Quarterlytics / Financial Services / Financial - Data & Stock Exchanges / Nasdaq

Nasdaq

ndaq · NASDAQ Financial Services
Claim this profile
Ticker ndaq
Exchange NASDAQ
Sector Financial Services
Industry Financial - Data & Stock Exchanges
Employees 1001-5000
← All annual reports
FY2022 Annual Report · Nasdaq
Sign in to download
Loading PDF…
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

☐

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

For the fiscal year ended December 31, 2022

OR

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)

Name of each exchange on which registered

NDAQ
NDAQ33
NDAQ30
NDAQ29

The Nasdaq Stock Market
The Nasdaq Stock Market
The Nasdaq Stock Market
The Nasdaq Stock Market

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

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

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. ☒

If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction

of an error to previously issued financial statements. ☐

Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation received by any of the registrant’s

executive officers during the relevant recovery period pursuant to §240.10D-1(b). ☐

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, 2022, the aggregate market value of the registrant’s common stock held by non-affiliates of the registrant was approximately $17.2 billion (this amount represents

approximately 341.3 million shares of Nasdaq, Inc.’s common stock based on the last reported sales price of $50.53 of the common stock on The Nasdaq Stock Market on such date).

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

Class
Common Stock, $0.01 par value per share

Outstanding at February 13, 2023

489,002,956  shares

Documents Incorporated by Reference: Certain portions of the Definitive Proxy Statement for the 2023 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

Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections

Item 9C.

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 Accountant Fees and Services

Part IV.

Item 15. Exhibits and Financial Statement Schedules

Item 16. Form 10-K Summary

Page  

1

19

34

34

34

34

34

37

37

58

58

58

58

60

60

60

60

60

60

61

61

64

i

 
 
 
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.

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

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

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

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

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

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

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

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

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

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

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

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

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

unsecured notes, repaid in full and terminated in March 2022

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

2030  Notes:  €600  million  aggregate  principal  amount  of  0.875%  senior

unsecured notes due February 13, 2030

2031  Notes:  $650  million  aggregate  principal  amount  of  1.650%  senior

unsecured notes due January 15, 2031

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

2052  Notes:  $500  million  aggregate  principal  amount  of  3.950%  senior

unsecured notes due March 7, 2052

ARR: Annualized Recurring Revenue

ASC: Accounting Standards Codification

ASU: Accounting Standards Update

ASU 2016-13: Measurement of Credit Losses on Financial Instruments

ASR: Accelerated Share Repurchase

ATS: Alternative Trading System

AUM: Assets Under Management

AWS: Amazon Web Services

CAT:  A  market-wide  consolidated  audit  trail  established  under  an  SEC

approved plan by Nasdaq and other exchanges

CCP: Central Counterparty

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.

2020  Credit  Facility:  $1.25  billion  senior  unsecured  revolving  credit  facility,

which was replaced by the 2022 Credit Facility in December 2022

CFTC: U.S. Commodity Futures Trading Commission

EMIR: European Market Infrastructure Regulation

Equity Plan: Nasdaq Equity Incentive Plan

ESG: Environmental, Social and Governance

2022  Credit  Facility:  $1.25  billion  senior  unsecured  revolving  credit  facility,

ESPP: Nasdaq Employee Stock Purchase Plan

which matures on December 16, 2027

2022  Notes:  $600  million  aggregate  principal  amount  of  0.445%  senior

unsecured notes; repaid in full, at maturity, in December 2022

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

ii

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

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

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

FINRA: Financial Industry Regulatory Authority

FRAML: Fraud Detection & Anti-Money Laundering

IPO: Initial Public Offering

MiFID II: Update to the Markets in Financial Instruments Directive

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  2023  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

SOFR: Secured Overnight Financing Rate

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

U.S. Tape plans: U.S. cash equity and U.S. options industry data

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

iii

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

• the  performance  and  reliability  of  our  technology  and  technology  of  third

parties on which we rely;

• any significant systems failures or errors 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
increased  regulatory  oversight

the  securities  markets  generally,  or 
domestically or internationally.

