  totaled  $8.4  billion  and 
intangible  assets,  net  of  accumulated  amortization,  totaled 
$2.8 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  were  no  impairment  charges  recorded  relating  to 
goodwill and indefinite-lived intangible assets and there were 
no  material  impairment  charges  recorded  relating  to  other 
long-lived assets in 2021, 2020 and 2019.

We  may  experience  future  events  that  may  result  in  asset 
impairments.  Future  disruptions  to  our  business,  prolonged 
economic  weakness,  due  to  COVID-19  or  otherwise,  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.

Acquisitions,  divestments,  investments,  joint  ventures  and 
transactional  activities  may  require  significant 
other 
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 have, and may continue 
to,  divest  additional  businesses  or  assets  in  the  future. 
Although  we  cannot  predict  our  transactional  activities,  we 
believe that additional acquisitions, divestments, investments, 
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.

We also invest in early-stage companies through our Nasdaq 
Ventures  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 
in  certain 
circumstances and financial and reputational risks if there are 
operational failures.

to  additional  capital 

requirements 

to 

In 

existing 

addition, 

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 
the 
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 
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.

in  significant 

incremental 

results 

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

• 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,  including  after  a 

transaction is completed; 

• incurred but unreported claims for an acquired company;

• difficulties  in  realizing  projected  efficiencies,  synergies 

and cost savings; and

• changes in our credit rating and financing costs.

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 

24

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 
in 
recording  acquired 
accordance with U.S. GAAP, as compared to book value as 
recorded;

tangible  assets  at  fair  value, 

• 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;

depositories,  clearinghouse  and  markets  for  violations  of 
applicable requirements.

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.

• 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

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.

• 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,  or  due  to  changes  in  trading 
patterns,  such  as  due  to  the  recent  volatility  involving  the 
trading of certain stocks.

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. 
There  is  no  assurance  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 
securities 
on  our  exchanges,  broker-dealers,  central 

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

to 

In  2016,  the  SEC  approved  a  plan  for  Nasdaq  and  other 
exchanges to establish a CAT, to improve regulators’ ability 
to  monitor 
increased 
trading  activity.  In  addition 
regulatory  obligations,  implementation  of  a  consolidated 
audit trail has resulted in significant additional expenditures, 
including  to  implement  the  new  technology  to  meet  any  of 
the  plan’s  requirements.  Creating  the  CAT  has  required  the 
development  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 the 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 

25

timely  launch  or  properly  operate  such  technology  exposes 
Nasdaq  and  other  exchanges  to  SEC  fines.  As  of  December 
31,  2021,  we  have  accrued  approximately  $54  million  as  a 
receivable in connection with our portion of expenses related 
to the CAT implementation.

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 
circumstances. 
under 
expand 
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.

business 

certain 

its 

or 

central 

exchanges, 
In 

clearinghouses 
these  countries,  we  have 

Our non-U.S. business is subject to regulatory oversight in all 
the countries in which we operate regulated businesses, such 
securities 
as 
received 
depositories. 
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  the  Benchmark  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 
material  adverse  effect  on  our  business,  financial  condition 
and operating results.

Regulatory  changes  and  changes  in  market  structure  and 
proprietary data 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  affecting  the  securities  markets,  including  market 
structure,  technological  oversight  and  fees  for  proprietary 
market data, connectivity and transactions. The SEC, FINRA 

26

and the national securities exchanges have introduced several 
initiatives to ensure the oversight, integrity and resilience of 
markets.

With respect to our regulated businesses, our business model 
can be severely impacted by policy decisions. In May 2020, 
the SEC adopted a rule to require changes to the governance 
of  securities  information  processors.  In  December  2020,  the 
SEC  adopted  a  rule  to  modify  the  infrastructure  for  the 
collection, consolidation and dissemination of market data for 
exchange-listed  national  market  stocks.  If  either  or  both  of 
these rules are fully implemented, they may adversely affect 
our  revenues.  The  timing  for  the  implementation  of  these 
rules  is  currently  unknown,  and  we  believe  they  may  take 
two  or  more  years  to  fully  implement.  If  the  rules  are 
ultimately implemented as set forth in their adopting releases, 
demand  for  certain  of  our  proprietary  tape  share  data 
products  may  be  reduced,  or  we  may  have  to  reduce  our 
pricing  to  compete  with  other  entrants  into  the  market  for 
consolidated data. 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.  These  regulatory  changes 
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.

In Canada, all new marketplace fees and changes to existing 
fees,  including  trading  and  market  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 market data products 
to  customers  on  a  non-discriminatory  and  reasonable 
commercial  basis.  The  MiFID  II/MiFIR  rules  entail  that  the 
price  for  regulated  market  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  market  data  products  adversely.  In 
addition,  any  future  actions  by  European  Union  institutions 
could  affect  our  ability  to  offer  market  data  products  in  the 
same manner as today, thereby causing an adverse effect on 
our market data revenues.

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 
regulations  promulgated  by 
regulatory agencies.

rules  and 

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  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.

27

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.

Laws  and  regulations  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.  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, 
future  enforcement  actions  or 
rules  or 
investigations,  or  the  creation  of  new  rights  to  pursue 
damages  could 
increased  costs  or 
restrictions on our business, and noncompliance could result 
in regulatory penalties and significant legal liability.

regulations, 

impact  us 

through 

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,  including 
federal  or  state  financial  transaction  taxes,  may  increase  the 
cost of our offerings or services, 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 ensure 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 such 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, 2021 was $5.8 billion. 
We  may  borrow  additional  amounts  by  utilizing  available 
liquidity under our existing credit facilities, issuing additional 
debt  securities  or  issuing  short-term,  unsecured  commercial 
paper notes through our 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  effect  certain  fundamental  transactions,  dispose  of 
certain  assets,  incur  additional  indebtedness  and  grant  liens 
on  assets.  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 
internally 
meet  our  current  capital  requirements  from 
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, 
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.

strategic 

engage 

in 

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

If  we  need  to  raise  funds  through  issuing  additional  equity, 
our  equity  holders  will  suffer  dilution.  If  we  need  to  raise 
funds  through  incurring  additional  debt,  we  may  become 
subject to covenants 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;

28

• 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,  IR  &  ESG  Services  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 
in 

including  any 

reporting, 

financial 

failures 

over 
supervision;

• extreme price volatility on our markets;

• any negative publicity surrounding our listed companies or 

our listing rules;

• 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

• any  misconduct,  fraudulent  activity  or  theft  by  our 
formerly  or  currently 

employees  or  other  persons 
associated with us.

Although we monitor developments, including social media, 
for  areas  of  potential  risk  to  our  brand  and  reputation, 
negative  publicity  or  misrepresentations  by  third  parties, 
particularly  on  social  media,  may  adversely  impact  our 
credibility  as  a  leader  in  the  global  capital  markets  and  as  a 
source for data and analytics, and may have an adverse effect 
on our brands, business and operating results. 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,  Index,  IR  &  ESG  Services  or  Market 
Technology  businesses.  This,  in  turn,  may  have  a  material 
adverse  effect  on  our  business,  financial  condition  and 
operating results.

Failure to meet customer expectations or deadlines for the 
implementation  of  our  products  could  result  in  negative 
publicity, losses and reduced sales, each of which may harm 
our reputation, business and results of operations.

and 

budget 

associated  with 

large-scale  market 

We  generally  mutually  agree  with  our  customers  on  the 
duration, 
the 
costs 
implementation  of  certain  of  our  products,  particularly  our 
Market  Technology 
infrastructure 
projects.  Various  factors  may  cause  implementations  to  be 
delayed, inefficient or otherwise unsuccessful, including due 
to  unforeseen  project  complexities,  our  deployment  of 
insufficient resources, logistical challenges due to the effects 
of  COVID-19  or  other  external  factors.  The  effects  of  a 
failure  to  meet  an  implementation  schedule  could  include 
monetary credits for current or future service engagements, a 
reduction  in  fees  for  the  project,  or  the  expenditure  of 
additional expenses to mitigate such delays. In addition, time-

consuming implementations may also increase the personnel 
we  must  allocate  to  such  customer,  thereby  increasing  our 
costs  and  diverting  attention 
from  other  projects. 
Unsuccessful,  lengthy,  or  costly  customer  implementation 
projects  could  result  in  claims  from  customers,  decreased 
customer 
reputation,  and 
opportunities  for  competitors  to  displace  us,  each  of  which 
could have an adverse effect on our reputation, business and 
results of operations.

satisfaction,  harm 

to  our 

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.

effective 

jurisdictions.  However, 

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  for 
software products and pursue patent protection for inventions 
developed  by  us.  We  hold  a  number  of  patents,  patent 
applications  and  licenses  in  the  United  States  and  other 
foreign 
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.  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  parties,  any  of  which  could 
adversely  affect  our  business,  financial  condition  and 
operating results.

29

GENERAL RISK FACTORS

We are a holding company that depends on cash flow from 
to  meet  our  obligations,  and  any 
our  subsidiaries 
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;

• volatility  in  commodity  markets,  including  the  energy 

markets;

• changes in government monetary or tax policy;

• the  imposition  of  governmental  economic  sanctions  on 
countries  in  which  we  do  business  or  where  we  plan  to 
expand our business;

• 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 

30

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 
is  below  management’s 
revenue. 
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.

If  actual 

revenue 

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 
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.

in  processes  or  reporting  due 

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, 
significant 
litigation  against  us  might  unduly  burden 
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  its  intended  purpose.  Because  our 
clients depend on our solutions for critical business 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,  and  climate  change  disclosure  requirements 
may reduce demand for listings on our exchanges.

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  that  we  use  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; cause increased volatility in commodity markets 
in which Nasdaq Clearing operates as a clearinghouse, which 
may result in Nasdaq Clearing holding insufficient collateral 
for  such  volatility;  lead  to  an  increase  in  costs  of  raw 
materials,  which  may  adversely  affect  certain  of  our  listed 
companies  operating  in  certain  sectors  and  create  adverse 
trading  volatility  beyond 
market  conditions, 
historical  levels,  any  of  which  could  adversely  affect  our 
business,  reputation,  financial  condition  and  operating 
results.  Additionally,  if  the  SEC  or  other  federal  regulatory 
reporting  obligations 
agencies 
regarding climate change on public companies, there may be 
a decrease in new listings or an increase in de-listings of our 
listed  companies,  which  may  adversely  affect  our  business, 
results.  Such  new 
financial  condition  and  operating 
regulations, whether in the U.S. or in other countries in which 
we  operate,  could  also  cause  us 
incur  additional 
compliance and reporting costs.

impose  comprehensive 

including 

to 

Our  businesses  operate  in  various  international  markets, 
including  certain  emerging  markets  that  are  subject  to 
greater  political,  economic  and  social  uncertainties  than 
developed countries.

to 

in 

the 

inherent 

the  risk 

Our  businesses  operate  in  various  international  markets, 
including but not limited to Northern Europe, the Baltics, the 
Middle  East,  Africa  and  Asia,  and  our  non-U.S.  operations 
are  subject 
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, have 
economies that may be subject to greater political, economic 
and  social  uncertainties  than  countries  with  more  developed 
institutional  structures,  which  may  increase  our  operational 
risk.

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, pandemics 
(such  as  COVID-19),  extreme  weather,  fire,  power  loss, 
telecommunications failures, human error, theft, sabotage and 

31

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, 
Sweden, 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.  Additionally, 
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.

We  have  operations  in  the  U.S.,  the  Nordic  and  Baltic 
countries, Canada, the United Kingdom, Australia and many 
other  foreign  countries.  We  therefore  have  significant 
exposure  to  exchange  rate  movements  between  the  Euro, 
Swedish  Krona,  the  Canadian  dollar  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 is comprised of senior executives and has 
the  responsibility  for  regularly  reviewing  risks  and  referring 
significant  risks  to  the  board  of  directors  or  specific  board 
committees.  Local  risk  management  committees  in  our 
international  offices  provide 
local  risk  oversight  and 
escalation  to  local  boards,  as  appropriate.  Certain  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 and 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 
imposed  by  applicable  law  and  other  factors  that  the  board 
deems relevant. Based on an evaluation of these factors, the 
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.

restrictions, 

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.

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 regularly monitor the facilities 
we occupy to ensure that they suit our needs, particularly as 
we transition to a hybrid work environment as we reopen our 
global  offices.  We  believe  the  facilities  that  we  occupy  are 
adequate  for  the  purposes  for  which  they  are  currently  used 
and  are  well-maintained.  See  Note  16,  “Leases,”  to  the 
consolidated financial statements for further discussion.

Item 3. Legal Proceedings

See “Legal and Regulatory Matters - Litigation,” of Note 18, 
“Commitments,  Contingencies  and  Guarantees,” 
the 
consolidated  financial  statements,  which  is  incorporated 
herein by reference.

to 

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 14, 2022, 
we had approximately 214 holders of record of our common 
stock.

32

• Employee transactions represents shares surrendered to us 
to  satisfy  tax  withholding  obligations  arising  from  the 
vesting of restricted stock and PSUs issued to employees.

• In  July  2021,  we  entered  into  an  ASR  agreement  to 
repurchase  $475  million  of  common  stock.  See  “ASR 
Agreements,” of Note 12, “Nasdaq Stockholders’ Equity,” 
to 
the  consolidated  financial  statements  for  further 
discussion.

Issuer Purchases of Equity Securities 

Share Repurchase Program

See  “Share  Repurchase  Program,”  of  Note  12,  “Nasdaq 
Stockholders’  Equity,” 
financial 
statements  for  further  discussion  of  our  share  repurchase 
program.

the  consolidated 

to 

Purchases of Equity Securities by the Issuer and 
Affiliated Purchasers

The table below represents repurchases made by or on behalf 
of  us  or  any  “affiliated  purchaser”  of  our  common  stock 
during the fiscal quarter ended December 31, 2021:

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

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

(a) 
Total Number 
of Shares 
Purchased

(b) 
Average 
Price Paid 
Per Share

—  $  — 

—  $  984 

12,368  $ 203.46 

 N/A

 N/A

—  $  — 

—  $  984 

  391,272 

See 
below   391,272  $  984 

515  $ 212.83 

 N/A

 N/A

Period

October 2021

Share 
repurchase 
program
Employee 
transactions

November 2021

Share 
repurchase 
program
ASR 
agreement
Employee 
transactions

December 2021

Share 
repurchase 
program
Employee 
transactions
Total Quarter Ended December 31, 2021

  287,657  $ 204.34 

46,854  $ 210.24 

  287,657  $  926 

 N/A

 N/A

Share 
repurchase 
program
ASR 
agreement
Employee 
transactions

  287,657  $ 204.34 

  287,657  $  926 

  391,272 

See 
below   391,272  $  926 

59,737  $ 208.86 

 N/A

N/A

In the table above:

• N/A - Not applicable.
• See  “Share  Repurchase  Program,”  of  Note  12,  “Nasdaq 
Stockholders’  Equity,” 
the  consolidated  financial 
to 
statements  for  further  discussion  of  our  share  repurchase 
program. 

33

 
 
 
 
 
 
 
 
 
 
 
PERFORMANCE GRAPH

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, shown below, for the past five years:

• ASX Limited

• Deutsche Börse AG

• LSE 

• B3 S.A.
• Bolsas Mexicana de Valores, S.A.B. 

• Euronext N.V.
• Hong Kong Exchanges and Clearing 

• Singapore Exchange Limited
• TMX Group Limited

Peer Group

de C.V.

• Cboe
• CME Group Inc.

Limited

• ICE
• Japan Exchange Group, Inc

The figures represented below assume an initial investment of $100 in the common stock or index at the closing price on 
December 31, 2016 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 12/31/2016 in stock or index, including reinvestment of dividends.

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

Fiscal Year Ended December 31,

2016

2017

2018

2019

2020

2021

$ 

100  $ 
100 
100 
100 

117  $ 
130 
122 
127 

126  $ 
126 
116 
129 

169  $ 
172 
153 
197 

213  $ 
250 
181 
248 

342 
305 
233 
216 

Copyright© 2022 Standard & Poor's, a division of S&P Global. All rights reserved.

34

Period EndedNasdaq, Inc.Nasdaq Composite IndexS&P 500Peer Group201620172018201920202021$50$100$150$200$250$300$350 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Year Ended December 31,

Percentage Change

2021

2020

2019

(in millions, except per share 
amounts)

2021 vs. 
2020

2020 vs. 
2019

$  3,420  $  2,903  $  2,535 

 17.8 %  14.5 %

  1,979    1,669    1,518 

 18.6 %  9.9 %

  1,441    1,234    1,017 

 16.8 %  21.3 %

$  1,187  $  933  $  774 

 27.2 %  20.5 %

$  7.05  $  5.59  $  4.63 

 26.1 %  20.7 %

$  2.11  $  1.94  $  1.85 

 8.8 %  4.9 %

Revenues 
less 
transaction-
based 
expenses
Operating 
expenses
Operating 
income

Net income 
attributable 
to Nasdaq

Diluted 
earnings 
per share

Cash 
dividends 
declared 
per 
common 
share

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.”

Nasdaq's Operating Results

The following chart summarizes our ARR (in millions): 

Item 6. [Reserved]

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, 2021 and December 31, 
2020. Discussion of fiscal year 2020 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, 2020 and December 31, 2019 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, 2020, which was previously filed with the SEC 
on February 23, 2021.

Business Segments

We manage, operate and provide our products and services in 
four  business  segments:  Market  Technology,  Investment 
Intelligence,  Corporate  Platforms  and  Market  Services.  See 
Note  1,  “Organization  and  Nature  of  Operations,”  and  Note 
19,  “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.  See  “Part  I,  Item  1. 
Business”  for  additional  discussion  on  recent  developments 
and highlights. 

Financial Summary

The  following  table  summarizes  our  financial  performance 
for the year ended December 31, 2021 when compared to the 
same  period  in  2020  and  for  the  year  ended  December  31, 
2020  when  compared  to  the  same  period  in  2019.  The 
comparability  of  our  results  of  operations  between  reported 
periods is impacted by the acquisition of Verafin in February 
2021 and the divestiture of our U.S. Fixed Income business, 
which  was  part  of  our  FICC  business  within  our  Market 
Services segment in June 2021. See “2021 Divestiture,” and 
“2021  Acquisition,”  of  Note  4,  “Acquisitions  and 
Divestiture,”  to  the  consolidated  financial  statements  for 
further discussion. For a detailed discussion of our results of 
operations, see “Segment Operating Results” below.

35

$1,871$1,577$1,446$330$308$284$546$470$430$567$516$472$428$283$260Market TechnologyInvestment IntelligenceCorporate PlatformsMarket Services4Q214Q204Q19 
 
 
 
 
Segment Operating Results

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

Year Ended December 31,

Percentage Change

2021

2020

2019

(in millions)

2021 vs. 
2020

2020 vs. 
2019

Market 
Technology  $ 

463  $ 

357  $ 

338 

 29.7  %

 5.6 %

Investment 
Intelligence

Corporate 
Platforms

Market 
Services

Other 
revenues

Total 
revenues

Transaction 
rebates

Brokerage, 
clearance 
and 
exchange 
fees

Total 
revenues 
less 
transaction-
based 
expenses

1,076   

898   

768 

 19.8  %  16.9 %

613   

521   

490 

 17.7  %

 6.3 %

3,707   

3,818   

2,616 

 (2.9) %  45.9 %

27   

31   

46 

 (12.9) %  (32.6) %

5,886   

5,625   

4,258 

 4.6  %  32.1 %

(2,168)   

(2,028)   

(1,324) 

 6.9  %  53.2 %

(298)   

(694)   

(399) 

 (57.1) %  73.9 %

$  3,420  $  2,903  $  2,535 

 17.8  %  14.5 %

ARR  for  a  given  period  is  the  annualized  revenue  derived 
from  subscription  contracts  with  a  defined  contract  value. 
This excludes contracts that are not recurring, are one-time in 
nature,  or  where  the  contract  value  fluctuates  based  on 
defined  metrics.  ARR 
is  currently  one  of  our  key 
performance metrics to assess the health and trajectory of our 
recurring  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 at the end of a reporting period used in calculating 
ARR  may  or  may  not  be  extended  or  renewed  by  our 
customers.

The ARR chart includes:
▪
▪

Active  Market  Technology  support  and  SaaS 
subscription contracts.

Proprietary market data and index data subscriptions 
as  well  as  subscription  contracts  for  eVestment, 
Solovis,  NDW  Research  Platform,  Nasdaq  Fund 
Network  and  Nasdaq  Data  Link.  It  also  includes 
guaranteed  minimum  on  futures  contracts  within  the 
Index business.

▪

▪

U.S.  and  Nordic  annual  listing  fees,  IR  and  ESG 
products,  including  subscription  contracts  for  IR 
Insight,  board  portals  and  OneReport,  as  well  as  IR 
advisory services. 

Trade Management Services business, excluding one-
time service requests.

The  following  chart  summarizes  our  quarterly  annualized 
SaaS  revenues  for  our  Solutions  Segments,  which 
is 
comprised  of  Market  Technology,  Investment  Intelligence 
and Corporate Platforms, for the fourth quarter of 2021, 2020 
and 2019 (in millions):

36

$640$448$404$148$144$136$208$180$160$284$124$108Market TechnologyInvestment IntelligenceCorporate Platforms4Q214Q204Q19 
 
 
 
 
 
 
 
 
 
 
 
The  following  charts  present  our  Market  Technology, 
Investment  Intelligence,  Corporate  Platforms  and  Market 
Services segments as a percentage of our total revenues, less 
transaction-based  expenses,  of  $3,420  million  for  the  year 
ended December 31, 2021, $2,903 million for the year ended 
December  31,  2020  and  $2,535  million  for  the  year  ended 
December 31, 2019.

Percentage of Revenues Less Transaction-based Expenses 
by Segment for the: 

37

Year Ended December 31, 2021MarketServices:36.3%CorporatePlatforms:17.9%Otherrevenues:0.8%InvestmentIntelligence:31.5%MarketTechnology:13.5%Year Ended December 31, 2020MarketServices:37.8%CorporatePlatforms:17.9%Otherrevenues:1.1%InvestmentIntelligence:30.9%MarketTechnology:12.3%Year Ended December 31, 2019MarketServices:35.2%CorporatePlatforms:19.4%Otherrevenues:1.8%InvestmentIntelligence:30.3%MarketTechnology:13.3% 
  216    227    217 

 (4.8) %  4.6 %

ARR (in millions)

$ 463  $ 357  $ 338 

 29.7 %  5.6 %

Market Data Revenues

SaaS revenues (in millions)

$  208  $  180  $  160 

Number of licensed ETPs
ETP AUM tracking Nasdaq 
indexes (in billions)

Net appreciation (in billions)
Net impact of ETP sponsor 
switches (in billions)

Net inflows in ETP AUM 
tracking Nasdaq indexes (in 
billions)

Year Ended December 31,

2021

2020

2019

362 

339 

332

$  424  $  359  $  233 

$ 

83  $ 

80  $ 

48 

$ 

(92)  $  —  $  — 

$ 

74  $ 

46  $ 

13 

$  567  $  516  $  472 

Market data revenues increased in 2021 compared with 2020 
primarily  due  to  an  increase  in  proprietary  data  revenues 
from new sales primarily outside the U.S., partially offset by 
lower U.S. shared tape plan revenues.

Index Revenues

Index  revenues  increased  in  2021  compared  with  2020 
primarily  due  to  higher  licensing  revenues  from  higher 
average AUM in ETPs linked to Nasdaq indexes and higher 
licensing  revenues  from  futures  trading  linked  to  the 
Nasdaq-100 Index.

Analytics Revenues

Analytics  revenues  increased  in  2021  compared  with  2020 
primarily  due  to  the  growth  in  our  eVestment  and  Solovis 
products  driven  by  new  sales,  strong  retention,  and  higher 
average revenue per client from expanded offerings. 

CORPORATE PLATFORMS

The  following  tables  present  revenues  and  key  drivers  from 
our Corporate Platforms segment:

Year Ended December 31,

Percentage Change

2021

2020

2019

(in millions)

Listing Services $  387  $  307  $  290 
IR & ESG 
Services
Total Corporate 
Platforms

$  613  $  521  $  490 

  226    214    200 

2021 vs. 
2020

2020 vs. 
2019

 26.1 %  5.9 %

 5.6 %  7.0 %

 17.7 %  6.3 %

MARKET TECHNOLOGY

The  following  tables  present  revenues  and  key  drivers  from 
our Market Technology segment:

Year Ended December 31,

Percentage Change

2021

2020

2019

(in millions)

2021 vs. 
2020

2020 vs. 
2019

$ 247  $ 130  $ 121 

 90.0 %  7.4 %

Anti Financial 
Crime 
Technology

Marketplace 
Infrastructure 
Technology
Total Market 
Technology

Order intake 
ARR
SaaS revenues

Year Ended December 31,

2021

2020

2019

$ 

(in millions)

378  $ 
428 
284 

240  $ 
283 
124 

366 
260
108

In the table above, order intake is the total contract value of 
orders signed during the period, excluding Verafin. ARR and 
SaaS revenues include Verafin.

Anti Financial Crime Technology Revenues

Anti-financial  crime  technology  revenues  increased  in  2021 
compared  with  2020  primarily  due  to  the  inclusion  of 
revenues  from  our  acquisition  of  Verafin  and  continued 
growth in surveillance solutions.

Marketplace Infrastructure Technology Revenues

Marketplace infrastructure technology revenues decreased in 
lower 
2021  compared  with  2020  primarily  due 
professional  services  revenues  reflecting  both  an  elevated 
prior  year  comparison  period  as  well  as  capacity  constraints 
that  pandemic-related 
imposed  on 
installation  and  change  request  projects  as  well  as  the 
completion of a significant long-term contract, partially offset 
by an increase in SaaS revenues.

logistical  challenges 

to 

INVESTMENT INTELLIGENCE

The  following  tables  present  revenues  and  key  drivers  from 
our Investment Intelligence segment:

Year Ended December 31,

2021

2020

2019

Percentage Change
2020 vs. 
2021 vs. 
2019
2020

(in millions)

Market Data
Index

Analytics

$  414  $  399  $  387 
223 

459   

324   

 3.8 %  3.1 %
 41.7 %  45.3 %

203   

175   

158 

 16.0 %  10.8 %

Total 
Investment 
Intelligence $  1,076  $  898  $  768 

 19.8 %  16.9 %

38

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Year Ended December 31,

2021

2020

2019

IR & ESG Services Revenues 

IR  &  ESG  Services  revenues  increased  in  2021  compared 
with  2020  primarily  due  to  higher  adoption  of  our  investor 
relations intelligence products as well as new ESG solutions.