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

Forward-Looking Statements

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

initiatives  and  strategies, 

• our strategic direction, including changes to our corporate structure;

• the  integration  of  acquired  businesses,  including  accounting  decisions

relating thereto;

• the  scope,  nature  or  impact  of  acquisitions,  divestitures,  investments,  joint

ventures or other transactional activities;

• the  effective  dates  for,  and  expected  benefits  of,  ongoing  initiatives,
transactional  activities  and  other  strategic,  restructuring,

including 
technology, ESG, 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; and

• any  litigation,  or  any  regulatory  or  government  investigation  or  action,  to
which  we  are  or  could  become  a  party  or  which  may  affect  us  and  any
potential settlements of litigation, regulatory or governmental investigations
or actions, including with respect to our CFTC investigation.

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

• loss  of  significant  trading  and  clearing  volumes  or  values,  fees,  market

share, listed companies, market data customers or other customers;

• our ability to develop and grow our non-trading businesses, including our

technology, analytics, ESG and anti-financial crime offerings;

• our  ability  to  keep  up  with  rapid  technological  advances  and  adequately

address cybersecurity risks;

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
enable clients to optimize and execute their business vision with confidence.

We manage, operate and provide our products and services in three business
segments:  Market  Platforms,  Capital  Access  Platforms  and  Anti-Financial
Crime.

In  2022,  we  announced  a  new  organizational  structure  which  aligns  our
businesses  more  closely  with  the  foundational  shifts  that  are  driving  the
evolution of the global financial system. In order to amplify our strategy, we
aligned the Company more closely with evolving client needs. As a result, we
have  identified  three  new  reporting  segments,  Market  Platforms,  Capital
Access Platforms and Anti-Financial Crime, which align to our new divisional
structure.

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.

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

Growth Strategy

To enable success in the evolving global financial system, we have established
our  purpose,  vision,  and  value  proposition  together  with  a  focused  growth
strategy:

Our Purpose: We advance economic progress for all.

Our Vision: We will be the trusted fabric of the world’s financial system.

Our Value Proposition: We deliver world-leading platforms that improve the
liquidity, transparency and integrity of the global economy.

Our  Strategy:  In  2017,  we  set  a  new  strategic  direction  focused  on
maximizing  the  resources,  people  and  capital  allocated  to  our  largest  growth
opportunities.  These  opportunities,  which  include  anti-financial  crime  and
marketplace  technology  solutions,  workflow  for  investment  managers  and
asset  owners  as  well  as  insight  solutions,  constituted  large  and  growing
opportunities where we felt our strengths in technology, analytics and capital
markets expertise, combined with our expansive client network, positioned us
to meet our clients’ evolving needs.

By  aligning  our  business  segments  against  these  secular  trends,  we  aim  to
deliver  more  for  our  clients  and  increase  growth  across  our  key  pillars  of
liquidity, transparency and integrity:

• Liquidity: Within our Market Platforms division, we continue to modernize
markets  by  utilizing  technology  to  maximize  the  liquidity  of  the  global
economy. New technologies, including cloud, blockchain, machine learning
and  artificial  intelligence,  present  significant  opportunities  to  further
enhance  market  resiliency  and  scalability  and  make  markets  even  more
accessible.  We  believe 
technologies  will  enable  more
these 
opportunities for market participants and new asset classes to be integrated
across  markets  globally.  We  brought  our  markets  and  market-related
technology  businesses  together,  aligning  complementary  capabilities  to
capture  the  potential  these  technologies  can  unlock  in  our  industry.  By
utilizing  the  division’s  position  at  the  center  of  markets,  we  believe  that
Market Platforms will be at the forefront of the financial system’s evolution
and  will  play  a  critical  role  in  advancing  the  modernization  of  markets
across geographies and asset classes.

that 

• Transparency: Our Capital Access Platforms division is uniquely placed to
help  clients  navigate  the  increasing  complexity  of  the  evolving  financial
system through access to capital and transparency which enables economic
growth.  With  over  10,000  corporate  clients  and  5,000  clients  across  the
investment  management  ecosystem,  Nasdaq  is  a  trusted  partner  to  aid  the
corporate and investment communities in making more informed decisions.
Leveraging  the  insights  and  capabilities  across  our  listings,  advisory,  data,
index,  and  analytics  teams,  we  believe  that  Capital  Access  Platforms  will
serve as a bridge between the investor and corporate communities, focused
on enhancing the client experience by providing efficient routes to capital,
delivering  more  holistic,  actionable  insights  and  intelligence,  modernizing
workflows, and navigating the climate and ESG landscape.