752 

316 

188

MARKET SERVICES

Equity Derivative Trading and Clearing Revenues 

The following tables present total revenues, transaction-based 
expenses, and total revenues less transaction-based expenses 
as  well  as  key  drivers  from  our  Equity  Derivative  Trading 
and Clearing business:

Year Ended December 31,

Percentage Change

2021

2020

2019

(in millions)

2021 vs. 
2020

2020 vs. 
2019

$ 1,469  $ 1,258  $  816 

 16.8  %  54.2  %

 (1,018)   (828)   (477) 

 22.9  %  73.6  %

(38)  

(76)  

(47)   (50.0) %  61.7  %

$  413  $  354  $  292 

 16.7  %  21.2  %

Equity Derivative 
Trading and 
Clearing 
Revenues

Transaction-based 
expenses:

Transaction 
rebates

Brokerage, 
clearance and 
exchange fees

Equity derivative 
trading and 
clearing 
revenues less 
transaction-based 
expenses

In  the  table  above,  brokerage,  clearance  and  exchange  fees 
includes Section 31 fees of $32 million in 2021, $69 million 
in 2020 and $43 million in 2019. Section 31 fees are recorded 
as  equity  derivative  trading  and  clearing  revenues  with  a 
transaction-based 
recorded 
corresponding 
expenses. 

amount 

in 

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

Total new listings
The Nasdaq Stock 
Market
Exchanges that 
comprise Nasdaq 
Nordic and Nasdaq 
Baltic

Number of listed 
companies
The Nasdaq Stock 
Market
Exchanges that 
comprise Nasdaq 
Nordic and Nasdaq 
Baltic

ARR (in millions)
SaaS revenues (in 
millions)

$ 

$ 

In the table above:

174 

45 

34

1,000 

454 

313

207 

67 

53

4,178 

3,392 

3,140 

1,235 

1,071 

546  $ 

470  $ 

1,040 

430 

148  $ 

144  $ 

136 

• The  Nasdaq  Stock  Market  new  listings  include  IPOs, 
including  issuers  that  switched  from  other  listing  venues 
and separately listed ETPs. For the years ended December 
31,  2021,  2020  and  2019,  IPOs  included  433,  132  and  43 
SPACs, respectively.

• Exchanges that comprise Nasdaq Nordic and Nasdaq Baltic 
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.

• Number  of  total  listed  companies  on  The  Nasdaq  Stock 
Market for the years ended December 31, 2021, 2020 and 
2019 included 441, 412 and 412 ETPs, respectively.

• Number  of  total  listed  companies  on  the  exchanges  that 
comprise  Nasdaq  Nordic  and  Nasdaq  Baltic  represents 
companies listed on these exchanges and companies on the 
alternative markets of Nasdaq First North.

Listing Services Revenues

Listing  services  revenues  increased  in  2021  compared  with 
2020  primarily  due  to  an  increase  in  the  overall  number  of 
listed companies.

39

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cash Equity Trading Revenues

The following tables present total revenues, transaction-based 
expenses, and total revenues less transaction-based expenses 
as well as key drivers and other metrics from our Cash Equity 
Trading business:

Year Ended December 31,

Percentage Change

2021

2020

2019

(in millions)

2021 vs. 
2020

2020 vs. 
2019

$ 1,854  $ 2,211  $ 1,462 

 (16.1) %  51.2 %

 (1,150)  (1,200)  

(847) 

 (4.2) %  41.7 %

(260)  

(618)  

(352) 

 (57.9) %  75.6 %

$  444  $  393  $  263 

 13.0 %  49.4 %

Cash Equity 
Trading 
Revenues

Transaction-
based 
expenses:

Transaction 
rebates

Brokerage, 
clearance 
and 
exchange 
fees

Cash equity 
trading 
revenues less 
transaction-
based 
expenses

In  the  table  above,  brokerage,  clearance  and  exchange  fees 
includes  Section  31  fees  of  $228  million  in  2021,  $586 
million in 2020 and $337 million in 2019. Section 31 fees are 
revenues  with  a 
recorded  as  cash  equity 
corresponding 
transaction-based 
expenses.

recorded 

amount 

trading 

in 

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

Year Ended December 31,

2021

2020

2019

  37.2 

  27.7 

  17.5 

 12.4% 

 12.7% 

 15.9% 

 8.1% 

 9.8% 

 8.8% 

 1.4% 

 0.2% 

 0.2% 

 6.6% 

 7.8% 

 9.0% 

 4.3% 

 5.6% 

 4.2% 

 1.6% 

 0.7% 

 0.2% 

 34.4% 

 36.8% 

 38.3% 

Nasdaq Nordic and Nasdaq Baltic options and futures
Total average daily volume of 
options and futures contracts

287,182 320,204  366,289 

In  the  table  above,  Nasdaq  Nordic  and  Nasdaq  Baltic  total 
average daily volume of options and futures contracts include 
Finnish  option  contracts  traded  on  Eurex  for  which  Nasdaq 
and Eurex have a revenue sharing arrangement.

Equity  derivative  trading  and  clearing  revenues  and  equity 
derivative  trading  and  clearing  revenues  less  transaction-
based  expenses  increased  in  2021  compared  with  2020 
primarily  due  to  higher  U.S.  industry  trading  volumes, 
partially  offset  by  lower  overall  U.S.  matched  market  share 
executed  on  Nasdaq's  exchanges  and  a  lower  capture  rate. 
Also  partially  offsetting  the  increase  in  equity  derivative 
trading  and  clearing  revenues  was  lower  Section  31  pass-
through fee revenue.

Section 31 fees are recorded as equity derivative trading and 
clearing  revenues  with  a  corresponding  amount  recorded  as 
brokerage,  clearance  and  exchange  fees  in  the  Consolidated 
Statements of Income. 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 brokerage, clearance and exchange fees, there is no impact 
on  our  revenues  less  transaction-based  expenses.  Section  31 
fees  decreased  in  2021  compared  with  2020  due  to  lower 
average SEC fee rates, partially offset by higher dollar value 
traded on Nasdaq's exchanges. 

Transaction  rebates,  in  which  we  credit  a  portion  of  the  per 
share execution charge to the market participant, increased in 
2021  compared  with  2020.  The  increase  in  2021  was 
primarily  due  to  higher  U.S.  industry  trading  volumes, 
partially  offset  by  lower  overall  U.S.  matched  market  share 
executed  on  Nasdaq's  exchanges  and  a  lower  rebate  capture 
rate. 

40

 
 
 
 
 
 
 
 
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

Year Ended December 31,

2021

2020

2019

  11.4 

  10.9 

7.0 

  491.9 

  508.3 

  348.1 

 15.8% 

 16.8% 

 17.2% 

Transaction rebates decreased 2021 compared with 2020. For 
The  Nasdaq  Stock  Market  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. The decrease was 
primarily  due  to  lower  overall  U.S.  matched  market  share 
executed  on  Nasdaq's  exchanges  and  a  lower  rebate  capture 
rate, partially offset by higher U.S. industry trading volumes.

 0.6% 

 0.9% 

 1.7% 

FICC Revenues

 0.7% 

 0.6% 

 0.7% 

The  following  table  present  revenues  from  our  FICC 
business:

 17.1% 

 18.3% 

 19.6% 

 34.9% 

 52.0% 

 31.8% 

 50.1% 

 29.8% 

 49.4% 

Nasdaq Nordic and Nasdaq Baltic securities
Average daily number of 
equity trades executed on 
Nasdaq’s exchanges

1,036,523 933,822  590,705 

Total average daily value of 
shares traded (in billions)

Total market share executed 
on Nasdaq’s exchanges

$  6.4 

$  5.6 

$  4.5 

 76.9% 

 78.1% 

 72.8% 

In  the  table  above,  total  market  shares  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.

Cash  equity  trading  revenues  decreased  in  2021  compared 
with 2020 primarily due to lower Section 31 pass-through fee 
revenue  and  lower  overall  U.S.  matched  market  share 
executed  on  Nasdaq's  exchanges,  partially  offset  by  higher 
U.S.  industry  trading  volumes,  higher  U.S.  gross  capture 
rates,  higher  European  value  traded  and  a  favorable  impact 
from changes in foreign exchange rates.

Cash equity trading revenues less transaction-based expenses 
increased  in  2021  compared  with  2020  primarily  due  to 
higher  U.S.  net  capture  rates,  higher  U.S.  industry  trading 
volumes,  higher  European  value  traded  and  a  favorable 
impact  from  changes  in  foreign  exchange  rates,  partially 
offset  by  lower  overall  U.S.  matched  market  share  executed 
on Nasdaq's 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  brokerage, 
clearance  and  exchange  fees  in  the  Consolidated  Statements 
of Income. 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 brokerage, clearance and exchange fees, 
there  is  no  impact  on  our  revenues  less  transaction-based 
expenses.  Section  31  fees  decreased  in  2021  compared  with 
2020 primarily due to lower average SEC fee rates.

41

Year Ended December 31,

Percentage Change

2021

2020

2019

(in millions)

2021 vs. 
2020

2020 vs. 
2019

FICC Revenues $ 

59  $ 

53  $ 

51 

 11.3  %  3.9  %

FICC  revenues  increased  in  2021  compared  with  2020 
primarily  due  to  higher  European  products  revenues  and  a 
positive impact from foreign exchange rates.

Trade Management Services Revenues

The  following  tables  present  revenues  and  key  drivers  from 
our Trade Management Services business:

Year Ended December 31,

Percentage Change

2021

2020

2019

(in millions)

2021 vs. 
2020

2020 vs. 
2019

Trade 
Management 
Services 
Revenues

ARR

$  325  $  296  $  287 

 9.8 %  3.1 %

Year Ended December 31,

2021

2020

2019

(in millions)
$  330  $  308  $  284 

Trade  management  services  revenues  increased  in  2021 
compared  with  2020  primarily  due  to  increased  demand  for 
connectivity and infrastructure services.

OTHER REVENUES

Other revenues include the revenues associated with our U.S. 
Fixed Income business, which was sold in June 2021. Prior to 
the  sale  date,  these  revenues  were  included  in  our  Market 
Services  and  Investment  Intelligence  segments.  See  “2021 
Divestiture,” of Note 4,“Acquisitions and Divestiture,” to the 
consolidated  financial  statements  for  further  discussion  of 
this  divestiture.  Additionally,  other 
include 
revenues  associated  with  the  NPM  business  which  we 
contributed  in  July  2021  to  a  standalone,  independent 
company,  of  which  we  own  the  largest  minority  interest, 
together  with  a  consortium  of 
financial 
institutions. Prior to July 2021, these revenues were included 
in our Corporate Platforms segment. 

third  party 

revenues 

 
 
 
 
EXPENSES

Operating Expenses 

The following tables present our operating expenses:

Year Ended December 31,

2021

2020

2019

(in millions)

Percentage Change
2020 vs. 
2021 vs. 
2019
2020

$  938  $  786  $  707 

 19.3  %  11.2 %

144   

137   

127 

 5.1  %  7.9 %

186   

151   

133 

 23.2  %  13.5 %

Compensation and 
benefits

Professional and 
contract services
Computer 
operations and 
data 
communications

Occupancy

109   

107   

97 

 1.9  %  10.3 %

General, 
administrative 
and other

Marketing and 
advertising

Depreciation and 
amortization

Regulatory

Merger and 
strategic 
initiatives
Restructuring 
charges
Total 
operating 
expenses

85   

142   

125 

 (40.1) %  13.6 %

57   

39   

39 

 46.2  %

 — %

278   

202   

190 

 37.6  %  6.3 %

64   

24   

31 

 166.7  %  (22.6) %

87   

33   

30 

 163.6  %  10.0 %

31   

48   

39 

 (35.4) %  23.1 %

$ 1,979  $ 1,669  $ 1,518 

 18.6  %  9.9 %

The  increase  in  compensation  and  benefits  expense  in  2021 
compared  with  2020  was  primarily  driven  by  higher 
performance-linked  compensation  expense,  our  continued 
investment  to  drive  growth,  an  increase  in  headcount  as  a 
result  of  our  acquisition  of  Verafin  and  an  unfavorable 
impact from foreign exchange rates. 

Headcount increased to 5,814 employees as of December 31, 
2021  from  4,830  as  of  December  31,  2020  primarily  due  to 
our recent acquisition of Verafin.

Professional and contract services expense increased in 2021 
compared  with  2020  primarily  due  to  an  increase  in 
consulting costs.

Computer  operations  and  data  communications  expense 
increased  in  2021  compared  with  2020  primarily  due  to  our 
acquisition  of  Verafin  and  higher  hardware  and  software 
maintenance costs due to increased cloud storage costs.

Marketing  and  advertising  expense 
in  2021 
compared  with  2020  primarily  due  to  an  increase  in 
marketing  commitments  primarily  driven  by  the  increase  in 
new listings.

increased 

Depreciation  and  amortization  expense  increased  in  2021 
compared with 2020 primarily due to additional expense for 
acquired  intangible  assets  related  to  our  acquisition  of 
Verafin. 

Regulatory  expense  increased  in  2021  compared  with  2020 
primarily  due  to  a  charge  associated  with  an  administrative 
fine issued by the SFSA. See “Nasdaq Commodities Clearing 
Default,”  of  Note  15,  “Clearing  Operations,” 
the 
consolidated financial statements for further discussion of the 
SFSA administrative fine. 

to 

Merger  and  strategic  initiatives  expense  increased  in  2021 
compared  with  2020  primarily  due  to  the  acquisition  of 
Verafin.  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  party 
transaction  costs  and  will  vary  based  on  the  size  and 
frequency of the activities described above.

See  Note  20,  “Restructuring  Charges,”  to  the  consolidated 
financial  statements  for  further  discussion  of  our  2019 
restructuring plan and charges associated with this plan.

Non-operating Income and Expenses

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

Year Ended December 31,

Percentage Change

2021

2020

2019

(in millions)

2021 vs. 
2020

2020 vs. 
2019

Interest income

$ 

1  $ 

4  $ 

10 

 (75.0) %  (60.0) %

Interest expense  

(125)   

(101)   

(124) 

 23.8  %  (18.5) %

Net interest 
expense

Net gain on 

divestiture of 
businesses

(124)   

(97)   

(114) 

 27.8  %  (14.9) %

84 

  — 

27 

N/M  (100.0) %

Other income

81 

5 

5 

 1,520.0  %

 — %

Net income 

from 
unconsolidated 
investees

Total non-
operating 
income

52 

70 

84 

 (25.7) %  (16.7) %

$ 

93  $ 

(22)  $ 

2 

 (522.7) %  (1,200.0) %

Occupancy  expense  increased  in  2021  compared  with  2020 
due to our acquisition of Verafin and higher data center costs.

____________
N/M Not meaningful.

General, administrative and other expense decreased in 2021 
compared  with  2020  primarily  due  to  charitable  donations 
made  to  the  Nasdaq  Foundation,  COVID-19  response  and 
relief  efforts  and  social  justice  charities  in  2020,  and  a 
reserve  recorded  for  a  loss  on  a  Market  Technology 
implementation project in 2020.

Interest  income  decreased  in  2021  compared  with  2020 
primarily due to a decrease in interest rates and lower average 
cash and cash equivalents balance.

42

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table presents our interest expense:

NON-GAAP FINANCIAL MEASURES

Year Ended December 31,

Percentage Change

2021

2020

2019

(in millions)

2021 vs. 
2020

2020 vs. 
2019

$ 115  $  93  $ 115 

 23.7 %  (19.1) %

7   

3   

6   

2   

6 

3 

 16.7 %  — %

 50.0 %  (33.3) %

Interest expense 
on debt

Accretion of debt 
issuance costs 
and debt 
discount

Other fees

Interest expense

$ 125  $ 101  $ 124 

 23.8 %  (18.5) %

Interest  expense  increased  in  2021  compared  with  2020 
primarily due to new issuances of senior notes in December 
2020  and  commercial  paper  issuances  in  the  first  quarter  of 
2021  to  fund  our  acquisition  of  Verafin.  See  “2021 
Acquisition,”  of  Note  4,  “Acquisitions  and  Divestiture,”  to 
the consolidated financial statements for further discussion of 
the acquisition of Verafin. See Note 9, “Debt Obligations,” to 
the consolidated financial statements for further discussion of 
our debt obligations.

The  net  gain  on  divestiture  of  businesses  in  2021  relates  to 
the  sale  of  our  U.S.  Fixed  Income  business,  which  was  part 
of  our  FICC  business  within  our  Market  Services  segment. 
We recognized a pre-tax gain on the sale of $84 million, net 
of  disposal  costs.  See  “2021  Divestiture,”  of  Note  4, 
“Acquisitions  and  Divestiture,”  to  the  consolidated  financial 
statements for further discussion.

Other  income  increased  in  2021  compared  with  2020 
primarily  due  to  gains  from  sales  of  strategic  investments 
entered into through our corporate venture program.

Net  income  from  unconsolidated  investees  decreased  in  the 
2021  compared  with  2020  primarily  due  to  a  decrease  in 
income  recognized  from  our  equity  method  investment  in 
OCC.  See  “Equity  Method  Investments,”  of  Note  6, 
“Investments,”  to  the  consolidated  financial  statements  for 
further discussion.

Tax Matters

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

Year Ended December 31,

Percentage Change

2021

2020

2019

(in millions)

2021 vs. 
2020

2020 vs. 
2019

Income tax 
provision

$  347  $  279  $  245 

 24.4 %  13.9 %

Effective tax rate

 22.6 %  23.0 %  24.0 %

For  further  discussion  of  our  tax  matters,  see  Note  17, 
“Income Taxes,” to the consolidated financial statements.

In  addition  to  disclosing  results  determined  in  accordance 
with  U.S.  GAAP,  we  have  also  provided  non-GAAP  net 
income  attributable  to  Nasdaq  and  non-GAAP  diluted 
earnings  per  share.  Management  uses  this  non-GAAP 
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 
the 
assess 
businesses,  the  relative  operating  performance  of  the 
businesses  between  periods,  and  the  earnings  power  of 
Nasdaq.  Performance  measures  excluding  intangible  asset 
amortization  expense  therefore  provide  investors  with  a 

the  day-to-day  operating  performance  of 

43

 
 
 
 
 
 
receivable  associated  with 

• for  the  year  ended  December  31,  2020,  a  provision  for 
notes 
funding  of 
technology  development  for  the  CAT  included  in 
in  our 
general,  administrative  and  other  expense 
Consolidated Statements of Income;

the 

• for  the  years  ended  December  31,  2021  and  2020,  a 
charge  on  extinguishment  of  debt  which  is  included  in 
general,  administrative  and  other  expense 
in  our 
Consolidated Statements of Income;

• for  the  year  ended  December  31,  2021,  a  net  gain  on 
divestiture of business, which represents our pre-tax net 
gain of $84 million on the sale of our U.S. Fixed Income 
business; 

• for  the  year  ended  December  31,  2020,  charitable 
donations  made  to  the  Nasdaq  Foundation,  COVID-19 
response  and  relief  efforts,  and  social  justice  charities 
included in general, administrative and other expense in 
our Consolidated Statements of Income; and

• for  the  year  ended  December  31,  2021  gains  from 
strategic investments entered into through our corporate 
venture  program  included  in  other  income  in  our 
Consolidated Statements of Income.

• Significant  tax  items:  The  non-GAAP  adjustment  to  the 
income  tax  provision  for  the  years  ended  December  31, 
2021 and 2020 includes the tax impact of each non-GAAP 
adjustment.  In  addition,  for  year  ended  December  31, 
2021,  the  non-GAAP  adjustment  to  the  income  tax 
provision  includes  return-to-provision  adjustments  and 
prior period tax benefits and for the year ended December 
31, 2020, a tax benefit on compensation related deductions 
determined  to  be  allowable  and  excess  tax  benefit  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. Beginning with the quarter 
ended  March  31,  2021,  such  excess  tax  benefits  are  no 
longer included as a non-GAAP adjustment as they do not 
have a material impact on period over period comparison.

useful representation of our businesses’ ongoing activity in 
each period.

• 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  20,  “Restructuring  Charges,”  to  the  consolidated 
financial  statements  for  further  discussion  of  our  2019 
restructuring  plan,  which  was  completed  in  June  2021. 
represented  a 
Charges  associated  with 
fundamental shift in our strategy and technology as well as 
executive re-alignment and were 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.

this  plan 

• Net  income  from  unconsolidated  investee:  See  “Equity 
Method  Investments,”  of  Note  6,  “Investments,”  to  the 
consolidated  financial  statements  for  further  discussion. 
Our  income  on  our  investment  in  OCC  may  vary 
significantly compared to prior periods due to the changes 
in OCC's capital management policy. 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.

• 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.  Other  significant 
items include:

• for the year ended December 31, 2021 a charge related to 
an  administrative  fine  imposed  by  the  SFSA  associated 
with  the  default  that  occurred  in  2018,  see  “Nasdaq 
Commodities  Clearing  Default,”  of  Note  15,  “Clearing 
Operations,” to the consolidated financial statements for 
further discussion, and for the year ended December 31, 
2020, the reversal of a $6 million regulatory fine issued 
by  the  SFSA.  Both  charges  have  been  included  in 
regulatory  expense  in  our  Consolidated  Statements  of 
Income;

44

The  following  table  presents  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:

U.S. GAAP net income 
attributable to Nasdaq

Non-GAAP adjustments:
Amortization expense of 
acquired intangible assets
Merger and strategic initiatives 
expense
Restructuring charges
Net income from unconsolidated 
investee

Regulatory matters

Provision for notes receivable

Extinguishment of debt
Net gain on divestiture of 
businesses

Charitable donations
Other

Year Ended December 31,

2021

2020

2019

(in millions, except per share 
amounts)

$ 1,187  $ 933 

$ 774 

  170 

  103 

  101 

  87 
  31 

  33 
  48 

  30 
  39 

  (52) 

  (70) 

  (82) 

  33 

  — 

  33 

(6) 

  — 

6 

  36 

  20 

  11 

  (84) 

  — 

  (27) 

  — 
  (71) 

  17 
  14 

  181 

  — 
  17 

  109 

  (77) 

  (43) 

Total non-GAAP adjustments

  147 

Adjustment to the income tax 
provision to reflect non-GAAP 
adjustments and other tax items   (61) 

Excess tax benefits related to 
employee share-based 
compensation
Total non-GAAP tax 
adjustments

  — 

(6) 

(5) 

  (61) 

  (83) 

  (48) 

Total non-GAAP adjustments, 
net of tax

  86 

  98 

  61 

Non-GAAP net income 
attributable to Nasdaq

U.S. GAAP effective tax rate
Total adjustments from non-
GAAP tax rate

$ 1,273  $ 1,031  $ 835 

 22.6 %  23.0 %  24.0 %

 1.7 %  3.0 %  2.0 %

Non-GAAP effective tax rate

 24.3 %  26.0 %  26.0 %

Weighted-average common shares 
outstanding for diluted earnings 
per share

 168.4 

 166.9 

 167.0 

U.S. GAAP diluted earnings per 
share
Total adjustments from non-
GAAP net income

Non-GAAP diluted earnings per 
share

$ 7.05  $ 5.59  $ 4.63 

 0.51 

 0.59 

 0.37 

$ 7.56  $ 6.18  $ 5.00 

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.

As of December 31, 2021, our sources and uses of cash were 
not  materially  impacted  by  COVID-19  and  we  have  not 
identified any liquidity deficiencies as a result of the ongoing 
impact of the COVID-19 pandemic. 

We will continue to closely monitor and manage our liquidity 
and  capital  resources.  In  addition,  we  continue  to  prudently 
assess  our  capital  deployment  strategy  through  balancing 
acquisitions,  internal  investments,  debt  repayments,  and 
shareholder  return  activity,  including  share  repurchases  and 
dividends.

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

revolving  credit 

In  April  2021,  we  filed  a  universal  shelf  registration 
statement  on  Form  S-3ASR  (Automatic  Shelf  Registration) 
with  the  SEC  to  have  the  ability  to  sell  various  types  of 
securities including debt securities, common stock, preferred 
stock,  depository  receipts,  warrants,  subscription  rights, 
purchase contracts and purchase units. The specific terms of 
any  securities  to  be  sold  will  be  described  in  supplemental 
filings with the SEC. The registration statement will expire in 
April 2024.

In  July  2021,  we  issued  the  2033  Notes  and  primarily  used 
the  net  proceeds  from  the  sale  of  the  2033  Notes  to  redeem 
the  2023  Notes.  See 
“Early 
Extinguishment  of  2023  Notes,”  of  Note  9,  “Debt 
Obligations,”  to  the  consolidated  financial  statements  for 
further discussion.

“2033  Notes,” 

and 

the  current  portion  of 

The value of various assets and liabilities, including cash and 
cash  equivalents,  receivables,  accounts  payable  and  accrued 
expenses, 
long-term  debt,  and 
commercial  paper,  can  fluctuate  from  month  to  month. 
Working  capital  (calculated  as  current  assets  less  current 
liabilities)  was  $(449)  million  as  of  December  31,  2021, 
compared  with  $2,736  million  as  of  December  31,  2020,  a 
decrease  of  $3,185  million.  The  decrease  was  primarily  due 
to a decrease in cash and cash equivalents, mainly due to the 
utilization of cash to partially fund the acquisition of Verafin, 
increases  in  short-term  debt  and  deferred  revenue,  partially 
offset  by  a  decrease  in  Section  31  fees  payable  and  an 
increase in other current assets. 

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

•  deterioration  of  our  revenues  in  any  of  our  business 

segments;

45

 
 
 
 
 
•  changes  in  regulatory  and  working  capital  requirements; 

• other investing activities;

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;

•  credit  rating  downgrades,  which  could  limit  our  access  to 

additional debt;

•  a  significant  decrease  in  the  market  price  of  our  common 

stock; 

•  volatility  or  disruption  in  the  public  debt  and  equity 

markets; and

•  the impact of the COVID-19 pandemic on our business.

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

Financial Assets

The following table summarizes our financial assets:

December 31, 
2021

December 31, 
2020

(in millions)

393  $ 

2,745 

208 

195 

601  $ 

2,940 

$ 

$ 

Cash and cash equivalents

Financial investments

Total financial assets

Cash and Cash Equivalents

rates,  our 

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 
investment  policy,  and  alternative 
investment choices. As of December 31, 2021, our cash and 
cash  equivalents  of  $393  million  were  primarily  invested  in 
bank deposits and money market funds. 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,  2021 
decreased $2,352 million from December 31, 2020, primarily 
due to:

• payments related to employee shares withheld for taxes;

• payment of debt extinguishment cost, partially offset by;

• net cash provided by operating activities;

• proceeds from issuances of long-term debt, net of issuance 

costs and utilization of credit commitment;

• proceeds from commercial paper, net; and

• proceeds  from  divestiture  of  businesses,  net  of  cash 

divested.

See “Cash Flow Analysis” below for further discussion. 

Repatriation of Cash

Our  cash  and  cash  equivalents  held  outside  of  the  U.S.  in 
various  foreign  subsidiaries  totaled  $266  million  as  of 
December  31,  2021  and  $237  million  as  of  December  31, 
2020.  The  remaining  balance  held  in  the  U.S.  totaled  $127 
million  as  of  December  31,  2021  and  $2,508  million  as  of 
December 31, 2020. 

Unremitted  earnings  of  certain  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  12,  “Nasdaq 
Stockholders’  Equity,” 
financial 
statements  for  further  discussion  of  our  share  repurchase 
program.

the  consolidated 

to 

ASR Agreements

See “ASR Agreements,” of Note 12, “Nasdaq Stockholders’ 
Equity,”  to  the  consolidated  financial  statements  for  further 
discussion of our ASR agreements.

Cash Dividends on Common Stock

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

First quarter

Second quarter
Third quarter

Fourth quarter

Total

2021

2020

$ 

$ 

0.49 

0.54 
0.54 

0.54 

2.11 

$ 

$ 

0.47 

0.49 
0.49 

0.49 

1.94 

See  “Cash  Dividends  on  Common  Stock,”  of  Note  12, 
“Nasdaq Stockholders’ Equity,” to the consolidated financial 
statements for further discussion of the dividends. 

• our acquisition of Verafin, net of cash and cash equivalents 

Financial Investments

acquired; 

• repayment of borrowings under our credit commitment and 

debt obligations;
• the ASR agreement;
• other repurchases of our common stock;
• cash dividends paid on our common stock;
• purchases of property and equipment;

46

investments 

Our  financial 
totaled  $208  million  as  of 
December  31,  2021  and  $195  million  as  of  December  31, 
2020.  Of  these  securities,  $162  million  as  of  December  31, 
2021  and  $175  million  as  of  December  31,  2020  are  assets 
primarily  utilized  to  meet  regulatory  capital  requirements, 
mainly  for  our  clearing  operations  at  Nasdaq  Clearing.  See 
Note  6,  “Investments,” 
financial 
statements for further discussion. 

the  consolidated 

to 

 
 
 
 
 
 
 
 
 
 
Debt Obligations

Regulatory Capital Requirements

The  following  table  summarizes  our  debt  obligations  by 
contractual maturity:

$ 

1,018  $ 

597 

Broker-Dealer Net 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, 
2021,  our  required  regulatory  capital  of  $138  million  was 
comprised  of  highly  rated  European  government  debt 
securities  that  are  included  in  financial  investments  in  the 
Consolidated Balance Sheets.

Our  broker-dealer  subsidiaries,  Nasdaq  Execution  Services, 
NFSTX,  LLC,  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,  2021, 
the 
combined  required  minimum  net  capital  totaled  $1  million 
and  the  combined  excess  capital  totaled  $21  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 and cash equivalents 
in the Consolidated Balance Sheets. 

Nordic 
Requirements

and  Baltic  Exchange  Regulatory  Capital 

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,  2021,  our  required  regulatory  capital  of  $35 
million was primarily invested in European government debt 
securities  that  are  included  in  financial  investments  in  the 
Consolidated  Balance  Sheets  and  cash,  which  is  included  in 
restricted  cash  and  cash  equivalents  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, 2021, other required 
regulatory capital was $8 million and was primarily included 
in restricted cash in the Consolidated Balance Sheets.

Maturity Date

December 31, 
2021

December 31, 
2020

(in millions)

Weighted-
average 
maturity of 29 
days

$ 

420  $ 

December 2022

598  

— 

597 

May 2023 $ 

—  $ 

June 2024  

499 

730 

498 

December 2025  

(4)   

(4) 

June 2026  

March 2029  

February 2030  

January 2031  

July 2033  

December 2040  

April 2050  

498 

676 

676 

643 

694 

644 

486 

497 

726 

726 

643 

— 

643 

485 

$ 

$ 

4,812  $ 

4,944 

5,830  $ 

5,541 

Short-term debt - 
commercial 
paper

2022 Notes
Total short-term 

debt

Long-term debt 

- senior 
unsecured 
notes:

2023 Notes

2024 Notes
2020 Credit 
Facility

2026 Notes

2029 Notes

2030 Notes

2031 Notes

2033 Notes

2040 Notes

2050 Notes
Total long-term 

debt
Total debt 

obligations

In the table above, the 2022 Notes were reclassified to short-
term debt as of December 31, 2021.

In  addition  to  the  $1.25  billion  revolving  credit  facility,  we 
also  have  other  credit  facilities  primarily  to  support  our 
Nasdaq Clearing operations in Europe, as well as to provide a 
cash  pool  credit  line  for  one  subsidiary.  These  credit 
facilities,  which  are  available  in  multiple  currencies,  totaled 
$212 million as of December 31, 2021 and $232 million as of 
December 31, 2020 in available liquidity, none of which was 
utilized.

As  of  December  31,  2021,  we  were  in  compliance  with  the 
covenants of all of our debt obligations.

See Note 9, “Debt Obligations,” to the consolidated financial 
statements for further discussion of our debt obligations.

47

 
 
 
 
 
 
 
 
 
 
 
 
Cash Flow Analysis

The following table summarizes the changes in cash flows:
Year Ended December 31,

Net cash provided by (used in):

Operating activities

Investing activities

Financing activities

Effect of exchange rate changes on cash and 

cash equivalents and restricted cash and cash 
equivalents

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

Cash and cash equivalents, restricted cash and 

cash equivalents at beginning of period

Cash and cash equivalents, restricted cash and 

cash equivalents at end of period

Reconciliation of Cash, Cash Equivalents and 

Restricted Cash and Cash Equivalents

Cash and cash equivalents
Restricted cash and cash equivalents
Restricted cash and cash equivalents (default 

funds and margin deposits)

Total

2021

2020

2019

(in millions)

$ 1,083  $ 1,252  $  963 

  (2,653)   

(122)   

(414) 

  1,418 

  1,910 

  (2,472) 

(331)  

353  

(188) 

(483)    3,393 

  (2,111) 

  5,979 

  2,586 

  4,697 

$ 5,496  $ 5,979  $ 2,586 

$  393  $ 2,745  $  332 
30 

37 

29 

  5,074 

  3,197 

  2,224 

$ 5,496  $ 5,979  $ 2,586 

We  have  adjusted  prior  period  presentation  of  opening  and 
ending amounts of cash, cash equivalents, and restricted cash 
and  cash  equivalents  in  our  consolidated  statements  of  cash 
flows  to  include  restricted  cash  and  cash  equivalents  related 
to  the  default  funds  and  margin  deposits.  See  Note  2, 
“Summary  of  Significant  Accounting  Policies,”  to  the 
consolidated  financial  statements  for  further  discussion  of 
this adjustment. 

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;  expense  associated  with  share-based 
compensation;  deferred  income  taxes;  debt  extinguishment 
costs;  net  gain  on  divestiture  of  a  business,  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  and  deferred  revenue  which  are 
impacted  by  the  timing  of  customer  billings  and  related 
collections  from  our  customers;  accounts  payable  and 
accrued  expenses  due  to  timing  of  payments;  accrued 
impacted  by  employee 
personnel  costs,  which  are 
performance  targets  and  the  timing  of  payments  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  $169 
million for the year ended December 31, 2021 compared with 
2020. The decrease was primarily driven by a cash payment 
of  an  acquisition-related  tax  obligation  on  behalf  of  Verafin 
of  $221  million  and  a  cash  payment  of  $102  million,  the 
release  of  which  is  subject  to  certain  employment-related 
conditions  over  three  years  following  the  closing  of  the 
acquisition of Verafin, partially offset by higher net income. 
The remaining change was primarily due to other fluctuations 
in our working capital.

Net Cash Used in Investing Activities

Net  cash  used  in  investing  activities  for  the  year  ended 
December  31,  2021  primarily  related  to  $2,430  million  of 
cash used for the acquisition of Verafin, net of cash and cash 
equivalents  acquired  of  $221  million,  which  was  utilized  to 
satisfy  an  acquisition-related  tax  obligation  on  behalf  of 
Verafin,  $163  million  of  purchases  of  property  and 
equipment,  a  net  decrease  in  investments  related  to  default 
funds  and  margin  deposits  $132  million,  $31  million  of  net 
purchases  of  securities  and  other  investing  activities  of  $87 
million,  partially  offset  by  proceeds  from  divestiture  of 
businesses, net of cash divested $190 million.

Net  cash  used  in  investing  activities  for  the  year  ended 
December 31, 2020 primarily related to $157 million of cash 
used  for  acquisitions,  net  of  cash  and  cash  equivalents 
acquired  and  $188  million  of  purchases  of  property  and 
equipment, partially offset by $119 million of proceeds from 
the  net  sales  of  securities  and  a  net  increase  in  investments 
related to default funds and margin deposits of $109 million. 

Net Cash Provided by (Used in) Financing Activities

Net cash provided by financing activities for the year ended 
December  31,  2021  primarily  related  to  a  net  increase  in 
default  funds  and  margin  deposits  of  $2,330  million, 
proceeds  of  $826  million  from  the  issuances  of  long-term-
debt  and  utilization  of  credit  commitment  and  $420  million 
of  proceeds  from  issuances  of  commercial  paper,  net, 
partially offset by repayment of borrowings under our credit 
commitment  and  debt  obligations  of  $804  million,  $475 
million of repurchases of common stock pursuant to the ASR 
agreement,  $468  million  in  other  repurchases  of  common 
stock, $350 million of dividend payments to our shareholders 
and a $33 million payment for debt extinguishment costs. 

Net cash provided by financing activities for the year ended 
December  31,  2020  primarily  related  to  $3,807  million  of 
proceeds from issuances of long-term debt and the utilization 
of our credit commitment and a net increase in default funds 
and margin deposits $527 million, partially offset by $1,468 
million  in  repayments  of  borrowings  under  our  credit 
commitment  and  debt  obligations,  $222  million 
in 
repurchases  of  common  stock,  $391  million  of  net 
repayments  of  commercial  paper,  $320  million  of  dividend 
payments to our shareholders and a $36 million payment for 
debt extinguishment costs. 

48

 
 
 
 
 
 
 
See  Note  4,  “Acquisitions  and  Divestiture,” 
the 
consolidated financial statements for further discussion of our 
acquisitions and divestiture. 

to 

See Note 9, “Debt Obligations,” to the consolidated financial 
statements for further discussion of our debt obligations.

See  “ASR  Agreements,”  “Share  Repurchase  Program,”  and 
“Cash  Dividends  on  Common  Stock,”  of  Note  12,  “Nasdaq 
Stockholders’  Equity,” 
financial 
statements  for  further  discussion  of  our  ASR  agreement, 
share  repurchase  program  and  cash  dividends  paid  on  our 
common stock. 

the  consolidated 

to 

Off-Balance Sheet Arrangements

For discussion of off-balance sheet arrangements see:

•  Note  15,  “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  18,  “Commitments,  Contingencies  and  Guarantees,” 
the  consolidated  financial  statements  for  further 

to 
discussion of:

◦ Guarantees issued and credit facilities available;

Contractual Obligations and Contingent Commitments

◦ Other guarantees;

Nasdaq has contractual obligations to make future payments 
under  debt  obligations  by  contract  maturity,  operating  lease 
payments,  and  other  obligations.  The  following 
table 
summarizes  material 
for  known 
cash 
contractual  and  other  obligations  as  of  December  31,  2021, 
and the estimated timing thereof.

requirements 

(in millions)

Total

<1 year

1-3 
years

3-5 
years

5+ years

Payments Due by Period

Debt obligation by 
contractual maturity

Operating lease 
obligations

Purchase obligations

$ 7,125  $ 1,131  $  705  $  664  $ 4,625 

697   

477   

65   

137   

111   

64   

106   

90   

384 

217 

Total

$ 8,299  $ 1,260  $  948  $  865  $ 5,226 

In the table above:

• Debt  obligations  by  contractual  maturity  include  both 
principal  and  interest  obligations.  As  of  December  31, 
2021,  an  interest  rate  of  2.4%  was  used  to  compute  the 
amount  of  the  contractual  obligations  for  interest  on  the 
2020  Credit  Facility.  All  other  debt  obligations  were 
primarily  calculated  on  a  365-day  basis  at  the  contractual 
fixed rate multiplied by the aggregate principal amount as 
of December 31, 2021. See Note 9, “Debt Obligations,” to 
the consolidated financial statements for further discussion.

• Operating  lease  obligations  represent  our  undiscounted 
operating  lease  liabilities  as  of  December  31,  2021.  See 
Note 16, “Leases,” to the consolidated financial statements 
for further discussion of our leases.

• Purchase  obligations  primarily 

represent  minimum 
outstanding  obligations  due  under  software 
license 
agreements.  The  balance  as  of  December  31,  2021  is 
primarily  comprised  of  our  multi-year  AWS  partnership 
contract,  which  replaces  our  previous  shorter 
term 
contracts, 
those  with  no  minimum  spend 
commitment,  and  is  not  expected  to  increase  our  overall 
spend  footprint  with  AWS  over  the  life  of  the  contract, 
based  on  projected  growth  and  expansion  of  our  existing 
AWS-based solutions.

including 

◦ 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,  2021,  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  a  hypothetical  100  basis  points  from  levels  as 
of December 31, 2021, the fair value of this portfolio would 
have declined by $5 million. 

49

 
 
Debt Obligations

Foreign Currency Exchange Rate Risk

the  amounts  outstanding  from 

As  of  December  31,  2021,  the  majority  of  our  debt 
obligations  were  fixed-rate  obligations.  Interest  rates  on 
certain  tranches  of  notes  are  subject  to  adjustment  to  the 
extent our debt rating is downgraded below investment grade, 
as  further  discussed  in  Note  9,  “Debt  Obligations,”  to  the 
consolidated  financial  statements.  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  sale  of 
commercial paper, which have variable interest rates and any 
borrowings under our 2020 Credit Facility, as the interest rate 
on  this  facility  has  a  variable  interest  rate.  As  of  December 
31,  2021,  we  had  principal  amounts  outstanding  of  $420 
million  of  commercial  paper  and  no  amounts  outstanding 
under  our  2020  Credit  Facility.  A  hypothetical  100  basis 
points 
rates  on  our  outstanding 
commercial paper would increase annual interest expense by 
approximately  $4  million  based  on  borrowings  as  of 
December 31, 2021.

increase 

interest 

in 

We  may  utilize  interest  rate  swap  agreements  to  achieve  a 
desired mix of variable and fixed rate debt.

transactional 

We  are  subject  to  foreign  currency  exchange  rate  risk.  Our 
currency 
exposure 
primary 
denominated  revenues  less  transaction-based  expenses  and 
operating income for the years ended December 31, 2021 and 
2020 are presented in the following tables:

foreign 

to 

Euro

Swedish 
Krona

Other 
Foreign 
Currencies

U.S. 
Dollar

Total

(in millions, except currency rate)

Year Ended December 31, 2021

Average foreign 
currency rate to 
the U.S. dollar

Percentage of 
revenues less 
transaction-
based expenses

Percentage of 
operating 
income

Impact of a 10% 

adverse 
currency 
fluctuation on 
revenues less 
transaction-
based expenses

Impact of a 10% 

adverse 
currency 
fluctuation on 
operating 
income

1.183

0.117

#

N/A

N/A

 7.1 %  6.2 %

 4.9 %  81.8 %  100.0 %

 10.4 %  (4.6) %

 (9.1) %  103.3 %  100.0 %

$ (24) 

$ (21) 

$  (17) 

$  — 

$  (62) 

$ (15) 

$  (7) 

$  (13) 

$  — 

$  (35) 

Year Ended December 31, 2020

Average foreign 
currency rate to 
the U.S. dollar

Percentage of 
revenues less 
transaction-
based expenses

Percentage of 
operating 
income

Impact of a 10% 

adverse 
currency 
fluctuation on 
revenues less 
transaction-
based expenses

Impact of a 10% 

adverse 
currency 
fluctuation on 
operating 
income

1.1398

0.1086

#

N/A

N/A

 7.7 %  6.6 %

 4.7 %  81.0 %  100.0 %

 10.7 %  (4.6) %

 (4.9) %  98.8 %  100.0 %

$ (22) 

$ (19) 

$  (14) 

$  — 

$  (55) 

$ (13) 

$  (6) 

$ 

(6) 

$  — 

$  (25) 

____________
# 
N/A  Not applicable.

Represents multiple foreign currency rates.

50

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, 2021 is presented in the following table:

$ 

Swedish Krona
British Pound
Norwegian Krone
Canadian Dollar
Australian Dollar
Euro

Net Assets

Impact of a 10% 
Adverse Currency 
Fluctuation

(in millions)

3,369  $ 
181 
168 
171 
117 
54 

337 
18 
17 
17 
12 
5 

In  the  table  above,  Swedish  Krona  includes  goodwill  of 
$2,484 million and intangible assets, net of $589 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,  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 
financial 
ratings,  well-capitalized 
investment 
institutions and other creditworthy counterparties. 

grade 

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 

transaction.  Once 

the  clearinghouse  enters 
the 
clearinghouse  officially  accepts  the  trade  for  novation, 
Nasdaq  Execution  Services  is  legally  removed  from  trade 
risk.  However,  Nasdaq  has  membership 
execution 
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 
risk  on  self-cleared 
NSCC 
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 
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. 

limit  counterparty 

to  a  system 

rules 

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 

We  also  are  exposed  to  credit  risk  through  our  clearing 
operations  with  Nasdaq  Clearing.  See  Note  15,  “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 
investments  are  primarily  placed  in  large,  highly  rated 
financial 
rated  government  debt 
instruments and other creditworthy counterparties.

institutions,  highly 

51

 
 
 
 
 
 
 
 
 
 
 
 
• 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  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. 
investment 
guidelines  allow  for  direct  purchases  or  repurchase 
agreements  with  short  dated  maturities  of  high  quality 
sovereign  debt  (for  example,  European  government  and 
U.S.  Treasury  securities),  central  bank  certificates  and 
multilateral development bank debt instruments.

the  clearinghouse 

In  addition, 

• 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 
reverse 
sovereign, 
repurchase  agreements 
government agency or multilateral development bank debt 
instruments.

investments  and  collateral  under 

to  high  quality 

Critical Accounting Policies and Estimates 

financial  statements  and 
in  conformity  with  U.S.  GAAP 

related 
The  preparation  of 
disclosures 
requires 
management to make judgments, assumptions, and estimates 
that affect the amounts reported in the consolidated financial 
statements  and  accompanying  notes.  Note  2,  “Summary  of 
Significant  Accounting  Policies,” 
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.

to 

Revenue Recognition

Market Technology Revenues

Within  our  market  infrastructure  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 
these  contracts  containing 
in 
customers  which  results 
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, 
the  complexity  of  work  performed,  and 
logistical  challenges  due  to  the  effects  of  COVID-19. 
Revenue  and  cost  estimates  for  our  long-term  contracts  are 
reviewed and reassessed at least quarterly. 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. 

Due to the significance of judgment in the estimation process, 
as  discussed  above,  changes  in  assumptions  and  estimates 
may  adversely  or  positively  affect  financial  performance  in 
future periods.

For  further  discussion  related  to  recognition  of  these 
revenues,  see  “Revenue  From  Contracts  with  Customers  - 
Revenue  Recognition  -  Market  Technology,”  of  Note  2, 
“Summary  of  Significant  Accounting  Policies,”  to  the 
consolidated financial statements.

52

Goodwill,  Indefinite-Lived  Intangible  Assets  and  Related 
Impairment

Assets  acquired  and  liabilities  assumed  in  connection  with 
our  acquisitions  are  recorded  at  their  estimated  fair  values. 
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  recognize  specifically  identifiable  intangibles, 
such  as  customer  relationships,  technology,  exchange  and 
clearing  registrations,  trade  names  and  licenses  when  a 
specific right or contract is acquired. Goodwill and 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  as  of 
October  1  and  more  frequently  whenever  events  or  changes 
in circumstances indicate that the fair value of the asset may 
be  less  than  its  carrying  amount,  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.  We  perform  our  goodwill  impairment  test  at  the 
reporting  unit  level  for  our  five  reporting  units:  Market 
the 
Services  segment, 
Corporate  Platforms  segment:  Listing  Services  and  IR  & 
ESG  Services,  the  Investment  Intelligence  segment,  and  the 
Market  Technology  segment.  When  testing  goodwill  and 
indefinite-lived intangible assets 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 or indefinite-lived intangible asset is 
less  than  their  respective  carrying  amounts  as  the  basis  to 
determine  if  it  is  necessary  to  perform  a  quantitative 
impairment  test.  If  we  choose  not  to  complete  a  qualitative 
assessment,  or  if  the  initial  assessment  indicates  that  it  is 
more likely than not that the carrying amount of a reporting 
unit  or  the  carrying  amount  of  an  indefinite-lived  intangible 
asset  exceed 
their  respective  estimated  fair  values,  a 
quantitative  test  is  required.  Our  decision  to  perform  a 
qualitative 
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  or 
the  indefinite-lived  intangible  asset’s  fair  value  over  their 
last  quantitative 
respective  carrying  amounts  at 
assessment  date,  and  the  amount  of  time  in  between 
quantitative fair value assessments.

two  businesses  comprising 

impairment  assessment 

in  a  given  year 

the 

the 

and 

assumptions  used 

In performing a quantitative impairment test, we compare the 
fair  value  of  each  reporting  unit  and 
indefinite-lived 
intangible  asset  with  their  respective  carrying  amounts.  The 
fair  value  of  each  reporting  unit  is  estimated  using  a 
combination  of  a  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 
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.  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. If the carrying amounts of the reporting unit or 
the  indefinite-lived  intangible  asset  exceed  their  respective 
fair values, an impairment charge is recognized in an amount 
equal  to  the  difference,  limited  to  the  total  amount  of 
goodwill allocated to that reporting unit or the total carrying 
value of the indefinite-lived intangible asset.

The following table presents the balances of goodwill for our 
reportable  segments  at  the  time  of  our  2021  annual 
impairment test:

Market Technology
Investment Intelligence
Corporate Platforms
Market Services

October 1, 2021

(in millions)

$ 

$ 

2,176 
2,457 
470 
3,407 
8,510 

In 2021 and 2020, we have elected to perform a quantitative 
impairment  test  for  goodwill  and  indefinite-lived  intangible 
assets.  In  conducting 
the  quantitative  assessment,  we 
determined that the fair value of our goodwill for each of our 
reporting  units  and  the  fair  value  of  our  indefinite-lived 
intangible assets sufficiently exceed their respective carrying 
amounts.  As  a  result,  there  were  no  goodwill  or  indefinite-
lived  intangible  assets  impairment  charges  recorded  in  2021 
or 2020. In 2019, we performed a qualitative assessment and 
no impairment was recorded.

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

53

 
 
 
 
 
Subsequent  to  our  annual  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,  equity 
securities, property and equipment, and operating lease assets 
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.

We  recorded  an  impairment  charge  of  $14  million  in  2021 
related  to  a  finite-lived  intangible  asset  for  customer 
relationships  associated  with  the  wind  down  of  a  previous 
acquisition included in depreciation and amortization expense 
in  the  Consolidated  Statements  of  Income.  There  were  no 
material finite-lived impairment charges in 2020 and 2019.

We recorded pre-tax, non-cash property and equipment asset 
impairment  charges  of  $4  million  in  2021,  $14  million  in 
2020 and $26 million in 2019. The asset impairment charges 
in  2020  and  2019  primarily  related  to  capitalized  software 
that  was  retired  and  are  included  in  restructuring  charges  in 
the  Consolidated  Statements  of  Income  for  2021,  2020  and 
the 
2019.  See  Note  20,  “Restructuring  Charges,” 
consolidated financial statements for a discussion of our 2019 
restructuring plan. 

to 

No  material  impairments  were  recorded  to  reduce  the 
carrying  value  of  our  other  long-lived  assets  during  2021, 
2020 or 2019.

Income Taxes

the 

tax  and 

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

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 Not Yet Adopted

We  have  considered  all  recent  accounting  pronouncements 
and have concluded that no accounting pronouncements that 
have not yet been adopted would have a material impact on 
our  financial  position  or  results  of  operations.  See  “Recent 
Accounting  Pronouncements,”  of  Note  2,  “Summary  of 
Significant  Accounting  Policies,” 
the  consolidated 
financial statements for further discussion of recently adopted 
and  recently  issued  accounting  pronouncements  that  are 
applicable to Nasdaq.

to 

54

Item 7A. Quantitative and Qualitative Disclosures About 
Market Risk

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.

issued  by 

Our  management  assessed  the  effectiveness  of  our  internal 
control  over  financial  reporting  as  of  December  31,  2021, 
based  on  criteria  established  in  Internal  Control—Integrated 
Framework 
the  Committee  of  Sponsoring 
Organizations  of  the  Treadway  Commission  (COSO)  (2013 
framework).  This  evaluation 
the 
the  design 
documentation  of  controls,  evaluation  of 
effectiveness  of  controls, 
the  operating 
effectiveness of controls and a conclusion on this evaluation. 
Based on its assessment, our management believes that, as of 
December  31,  2021,  our  internal  control  over  financial 
reporting is effective.

testing  of 

review  of 

included 

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.

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,  2021  and 
2020, Consolidated Statements of Income for the years ended 
December 31, 2021, 2020 and 2019, Consolidated Statements 
of Comprehensive Income for the years ended December 31, 
2021, 2020 and 2019, Consolidated Statements of Changes in 
Stockholders' Equity for the years ended December 31, 2021, 
2020  and  2019,  Consolidated  Statements  of  Cash  Flows  for 
the  years  ended  December  31,  2021,  2020  and  2019  and 
notes to our consolidated financial statements, together with a 
report  thereon  of  Ernst  &  Young  LLP,  dated  February  23, 
2022,  are  attached  hereto  as  pages  F-1  through  F-46  and 
incorporated by reference herein.
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  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  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. 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,  2021  that  have  materially 
affected,  or  are  reasonably  likely  to  materially  affect, 
Nasdaq’s internal control over financial reporting.

55

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 
timely 
reasonable  assurance 
detection  of  unauthorized  acquisition,  use,  or  disposition  of 
the company’s assets that could have a material effect on the 
financial statements.

regarding  prevention  or 

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 23, 2022 

Report of Independent Registered Public Accounting 
Firm

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

in 

established 

Opinion on Internal Control over Financial Reporting
We  have  audited  Nasdaq,  Inc.’s  internal  control  over 
financial  reporting  as  of  December  31,  2021,  based  on 
Internal  Control—Integrated 
criteria 
the  Committee  of  Sponsoring 
Framework 
Organizations  of 
(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, 
2021, based on the COSO criteria.

the  Treadway  Commission 

issued  by 

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,  2021  and  2020,  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, 2021, and 
the  related  notes  and  our  report  dated  February  23,  2022 
expressed an unqualified opinion thereon. 

included 

reporting 

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 
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.

the 

in 

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. 

56

 
Item 9B. Other Information

None. 

Item 9C. Disclosure Regarding Foreign Jurisdictions that 
Prevent Inspections

Not applicable.

PART III

In  addition,  in  jurisdictions  where  participation  in  the  ESPP 
is permitted, all our employees are eligible. Employees may 
purchase  shares  of  our  common  stock  at  a  15%  discount  to 
the lesser of the closing price of our common stock on (i) the 
first trading day of the offering period or (ii) the last trading 
day of the offering period. Offering periods under the ESPP 
are six months in duration. As of December 31, 2021, all our 
employees are eligible to participate.

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  “Director  Nominees-
Proposal  1:  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  &  Risk  Committee  and  Audit  &  Risk 
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 
“Director  Nominees-Proposal  1:  Election  of  Directors”  and 
the  Proxy 
“Director  Nominees-Board  Committees” 
Statement.

in 

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 “Director Nominees-
Director  Compensation”  and  “Executive  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 
Items-Security 
Ownership  of  Certain  Beneficial  Owners  and  Management” 
in the Proxy Statement.

the  heading  “Other 

Equity Compensation Plan and ESPP Information

Nasdaq’s Equity Plan provides for the issuance of our equity 
securities  to  all  employees  and  directors  as  part  of  their 
compensation plan. 

57

The  Equity  Plan  and  the  ESPP  have  been  previously 
approved by our stockholders. The following table sets forth 
regarding  outstanding  options  and  shares 
information 
reserved 
issuance  under  all  of  Nasdaq’s 
compensation plans as of December 31, 2021.

future 

for 

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

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)

268,817  $ 

66.68 

  13,767,883 

— 

— 

— 

Plan Category

Equity 
compensation 
plans approved 
by stockholders
Equity 
compensation 
plans not 
approved by 
stockholders

Total

268,817  $ 

66.68 

  13,767,883 

In the table above:

• The  number  of  shares  to  be  issued  upon  exercise  of 
outstanding  options,  warrants  and  rights  include  only  the 
number of shares to be issued upon exercise of outstanding 
options, warrants and rights. As of December 31, 2021, we 
also  had  2,280,198  shares  to  be  issued  upon  vesting  of 
outstanding restricted stock and PSUs.

• The  number  of  shares  remaining  available  for  future 
issuance  under  equity  compensation  plans  (excluding 
shares reflected in column (a) includes 9,535,851 shares of 
common stock that may be awarded pursuant to the Equity 
Plan  and  4,232,032  shares  of  common  stock  that  may  be 
issued pursuant to the ESPP.

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

and 

about 

certain 

relationships 

related 
Information 
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  “Director  Nominees-Proposal 
1: Election of Directors” in the Proxy Statement.

 
 
 
 
 
Item 14. Principal Accountant Fees and Services

Information  about  principal  accountant  fees  and  services,  as 
required by Item 9(e) of Schedule 14A, is incorporated herein 
by reference from the discussion under the heading “Audit & 
Risk  Committee  Matters-Annual  Evaluation  and  2022 
Selection  of 
the  Proxy 
the  Independent  Auditor” 
Statement.

in 

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

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).

Share Purchase Agreement, dated as of 
November 18, 2020, by and among Osprey 
Acquisition Corporation, a wholly owned 
subsidiary of Nasdaq, Verafin Holdings Inc., 
certain shareholders of Verafin (the “Sellers”), 
and Shareholder Representative Services LLC, 
solely in its capacity as the representative of the 
Sellers (incorporated herein by reference to 
Exhibit 2.2 to the Annual Report on Form 10-K 
for the year ended December 31, 2020 filed on 
February 23, 2021).†

Amendment to Share Purchase Agreement, 
dated as of February 11, 2021, by and among 
Osprey Acquisition Corporation, a wholly 
owned subsidiary of Nasdaq, Verafin Holdings 
Inc., certain shareholders of Verafin (the 
“Sellers”), and Shareholder Representative 
Services LLC, solely in its capacity as the 
representative of the Sellers (incorporated herein 
by reference to Exhibit 2.3 to the Annual Report 
on Form 10-K for the year ended December 31, 
2020 filed on February 23, 2021).

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).

2.1

2.2

2.3

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

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).

58

 
4.5

4.6

4.7

4.8

4.9

4.10

4.11

4.12

4.13

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).

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).

Seventh Supplemental Indenture, dated February 
13, 2020, 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 Exhibit 4.2 
to the Company’s Form 8-A filed on February 
13, 2020).

Eighth Supplemental Indenture, dated April 28, 
2020, by and between Nasdaq, Inc. and Wells 
Fargo Bank, National Association, as Trustee 
(incorporated herein by reference to Exhibit 4.2 
to the Current Report on Form 8-K filed on 
April 28, 2020).

Ninth Supplemental Indenture, dated December 
21, 2020, by and between Nasdaq, Inc. and 
Wells Fargo Bank, National Association, as 
Trustee (incorporated herein by reference to 
Exhibit 4.2 to the Current Report on Form 8-K 
filed on December 21, 2020).

59

4.14

4.15

4.16

4.17

Tenth Supplemental Indenture, dated December 
21, 2020, by and between Nasdaq, Inc. and 
Wells Fargo Bank, National Association, as 
Trustee (incorporated herein by reference to 
Exhibit 4.3 to the Current Report on Form 8-K 
filed on December 21, 2020).

Eleventh Supplemental Indenture, dated 
December 21, 2020, by and between Nasdaq, 
Inc. and Wells Fargo Bank, National 
Association, as Trustee (incorporated herein by 
reference to Exhibit 4.4 to the Current Report on 
Form 8-K filed on December 21, 2020).

Twelfth Supplemental Indenture, dated July 30, 
2021, by and among Nasdaq, Inc., Wells Fargo 
Bank, National Association, as Trustee and 
HSBC Bank USA, National Association, as 
registrar and transfer agent (incorporated by 
reference to Exhibit 4.2 to the Company’s 8-A 
filed on July 30, 2021).

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).

4.18

Description of Securities.

10.1

10.2

10.3

10.4

10.5

10.6

10.7

Amended and Restated Board Compensation 
Policy, effective on June 16, 2021 (incorporated 
herein by reference to Exhibit 10.1 to the 
Quarterly Report on Form 10-Q for the quarter 
ended June 30, 2021 filed on August 4, 2021).*

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, 
2021 filed on August 4, 2021).*

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, 
2021 filed on August 4, 2021).*

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).*

10.8

Form of Nasdaq Three-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, 
2021 filed on August 4, 2021).*

10.9

Form of Nasdaq Continuing Obligations 
Agreement.

10.10

10.10.1

10.11

10.12

10.13

10.14

10.15

10.16

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).*

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 Agreement between Nasdaq and 
Adena Friedman, made and entered into on 
November 19, 2021 and effective as of January 
1, 2022.*

Nonqualified Stock Option Award Certificate to 
Adena T. Friedman from Nasdaq, Inc. in 
connection with grant made on January 3, 
2022.*

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).*

Retirement Agreement and General Release of 
Claims by and between Nasdaq, Inc. and 
Michael Ptasznik, dated October 21, 2020 
(incorporated herein by reference to Exhibit 
10.15 to the Annual Report on Form 10-K for 
the year ended December 31, 2020 filed on 
February 23, 2021).*

Employment Agreement by and between 
Nasdaq, Inc. and Bradley J. Peterson, dated 
October 1, 2020 (incorporated herein by 
reference to Exhibit 10.17 to the Annual Report 
on Form 10-K for the year ended December 31, 
2020 filed on February 23, 2021).*

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).*

Employment Offer Letter by and between 
Nasdaq, Inc. and Michelle Daly (incorporated 
by reference to Exhibit 10.1 to the Current 
Report on Form 8-K filed on May 3, 2021).*

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 December 21, 
2020, among Nasdaq, Inc., the various lenders 
from time to time party thereto and, Bank of 
America, N.A., as administrative agent and 
issuing bank (incorporated herein by reference 
to Exhibit 10.1 to the Current Report on Form 8-
K filed on December 21, 2020).

LIBOR Transition Amendment, dated as of 
October 19, 2021 by and among Nasdaq, Inc. 
and Bank of America, N.A., as administrative 
agent.

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 13 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 and 
Chief Financial Officer pursuant to Section 302 
of Sarbanes-Oxley.

10.17

10.18

10.19

10.20

10.21

10.22

10.23

10.24

11

21.1

23.1

24.1

31.1

31.2

60

32.1

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

101

The following materials from the Nasdaq, Inc. 
Annual Report on Form 10-K for the year ended 
December 31, 2021, formatted in iXBRL (Inline 
eXtensible Business Reporting Language): (i) 
Consolidated Balance Sheets as of December 
31, 2021 and December 31, 2020; (ii) 
Consolidated Statements of Income for the years 
ended December 31, 2021, 2020 and 2019 (iii) 
Consolidated Statements of Comprehensive 
Income for the years ended December 31, 2021, 
2020 and 2019; (iv) Consolidated Statements of 
Changes in Stockholders' Equity for the years 
ended December 31, 2021, 2020 and 2019; (v) 
Consolidated Statements of Cash Flows for the 
years ended December 31, 2021, 2020 and 2019; 
and (vi) notes to consolidated financial 
statements.

104

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

____________
*  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 
consolidated financial statements or notes.

information 

included 

required 

the 

in 

is 

Item 16. Form 10-K Summary

None.

61

 
 
By:

Name:

Title:

By:

Name:

Title:

By:

Name:

Title:

By:

Name:

Title:

By:

Name:

Title:

*
Thomas A. Kloet

Director

*
John D. Rainey

Director

*
Toni Townes-Whitley

Director

*
Jacob Wallenberg

Director

*
Alfred W. Zollar

Director

* Pursuant to Power of Attorney

By:

Name:

Title:

/s/ John A. Zecca
John A. Zecca

Attorney-in-Fact

SIGNATURES

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  23, 
2022.

Nasdaq, Inc.
(Registrant)

By:

Name:

Title:

Date:

/s/ Adena T. Friedman
Adena T. Friedman

President and Chief Executive Officer

February 23, 2022

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 23, 2022.

By:

Name:

Title:

By:

Name:
Title:

By:
Name:
Title:

By:
Name:
Title:

By:
Name:
Title:

By:
Name:
Title:

By:
Name:
Title:

By:
Name:

Title:

/s/ Adena T. Friedman
Adena T. Friedman

President and Chief Executive Officer; 
Director

/s/ Ann M. Dennison
Ann M. Dennison
Executive Vice President and Chief 
Financial Officer

/s/ Michelle Daly
Michelle Daly
Senior Vice President, Controller and 
Principal Accounting Officer

*
Michael R. Splinter
Chairman of the Board

*
Melissa M. Arnoldi
Director

*
Charlene T. Begley
Director

*
Steven D. Black
Director

*
Essa Kazim

Director

62

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 (PCAOB ID 42)
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-5
F-6
F-7
F-8
F-9
F-10

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

Critical Audit Matters

The  critical  audit  matters  communicated  below  are  matters 
arising  from  the  current  period  audit  of  the  financial 
statements  that  were  communicated  or  required  to  be 
communicated  to  the  audit  committee  and  that:  (1)  relate  to 
accounts  or  disclosures  that  are  material  to  the  financial 
statements  and  (2)  involved  our  especially  challenging, 
subjective  or  complex  judgments.  The  communication  of 
critical audit matters 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  matters 
below,  providing  separate  opinions  on  the  critical  audit 
matters or on the accounts or disclosures to which they relate.

We  have  audited  the  accompanying  consolidated  balance 
sheets  of  Nasdaq,  Inc.  (the  Company)  as  of  December  31, 
2021  and  2020,  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, 2021, 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,  2021  and  2020,  and  the  results  of  its 
operations and its cash flows for each of the three years in the 
period  ended  December  31,  2021,  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,  2021,  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  23,  2022  expressed  an  unqualified  opinion 
thereon.

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. 

F-2

 
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.

and 

modifications, 

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 
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  2,  3  and  8  to  the  consolidated  financial 
statements 
technology 
related 
revenue recognition.

to  market 

Description 
of the 
Matter

contracts 

containing 

statements, 

financial 
into 

Market Technology Revenue Recognition
As  described  in  Notes  2,  3  and  8  to  the 
the 
consolidated 
long-term  market 
Company  enters 
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 
multiple 
performance  obligations.  The  Company 
recorded  market  technology  deferred  revenue 
of $117 million as of December 31, 2021 and 
recognized  $463  million  in  revenue  for  the 
year  then  ended.  Of  the  market  technology 
revenue  recognized,  $216  million  relates  to 
marketplace  infrastructure  technology,  where 
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 
technology  contract.  In 
respective  market 
instances where standalone selling price is not 
directly observable, such as when a product or 
service  is  not  sold  separately,  the  Company 
selling  price 
standalone 
determines 
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.

the 

the  significant  management 

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 
judgment 
the  estimates.  The 
required 
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.

to  develop 

F-3

Description 
of the 
Matter

resulted 

recorded. 

Intangible 

Accounting for Acquisition of Verafin
As  described  in  Note  4  to  the  consolidated 
financial  statements  the  Company  completed 
its  acquisition  of  Verafin,  accounted  for  as  a 
business  combination, 
for  an  aggregate 
purchase  price  of  $2.75  billion.  The 
in  $1.88  billion  of 
transaction 
goodwill and $815 million of intangible assets 
being 
assets  were 
comprised  of  customer  relationships  of  $532 
million,  developed 
technology  of  $246 
million,  and  a  trade  name  of  $37  million.    
Auditing  the  Company's  accounting  for  its 
acquisition  of  Verafin  was  complex  due 
primarily  to  the  significant  estimation  in  the 
Company’s  determination  of  the  fair  value  of 
the  customer  relationships  and  developed 
technology  intangible  assets,  both  of  which 
were  valued  using  the  income  approach.  The 
significant assumptions used in estimating the 
value  of  the  intangible  assets  included  the 
discount  rate  for  customer  relationships  and 
the royalty rate for the developed technology.

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 accounting 
for  the  Verafin  acquisition.  For  example,  we 
tested  controls  over  the  estimation  process 
supporting the recognition and measurement of 
the  customer  relationships  and  developed 
technology  intangible  assets,  which  included 
testing  controls  over  management’s  review  of 
assumptions used in the valuation models. 

and 

developed 

evaluating 

supporting 

underlying 

assets,  we 
that 

To test the estimated fair value of the customer 
technology 
relationships 
intangible 
audit 
performed 
procedures 
included,  among  others, 
evaluating  the  Company's  use  of  valuation 
methodologies, 
significant 
assumptions  utilized  by  the  Company,  and 
evaluating  the  completeness  and  accuracy  of 
those 
data 
the 
significant  assumptions.  We 
involved  our 
valuation  specialists 
to  assist  with  our 
evaluation  of  the  methodologies  used  by  the 
Company, the discount rate applied in valuing 
the customer relationships, and the royalty rate 
utilized in the developed technology fair value 
estimates.  We  performed  sensitivity  analyses 
over the selected discount rate and royalty rate 
to evaluate the impact that movements in those 
assumptions  would  have  on  the  fair  value  of 
the  customer  relationships  and  developed 
technology intangible assets.

/s/ Ernst & Young LLP 

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

New York, New York
February 23, 2022

F-4

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

December 31, 2021

December 31, 2020

Assets
Current assets:

Cash and cash equivalents
Restricted cash and cash equivalents
Default funds and margin deposits (including restricted cash and cash equivalents of 

$ 

393  $ 
29 

$5,074 and $3,197, respectively)

Financial investments
Receivables, net
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:

$ 

$ 

5,911 
208 
588 
294 
7,423 
509 
8,433 
2,813 
366 
571 
20,115  $ 

185  $ 
62 
252 
329 
115 
5,911 
1,018 
7,872 
4,812 
406 
386 
234 
13,710 

2,745 
37 

3,942 
195 
566 
175 
7,660 
475 
6,850 
2,255 
381 
358 
17,979 

175 
224 
227 
235 
121 
3,942 
— 
4,924 
5,541 
502 
389 
187 
11,543 

Common stock, $0.01 par value, 300,000,000 shares authorized, shares issued: 
173,418,939 at December 31, 2021 and 171,278,761 at December 31, 2020; shares 
outstanding: 166,679,635 at December 31, 2021 and 164,933,678 at December 31, 2020  
Additional paid-in capital
Common stock in treasury, at cost: 6,739,304 shares at December 31, 2021 and 
6,345,083 shares at December 31, 2020 
Accumulated other comprehensive loss
Retained earnings

Total Nasdaq stockholders’ equity

Noncontrolling interests

Total equity

Total liabilities and equity

See accompanying notes to consolidated financial statements.

F-5

2 
1,952 

(437)   
(1,587)   
6,465 
6,395 

10 
6,405 

2 
2,547 

(376) 
(1,368) 
5,628 
6,433 

3 
6,436 

$ 

20,115  $ 

17,979 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Nasdaq, Inc.
Consolidated Statements of Income
(in millions, except per share amounts)

Revenues:
Market Technology
Investment Intelligence
Corporate Platforms
Market Services
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

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

Year Ended December 31,

2021

2020

2019

$ 

463  $ 

1,076 
613 
3,707 
27 
5,886 

357  $ 
898  $ 
521  $ 
3,818  $ 
31 
5,625 

338 
768 
490 
2,616 
46 
4,258 

(2,168)   
(298)   
3,420 

(2,028)   
(694)   
2,903 

(1,324) 
(399) 
2,535 

938 
144 
186 
109 
85 
57 
278 
64 
87 
31 
1,979 
1,441 
1 

786 
137 
151 
107 
142 
39 
202 
24 
33 
48 
1,669 
1,234 
4 

(125)   

(101)   

84 

— 

81 
52 
1,534 
347 
1,187  $ 

5 
70 
1,212 
279 
933  $ 

707 
127 
133 
97 
125 
39 
190 
31 
30 
39 
1,518 
1,017 
10 

(124) 

27 

5 
84 
1,019 
245 
774 

7.15  $ 
7.05  $ 
2.11  $ 

5.67  $ 
5.59  $ 
1.94  $ 

4.69 
4.63 
1.85 

$ 

$ 
$ 
$ 

See accompanying notes to consolidated financial statements.

F-6

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Nasdaq, Inc.
Consolidated Statements of Comprehensive Income
(in millions)

Net income

Other comprehensive income (loss):

Foreign currency translation gains (losses)
Income tax benefit (expense)(1)

Foreign currency translation, net

Employee benefit plan adjustment losses

Employee benefit plan income tax benefit

Employee benefit plan, net

Year Ended December 31,

2021

2020

2019

$ 

1,187  $ 

933  $ 

774 

(176)   

(42)   

(218)   

(1)   

— 

(1)   

269 

49 

318 

— 

— 

— 

(122) 

(31) 

(153) 

(4) 

1 

(3) 

(156) 

618 

Total other comprehensive income (loss), net of tax
Comprehensive income attributable to Nasdaq

(219)   

318 

$ 

968  $ 

1,251  $ 

____________
(1) Primarily relates to the tax effect of unrealized gains and losses on Euro denominated notes.

See accompanying notes to consolidated financial statements.

F-7

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Nasdaq, Inc. 
Consolidated Statements of Changes in Stockholders' Equity
(in millions)

Common stock

Additional paid-in capital

Beginning balance

Share repurchase program
ASR agreement(1)
Share-based compensation

Stock option exercises, net
Other issuances of common stock, net(2)

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)

Ending balance

Retained earnings

Beginning balance

Impact of adoption of ASU 2016-13

Net income

Cash dividends declared per common share

Ending balance

Year Ended December 31,

2021

2020

Shares

165 

$

2 

Shares

165 

2019

Shares

$

165 

2 

$

2 

  2,547 

  2,632 

  2,716 

(3)   

(2)   

1 

—  

6  

(468)   

(2)   

(222)   

(2)   

(200) 

(475)    — 

90 

1 

257 

1 

—  

1  

— 

87 

2 

48 

  — 

1 

—  

1  

— 

79 

2 

35 

  1,952 

  2,547 

  2,632 

—  

(376) 

(61) 

(437) 

(336) 

—  

(40)    — 

(376) 

(297) 

(39) 

(336) 

  (1,368) 

(219) 

  (1,587) 

  5,628 

— 

  1,187 

(350) 

  6,465 

  (1,686) 

318 

  (1,368) 

  (1,530) 

(156) 

  (1,686) 

  5,027 

  4,558 

(12) 

933 

(320) 

— 

774 

(305) 

  5,628 

  5,027 

Total Nasdaq stockholders’ equity

  6,395 

  6,433 

  5,639 

Noncontrolling interests

Beginning balance

Net activity related to noncontrolling interests

Ending balance

Total Equity

3 

7 

10 

— 

3 

3 

— 

— 

— 

167  $  6,405 

165  $  6,436 

165  $  5,639 

____________
(1) See “ASR Agreements,” of Note 12, “Nasdaq Stockholders’ Equity,” for further discussion.
(2) For the year ended December 31, 2021 primarily relates to the tax impact of shares accelerated and issued upon the sale of 
our U.S. Fixed Income business. See “2021 Divestiture,” of Note 4, “Acquisitions and Divestiture,” for further discussion.

See accompanying notes to consolidated financial statements.

F-8

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Nasdaq, Inc.
Consolidated Statements of Cash Flows
(in millions)

Year Ended December 31,
2020

2019

2021

Cash flows from operating activities:
Net income
Adjustments to reconcile net income to net cash provided by operating activities:

$ 

1,187  $ 

933  $ 

774 

Depreciation and amortization
Share-based compensation
Deferred income taxes
Extinguishment of debt
Net gain on divestiture of businesses
Net income from unconsolidated investees
Other reconciling items included in net income

Net change in operating assets and liabilities, net of effects of acquisitions:

Receivables, net
Other assets
Accounts payable and accrued expenses
Section 31 fees payable to SEC
Accrued personnel costs
Deferred revenue
Other liabilities(1)

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 of cash divested
Proceeds from sale of investment securities
Acquisition of businesses, net of cash and cash equivalents acquired
Purchases of property and equipment
Investments related to default funds and margin deposits, net (2)
Other investing activities
Net cash used in investing activities
Cash flows from financing activities:
Proceeds from (repayments of) commercial paper, net
Repayments of borrowings under our credit commitment and debt obligations
Payment of debt extinguishment cost
Proceeds from issuances of debt, net of issuance costs and utilization of credit commitment
Repurchases of common stock
ASR agreement
Dividends paid
Proceeds received from employee stock activity and other issuances
Payments related to employee shares withheld for taxes
Default funds and margin deposits
Other financing activities
Net cash provided by (used in) financing activities
Effect of exchange rate changes on cash and cash equivalents and restricted cash and cash equivalents
Net increase (decrease) in cash and cash equivalents and restricted cash and cash equivalents
Cash and cash equivalents, restricted cash and cash equivalents at beginning of period
Cash and cash equivalents, restricted cash and cash equivalents at end of period
Reconciliation of Cash, Cash Equivalents and Restricted Cash and Cash Equivalents
Cash and cash equivalents
Restricted cash and cash equivalents
Restricted cash and cash equivalents (default funds and margin deposits)
Total
Supplemental Disclosure Cash Flow Information
Cash paid for: Interest
                        Income taxes, net of refund(1)

278 
90 
94 
33 
(84) 
(52) 
6 

(6) 
(140) 
(17) 
(162) 
28 
106 
(278) 
1,083 

(316) 
285 
190 
— 
(2,430)   
(163) 
(132) 
(87) 
(2,653)   

202 
87 
41 
36 
— 
(70) 
32 

(167) 
26 
5 
92 
32 
15 
(12) 
1,252 

(283) 
402 
— 
22 
(157) 
(188) 
109 
(27) 
(122) 

190 
79 
35 
11 
(27) 
(84) 
33 

(42) 
(173) 
(49) 
23 
(9) 
(15) 
217 
963 

(579) 
543 
132 
11 
(206) 
(127) 
(174) 
(14) 
(414) 

420 
(804) 
(33) 
826 
(468) 
(475) 
(350) 
26 
(61) 
2,330 
7 
1,418 
(331) 
(483) 
5,979 
5,496  $ 

(391) 
(1,468)   
(36) 
3,807 
(222) 
— 
(320) 
50 
(40) 
527 
3 
1,910 
353 
3,393 
2,586 
5,979  $ 

116 
(1,215) 
(11) 
680 
(200) 
— 
(305) 
37 
(39) 
(1,535) 
— 
(2,472) 
(188) 
(2,111) 
4,697 
2,586 

393  $ 
29 
5,074 
5,496  $ 

2,745  $ 
37 
3,197 
5,979  $ 

332 
30 
2,224 
2,586 

118  $ 
501  $ 

97  $ 
290  $ 

120 
205 

$ 

$ 

$ 

$ 
$ 

___________
(1)

(2)

Includes payment of an acquired tax liability in 2021 related to the Verafin acquisition. See “2021 Acquisition,” of Note 4, “Acquisitions and 
Divestiture,” for further discussion.
Includes  purchases  and  proceeds  from  sales  and  redemptions  related  to  the  default  funds  and  margin  deposits  of  our  clearing  operations.  For 
further information, see "Default Fund Contributions and Margin Deposits," within Note 15, "Clearing Operations." 

See accompanying notes to consolidated financial statements.

F-9

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Nasdaq, Inc.

Notes to Consolidated Financial Statements 

1. ORGANIZATION AND NATURE OF OPERATIONS

Investment Intelligence

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

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

For  further  discussion  of  our  businesses,  see  “Products  and 
Services,” of “Item 1. Business.”

Market Technology 

is  a 

Our  Market  Technology  segment 
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  are  utilized  by  leading  markets  in 
the U.S., Europe and Asia as well as emerging markets in the 
Middle  East,  Latin  America,  and  Africa.  The  Market 
Technology  segment  includes  our  Anti  Financial  Crime 
Technology  business  and  our  Marketplace  Infrastructure 
Technology business.

Our  Anti  Financial  Crime  Technology  business  includes 
Nasdaq  Trade  Surveillance,  a  SaaS  solution  designed  for 
brokers  and  other  market  participants  to  assist  them  in 
complying with market rules, regulations and internal market 
surveillance  policies.  The  Nasdaq  Automated  Investigator  is 
our  cloud-deployed  anti-money  laundering  offering  with  an 
automated  investigator  tool  for  retail  banks.  In  February 
2021,  we  completed  the  acquisition  of  Verafin,  a  SaaS 
technology  provider  of  anti-financial  crime  management 
solutions  that  offers  a  cloud-based  platform  to  help  detect, 
investigate, and report money laundering and financial fraud. 
See  “2021  Acquisition,”  of  Note  4,  “Acquisitions  and 
Divestiture,” for further discussion.

Our Marketplace Infrastructure Technology business powers 
over  130  market  infrastructure  operators  and  new  market 
clients in more than 55 countries and handles 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  markets  customers,  including  those 
in  insurance  liabilities  securitization,  cryptocurrencies  and 
sports wagering.

Our  Investment  Intelligence  segment  includes  our  Market 
Data, Index and Analytics businesses.

Our Market Data business sells and distributes historical and 
real-time  market  data  to  the  sell-side,  the  institutional 
investing  community,  retail  online  brokers,  proprietary 
trading  shops,  other  venues,  internet  portals  and  data 
distributors.  Our  market  data  products  can  enhance 
transparency  of  market  activity  within  our  exchanges  and 
provide  critical 
to  professional  and  non-
professional  investors  globally.  Additionally,  our  Nasdaq 
Cloud  Data  Service  provided  on  our  Data  Link  data 
dissemination  platform  provides  a  flexible  and  efficient 
method  of  delivery  for  real-  time  exchange  data  and  other 
financial information.

information 

Our  Index  business  develops  and  licenses  Nasdaq-branded 
indexes  and  financial  products.  We  also  license  cash-settled 
options, futures and options on futures on our indexes. As of 
December 31, 2021, 362 ETPs listed on 25 exchanges in over 
20 countries tracked a Nasdaq index and accounted for $424 
billion in AUM.

Our  Analytics  business  provides  asset  managers,  investment 
consultants  and  institutional  asset  owners  with  investment 
insights  and  workflow  solutions.  The  eVestment  platform 
provides  asset  owners  and  allocators  with  analytics  to  make 
data-driven  investment  decisions,  enables  asset  managers  to 
position 
institutional  products  worldwide  and  provides 
liquidity solutions for private funds. Together with Solovis, a 
cloud-based  multi-asset  portfolio  management  provider,  we 
offer  a  suite  of  cloud-based  solutions  that  help  institutional 
investors  and  consultants  conduct  pre-investment  due 
diligence,  and  monitor  their  portfolios  post-investment. 
During  2021,  we  launched  Data  Fabric,  a  managed  data 
solution  utilizing  our  Nasdaq  Data  Link  to  help  investment 
management  firms  scale 
infrastructure  with 
enhanced quality, governance and integrity.

their  data 

Corporate Platforms

Our  Corporate  Platforms  segment  includes  our  Listing 
Services  and  IR  &  ESG  Services  businesses.  These 
businesses  deliver  critical  capital  market  and  ESG  solutions 
across the lifecycle of public and private companies.

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  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.  In  July  2021,  we  contributed  our  NPM 
business,  which  was  included  in  our  Listing  Services 
business, to a standalone, independent company, of which we 

F-10

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.

2. Summary of Significant Accounting Policies

Basis of Presentation and Principles of Consolidation

The  consolidated  financial  statements  are  prepared 
in 
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  6, 
“Investments,”  for  further  discussion  of  our  equity  method 
investments.

The  accompanying  consolidated  financial  statements  reflect 
all  adjustments  which  are,  in  the  opinion  of  management, 
the  results.  These 
necessary  for  a  fair  statement  of 
adjustments are of a normal recurring nature. All significant 
intercompany accounts and transactions have been eliminated 
in consolidation.

Certain prior year amounts have been reclassified to conform 
to the current year presentation.

the  fourth  quarter  of  2021,  we  adjusted 

During 
the 
presentation of cash and cash equivalents held within default 
funds  and  margin  deposits  on  the  consolidated  statement  of 
cash  flows  from  operating  activities,  to  present  them  as 
restricted  cash  and  cash  equivalents  with  the  associated 
changes being included within cash flows from investing and 
financing activities. These balances cannot be used to satisfy 
the  Company's  operating  or  other  liabilities.  See  Note  15, 
“Clearing  Operations,”  for  further  discussion  of  the  default 
funds and margin deposits. 

Prior  period  amounts  have  also  been  adjusted  to  conform  to 
current  period  presentation.  This  immaterial  adjustment  had 
no  impact  on  our  previously  reported  consolidated  balance 
sheets,  consolidated  statements  of  income,  or  consolidated 
statements of comprehensive income.

own the largest minority interest, together with a consortium 
of  third  party  financial  institutions.  The  NPM  business 
provides  liquidity  solutions  for  private  companies  to  enable 
employees, investors, and companies to execute transactions.

As of December 31, 2021, there were 4,178 total listings on 
The  Nasdaq  Stock  Market,  including  441  ETPs.  The 
combined  market  capitalization  was  approximately  $28.2 
trillion.  In  Europe,  the  Nasdaq  Nordic  and  Nasdaq  Baltic 
exchanges,  together  with  Nasdaq  First  North,  were  home  to 
1,235 listed companies with a combined market capitalization 
of approximately $2.6 trillion.

We continue to grow our U.S. Corporate Bond exchange for 
the  listing  of  corporate  bonds.  This  exchange  operates 
pursuant  to  The  Nasdaq  Stock  Market  exchange  license  and 
is  powered  by  the  NFF.  As  of  December  31,  2021,  107 
corporate bonds were listed on the Corporate Bond exchange. 
We  also  continue  to  develop  the  Nasdaq  Sustainable  Bond 
Network, a platform for increased transparency in the global 
sustainable bond markets.

Our  IR  &  ESG  Services  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. 
Our  private  company  clients  include  a  diverse  group  of 
organizations  ranging  from  family  owned  companies, 
government  organizations,  law  firms,  privately  held  entities, 
various  non-profit  organizations  to  hospitals  and  health  care 
systems.  We  help  organizations  enhance  their  ability  to 
understand  and  expand 
their  global  shareholder  base, 
improve  corporate  governance,  and  navigate  the  evolving 
ESG  landscape  through  our  suite  of  advanced  technology, 
analytics,  reporting  and  consultative  services.  In  December 
2021,  we  acquired  QDiligence,  a  provider  of  software  that 
facilitates digital director and officer questionnaires and self-
evaluations for boards of directors and corporate secretaries. 

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 
certain  countries  where  we  operate  exchanges,  we  also 
provide  broker  services,  clearing,  settlement  and  central 
depository  services.  In  January  2020,  we  commenced  an 
orderly wind-down of our Nordic broker services operations 
business. We expect this wind-down to continue through the 
second quarter of 2022. In June 2021, we sold our U.S. Fixed 
Income  business  which  included  an  electronic  platform  for 
trading of U.S. Treasuries. See “2021 Divestiture,” of Note 4, 
“Acquisitions  and  Divestiture,”  for  further  discussion.  Also 
in  June  2021,  we  completed  the  acquisition  of  a  majority 
stake  in  Puro.earth,  a  Finnish-based  leading  marketplace  for 
carbon removal.

F-11

The  tables  below  present  a  summary  of  the  2020  and  2019 
Statements of Cash Flows as reported and as adjusted:

Year Ended December 31, 2020

As Reported Adjustment Adjusted

(in millions)

$ 

1,252  $ 

—  $  1,252 

(231)   

109   

(122) 

1,383   

527    1,910 

16   

337   

353 

2,420   

973    3,393 

362   

2,224    2,586 

Net cash provided by operating 

activities

Net cash used in investing 

activities

Net cash provided by (used in) 

financing activities

Effect of exchange rate changes 

on cash, cash equivalents, 
restricted cash and cash 
equivalents

Net increase (decrease) in cash, 

cash equivalents, restricted cash 
and cash equivalents

Cash, cash equivalents, restricted 
cash and cash equivalents at 
beginning of period

Cash, cash equivalents, restricted 
cash and cash equivalents at end 
of period

Use of Estimates

In preparing our consolidated financial statements, we make 
assumptions,  judgments  and  estimates  that  can  have  a 
significant impact on our revenue, operating income and net 
income, as well as on the value of certain assets and liabilities 
in  our  consolidated  balance  sheets.  At  least  quarterly,  we 
evaluate  our  assumptions,  judgments  and  estimates,  and 
make changes as deemed necessary.

limited 

including  but  not 

Nasdaq  has  considered  the  impact  of  COVID-19  on  the 
assumptions and estimates used in evaluating our assets and 
to  our  goodwill, 
liabilities, 
intangible  assets,  equity  method 
investments,  equity 
securities  and  allowance  for  losses  on  accounts  receivable. 
We determined that there was no material adverse impact on 
our  results  of  operations  and  financial  position  for  the  year 
ended  December  31,  2021.  These  estimates  may  change  as 
new  events  occur  and  additional  information  is  obtained. 
Actual  results  could  differ  from  these  estimates  under 
different assumptions or conditions.

$ 

2,782  $ 

3,197  $  5,979 

Foreign Currency

Reconciliation of Cash, Cash Equivalents and Restricted Cash and Cash 

Equivalents

Cash and cash equivalents

$ 

2,745  $ 

—  $  2,745 

Restricted cash and cash 

equivalents

Restricted cash and cash 

equivalents (Default funds and 
margin deposits)

Total

Net cash provided by operating 

activities

Net cash used in investing 

activities

Net cash provided by (used in) 

financing activities

Effect of exchange rate changes on 
cash, cash equivalents, restricted 
cash and cash equivalents

Net increase (decrease) in cash, 

cash equivalents, restricted cash 
and cash equivalents

Cash, cash equivalents, restricted 
cash and cash equivalents at 
beginning of period

Cash, cash equivalents, restricted 
cash and cash equivalents at end 
of period

37   

—   

37 

—   

3,197    3,197 

$ 

2,782  $ 

3,197  $  5,979 

Year Ended December 31, 2019

As Reported Adjustment

Adjusted

(in millions)

$ 

963  $ 

—  $ 

963 

(240)   

(174)   

(414) 

(937)   

(1,535)   

(2,472) 

(10)   

(178)   

(188) 

(224)   

(1,887)   

(2,111) 

586   

4,111   

4,697 

$ 

362  $ 

2,224  $  2,586 

Reconciliation of Cash, Cash Equivalents and Restricted Cash and Cash 

Equivalents

Cash and cash equivalents

$ 

332  $ 

—  $ 

332 

Restricted cash and cash 

equivalents

Restricted cash and cash 

equivalents (Default funds and 
margin deposits)

Total

30   

—   

30 

—   

2,224   

2,224 

$ 

362  $ 

2,224  $  2,586 

Foreign  denominated  assets  and  liabilities  are  remeasured 
into the functional currency at exchange rates in effect at the 
balance  sheet  date  and  recorded 
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  in 
the Consolidated Statements of Income.

through 

the 

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  $109  million  as  of 
December  31,  2021  and  $2,509  million  as  of  December  31, 
2020.  Cash  equivalents  are  carried  at  cost  plus  accrued 
interest,  which  approximates  fair  value  due  to  the  short 
maturities  of  these  investments.  The  decrease  in  cash 
equivalents  in  2021  was  primarily  due  to  the  use  of  net 
proceeds of $1.9 billion from issuances of long-term debt in 
the  fourth  quarter  of  2020  to  acquire  Verafin  in  February 
2021. See “Acquisition of Verafin,” of Note 4, “Acquisitions 
and Divestiture,” for further discussion.

F-12

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Restricted Cash

Restricted cash and cash equivalents, which was $29 million 
as of December 31, 2021 and $37 million as of December 31, 
2020,  is  restricted  from  withdrawal  due  to  a  contractual  or 
regulatory requirement or not available for general use and as 
such  is  classified  as  restricted  in  the  Consolidated  Balance 
Sheets.  As  of  December  31,  2021  and  2020,  restricted  cash 
and  cash  equivalents  primarily  includes  funds  held  for  our 
trading and clearing businesses.

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 
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.

cash  or  non-cash 

Receivables, net

Our  receivables  are  concentrated  with  our  member  firms, 
market  data  distributors,  listed  companies,  investor  relations 
intelligence,  governance  and  market  technology  customers. 
Receivables are shown net of allowance for credit losses. The 
allowance is maintained at a level that management believes 
to be sufficient to absorb expected losses over the life of our 
accounts receivable portfolio. The allowance is increased by 
the  provision  for  bad  debts,  which  is  included  in  general, 
administrative  and  other  expense 
the  Consolidated 
Statements  of  Income,  and  decreased  by  the  amount  of 
charge-offs, net of recoveries. 

in 

The allowance is primarily based on an aging methodology. 
This  method  applies  loss  rates  based  on  historical  loss 
information which is disaggregated by business segment and, 
as  deemed  necessary,  is  adjusted  for  other  factors  and 
considerations  that  could  impact  collectibility.  Additionally, 
we consider corporate default rate averages over an extended 
period  as  compared  to  the  period  covered  by  our  historical 
loss  data  and  include  an  adjustment  to  historical  loss 
percentages  for  current  conditions  and  expected  future 
conditions if necessary.

In  circumstances  where  a  specific  customer’s  inability  to 
meet  its  financial  obligations  is  known  (i.e.,  bankruptcy 
filings),  we  determine  whether  a  specific  provision  for  bad 
debts is required. Accounts receivable are written-off against 
the allowance when collection efforts cease. Due to changing 
economic,  business  and  market  conditions,  we  review  the 
allowance  quarterly  and  make  changes  to  the  allowance 
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  allowance  netted 
against  receivables  in  the  Consolidated  Balance  Sheets  was 
$17  million  as  of  December  31,  2021,  $21  million  as  of 
December 31, 2020 and $9 million as of December 31, 2019. 
The change in the balance in 2021 was immaterial.

In  2020  we  adopted  ASU  2016-13,  which  changed  the 
impairment  model  for  certain  financial  instruments.  We 
recorded  a  $12  million  non-cash  cumulative  effect 
adjustment to retained earnings on our opening Consolidated 
Balance  Sheets  as  of  January  1,  2020  as  a  result  of  the 
adoption of this new standard. 

Investments

Purchases  and  sales  of  investment  securities  are  recognized 
on settlement date.

Financial investments

Financial  investments  are  comprised  of  trading  securities 
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,  with  changes  in  fair  value 
included  in  other  income  in  the  Consolidated  Statements  of 
Income.

Fair  value  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, 

F-13

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,  will  recognize  an 
impairment loss in net income equal to the difference in the 
period the impairment occurs. See Note 6, “Investments,” for 
further discussion of our equity securities.

For the years ended December 31, 2021, 2020 and 2019, no 
material adjustments were made to the carrying value of our 
equity securities.

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  under  the  equity  method  of 
accounting.  We  record  our  estimated  pro-rata  share  of 
earnings  or  losses  each  reporting  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  6, 
“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  2021, 
2020 or 2019.

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, 2021 and 2020, 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  2029,  2030  and  2033  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  2029,  2030,  and  2033 
Notes  into  U.S.  dollars  is  recorded  in  accumulated  other 
comprehensive  loss  within  stockholders’  equity  in  the 
Consolidated  Balance  Sheets.  See  “2029  Notes,”  “2030 
Notes,” and “2033 Notes,” of Note 9, “Debt Obligations,” for 
further discussion.

Property and Equipment, net

Property  and  equipment,  including  leasehold  improvements, 
are  carried  at  cost  less  asset  impairment  charges  and 
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.

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.

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 
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.

in 

incurred 

Implementation  costs 
in  a  cloud  computing 
arrangement  that  is  a  service  contract  are  capitalized  as  a 
prepaid  asset  included  in  other  assets  in  our  Consolidated 
Balance  Sheets  and  are  amortized  over  the  expected  service 
period  in  the  relevant  expense  category  in  the  Consolidated 
Statements of Income.

F-14

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 
allocated  to  our  reporting  units  based  on  the  assignment  of 
the  fair  values  of  each  reporting  unit  of  the  acquired 
company.  We  recognize  specifically  identifiable  intangibles, 
such  as  customer  relationships,  technology,  exchange  and 
clearing  registrations,  trade  names  and  licenses  when  a 
specific right or contract is acquired. Goodwill and 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  as  of 
October  1  and  more  frequently  whenever  events  or  changes 
in circumstances indicate that the fair value of the asset may 
be  less  than  its  carrying  amount,  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  and  indefinite-lived  intangible 
assets 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  or 
indefinite-lived  intangible  asset  is  less  than  their  respective 
carrying amounts as the basis to determine if it is necessary 
to perform a quantitative impairment test. If we choose not to 
complete a qualitative assessment, or if the initial assessment 
indicates  that  it  is  more  likely  than  not  that  the  carrying 
amount  of  a  reporting  unit  or  the  carrying  amount  of  an 
indefinite-lived  intangible  asset  exceed  their  respective 
estimated fair values, a quantitative test is required. 

In performing a quantitative impairment test, we compare the 
indefinite-lived 
fair  value  of  each  reporting  unit  and 
intangible asset with their respective carrying amounts. If the 
carrying amounts of the reporting unit or the indefinite-lived 
intangible  asset  exceed  their  respective  fair  values,  an 
impairment  charge  is  recognized  in  an  amount  equal  to  the 
difference,  limited  to  the  total  amount  of  goodwill  allocated 
to  that  reporting  unit  or  the  total  carrying  value  of  the 
indefinite-lived intangible asset.

There  was  no  impairment  of  goodwill  or  indefinite-lived 
intangible  assets  for  the  years  ended  December  31,  2021, 
2020 and 2019. Future disruptions to our business and events, 
such  as  prolonged  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.

Property  and  equipment  are  subject  to  impairment  testing 
when  events  or  conditions  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.  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.

See  Note  7,  “Property  and  Equipment,  net,”  for  further 
discussion.

Leases

At inception, we determine whether a contract is or contains 
a  lease.  We  have  operating  leases  which  are  primarily  real 
estate leases for our U.S. and European headquarters and for 
general office space. As of December 31, 2021, these leases 
have  varying  lease  terms  with  remaining  maturities  ranging 
from  1  month  to  15  years.  Operating  lease  balances  are 
included  in  operating  lease  assets,  other  current  liabilities, 
and  operating  lease  liabilities  in  our  Consolidated  Balance 
Sheets.  We  do  not  have  any  leases  classified  as  finance 
leases. 

Operating 
to  use  an 
lease  assets  represent  our  right 
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 

We  have 
lease  and  non-lease 
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 16, “Leases,” for further discussion.

F-15

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  finite-lived  intangible  assets 
impairment charges of $14 million in 2021 and property and 
equipment  asset  impairment  charges  of  $4  million  in  2020 
and $24 million in 2019. 

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 
the 
judgments  and  estimates  were  used 
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.

in 

Revenue Recognition and Transaction-Based Expenses

Revenue Recognition

Revenue From Contracts With Customers

Our  revenue  recognition  policies  under  ASU  2014-09, 
“Revenue  from  Contracts  with  Customers  (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 an allowance for credit 
losses  of  $17  million  as  of  December  31,  2021  and  $21 
million as of December 31, 2020. 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 there is no 
significant variable consideration. We do not have a material 
amount of 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, the portion 
of  transaction  price  allocated  to  unsatisfied  performance 
obligations is included in  Note 3, “Revenue From Contracts 
With Customers.” Deferred revenue primarily represents our 
contract  liabilities  related  to  our  fees  for  annual  and  initial 
listings,  market 
technology,  IR  &  ESG  services  and 
investment  intelligence  contracts.  Deferred  revenue  is  the 
only significant contract asset or liability as of December 31, 
2021. See Note 8, “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.

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 
similar  economic 
characteristics of the nature, amount, timing and uncertainty 
of our revenues and cash flows.

that  depict 

represent 

those 

Market Technology

Market  Technology  revenues  primarily  consist  of  SaaS 
revenues, software, license and support revenues, and change 
request revenues.

long-term  contracts  with  customers 

In  our  market  infrastructure  technology  business,  we  enter 
into 
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.

long-term  contracts  with  customers 

Our 
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.

F-16

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. 

Investment Intelligence

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 
in 
subscribers  and 
distributors  and 
accordance with the provisions of the plan, subject to SEC 
approval.

taking  action 

• 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  and 
financial products. We also provide index data products and 
custom calculation services for third-party clients. Revenues 
primarily include license fees from these branded indexes 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 

F-17

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.

Analytics

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  one  to  three  years  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.

Corporate Platforms

Listing Services

the  standalone  selling  price  of 

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 IR & ESG 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 
performance  obligations  is  based  on  the  initial  and  annual 
listing  fees  and  the  standalone  selling  price  of  the  IPO 
complimentary  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 
IPO 
complimentary services performance obligation is recognized 
ratably  over  a  three-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.

amount  of 

revenue 

related 

to 

In  the  U.S.,  annual  renewal  fees  are  charged  to  listed 
companies based on their number of outstanding shares at the 
end  of  the  prior  year  and  are  recognized  ratably  over  the 
following  twelve-month  period  since  the  customer  receives 
and  consumes  the  benefit  as  Nasdaq  provides  the  service. 
Annual fees are charged to newly listed companies on a pro-
rata  basis,  based  on  outstanding  shares  at  the  time  of  listing 
and  recognized  over  the  remainder  of  the  year.  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  twelve-month 
basis  and  are  recognized  ratably  over  the  following  twelve-
month  period  since  the  customer  receives  and  consumes  the 
benefit as Nasdaq provides the service.

IR & ESG Services

Our  IR  &  ESG  Services  business  includes  our  Investor 
Relations Intelligence and Governance Solutions businesses, 
which  serve  both  public  and  private  companies  and 
organizations.

IR  &  ESG  Services  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.

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 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 
primarily based on volume of traded and cleared contracts. 

F-18

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  The 
Nasdaq  Stock  Market,  Nasdaq  PSX  and  Nasdaq  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  CX2,  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 
the 
are 
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.

transaction-based  expenses 

included 

in 

in 

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  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  twelve-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  back  office  technology  solutions.  Revenues  from 
broker  services  are  based  on  a  fixed  basic  fee  for  licensing, 
maintenance  and  support  and  development,  and  an 
incremental  fee  depending  on  the  number  of  transactions. 
Broker services revenues are generally billed and recognized 
monthly.  As  previously  disclosed,  in  January  2020,  we 
commenced  an  orderly  wind-down  of  this  broker  services 
business. We expect this wind-down to continue through the 
second quarter of 2022.

Other Revenues

revenues 

For  the  years  ended  December  31,  2021,  2020  and  2019, 
other revenues include the revenues associated with our U.S. 
Fixed Income business, which was sold in June 2021. Prior to 
the  sale  date,  these  revenues  were  included  in  our  Market 
Services  and  Investment  Intelligence  segments.  See  “2021 
Divestiture,” of Note 4,“Acquisitions and Divestiture,” to the 
consolidated  financial  statements  for  further  discussion  of 
this  divestiture.  Additionally,  other 
include 
revenues  associated  with  the  NPM  business  which  we 
contributed to a standalone, independent company, of which 
we  own  the  largest  minority  interest,  together  with  a 
consortium  of  third  party  financial  institutions  in  July  2021. 
Prior to July, these revenues were included in our Corporate 
Platforms  segment.  For  the  year  ended  December  31,  2019, 
other  revenues  also  include  the  revenues  from  the  BWise 
enterprise  governance, 
risk  and  compliance  software 
platform,  which  was  sold  in  March  2019.  Prior  to  the  sale 
date, these revenues were included in our IR & ESG Services 
business  within  our  Corporate  Platforms  segment  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  restricted  stock,  PSUs,  and 
employee  stock  options.  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.  Shares  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 13, “Earnings Per Share,” 
for further discussion.

F-19

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  allocations.  See  Note  10,  “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.

The  expected  rate  of  return  on  plan  assets  for  our  U.S. 
pension  plans  represents  our  long-term  assessment  of  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 
restricted  stock,  PSUs,  and  stock  options.  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.  The  fair  value  of  stock  options  are 
estimated using the Black-Scholes option-pricing model.

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  11,  “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 
generally  include  integration  costs,  as  well  as  legal,  due 
diligence  and  other  third  party  transaction  costs.  As  of 
December  31,  2021,  all  planned  integrations  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 
fair  value 
measurement  date.  When  determining 
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 
that  are  not  active;  and  model-derived 
in  markets 
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  14,  “Fair  Value  of  Financial  Instruments,”  for 
further discussion.

F-20

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 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.

Subsequent Events

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, 2021, 2020 and 2019:

Year Ended December 31,

2021

2020

2019

(in millions)

Market Technology

Anti Financial Crime Technology $  247  $  130  $  121 
Marketplace Infrastructure 
Technology
Investment Intelligence

  216 

  227 

  217 

Market data

Index

Analytics

Corporate Platforms

Listing services

IR & ESG Services

Market Services
Transaction-based trading and 
clearing, net

  414 

  399 

  387 

  459 

  324 

  223 

  203 

  175 

  158 

  387 

  307 

  290 

  226 

  214 

  200 

  916 

  800 

  606 

Trade management services

  325 

  296 

  287 

We  have  evaluated  subsequent  events  through  the  issuance 
date  of  this  Annual  Report  on  Form  10-K.  See  Note  21, 
“Subsequent Events,” for further discussion.

Other revenues
Revenues less transaction-based 
expenses

27 

31 

46 

$ 3,420  $ 2,903  $ 2,535 

Recent Accounting Developments

In October 2021, the FASB issued ASU 2021-08, “Business 
Combinations (Topic 805) - Accounting for Contract Assets 
and Contract Liabilities from Contracts with Customers.” The 
ASU  requires  an  acquirer  in  a  business  combination  to 
recognize and measure contract assets and contract liabilities 
from  acquired  contracts  using  the  revenue  recognition 
guidance under Topic 606 in order to align the recognition of 
a  contract  liability  with  the  definition  of  a  performance 
obligation.  This  approach  differs 
the  current 
requirement to measure contract assets and contract liabilities 
acquired in a business combination at fair value. This ASU is 
effective for fiscal years beginning after December 15, 2022, 
including  interim  periods  within  those  fiscal  years.  Early 
adoption is permitted. We adopted this standard on January 1, 
2022 on a prospective basis.

from 

Substantially  all  revenues  from  the  Market  Technology, 
Investment  Intelligence  and  Corporate  Platforms  segments 
were recognized over time for the years ended December 31, 
2021,  2020,  and  2019.  For  the  years  ended  December  31, 
2021,  2020  and  2019  approximately  70.8%,  69.8%  and 
64.4%,  respectively,  of  Market  Services  revenues  were 
recognized at a point in time and 29.2%, 30.2% and 35.6%, 
respectively, were recognized over time. 

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  $17  million  as  of  December  31,  2021  and  $21 
million as of December 31, 2020. 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  range  from  three  months  to  three 
years and there is no significant variable consideration.

F-21

 
 
 
 
 
Deferred  revenue  is  the  only  significant  contract  asset  or 
liability  as  of  December  31,  2021.  Deferred  revenue 
represents consideration received that is yet to be recognized 
as revenue for unsatisfied performance obligations. Deferred 
revenue primarily represents our contract liabilities related to 
our fees for Market Technology, Analytics, annual and initial 
listings,  and  IR  &  ESG  Services  contracts.  See  Note  8, 
“Deferred Revenue,” for our discussion on deferred revenue 
balances, activity, and expected timing of recognition.

the 

We  do  not  have  a  material  amount  of  revenue  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  our  initial 
listings 
remaining 
transaction  price  allocated 
performance obligations is included in deferred revenue. For 
our  market  technology,  Analytics,  and  IR  &  ESG  contracts 
the  portion  of  transaction  price  allocated  to  unsatisfied 
performance  obligations  is  presented  in  the  table  below.  To 
the  extent  consideration  has  been  received,  unsatisfied 
performance obligations would be included in the table below 
as well as deferred revenue. 

to 

table  summarizes 

the 
The  following 
transaction price allocated to performance obligations that are 
unsatisfied, for contract durations greater than one year, as of 
December 31, 2021:

the  amount  of 

Market 
Technology

Analytics

IR & ESG 
Services

Total

2022
2023
2024
2025
2026
2027+
Total

$ 

$ 

506  $ 
337 
178 
106 
68 
92 
1,287  $ 

(in millions)
63  $ 
38 
15 
4 
3 
2 
125  $ 

57  $ 
30 
8 
1 
— 
— 
96  $ 

626 
405 
201 
111 
71 
94 
1,508 

4. ACQUISITIONS AND DIVESTITURE 

We  completed  the  following  divestiture  and  acquisitions  in 
2021  and  2020.  Financial  results  of  each  transaction  are 
included  in  our  consolidated  financial  statements  from  the 
date of each acquisition.

2021 Divestiture

In June 2021, we sold our U.S. Fixed Income business, which 
was  part  of  our  FICC  business  within  our  Market  Services 
segment, to Tradeweb Markets Inc. We recognized a pre-tax 
gain on the sale of $84 million, net of disposal costs. The pre-
tax gain is included in net gain on divestiture of businesses in 
the Consolidated Statements of Income.

As  part  of  the  purchase  price  consideration  related  to  this 
business  when  it  was  acquired  in  2013,  we  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  were  to  be  issued  annually  through  2027  if 
Nasdaq’s  total  gross  revenues  equaled  or  exceeded  $25 
million in each such year. The contingent future issuances of 
Nasdaq  common  stock  were  subject 
to  anti-dilution 
protections and acceleration upon certain events.

Upon the consummation of the sale of our U.S. Fixed Income 
business,  the  aggregate  number  of  Nasdaq  shares  remaining 
under  the  contingent  obligation  described  above  were 
reduced  (pursuant  to  the  discounting  adjustment  provisions 
set  forth  in  the  original  purchase  agreement  for  Nasdaq's 
acquisition  of  the  business)  and  accelerated,  resulting  in  an 
issuance  of  approximately  6.2  million  shares  of  Nasdaq 
common  stock  to  an  assignee  of  the  entity  that  sold  this 
business to us in 2013.

Nasdaq  intends  to  use  the  proceeds  from  the  sale,  available 
tax benefits and working and clearing capital of this business, 
as  well  as  other  sources  of  cash,  to  repurchase  shares  of 
Nasdaq common stock to reduce the impact on earnings per 
share dilution from the sale.

To  facilitate  these  repurchases,  the  board  of  directors 
authorized  an  increase  to  the  share  repurchase  program.  See 
“Share  Repurchase  Program,”  of  Note  12,  “Nasdaq 
Stockholders' Equity,” for further discussion. 

2021 Acquisition

Acquisition of Verafin

of 

provider 

technology 

anti-financial 

In February 2021, we completed the acquisition of Verafin, a 
SaaS 
crime 
management  solutions  that  provides  a  cloud-based  platform 
to help detect, investigate, and report money laundering and 
financial  fraud,  for  an  aggregate  purchase  price  of  $2.75 
billion,  subject  to  certain  adjustments.  The  $2.75  billion 
purchase  price  includes  a  cash  payment  of  $102  million, 
reflected in cash from operating activities in our Consolidated 
Statements of Cash Flows, the release of which is subject to 
certain  employment-related  conditions  over  three  years 
following  the  closing  of  the  transaction.  This  payment  was 
recorded as a prepaid expense and is recorded in other current 
and  non-current  assets  in  our  Consolidated  Balance  Sheets 
and  will  be  amortized  to  merger  and  strategic  initiatives 
expense  on  a  straight-line  basis  over  a  three-year  period. 
Verafin is part of our Market Technology segment.

Nasdaq  used  the  net  proceeds  from  our  offering  of  senior 
notes  in  December  2020,  commercial  paper  issuances,  and 
cash  on  hand  to  fund  this  acquisition.  See  “Commercial 
Paper  Program,”  and  “Senior  Unsecured  Notes  Due  2022, 
2031  and  2040,”  of  Note  9,  “Debt  Obligations,”  for  further 
discussion.

F-22

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
As  of  December  31,  2021,  the  allocation  of  purchase  price 
includes  the  effect  of  a  $9  million  measurement  period 
adjustment  recorded  during 
the  second  quarter.  This 
adjustment resulted in an increase to both total net liabilities 
the 
acquired  and  goodwill.  Additional  adjustments 
provisional  values  may  result  before 
the 
measurement period, a period not to exceed 12 months from 
the  acquisition  date.  These  adjustments,  which  may  include 
tax  and  other  estimates  will  be  recorded  in  the  reporting 
period  in  which  the  adjustment  amounts  are  determined. 
Changes  to  amounts  recorded  as  assets  and  liabilities  may 
result in a corresponding adjustment to goodwill.

to 
the  end  of 

Goodwill
Acquired Intangible Assets

Total Net Liabilities Acquired

Purchase Consideration

Intangible Assets

(in millions)

$ 

1,882 
815 

(46) 

$ 

2,651 

The following table presents the details of acquired intangible 
assets  for  Verafin  at  the  date  of  acquisition.  Acquired 
intangible  assets  with  finite  lives  are  amortized  using  the 
straight-line method.

Customer 

Relationships Technology

Trade 
Name

Total 
Acquired 
Intangible 
Assets

Intangible asset 
value (in millions)

$ 

532 

$  246 

$  37 

$ 

815 

Discount rate used

 7.5 %

 7.5 %

 7.5 %

Estimated average 
useful life

22 years

7 years 20 years

Customer Relationships

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.

Discount Rate

for 

flows 

the  hypothetical  cash 

The discount rate used reflects the amount of risk associated 
with 
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  utilized  this  rate  as  an  input  when  discounting  the  cash 
flows.  The  resulting  discounted  cash  flows  were  then  tax-
effected at the applicable statutory rate.

For our acquisition of Verafin, a discounted tax amortization 
benefit  was  added  to  the  fair  value  of  the  assets  under  the 
assumption 
the  customer  relationships  would  be 
amortized for tax purposes over a period of 20 years.

that 

Estimated Useful Life 

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.

Technology 

As part of our acquisition of Verafin, we acquired developed 
technology.

Methodology

The  developed  technology  was  valued  using  the  income 
approach,  specifically  the  relief-from-royalty  method,  or 
RFRM. The RFRM is used to estimate the cost savings that 
accrue  to  the  owner  of  an  intangible  asset  who  would 
otherwise  have  to  pay  royalties  or  license  fees  on  revenues 
earned  through  the  use  of  the  asset.  The  royalty  rate  is 
applied to the projected revenue over the expected remaining 
life  of  the  intangible  asset  to  estimate  royalty  savings.  The 
net  after-tax  royalty  savings  are  calculated  for  each  year  in 
the remaining economic life of the technology and discounted 
to present value.

Discount Rate

the  hypothetical  cash  flows  for 

The discount rates used reflect the amount of risk associated 
with 
the  developed 
technology relative to the overall business as discussed above 
in “Customer Relationships.”

Estimated Useful Life

We have estimated the useful life of the Verafin technology 
to be 7 years.

Trade Name

As  part  of  our  acquisition  of  Verafin,  we  acquired  a  trade 
name.  The  trade  name  is  recognized  in  the  industry  and 
carries  a  reputation  for  quality.  As  such,  the  reputation  and 
positive recognition embodied in the trade name is a valuable 
asset to Nasdaq.

Methodology

The  Verafin  trade  name  was  valued  using  the  income 
approach,  specifically  the  RFRM  as  discussed  above  in 
“Technology.”

Discount Rate

The discount rate used reflects the amount of risk associated 
with the hypothetical cash flows for the trade name relative to 
the  overall  business  as  discussed  above  in  “Customer 
Relationships.”

F-23

 
 
Estimated Useful Life

We have estimated the useful life of the Verafin trade name 
to be 20 years and our intention is to continue to use it in the 
branding of products.

2020 Acquisition

Acquisition of Solovis

5. GOODWILL AND ACQUIRED INTANGIBLE 
ASSETS

Goodwill

The  following  table  presents  the  changes  in  goodwill  by 
business segment during the year ended December 31, 2021:

(in millions)

In  March  2020,  we  acquired  Solovis,  a  provider  of  multi-
asset  class  portfolio  management,  analytics  and  reporting 
tools across public and private markets. Solovis is part of our 
Investment Intelligence segment.

Pro Forma Results and Acquisition-Related Costs

The  consolidated  financial  statements  for  the  years  ended 
December  31,  2021,  2020  and  2019  include  the  financial 
results  of  the  above  acquisitions  from  the  dates  of  these 
acquisitions.  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.

Market Technology
Balance at December 31, 2020
Goodwill acquired
Other adjustments
Balance at December 31, 2021
Investment Intelligence
Balance at December 31, 2020
Divestiture of business
Other adjustments
Balance at December 31, 2021
Corporate Platforms
Balance at December 31, 2020
Other adjustments
Balance at December 31, 2021
Market Services
Balance at December 31, 2020
Goodwill acquired
Divestiture of business
Other adjustments
Balance at December 31, 2021

Total
Balance at December 31, 2020
Goodwill acquired
Divestiture of business
Other adjustments
Balance at December 31, 2021

In the table above: 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

309 
1,873 
(11) 
2,171 

2,541 
(23) 
(90) 
2,428 

481 
(12) 
469 

3,519 
15 
(37) 
(132) 
3,365 

6,850 
1,888 
(60) 
(245) 
8,433 

• Divestiture of business relates to the sale of our U.S. Fixed 
Income  business.  See  “2021  Divestiture,”  of  Note  4, 
“Acquisitions  and  Divestiture,”  for  further  discussion.  In 
addition  to  revenues  earned  through  Market  Services,  our 
U.S.  Fixed  Income  business  also  earned  fees  from  market 
data,  which  are  included  in  our  Investment  Intelligence 
segment.  Therefore,  a  portion  of  the  goodwill  was 
allocated to this segment.

• Other  adjustments  includes  foreign  currency  translation 
adjustment.  For  Market  Technology,  it  also  includes  a 
measurement  period  adjustment  related  to  our  acquisition 
of  Verafin.  See  “2021  Acquisition,”  of  Note  4, 
“Acquisitions and Divestiture,” for further discussion.

As of December 31, 2021, the amount of goodwill, primarily 
relating  to  our  acquisition  of  Verafin,  that  is  expected  to  be 
deductible for tax purposes in future periods is $1.8 billion.

F-24

 
 
 
 
 
 
 
 
 
 
 
The  change  in  the  gross  and  net  amounts  for  technology, 
customer relationships and trade names and other finite-lived 
intangible  assets  as  of  December  31,  2021  compared  with 
December 31, 2020 is primarily related to our acquisition of 
Verafin.  The  change  in  the  gross  and  net  amounts  for 
customer  relationships  as  of  December  31,  2021  compared 
with  December  31,  2020  is  also  related  to  the  divestiture  of 
our U.S. Fixed Income business. See “2021 Acquisition,” and 
“2021  Divestiture,”  of  Note  4,  “Acquisitions  and 
Divestiture,”  for  further  discussion  of  these  transactions. 
There was no impairment of indefinite-lived intangible assets 
for the years ended December 31, 2021, 2020 and 2019. We 
recorded an impairment charge of $14 million in 2021 related 
to  a  finite-lived  intangible  asset  for  customer  relationships 
associated  with  the  wind  down  of  a  previous  acquisition 
included  in  depreciation  and  amortization  expense  in  the 
Consolidated  Statements  of  Income.  There  were  no  material 
finite-lived impairment charges in 2020 and 2019.

The  following  table  presents  our  amortization  expense  for 
acquired finite-lived intangible assets:

Year Ended December 31,

2021

2020

2019

(in millions)

Amortization expense

$ 

170  $ 

103  $ 

101 

The  increase  in  amortization  expense  for  the  year  ended 
December 31, 2021 compared with the same periods in 2020 
and  2019  was  primarily  due  to  additional  amortization 
expense  for  acquired 
to  our 
acquisition  of  Verafin.  These  amounts  are  included  in 
depreciation  and  amortization  expense  in  the  Consolidated 
Statements of Income.

intangible  assets  related 

The  table  below  presents  the  estimated  future  amortization 
expense (excluding the impact of foreign currency translation 
adjustments  of  $62  million  as  of  December  31,  2021)  of 
acquired  finite-lived  intangible  assets  as  of  December  31, 
2021:

2022
2023

2024

2025

2026

2027+

Total

(in millions)

$ 

161 
157 

152 

149 

146 

864 

$  1,629 

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, 
2021,  2020  and  2019;  however,  events  such  as  prolonged 
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.

Acquired Intangible Assets

The following table presents details of our total acquired 
intangible assets, both finite- and indefinite-lived:

Finite-Lived Intangible Assets

(in millions)

December 31, 
2021

December 31, 
2020

Gross Amount

Technology

Customer relationships

Trade names and other
Foreign currency translation 
adjustment

Total gross amount
Accumulated Amortization
Technology
Customer relationships
Trade names and other
Foreign currency translation 
adjustment

Total accumulated amortization
Net Amount
Technology
Customer relationships
Trade names and other
Foreign currency translation 
adjustment

Total definite-lived intangible 

assets

$ 

295  $ 

76 

2,050 

60 

1,599 

18 

(143)   

(104) 

$ 

2,262  $ 

1,589 

$ 

$ 

$ 

(54)  $ 
(711)   
(11)   

81 
(695)  $ 

241  $ 

1,339 
49 

(24) 
(648) 
(6) 

58 
(620) 

52 
951 
12 

(62)   

(46) 

$ 

1,567  $ 

969 

Indefinite-Lived Intangible Assets
Exchange and clearing 
registrations

Trade names

Licenses
Foreign currency translation 
adjustment
Total indefinite-lived 
intangible assets

Total intangible assets, net

$ 

1,257  $ 

1,257 

121 

52 

121 

52 

(184)   

(144) 

$ 

$ 

1,246  $ 

1,286 

2,813  $ 

2,255 

F-25

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6. INVESTMENTS

7. PROPERTY AND EQUIPMENT, NET

The following table presents the details of our investments:

December 31, 2021

December 31, 2020

The following table presents our major categories of property 
and equipment, net:

Financial investments

$ 

Equity method investments $ 

Equity securities

$ 

Financial Investments

(in millions)

208  $ 

363  $ 

67  $ 

195 

216 

60 

Financial  investments  are  comprised  of  trading  securities, 
primarily  highly  rated  European  government  debt  securities, 
of  which  $162  million  as  of  December  31,  2021  and  $175 
million as of December 31, 2020, are assets primarily utilized 
to  meet  regulatory  capital  requirements,  mainly  for  our 
clearing operations at Nasdaq Clearing.

Equity Method Investments

We record our estimated pro-rata share of earnings or losses 
each reporting period and record any dividends as a reduction 
in  the  investment  balance.  As  of  December  31,  2021  and 
2020, our equity method investments primarily included our 
40.0% 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  for 
the years end December 31, 2021 and 2020.

Net  income  recognized  from  our  equity  interest  in  the 
earnings  and  losses  of  these  equity  method  investments, 
primarily  OCC,  was  $52  million  for  the  year  ended 
December  31,  2021,  $70  million  for  the  year  ended 
December  31,  2020  and  $84  million  for  the  year  ended 
December 31, 2019. For the year ended December 31, 2021, 
lower equity interest in the earnings of OCC as compared to 
2020 and 2019 is primarily driven by a reduction, in 2021, in 
the clearing fee rates that OCC charged its customers.

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  for  the  year 
ended December 31, 2021, 2020 and 2019. As of December 
31,  2021  and  December  31,  2020,  our  equity  securities 
primarily  represent  various  strategic 
investments  made 
through  our  corporate  venture  program  as  well  as 
investments acquired through various acquisitions.

Data processing equipment and 
software
Furniture, equipment and leasehold 
improvements

Total property and equipment
Less: accumulated depreciation and 
amortization and impairment 
charges

Year Ended December 31,

2021

2020

(in millions)

$ 

735  $ 

732 

288 

1,023 

300 

1,032 

(514)   

(557) 

Total property and equipment, net

$ 

509  $ 

475 

Depreciation  and  amortization  expense  for  property  and 
equipment  was  $108  million  for  the  year  ended  December 
31, 2021, $99 million for the year ended December 31, 2020, 
and  $89  million  for  the  year  ended  December  31,  2019. 
These amounts are included in depreciation and amortization 
expense in the Consolidated Statements of Income.

We recorded pre-tax, non-cash property and equipment asset 
impairment  charges  on  capitalized  software  that  was  retired 
and  accelerated  depreciation  expense  on  certain  assets  as  a 
result of a decrease in their useful life of $4 million in 2021, 
$14 million in 2020 and $26 million in 2019. These charges 
are  included  in  restructuring  charges  in  the  Consolidated 
Statements of Income. See Note 20, “Restructuring Charges,” 
for  a  discussion  of  our  2019  restructuring  plan.  There  were 
no  other  material  impairments  of  property  and  equipment 
recorded in 2021, 2020 or 2019. 

As of December 31, 2021 and 2020, we did not own any real 
estate properties.

8. 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,  2021  are 
reflected in the following table: 

Balance at 
December 31, 
2020

Revenue 

Additions

Recognized Adjustments

Balance at 
December 31, 
2021

(in millions)

Market 
Technology $ 
Investment 
Intelligence  
Corporate Platforms:

Initial Listing  
Annual 

Listings

IR & ESG 
Services

53  $  113  $ 

(46) $ 

(3) $ 

117 

97    104   

(95)  

—   

106 

91   

97   

(41)  

2   

3   

(2)  

46   

17   

52   

15   

(41)  

(9)  

(2)  

(1)  

—   

(2)  

145 

2 

57 

21 

$ 

306  $  384  $  (234) $ 

(8) $ 

448 

Other

Total

F-26

 
 
 
 
 
 
 
 
 
 
 
 
In the preceding table:

9. DEBT OBLIGATIONS

• Additions  primarily  reflect  deferred  revenue  billed  in  the 
current  period,  net  of  recognition.  Market  Technology 
additions  include  deferred  revenue  acquired  as  part  of  the 
acquisition of Verafin.

• Revenue  recognized  includes  revenue  recognized  during 
the  current  period  that  was  included  in  the  beginning 
balance.

The  following  table  presents  the  changes  in  the  carrying 
amount  of  our  debt  obligations  during  the  year  ended 
December 31, 2021:

December 31, 
2020

Additions

Payments, 
Foreign 
Currency 
Translation 
and 
Accretion

December 31, 
2021

reflect 

foreign 

currency 

translation 

(in millions)

• Adjustments 
adjustments.

• Other  primarily  includes  deferred  revenue  from  non-U.S. 
listing of additional shares fees. Listing of additional shares 
fees are included in our Listing Services business. 

As  of  December  31,  2021,  we  estimate  that  our  deferred 
revenue will be recognized in the following years:

Fiscal year 
ended:

2022

2023

2024

2025

2026

2027+

Total

(in millions)

Market 
Technology  $ 109  $  6  $  1  $  1  $  —  $  —  $ 117 
Investment 
Intelligence

2    —    —    —    —    106 

  104   

Corporate Platforms:

Initial 

Listings

Annual 

Listings

IR & ESG 
Services 

Other

Total

  49    35    26    17    14   

4    145 

2    —    —    —    —    —   

2 

  56   

1    —    —    —    —   

9   

7   

4   

1    —    —   

57 

21 

$ 329  $  51  $  31  $  19  $  14  $  4  $ 448 

In the above table, the timing of recognition of our deferred 
market technology revenues is primarily dependent upon the 
completion 
significant 
modifications  made  pursuant  to  existing  market  technology 
contracts.  As  such,  as  it  relates  to  market  technology 
revenues, the timing represents our best estimate.

customization 

any 

and 

of 

Short-term 
debt - 
commercial 
paper

2022 Notes
Total short-
term debt

Long-term   
debt - senior 
unsecured 
notes:

$ 

—  $ 4,079  $  (3,659)  $ 

597   — 

1 

420 

598 

$ 

597  $ 4,079  $  (3,658)  $ 

1,018 

2024 Notes

$ 

498  $  —  $ 

1  $ 

2023 Notes

2026 Notes

2029 Notes

2030 Notes

2050 Notes

2031 Notes

2040 Notes

2033 Notes
2020 Credit 
Facility
Total long-
term debt
Total debt 
obligations

$ 

$ 

730 

  — 

(730)   

497 

  — 

726 

  — 

726 

  — 

485 

  — 

643 

  — 

643 

  — 

1 

(50)   

(50)   

1 

— 

1 

— 

726 

(32)   

499 

— 

498 

676 

676 

486 

643 

644 

694 

(4)   

100 

(100)   

(4) 

4,944  $  826  $ 

(958)  $ 

4,812 

5,541  $ 4,905  $  (4,616)  $ 

5,830 

In the table above, the 2022 Notes were reclassified to short-
term debt as of December 31, 2021.

Commercial Paper Program

Our  U.S.  dollar  commercial  paper  program  is  supported  by 
our 2020 Credit Facility which provides liquidity support for 
the  repayment  of  commercial  paper  issued  through  this 
program.  See  “2020  Credit  Facility”  below  for  further 
discussion.  The  effective  interest  rate  of  commercial  paper 
issuances  fluctuates  as  short  term  interest  rates  and  demand 
fluctuate.  The  fluctuation  of  these  rates  may  impact  our 
interest expense.

In  February  2021,  we  issued  $475  million  of  commercial 
paper to partially fund the acquisition of Verafin. For further 
the  acquisition  of  Verafin,  see  “2021 
discussion  of 
Acquisition,” of Note 4, “Acquisitions and Divestiture.”

F-27

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In  July  2021,  we  issued  commercial  paper  to  partially  fund 
our  ASR  agreement.  See  “ASR  Agreements,”  of  Note  12, 
“Nasdaq Stockholders' Equity."

reflect 

As  of  December  31,  2021,  commercial  paper  notes  in  the 
table  above 
the  aggregate  principal  amount 
outstanding,  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 31 days to 66 days and the weighted-average maturity is 
29  days.  The  weighted-average  effective  interest  rate  is 
0.34% per annum. 

Senior Unsecured Notes

Our 2022 and 2040 Notes were issued at par. All of our other 
outstanding senior unsecured notes were 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,  2021,  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,  Foreign  Currency  Translation  and  Accretion” 
impact  of  foreign  currency 
column  also 
translation. Our senior unsecured notes are general unsecured 
obligations  which  rank  equally  with  all  of  our  existing  and 
future unsubordinated obligations and 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. The senior unsecured notes may be redeemed by 
Nasdaq at any time, subject to a make-whole amount. 

includes 

the 

Upon a change of control triggering event (as defined in the 
various  supplemental  indentures  governing  the  applicable 
notes), 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. 

2026 Notes

In  June  2016,  Nasdaq  issued  the  2026  Notes,  which  pay 
interest  semi-annually  at  a  rate  of  3.85%  per  annum  until 
June  30,  2026.  Such  interest  rate  may  vary  with  Nasdaq’s 
debt  rating,  to  the  extent  Nasdaq  is  downgraded  below 
investment grade, up to a rate not to exceed 5.85%.

2029 Notes

In  April  2019,  Nasdaq  issued  the  2029  Notes,  which  pay 
interest  annually  at  a  rate  of  1.75%  per  annum  until  March 
28,  2029.  Such  interest  rate  may  vary  with  Nasdaq’s  debt 
rating, to the extent Nasdaq is downgraded below investment 
grade, up to a rate not to exceed 3.75%.

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  decrease  in  the  carrying  amount  of 
$50  million  noted  in  the  “Payments,  Foreign  Currency 
Translation  and  Accretion”  column  in  the  table  above 
primarily  reflects  the  remeasurement  of  the  2029  Notes  into 
U.S.  dollars  and 
in  accumulated  other 
recorded 
comprehensive  loss  within  Nasdaq's  stockholders’  equity  in 
the Consolidated Balance Sheets as of December 31, 2021.

is 

2030 Notes

In  February  2020,  Nasdaq  issued  the  2030  Notes.  The  2030 
Notes  pay  interest  annually  in  arrears,  which  began  on 
February 13, 2021.

The  2030  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 
$50  million  noted  in  the  “Payments,  Foreign  Currency 
Translation  and  Accretion”  column  in  the  table  above 
primarily  reflects  the  remeasurement  of  the  2030  Notes  into 
U.S.  dollars  and 
in  accumulated  other 
recorded 
comprehensive  loss  within  Nasdaq's  stockholders’  equity  in 
the Consolidated Balance Sheets as of December 31, 2021.

is 

2024 Notes

2050 Notes

In  May  2014,  Nasdaq  issued  the  2024  Notes,  which  pay 
interest semiannually at a rate of 4.25% per annum until June 
1,  2024.  Such  interest  rate  may  vary  with  Nasdaq’s  debt 
rating, to the extent Nasdaq is downgraded below investment 
grade, up to a rate not to exceed 6.25%. 

Early Extinguishment of 2023 Notes

Nasdaq  issued  the  2023  Notes  in  May  2016,  which  paid 
interest  annually  at  a  rate  of  1.75%  per  annum.  In  August 
2021,  we  primarily  used  the  net  proceeds  from  the  2033 
Notes to repay in full and redeem our 2023 Notes. For further 
discussion  see  “2033  Notes”  below.  In  connection  with  the 
early  extinguishment  of  the  2023  Notes,  we  recorded  a  pre-
tax charge of $33 million, which primarily includes a make-
whole redemption price premium. This charge is included in 
general, administrative and other expense in the Consolidated 
Statements of Income for the year ended December 31, 2021.

In  April  2020,  Nasdaq  issued  the  2050  Notes.  The  2050 
Notes pay interest semi-annually in arrears, which began on 
October 28, 2020. The interest rate of 3.25% may vary with 
Nasdaq's  debt  rating,  to  the  extent  Nasdaq  is  downgraded 
below investment grade, up to a rate not to exceed 5.25%. 

Senior Unsecured Notes Due 2022, 2031 and 2040

In December 2020, Nasdaq issued the 2022, 2031 and 2040 
Notes.  The  net  proceeds  were  used  to  partially  fund  the 
acquisition  of  Verafin.  For  further  discussion  of 
the 
acquisition  of  Verafin,  see  “2021  Acquisition,”  of  Note  4, 
“Acquisitions and Divestiture.”

F-28

2022 Notes

The 2022 Notes pay interest semi-annually in arrears, which 
began  on  June  21,  2021.  The  interest  rate  of  0.445%  may 
vary  with  Nasdaq's  debt  rating,  to  the  extent  Nasdaq  is 
downgraded  below  investment  grade,  up  to  a  rate  not  to 
exceed 2.445%. 

2031 Notes

The 2031 Notes pay interest semi-annually in arrears, which 
began on January 15, 2021. The interest rate of 1.650% may 
vary  with  Nasdaq's  debt  rating,  to  the  extent  Nasdaq  is 
downgraded  below  investment  grade,  up  to  a  rate  not  to 
exceed 3.65%. 

2040 Notes

The 2040 Notes pay interest semi-annually in arrears, which 
began  on  June  21,  2021.  The  interest  rate  of  2.500%  may 
vary  with  Nasdaq's  debt  rating,  to  the  extent  Nasdaq  is 
downgraded  below  investment  grade,  up  to  a  rate  not  to 
exceed 4.50%.

2033 Notes

In July 2021, Nasdaq issued €615 million aggregate principal 
amount  of  0.900%  senior  notes  due  in  2033,  which  pay 
interest annually in arrears, beginning on July 30, 2022. The 
net proceeds from the 2033 Notes were approximately $726 
million  after  deducting 
the  underwriting  discount  and 
expenses of the offering. We primarily used the net proceeds 
from  the  2033  Notes  to  redeem  all  of  the  2023  Notes.  For 
further  discussion  of 
see  “Early 
Extinguishment of 2023 Notes” above.

the  2023  Notes, 

The 2033 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  decrease  in  the  carrying  amount  of 
$32  million  noted  in  the  “Payments,  Foreign  Currency 
Translation  and  Accretion”  column  in  the  table  above 
primarily  reflects  the  remeasurement  of  the  2033  Notes  into 
U.S.  dollars  and 
in  accumulated  other 
recorded 
comprehensive  loss  within  Nasdaq  stockholders’  equity  in 
the Consolidated Balance Sheets as of December 31, 2021.

is 

Credit Facilities

2020 Credit Facility

In  December  2020,  Nasdaq  entered  into  the  2020  Credit 
Facility, which replaced a former credit facility and consists 
of  a  $1.25  billion  five-year  revolving  credit  facility  (with 
sublimits  for  non-dollar  borrowings,  swingline  borrowings 
and  letters  of  credit).  Nasdaq  intends  to  use  funds  available 
under the 2020 Credit Facility for general corporate purposes 
and  to  provide  liquidity  support  for  the  repayment  of 
commercial  paper  issued  through  the  commercial  paper 
program. Nasdaq is permitted to repay borrowings under our 
2020 Credit Facility at any time in whole or in part, without 
penalty.

As  of  December  31,  2021,  no  amounts  were  outstanding  on 
the 2020 Credit Facility. The $(4) million balance represents 
unamortized  debt  issuance  costs  which  are  being  accreted 
through interest expense over the life of the credit facility. Of 
the $1.25 billion that is available for borrowing, $420 million 
provides liquidity support for the commercial paper program. 
As  such,  as  of  December  31,  2021,  the  total  remaining 
amount  available  under  the  2020  Credit  Facility  was  $830 
million,  excluding  the  amounts  that  support  the  commercial 
paper program. See “Commercial Paper Program” above for 
further discussion of our commercial paper program.

Under  our  2020  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 a successor rate to 
LIBOR), 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 
0.350%,  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  the 
year ended December 31, 2021 and 2020.

The  2020  Credit  Facility  contains  financial  and  operating 
covenants. Financial covenants include a maximum leverage 
ratio.  Operating  covenants  include,  among  other  things, 
limitations  on  Nasdaq’s  ability 
incur  additional 
indebtedness,  grant  liens  on  assets,  dispose  of  assets  and 
make  certain  restricted  payments.  The  facility  also  contains 
customary  affirmative  covenants, 
to 
financial  statements,  notice  of  defaults  and  certain  other 
material events, maintenance of properties and insurance, and 
customary  events  of  default,  including  cross-defaults  to  our 
material indebtedness. 

including  access 

to 

The  2020  Credit  Facility  includes  an  option  for  Nasdaq  to 
increase  the  available  aggregate  amount  by  up  to  $625 
million,  subject  to  the  consent  of  the  lenders  funding  the 
increase and certain other conditions.

Other Credit Facilities

Certain of our European subsidiaries have several other credit 
facilities,  which  are  available 
in  multiple  currencies, 
primarily  to  support  our  Nasdaq  Clearing  operations  in 
Europe, as well as to provide a cash pool credit line for one 
subsidiary. These credit facilities, in aggregate, totaled $212 
million  as  of  December  31,  2021  and  $232  million  as  of 
December 31, 2020 in available liquidity, none of which was 
utilized. Generally, these facilities each have a one year term. 
The  amounts  borrowed  under  these  various  credit  facilities 
bear interest on the principal amount outstanding at a variable 
interest rate based on a base rate (as defined in the applicable 
credit agreement), plus an applicable margin. We are charged 
commitment  fees  (as  defined  in  the  applicable  credit 
agreement),  whether  or  not  amounts  have  been  borrowed. 
These commitment fees are included in interest expense and 
were not material for the years ended December 31, 2021 and 
2020.

F-29

These  facilities  include  customary  affirmative  and  negative 
operating covenants and events of default.

Debt Covenants

As  of  December  31,  2021,  we  were  in  compliance  with  the 
covenants of all of our debt obligations.

10. 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  $14  million  for  the  year  ended 
December  31,  2021,  $14  million  for  the  year  ended 
December  31,  2020  and  $13  million  for  the  year  ended 
December 31, 2019.

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 $26 million for the year ended 
December  31,  2021,  $23  million  for  the  year  ended 
December  31,  2020  and  $20  million  for  the  year  ended 
December 31, 2019.

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  $111  million  as  of  December  31, 
2021  and  the  benefit  obligation  was  $112  million  as  of 
December  31,  2021.  As  a  result,  the  U.S.  defined-benefit 
pension plans are underfunded by $1 million as of December 
31, 2021. The fair value of our U.S. defined-benefit pension 
plans' assets was $119 million as of December 31, 2020 and 
the  benefit  obligation  was  $118  million  as  of  December  31, 
2020.  As  a  result,  the  U.S.  defined-benefit  pension  plans 
were fully funded as of December 31, 2020. During 2021 and 
2020, we did not make any contributions to our U.S. defined-
benefit  pension  plans.  For  our  SERP  and  other  post-
retirement  benefit  plans,  the  net  underfunded  liability  was 
$34 million as of December 31, 2021 and  $30 million as of 
December 31, 2020. 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  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, 2021, accumulated other comprehensive
loss for the Nasdaq Benefit Plans was $26 million reflecting 
an unrecognized net loss of $33 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:

Fiscal Year Ended:

(in millions)

Pension

SERP

Post-
retirement

Total

2022

2023

2024

2025

2026

2027 through 2031

$ 

8  $ 

6  $  —  $ 

7 

8 

8 

10 

38 

2 

2 

2 

2 

8 

  — 

  — 

  — 

  — 

2 

14 

9 

10 

10 

12 

48 

$ 

79  $ 

22  $ 

2  $  103 

11. SHARE-BASED COMPENSATION

We have a share-based compensation program for employees 
and  non-employee  directors.  Share-based  awards  granted 
under  this  program  include  restricted  stock  (consisting  of 
restricted  stock  units),  PSUs  and  stock  options.  For 
accounting  purposes,  we  consider  PSUs  to  be  a  form  of 
restricted stock.

Summary of Share-Based Compensation Expense

the 

total 

following 

table  presents 

The 
share-based 
compensation  expense  resulting  from  equity  awards  and  the 
15.0% discount for the ESPP for the years ended December 
31, 2021, 2020 and 2019, which is included in compensation 
and  benefits  expense  in  the  Consolidated  Statements  of 
Income:

Year Ended December 31,

2021

2020

2019

(in millions)

Share-based compensation 
expense before income taxes

Income tax benefit
Share-based compensation 
expense after income taxes

$ 

90  $ 

87  $ 

79 

(24)   

(23)   

(21) 

$ 

66  $ 

64  $ 

58 

F-30

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Common Shares Available Under Our Equity Plan

PSUs

As of December 31, 2021, we had approximately 9.5 million 
shares of common stock authorized for future issuance under 
our Equity Plan.

Restricted Stock

We grant restricted stock to most 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 to employees 
below  the  manager  level  generally  vest  33.3%  on  the  first 
anniversary  of 
the  second 
anniversary  of  the  grant  date,  and  33.3%  on  the  third 
anniversary of the grant date. Restricted stock awards granted 
to  employees  at  or  above  the  manager  level  generally  vest 
33.3% on the second anniversary of the grant date, 33.3% on 
the  third  anniversary  of  the  grant  date,  and  33.3%  on  the 
fourth anniversary of the grant date.

the  grant  date,  33.3%  on 

Summary of Restricted Stock Activity

The following table summarizes our restricted stock activity 
for the years ended December 31, 2021, 2020 and 2019:

Restricted Stock

Number of Awards

Weighted-Average 
Grant Date Fair 
Value

Unvested at December 31, 
2018
Granted
Vested
Forfeited
Unvested at December 31, 
2019

Granted

Vested

Forfeited
Unvested at December 31, 
2020

Granted
Vested

Forfeited
Unvested at December 31, 
2021

1,583,375  $ 
605,033 
(548,588)   
(153,064)   

1,486,756  $ 

743,300 

(499,357)   

(91,648)   

1,639,051  $ 

507,745 
(541,603)   

(138,853)   

68.62 
85.03 
61.45 
73.99 

77.38 

89.93 

72.95 

81.17 

84.21 

151.56 
83.34 

102.11 

1,466,340  $ 

106.16 

As of December 31, 2021, $81 million of total unrecognized 
compensation cost related to restricted stock is expected to be 
recognized over a weighted-average period of 1.8 years.

PSUs  are  based  on  performance  measures  that  impact  the 
amount  of  shares  that  each  recipient  will  receive  upon 
vesting.  Prior  to  April  1,  2020,  we  had  two  performance-
based  PSU  programs  for  certain  officers,  a  one-year 
performance-based  program  and  a  three-year  cumulative 
performance-based  program  that  focuses  on  TSR.  Effective 
April 1, 2020, to better align the equity programs for eligible 
officers, 
the  one-year  performance-based  program  was 
eliminated  and  all  eligible  officers  now  participate  in  the 
three-year cumulative performance-based program. While the 
performance periods are complete for all PSUs granted under 
the  one-year  performance-based  program,  some  shares 
underlying these PSUs have not vested.

One-Year PSU Program

The  grant  date  fair  value  of  PSUs  under  the  one-year 
performance-based  program  was  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 received 
a target grant of PSUs, but could have received from 0.0% to 
150.0%  of  the  target  amount  granted,  depending  on  the 
achievement  of  performance  measures.  These  awards  vest 
three-year  period 
ratably  on  an  annual  basis  over  a 
commencing  with  the  end  of  the  one-year  performance 
period.  Compensation  cost 
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. 

recognized  over 

is 

Three-Year PSU Program

individual 

receives  PSUs,  subject 

Under  the  three-year  performance-based  program,  each 
eligible 
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 award issuance 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  award  issuance  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. 

F-31

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Grants  of  PSUs  that  were  issued  in  2019  with  a  three-year 
performance  period  exceeded  the  applicable  performance 
parameters. As a result, an additional 289,307 units above the 
original  target  were  granted  in  the  first  quarter  of  2022  and 
were fully vested upon issuance.

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  for  the 
years ended December 31, 2021 and 2020:

Year Ended December 31,

2021

2020

Weighted-average risk free 
interest rate

Expected volatility
Weighted-average grant date 
share price
Weighted-average fair value 
at grant date

$ 

$ 

 0.33 %

 30.30 %

 0.27 %

 27.40 %

155.63 

218.24 

$ 

$ 

92.34 

111.50 

In the table above:

• 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; and 

• 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.

Summary of PSU Activity

The  following  table  summarizes  our  PSU  activity  for  the 
years ended December 31, 2021, 2020 and 2019:

PSUs

One-Year Program

Three-Year Program

Weighted-
Average 
Grant 
Date Fair 
Value

Number of 
Awards

Weighted-
Average 
Grant 
Date Fair 
Value

Number of 
Awards

  314,231  $  74.01 

837,750    $  96.57 

  179,599 
  83.56 
 (147,984)    70.64 
  (28,595)    75.43 

397,553 
  96.55 
(431,751)    93.25 
(6,101)    103.29 

  317,251  $  80.87 

797,451    $  98.31 

  26,780 

  84.17 

320,328 

  107.42 

 (138,423)    78.09 

(300,767)    81.57 

Unvested at 
December 
31, 2018

Granted
Vested
Forfeited

Unvested at 
December 
31, 2019

Granted

Vested

Forfeited

  (36,060)    82.41 

(7,023)    98.26 

Unvested at 
December 
31, 2020

Granted

Vested

  169,548  $  83.33 

809,989  $ 108.12 

— 

  — 

360,569 

  175.98 

  (99,764)    82.99 

(392,727)    116.86 

Forfeited

  (20,050)    83.29 

(13,707)    142.29 

Unvested at 
December 
31, 2021

  49,734  $  84.03 

764,124  $ 135.04 

In  the  table  above,  the  granted  amount  includes  additional 
awards  granted  based  on  overachievement  of  performance 
parameters as well as target awards.

As  of  December  31,  2021,  $1  million  of  total  unrecognized 
compensation  cost  related  to  the  one-year  PSU  program  is 
expected to be recognized over a weighted-average period of 
1.0  year.  For  the  three-year  PSU  program,  $43  million  of 
total  unrecognized  compensation  cost  is  expected  to  be 
recognized over a weighted-average period of 1.4 years. 

F-32

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Stock Options 

ESPP

A  summary  of  stock  option  activity  for  the  years  ended 
December 31, 2021, 2020 and 2019 is as follows:

Number of 
Stock Options

Weighted-
Average 
Exercise 
Price

Outstanding at December 31, 2018

  448,966  $  49.25 

Exercised

Forfeited

(69,699)   

(165)   

20.84 

25.28 

Outstanding at December 31, 2019

  379,102  $  54.32 

Exercised

Forfeited
Outstanding and exercisable at 

December 31, 2020

Exercised

Forfeited
Outstanding and exercisable at 
December 31, 2021

(85,195)   

(554)   

23.91 

20.94 

  293,353  $  63.22 

(24,409)   

(127)   

25.28 

25.28 

  268,817  $  66.68 

The  net  cash  proceeds  from  the  exercise  of  24,409  stock 
options  for  the  year  ended  December  31,  2021  was  $1 
million.  The  net  cash  proceeds  from  the  exercise  of  85,195 
stock options for the year ended December 31, 2020 was $2 
million.  The  net  cash  proceeds  from  the  exercise  of  69,699 
stock options for the year ended December 31, 2019 was $2 
million.

As  of  December  31,  2021,  the  aggregate  pre-tax  intrinsic 
value of the outstanding and exercisable stock options in the 
above  table  was  $39  million  and  represents  the  difference 
between  our  closing  stock  price  on  December  31,  2021  of 
$210.01  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.  As  of  December  31,  2021,  the  weighted-
average  remaining  contractual  term  of  the  outstanding  and 
exercisable stock options included in the above table was 5.0 
years. 

The  total  pre-tax  intrinsic  value  of  stock  options  exercised 
was  $3  million  for  the  year  ended  December  31,  2021,  $9 
million for the year ended December 31, 2020 and $6 million 
for the year ended December 31, 2019. 

We  have  an  ESPP  under  which  approximately  4.2  million 
shares  of  our  common  stock  were  available  for  future 
issuance  as  of  December  31,  2021.  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 expense associated with the ESPP for 
the years ended December 31, 2021, 2020 and 2019:

Year Ended December 31,

2021

2020

2019

Number of shares 
purchased by 
employees
Weighted-average price 
of shares purchased
Compensation expense 
(in millions)

  201,758 

  221,123 

  229,172 

$  124.24  $  95.79  $  73.79 

$ 

7  $ 

5  $ 

4 

12. NASDAQ STOCKHOLDERS' EQUITY

Common Stock

As  of  December  31,  2021,  300,000,000  shares  of  our 
common  stock  were  authorized,  173,418,939  shares  were 
issued  and  166,679,635  shares  were  outstanding.  As  of 
December  31,  2020,  300,000,000  shares  of  our  common 
stock  were  authorized,  171,278,761  shares  were  issued  and 
164,933,678  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 
shareholder 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 
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.  If  treasury  shares  are  reissued,  they  are  recorded  at 
the  average  cost  of  the  treasury  shares  acquired.  We  held 
6,739,304  shares  of  common  stock  in  treasury  as  of 
December 31, 2021 and 6,345,083 shares as of December 31, 
2020,  most  of  which  are  related  to  shares  of  our  common 
tax 
stock  withheld 
withholding obligations arising from the vesting of restricted 
stock and PSUs. 

the  settlement  of  employee 

for 

F-33

 
 
 
 
 
 
 
Share Repurchase Program

Preferred Stock

April 21, 2021

July 21, 2021

0.54 

0.54 

Year Ended 
December 31, 2021

October 20, 2021

0.54 

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,  2021  and  December  31,  2020,  no  shares  of 
preferred stock were issued or outstanding.

Cash Dividends on Common Stock

During 2021, our board of directors declared and paid the 
following cash dividends:

Declaration Date

Dividend 
Per
Common 
Share

Record Date

Total 
Amount 
Paid

(in millions)

January 27, 2021

$  0.49 

March 12, 
2021

$ 

Payment 
Date

March 26, 
2021

June 25, 
2021

September 
24, 2021

December 
17, 2021

81 

89 

90 

June 11, 
2021

September 
10, 2021

December 
3, 2021

90 

350 

$ 

The  total  amount  paid  of  $350  million  was  recorded  in 
retained earnings within Nasdaq's stockholders' equity in the 
Consolidated Balance Sheets at December 31, 2021. 

In  January  2022,  the  board  of  directors  approved  a  regular 
quarterly cash dividend of $0.54 per share on our outstanding 
common  stock.  The  dividend  is  payable  on  March  25,  2022 
to  shareholders  of  record  at  the  close  of  business  on  March 
11,  2022.  The  estimated  amount  of  this  dividend  is  $90 
million.  Future  declarations  of  quarterly  dividends  and  the 
establishment of future record and payment dates are subject 
to approval by the board of directors.

The  board  of  directors  maintains  a  dividend  policy  with  the 
intention to provide stockholders with regular and increasing 
dividends as earnings and cash flows increase.

As discussed in “2021 Divestiture,” of Note 4, “Acquisitions 
and  Divestiture,”  on  June  16,  2021,  our  board  of  directors 
authorized an increase to our share repurchase program to an 
aggregate authorized amount of $1.5 billion. As of December 
31,  2021,  the  remaining  aggregate  authorized  amount  under 
the existing share repurchase program was $926 million.

transactions,  block  purchase 

These  repurchases  may  be  made  from  time  to  time  at 
prevailing market prices in open market purchases, privately-
negotiated 
techniques,  an 
accelerated  share  repurchase  program  or  otherwise,  as 
determined  by  our  management.  The  repurchases  are 
primarily  funded  from  existing  cash  balances.  The  share 
repurchase  program  may  be  suspended,  modified  or 
discontinued at any time, and has no defined expiration date.

The following is a summary of our share repurchase activity, 
excluding the repurchases done through our ASR agreement 
described  below,  reported  based  on  settlement  date,  for  the 
year ended December 31, 2021:

Number of shares of common stock 
repurchased

Average price paid per share 

Total purchase price (in millions)

2,911,208 

160.87 

468 

$ 

$ 

In  the  table  above,  the  number  of  shares  of  common  stock 
repurchased  excludes  an  aggregate  of  394,221  shares 
withheld  upon  the  vesting  of  restricted  stock  and  PSUs  for 
the year ended December 31, 2021.

As discussed above in “Common Stock in Treasury, at Cost,” 
shares  repurchased  under  our  share  repurchase  program  are 
currently retired and cancelled.

ASR Agreements

In  July  2021,  we  entered  into  an  ASR  agreement  to 
repurchase  $475  million  of  common  stock.  We  received  a 
total  delivery  of  2,431,212  shares  of  common  stock  and 
completed  the  ASR  program  during  the  fourth  quarter  of 
2021.  The  ASR  agreement  was  entered  into  pursuant  to  our 
$1.5  billion  share  repurchase  authorization  as  discussed  in 
"Share Repurchase Program," above.

On  January  26,  2022  we  announced  that  we  entered  into 
an  ASR  agreement  to  repurchase  $325  million  of  common 
stock and received an initial delivery of 1,533,923 shares of 
common stock. The final number of shares to be repurchased 
will  be  based  on  the  volume-weighted  average  price  of  the 
Company’s  common  stock  during  the  term  of  the  ASR 
agreement,  less  a  discount  and  subject  to  adjustments 
pursuant  to  the  terms  of  the  ASR  agreement.  The  final 
settlement of the ASR agreement is expected to be completed 
in  the  first  quarter  of  2022.  At  settlement,  our  counterparty 
may be required to deliver additional shares of common stock 
to us, or, under certain circumstances, we may be required to 
deliver  shares  of  our  common  stock  or  may  elect  to  make  a 
cash payment to our counterparty.

F-34

 
 
 
 
 
 
 
 
 
 
 
13. EARNINGS PER SHARE

14. FAIR VALUE OF FINANCIAL INSTRUMENTS

The following table sets forth the computation of basic and 
diluted earnings per share:

The following tables present our financial assets and financial 
liabilities  that  were  measured  at  fair  value  on  a  recurring 
basis as of December 31, 2021 and December 31, 2020.

Year Ended December 31,

2021

2020

2019

(in millions, except share and per share amounts)

$ 

1,187  $ 

933  $ 

774 

 165,899,459 

 164,415,191 

 164,931,628 

Numerator:

Net income 
attributable to 
common 
shareholders

Denominator:

Weighted-average 
common shares 
outstanding for 
basic earnings per 
share

Weighted-average effect of dilutive securities:

Employee equity 
awards

Contingent 
issuance of 
common stock

Weighted-average 
common shares 
outstanding for 
diluted earnings 
per share

2,463,063 

2,135,532 

1,679,922 

— 

353,218 

358,611 

 168,362,522 

 166,903,941 

 166,970,161 

Basic and diluted earnings per share:
Basic earnings per 
share

7.15  $ 

$ 

5.67  $ 

4.69 

Diluted earnings 
per share

$ 

7.05  $ 

5.59  $ 

4.63 

In the tables above: 

• Employee equity awards from our PSU program, 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. 

• For  the  years  ended  December  31,  2020  and  2019,  the 
contingent  issuance  of  common  stock  was  related  to  a 
contingent obligation associated with a business we sold in 
June  2021.  See  “2021  Divestiture,”  of  Note  4, 
“Acquisitions and Divestiture,” 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, 2021, 2020 and 2019. 

December 31, 2021

Total

Level 1

Level 2

Level 3

(in millions)

$  144  $  144  $  —  $  — 

20 

  — 

20 

  — 

11 

  — 

11 

  — 

21 

12 

  — 

  — 

21 

12 

  — 

  — 

European 

government debt 
securities
Corporate debt 
securities
State owned 

enterprises and 
municipal 
securities

Swedish mortgage 

bonds

Time deposits
Total assets at fair 

value

$  208  $  144  $ 

64  $  — 

December 31, 2020

Total

Level 1

Level 2

Level 3

(in millions)

$  156  $  156  $  —  $  — 

2 

  — 

2 

  — 

15 

  — 

15 

  — 

22 

  — 

22 

  — 

European 

government debt 
securities
Corporate debt 
securities

State owned 

enterprises and 
municipal 
securities

Swedish mortgage 

bonds

Total assets at fair 

value

$  195  $  156  $ 

39  $  — 

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  and  cash 
equivalents,  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  6, 
“Investments,” for further discussion.

F-35

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
We  also  consider  our  debt  obligations  to  be  financial 
instruments.  As  of  December  31,  2021,  the  majority  of  our 
debt obligations were fixed-rate obligations. We are exposed 
to  changes  in  interest  rates  as  a  result  of  borrowings  under 
our 2020 Credit Facility, as the interest rates on this facility 
have  a  variable  rate  depending  on  the  maturity  of  the 
borrowing  and  the  implied  underlying  reference  rate.  As  of 
December 31, 2021, we had no outstanding borrowings under 
our 2020 Credit Facility. We are also exposed to changes in 
interest rates as a result of the amounts outstanding from the 
sale  of  commercial  paper  under  our  commercial  paper 
program.  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  $5.9 
billion  as  of  both  December  31,  2021  and  2020.  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  as  of 
December  31,  2021  approximated  the  carrying  value  since 
the  rates  of  interest  on  this  short-term  debt  approximated 
market  rates.  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  9, 
“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,  2021  and  December  31,  2020,  there  were  no 
non-financial assets measured at fair value on a non-recurring 
basis.

15. 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. 

include 

the  resale  and  repurchase  market, 

Through  our  clearing  operations  in  the  financial  markets, 
which 
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  three  member  sponsored  default 
funds:  one  related  to  financial  markets,  one  related  to 
commodities markets and one related to the seafood market. 
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. As of September 1, 2021, the mutualized 
default  fund  has  been  eliminated  and  the  default  fund 
structure 
“Default  Fund 
Contributions”  below  for  further  discussion  of  Nasdaq 
Clearing’s  default  fund.  A  power  of  assessment  and  a 
liability waterfall have also been implemented to further align 
risk between Nasdaq Clearing and its clearing members. See 
“Power  of  Assessment”  and  “Liability  Waterfall”  below  for 
further discussion.

segregated.  See 

fully 

is 

Nasdaq Commodities Clearing Default 

In  September  2018,  a  member  of  the  Nasdaq  Clearing 
commodities  market  defaulted  due  to  the  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  market  spread.  Nasdaq  Clearing 
followed default procedures and offset the future market risk 
on the defaulting member’s positions. 

Immediately  following  the  event,  Nasdaq  Clearing  launched 
a  comprehensive  enhancement  program  to  strengthen  the 
resilience and robustness of the clearinghouse.

F-36

In  December  2018,  the  SFSA  initiated  a  review  of  Nasdaq 
Clearing.  In  January  2021,  the  SFSA  issued  a  warning 
combined  with  an  administrative  fine  of  approximately  $33 
million  (SEK  300  million)  to  Nasdaq  Clearing  based  on  its 
review. Nasdaq Clearing appealed the SFSA´s decision to the 
Administrative  Court.  In  December  2021,  the  court  rejected 
Nasdaq  Clearing’s  appeal  and  upheld  the  decision  of  the 
SFSA.  In  January  2022,  Nasdaq  Clearing  appealed  this 
decision  to  the  Administrative  Court  of  Appeal.  While  we 
continue to firmly believe in the merit of our appeal, due to 
the  recent  decision  by  the  Administrative  Court,  we  have 
determined  it  is  appropriate  to  record  an  accrual  for  the  full 
amount  of  the  administrative  fine  issued  by  the  SFSA.  The 
charge is included in regulatory expense in our Consolidated 
Statements of Income for the year ended December 31, 2021. 

Default Fund Contributions and Margin Deposits

As  of  December  31,  2021,  clearing  member  default  fund 
contributions and margin deposits were as follows:

December 31, 2021

Cash 
Contributions

Non-Cash 
Contributions

Total 
Contributions

(in millions)

$ 

$ 

771  $ 

109  $ 

880 

5,140 

6,614 

11,754 

5,911  $ 

6,723  $  12,634 

Default fund 

contributions

Margin deposits

Total

Of  the  total  default  fund  contributions  of  $880  million, 
Nasdaq Clearing can utilize $804 million as capital resources 
in the event of a counterparty default. The remaining balance 
of $76 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 highly rated European 
government debt securities with original maturities primarily 
1 year or less, reverse repurchase agreements and multilateral 
development  bank  debt  securities.  Investments  in  reverse 
repurchase  agreements  range  in  maturity  from  4  days  to  14 
days and are secured with highly rated government securities. 
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 
$5,911 million as of December 31, 2021 and $3,942 million 
as of December 31, 2020, in accordance with its investment 
policy as follows:

December 31, 2021 December 31, 2020

Demand deposits

Central bank certificates
Restricted cash and cash 
equivalents
European government debt 
securities
Reverse repurchase 
agreements
Multilateral development 
bank debt securities
Investments

Total

$ 

$ 

$ 
$ 

(in millions)

3,061  $ 

2,013 

2,086 

1,111 

5,074  $ 

3,197 

414 

152 

271 
837  $ 
5,911  $ 

470 

180 

95 
745 
3,942 

In  the  table  above  the  change  from  December  31,  2020  to 
December 31, 2021 includes currency translation adjustments 
of  $321  million  for  restricted  cash  and  cash  equivalents  and 
$40 million for investments.

For  the  years  ended  December  31,  2021,  2020  and  2019 
investments related to default funds and margin deposits, net 
includes  purchases  of  investment  securities  of  $(41,098) 
$(38,203)  million, 
million, 
respectively,  and  proceeds  from  sales  and  redemptions  of 
investment securities of $40,966 million, $54,155 million and 
$38,029 million, respectively.

$(54,046)  million 

and 

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 
reverse 
repurchase  agreement  to  high  quality  issuers,  primarily 
government 
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.

the  acceptable  collateral  under 

securities  and  other 

the 

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  maintained  in  demand  deposits 
held  at  central  banks  and  large,  highly  rated  financial 
institutions  or  invested  by  Nasdaq  Clearing,  in  accordance 

F-37

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
with its investment policy, either in central bank certificates, 
highly  rated  government  debt  securities,  reverse  repurchase 
agreements  with  highly  rated  government  debt  securities  as 
collateral,  or  multilateral  development  bank  debt  securities. 
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. 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,  2021,  Nasdaq 
Clearing  committed  capital  totaling  $138  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

risk  management 

framework,  which 

Nasdaq  Clearing  manages  risk  through  a  comprehensive 
is 
counterparty 
comprised  of  policies,  procedures,  standards  and  financial 
resources.  The  level  of  regulatory  capital  is  determined  in 
accordance  with  Nasdaq  Clearing’s  regulatory  capital  and 
default  fund  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.

is 

the 

legal 
As  mentioned  above,  Nasdaq  Clearing 
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, 2021.

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 
230.0%  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 
the  defaulting  clearing  member’s 
default  occurs  and 

F-38

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 $44 million as of December 31, 2021;

• 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;

• 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; and

• fully  segregated  senior  capital  for  each  specific  market 
contributed  by  Nasdaq  Clearing,  calculated  in  accordance 
with  clearinghouse  rules,  which  totaled  $24  million  as  of 
December 31, 2021.

If additional funds are needed after utilization of the liability 
waterfall,  or  if  part  of  the  waterfall  has  been  utilized  and 
needs to be replenished, 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 $70 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  presents  the  market  value  of  derivative 
contracts outstanding prior to netting:

Commodity and seafood options, futures 
and forwards
Fixed-income options and futures

Stock options and futures

Index options and futures

Total

In the table above: 

December 31, 2021

(in millions)

$ 

$ 

282 
291 

147 

80 

800 

• 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.

• We determined the fair value of our futures contracts based 
upon  quoted  market  prices  and  average  quoted  market 
yields.

• We  determined  the  fair  value  of  our  forward  contracts 
using  standard  valuation  models  that  were  based  on 

market-based observable inputs including benchmark rates 
and the spot price of the underlying instrument.

Derivative Contracts Cleared

The  following  table  presents  the  total  number  of  derivative 
contracts  cleared  through  Nasdaq  Clearing  for  the  years 
ended December 31, 2021 and 2020:

December 31, 2021

December 31, 2020

Commodity and seafood 
options, futures and 
forwards
Fixed-income options and 
futures

536,252 

672,219 

23,140,918 

21,299,713 

Stock options and futures

20,308,811 

19,757,733 

Index options and futures

37,860,187 

51,371,391 

Total

81,846,168 

93,101,056 

In the table above, the total volume in cleared power related 
to  commodity  contracts  was  813  Terawatt  hours  (TWh)  and 
956 TWh for the years ended December 31, 2021 and 2020, 
respectively.

Resale 
Outstanding and Cleared

and  Repurchase  Agreements  Contracts 

The  outstanding  contract  value  of  resale  and  repurchase 
agreements  was  $139  million  and  $253  million  as  of 
December 31, 2021 and 2020, respectively. The total number 
of  resale  and  repurchase  agreements  contracts  cleared  was 
6,070,414  and  4,832,504  for  the  years  ended  December  31, 
2021 and 2020, respectively .

16. LEASES

We  have  operating  leases  which  are  primarily  real  estate 
leases predominantly 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

December 31, 
2021

December 31, 
2020

(in millions)

Assets:
Operating lease 
assets

Operating 
lease assets

$ 

366  $ 

381 

Liabilities:
Current lease 
liabilities

Non-current 
lease 
liabilities
Total lease 
liabilities

Other current 
liabilities

Operating 
lease 
liabilities

$ 

37  $ 

46 

386 

389 

$ 

423  $ 

435 

F-39

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table summarizes Nasdaq's lease cost: 

17. INCOME TAXES

Income Before Income Tax Provision

The  following  table  presents  the  domestic  and  foreign 
tax  provision:
components  of 

income  before 

income 

Year Ended December 31,

2021

2020

2019

(in millions)

Domestic

$  1,299  $ 

898  $ 

235 

314 

691 

328 

$  1,534  $  1,212  $  1,019 

Foreign
Income before income tax 
provision

Income Tax Provision

The income tax provision consists of the following amounts:

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

Year Ended December 31,

2021

2020

2019

(in millions)

$  144  $  114  $  120 

45 

64 

50 

74 

40 

50 

  253 

  238 

  210 

82 

22 

37 

6 

(10)   

(2)   

94 

41 

27 

7 

1 

35 

Total income tax provision

$  347  $  279  $  245 

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, 
2021,  the  cumulative  amount  of  undistributed  earnings  in 
these  subsidiaries  is  $286  million.  Given  our  intent  and 
ability  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.

Operating lease cost

Variable lease cost

Sublease income

Total lease cost

Year Ended December 31,

2021

2020

2019

(in millions)

$ 

85  $ 

85  $ 

28 

26 

79 

23 

(4)   

(4)   

(5) 

$  109  $  107  $ 

97 

In  the  table  above,  operating  lease  costs  include  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 Sheets.

2022

2023

2024

2025

2026

2027+

Total lease payments

      Less: interest
Present value of lease liabilities

December 31, 2021

(in millions)

$ 

$ 

52 

57 

52 

39 

36 

293 

529 

(106) 
423 

In the table above, interest is calculated using the interest rate 
for  each  lease.  Present  value  of  lease  liabilities  include  the 
current portion of $37 million.

Total lease payments in the table above exclude $168 million 
of  legally  binding  minimum  lease  payments  for  a  ten  year 
lease signed but not yet commenced.

The following table provides information related to Nasdaq's 
lease term and discount rate:

Weighted-average remaining lease term 
(in years)

Weighted-average discount rate

December 31, 2021

11.4

 3.8 %

The  following 
information related to Nasdaq's operating leases:

table  provides  supplemental  cash  flow 

Year Ended December 31,

2021

2020

2019

(in millions)

Cash paid for amounts included in 
the measurement of operating lease 
liabilities

$  77  $  77  $  78 

Lease assets obtained in exchange 
for new operating lease liabilities

$  45  $ 100  $  26 

F-40

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2021, 2020 and 2019 is as 
follows:

Federal income tax provision at 
the statutory rate
State income tax provision, net 
of federal effect

Excess tax benefits related to 
employee share-based 
compensation

Year Ended December 31,

2021

2020

2019

 21.0 %  21.0 %  21.0 %

 3.9 %  4.2 %  4.1 %

 (1.3) %  (0.6) %  (0.5) %

Non-U.S. subsidiary earnings

 0.3 %  0.5 %  1.0 %

Tax credits and deductions
Change in unrecognized tax 
benefits

Other, net

 (0.3) %  (0.2) %  (0.2) %

 0.6 %  (0.6) %  (0.1) %

 (1.6) %  (1.3) %  (1.3) %

Actual income tax provision

 22.6 %  23.0 %  24.0 %

The majority of the decrease in our effective tax rate in 2021 
compared to 2020 was due to a tax benefit related to federal, 
state  and  local  provision  to  return  adjustments,  which  is 
included  in  “Other,  net”  in  the  table  above.  The  majority  of 
the  decrease  in  our  effective  tax  rate  in  2020  compared  to 
2019  was  the  result  of  favorable  audit  settlements  and 
remeasurement  of  our  deferred  inventory,  which  is  included 
in “Other, net” in the table above. 

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:

Deferred tax assets:

Deferred revenues

U.S. federal net operating loss

Foreign net operating loss

State net operating loss

Compensation and benefits

Federal benefit of uncertain tax positions

Operating lease liabilities

Unrealized losses

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
Amortization of acquired intangible assets 
and goodwill

Investments

Operating lease assets

Other

Gross deferred tax liabilities

Net deferred tax liabilities

Reported as:

Non-current deferred tax assets
Deferred tax liabilities, net

Net deferred tax liabilities

December 31,

2021

2020

(in millions)

$  12  $ 

  — 

4 

1 

28 

6 

99 

2 

34 

8 

3 

4 

2 

28 

5 

97 

54 

39 

  186 

  240 

(4)   

(3) 

$  182  $  237 

$  (65)  $  (55) 

  (322)    (499) 

(99)   

(77) 

(84)   

(86) 

(16)   

(19) 

$ (586)  $ (736) 

$ (404)  $ (499) 

$ 
3 
2  $ 
  (406)    (502) 

$ (404)  $ (499) 

In  the  table  above,  non-current  deferred  tax  assets  are 
included  in  other  non-current  assets  in  the  Consolidated 
Balance Sheets.

As  of  December  31,  2021  and  2020,  we  recognized  a 
valuation  allowance  of  $4  million  and  $3  million, 
respectively,  due  to  recurring  operating  losses  in  a  foreign 
jurisdiction.  Based  on  all  available  positive  and  negative 
evidence, we believe the sources of future taxable income are 
sufficient  to  realize  the  remainder  of  Nasdaq's  deferred  tax 
asset inventory.

F-41

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

December 31, 2021

Expiration Date

Foreign NOL

State NOL

(in millions)

$ 

4  No expiration

1  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

Ending balance

Year Ended December 31,

2021

2020

2019

(in millions)
$  42  $  48  $  52 

  16 

9 

  10 

  11 

2 

1 

(6)   

(6)    (10) 

(6)    (11)   

(5) 

$  57  $  42  $  48 

We  had  $57  million  of  unrecognized  tax  benefits  as  of 
December  31,  2021,  $42  million  as  of  December  31,  2020, 
and  $48  million  as  of  December  31,  2019  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 was a $2 million tax benefit for 
both the years ended December 31, 2021 and 2020, and a tax 
provision  of  $3  million  for  2019.  Accrued  interest  and 
penalties,  net  of  tax  effect  were  $4  million  as  of  December 
31, 2021 and $8 million as of December 31, 2020.

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.  Our  Federal  income  tax  return  for  the  years 
2018 through 2020 is subject to examination by the Internal 
Revenue Service. Several state tax returns are currently under 
examination  by  the  respective  tax  authorities  for  the  years 
2012  through  2019.  Non-U.S.  tax  returns  are  subject  to 
examination  by  the  respective  tax  authorities  for  the  years 
2015  through  2020.  We  regularly  assess  the  likelihood  of 
jurisdiction  and  have 
additional  assessments  by  each 
established  tax  reserves  that  we  believe  are  adequate  in 
relation 
for  additional  assessments. 
Examination  outcomes  and  the  timing  of  examination 
settlements are subject to uncertainty. Although the results of 

the  potential 

to 

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.

18.  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 15, 
“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 
$5 million as of December 31, 2021 and December 31, 2020. 
As  discussed  in  “Other  Credit  Facilities,”  of  Note  9,  “Debt 
Obligations,”  we  also  have  credit  facilities  primarily  related 
to  our  Nasdaq  Clearing  operations,  which  are  available  in 
multiple currencies, and totaled $212 million as of December 
31,  2021  and  $232  million  as  of  December  31,  2020  in 
available liquidity, none of which was utilized.

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  15, 
“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.

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-42

 
 
 
 
 
 
Legal and Regulatory Matters 

Armenian Stock Exchange Investigation

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  ATS.  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,  leading  the  parties  to  commence  the  discovery 
process. Discovery, focused on issues of whether the case can 
be  certified  as  a  class  action  and  whether  the  plaintiffs’ 
claims  are  precluded  by  federal  securities  regulation,  ended 
on  April  26,  2021,  and  potentially  dispositive  motions 
regarding these issues were filed on May 28, 2021. 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.

As disclosed in our prior filings with the SEC, a former non-
U.S. subsidiary of Nasdaq, NASDAQ OMX Armenia OJSC, 
operated  the  Armenian  Stock  Exchange  and  the  Central 
Depository  of  Armenia,  which  are  regulated  by  the  Central 
Bank  of  Armenia  under  Armenian  law.  In  accordance  with 
the requirements of Armenian law, Mellat Bank SB CJSC, an 
Armenian  entity  that  is  designated  under  Executive  Order 
13382,  was  a  market  participant  on  the  Armenian  Stock 
Exchange and, as a result, paid participation and transaction 
fees to the Armenian Stock Exchange during the period from 
2012-2014. In 2014, we voluntarily self-disclosed this matter 
to  the  U.S.  Department  of  Treasury’s  Office  of  Foreign 
Assets  Control,  or  OFAC,  and  received  authorization  from 
OFAC  to  continue,  if  necessary,  certain  activities  pertaining 
to Mellat Bank SB CJSC in Armenia in a limited manner. In 
2015,  Nasdaq  sold  a  majority  of  its  ownership  of  Nasdaq 
OMX  Armenia  OJSC,  with  the  remaining  minority  interest 
sold in 2018. 

OFAC  has  been  conducting  an  inquiry  into  the  Armenian 
Stock  Exchange  matter  described  above  and  in  our  prior 
filings  since  2016,  and  during  the  first  quarter  of  2021,  we 
were  advised  that  OFAC  is  considering  a  civil  monetary 
penalty  in  connection  with  that  matter.  We  are  currently  in 
discussions with OFAC.

While  we  believe  our  decision  to  voluntarily  self-report  this 
issue and our continued cooperation with OFAC, along with 
the  permit  we  received  from  OFAC  in  connection  with  our 
transactions involving the Armenian Stock Exchange, will be 
mitigating  factors  with  respect  to  the  matter,  any  monetary 
fines  or  restrictions  may  nonetheless  be  material  to  our 
financial results in the period in which they are imposed. We 
cannot  currently  predict  when  our  discussions  with  OFAC 
will  conclude  or  the  amount  of  any  potential  penalties 
imposed. Accordingly, we are unable to reasonably estimate 
any  potential  loss  or  range  of  loss  and  we  have  not  accrued 
for a loss contingency.

Nasdaq Commodities Clearing Default

In  December  2021,  we  recorded  a  charge  related  to  an 
administrative  fine  issued  by  the  SFSA  associated  with  the 
default  which  occurred  in  2018.  The  charge  is  included  in 
regulatory expense in our Consolidated Statements of Income 
for  the  year  ended  December  31,  2021.  See  “Nasdaq 
Commodities  Clearing  Default,”  of  Note  15,  “Clearing 
Operations,” for further information.

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.

F-43

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 17, 
“Income Taxes,” for further discussion.

19. BUSINESS SEGMENTS

We manage, operate and provide our products and services in 
four  business  segments:  Market  Technology,  Investment 
Intelligence,  Corporate  Platforms  and  Market  Services.  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, 
2021, 2020 and 2019:

Market Technology

(in millions)

Year Ended December 31,

2021

2020

2019

Total revenues

Depreciation and 
amortization

Operating income

Purchase of property and 
equipment

Investment Intelligence
Total revenues

Depreciation and 
amortization

Operating income

Purchase of property and 
equipment

Corporate Platforms
Total revenues

Depreciation and 
amortization

Operating income

Purchase of property and 
equipment

Market Services

Total revenues

$ 

463  $ 

357  $ 

338 

111 

46 

48 

1,076 

62 

694 

44 

613 

31 

247 

30 

33 

32 

43 

898 

57 

572 

52 

521 

34 

187 

30 

30 

54 

40 

768 

52 

480 

30 

490 

34 

177 

27 

3,707 

3,818 

2,616 

Transaction-based expenses

(2,466)   

(2,722)   

(1,723) 

Revenues less transaction-
based expenses

1,241 

1,096 

Depreciation and 
amortization

Operating income

Purchase of property and 
equipment

Corporate Items

Total revenues

Depreciation and 
amortization
Operating income (loss)

Consolidated
Total revenues

Transaction-based expenses
Revenues less transaction-
based expenses
Depreciation and 
amortization

73 

800 

41 

27 

1 

76 

685 

63

31 

2 

893 

72 

508 

30

46 

2 

(346)   

(242)   

(202) 

$  5,886  $  5,625  $  4,258 

(2,466)   

(2,722)   

(1,723) 

$  3,420  $  2,903  $  2,535 

$ 

278  $ 

202  $ 

190 

Operating income

$  1,441  $  1,234  $  1,017 

Purchase of property and 
equipment

$ 

163  $ 

188  $ 

127 

F-44

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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  presented  in 
the table below, include the following:

the  day-to-day  operating  performance  of 

• 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 
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 
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.

• 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.  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:  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 20, “Restructuring Charges,” for further discussion of 
our  2019  restructuring  plan.  We  believe  performance 
measures 
charges  provide 
management with a useful representation of our segments' 
ongoing activity in each period.

restructuring 

excluding 

• Revenues  and  expenses  -  divested/contributed  businesses: 
We  have  included  in  corporate  items  the  revenues  and 
expenses  of  our  U.S.  Fixed  Income  business,  which  was 
previously included in our Market Services and Investment 
Intelligence  results.  See  “2021  Divestiture,”  of  Note  4, 
“Acquisitions  and  Divestiture,”  for  further  discussion  of 
this  divestiture.  Also  included  are  the  revenues  and 
expenses  associated  with  the  NPM  business  which  we 
contributed  to  a  standalone,  independent  company,  of 
which we own the largest minority interest, together with a 
consortium  of  third  party  financial  institutions  in  July 
2021.  Prior  to  July  these  revenues  were  previously 
included in our Corporate Platforms results. For 2019, we 
have  included  in  corporate  items  the  revenues  and 
expenses of the BWise business which was part of the IR 
&  ESG  Services  business  within  our  Corporate  Platforms 
segment as BWise was sold in March 2019. 

• 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. Other significant items include: 

◦ for the year ended December 31, 2021 a charge related to 
an  administrative  fine  imposed  by  the  SFSA  associated 
with  the  default  that  occurred  in  2018,  see  “Nasdaq 
Commodities  Clearing  Default,”  of  Note  15,  “Clearing 
Operations,”  for  further  discussion,  and  for  the  year 
ended  December  31,  2020  the  reversal  of  a  regulatory 
fine  issued  by  the  SFSA.  Both  charges  have  been 
included  in  regulatory  expense  in  the  Consolidated 
Statements of Income; 

◦ for  the  year  ended  December  31,  2020,  a  provision  for 
funding  of 

notes 
technology development for the consolidated audit trail; 

receivable  associated  with 

the 

◦ for  the  years  ended  December  31,  2021  and  2020,  a 

charge on extinguishment of debt; 

◦ for  the  year  ended  December  31,  2020,  charitable 
donations  made  to  the  Nasdaq  Foundation,  COVID-19 
response  and  relief  efforts,  and  social  justice  charities; 
and 

◦ for the years ended December 31, 2020, certain litigation 
costs  which  are  recorded  in  professional  and  contract 
services  expense  in  the  Consolidated  Statements  of 
Income.

The  above  charges  are  recorded  in  general,  administrative 
in  our 
and  other  expense,  unless  otherwise  noted, 
Consolidated Statements of Income. 

F-45

The following table summarizes our Corporate Items:

20. 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 retired certain 
elements  of  our  marketplace  infrastructure  and  technology 
product  offerings  as  we 
implement  NFF  and  other 
technologies  internally  and  externally.  This  represented  a 
fundamental  shift  in  our  strategy  and  technology  as  well  as 
executive  re-alignment.  In  June  2021,  we  completed  our 
2019 restructuring plan and recognized total pre-tax charges 
of $118 million over a two-year period. Total pre-tax charges 
related primarily to non-cash items such as asset impairments 
and accelerated depreciation, and third-party consulting costs. 
Severance and employee-related charges were also incurred. 

The  following  table  presents  a  summary  of  the  2019 
restructuring plan charges in the Consolidated Statements of 
Income  for  the  years  ended  December  31,  2021,  2020  and 
2019  which  primarily  consisted  of  consulting  services,  asset 
impairment  charges  primarily  related  to  capitalized  software 
that  was  retired,  and  accelerated  depreciation  expense  on 
certain assets as a result of a decrease in their useful life.

Year Ended December 31,

2021

2020

2019

(in millions)

Asset impairment charges 
and accelerated 
depreciation expense

$ 

4  $ 

14  $ 

26 

Consulting services

19 

22 

Contract terminations
Severance and employee-
related costs

Other

  — 

1 

7 

3 

3 

6 

2 

2 

8 

1 

Total restructuring charges $ 

31  $ 

48  $ 

39 

21. Subsequent Event

In  January  2022,  we  entered  into  an  ASR  agreement  to 
repurchase  $325  million  of  common  stock.  Refer  to  “ASR 
Agreements,” of Note 12, “Nasdaq Stockholders' Equity,” for 
further discussion. 

Revenues - divested/contributed 
businesses

Expenses:
Amortization expense of 
acquired intangible assets
Merger and strategic initiatives 
expense

Restructuring charges

Regulatory matters

Provision for notes receivable

  — 

Extinguishment of debt

Charitable donations
Expenses - divested/
contributed businesses

Other

Total expenses

Operating loss

Year Ended December 31,
2020

2019

2021

(in millions)

$ 

27  $ 

31  $ 

46 

170 

103 

101 

87 

31 

33 

33 

  — 

10 

9 

33 

48 

30 

39 

(6)    — 

6 

36 

17 

18 

18 

20 

11 

  — 

25 

22 

373 

273 

248 

$  (346)  $  (242)  $  (202) 

For further discussion of our segments’ results, see “Segment 
Operating  Results,”  of  “Item  7.  Management’s  Discussion 
and  Analysis  of  Financial  Condition  and  Results  of 
Operations.”
Geographic Data

The following table presents total revenues and property and 
equipment, net by geographic area for 2021, 2020 and 2019. 
Revenues  are  classified  based  upon  the  location  of  the 
customer.  Property  and  equipment  information  is  based  on 
the physical location of the assets. 

2021:
United States

All other countries

Total

2020:

United States

All other countries

Total

2019:

United States

All other countries

Total

Total
Revenues

Property and
Equipment, Net

 (in millions)

4,822  $ 

1,064 
5,886  $ 

4,662  $ 

963 

5,625  $ 

3,405  $ 

853 

4,258  $ 

$ 

$ 

$ 

$ 

$ 

$ 

325 

184 
509 

311 

164 

475 

250 

134 

384 

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 2021, 2020 
and 2019.

F-46