1

• Integrity:  Our  Anti-Financial  Crime  division  combines  Nasdaq's  fraud
detection, anti-money laundering, and surveillance businesses. This division
remains  focused  on  capturing  the  growth  associated  with  protecting  the
integrity of the financial system and fighting financial crime. The division
will continue its focus on delivering a world-class platform, leveraging the
power  of  the  cloud  and  machine  learning  across  asset  classes,  to  the  full
spectrum  of  banks  and  brokers,  including  the  emerging  ecosystem  of
financial technology, or FinTech, companies and digital banks.

Products and Services

Market Platforms

Our Market Platforms segment delivers world leading platforms that improve
the liquidity, transparency and integrity of the global economy by architecting
and operating the world's best markets.

Our Market Platforms segment includes our Trading Services and Marketplace
Technology businesses.

Trading Services

We  provide  trading  services  in  North  America  and  Europe.  In  the  U.S.,  we
operate  six  options  exchanges:  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.  Our  combined  options  market  share  in  2022  represented  the  largest
share  of  the  U.S.  market  for  multi-listed  equity  options.  Our  options  trading
platforms provide trading opportunities to 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.

We  also  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.

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

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

In 2022, we began migrating our North American markets to the AWS cloud-
computing platform in a phased approach as part of a partnership to build the
foundation of new capital markets. During the fourth quarter, we successfully
completed the migration of Nasdaq MRX to the cloud. We believe the shift to
cloud-based  markets  will  provide  our  exchanges  with  more  security,  greater
reliability,  better  scalability  and  the  ability  to  quickly  power  up  computing
resources.  This  will,  in  turn,  enable  Nasdaq  to  provide  its  clients  access  to
cloud-based  capabilities,  including  virtual  connectivity  services,  market
analytics and machine learning, at a lower cost.

In  Europe,  we  operate  exchanges  in  Tallinn  (Estonia),  Riga  (Latvia)  and
Vilnius (Lithuania) as Nasdaq Baltic and exchanges in Stockholm (Sweden),
Copenhagen (Denmark), Helsinki (Finland), and Reykjavik (Iceland) together
with the clearing operations of Nasdaq Clearing, as Nasdaq Nordic.

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-exchange  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.

In Europe, Nasdaq Nordic 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.

Nasdaq Fixed Income, or 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.

2

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

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

We also own a majority stake in Puro.earth, a Finnish-based leading platform
for carbon removal. Puro.earth offers engineered carbon removal instruments
that  are  verified  and  tradable  through  an  open,  online  platform.  Puro.earth’s
marketplace  capabilities  add  to  our  suite  of  ESG-focused  technologies  and
workflow  solutions  and  give  our  clients  further  resources  to  successfully
achieve their ESG objectives.

In  addition  to  our  trading  and  clearing  services  business  and  our  carbon
market  offering,  in  September  2022,  we  announced  our  planned  launch  of  a
new  digital  assets  business  to  power  the  digital  asset  ecosystem.  The  launch
to  advance  and  help  facilitate  broader
underpins  Nasdaq’s  ambition 
institutional  participation 
trusted  and
institutional-grade  solutions,  focused  on  enhanced  custody,  liquidity  and
integrity.  Nasdaq  Digital  Assets  will  initially  develop  an  advanced  custody
solution.  Nasdaq’s  offering  is  subject  to  regulatory  approval  in  applicable
jurisdictions.  Additionally,  we  expanded  our  anti-financial  crime  technology
with  new  coverage 
including  a
comprehensive  suite  of  crypto-specific  fraud  detection  capabilities  discussed
below in “Anti-Financial Crime.”

in  digital  assets  by  providing 

the  cryptocurrency  ecosystem, 

for 

Marketplace Technology

Marketplace  Technology  comprises  our  trade  management  services  and
market technology businesses.

Our trade management services business provides market participants with a
wide variety of alternatives for connecting to and accessing our markets for a
fee.  Our  marketplaces  may  be  accessed  via  a  number  of  different  protocols
used for quoting, order entry, trade reporting and connectivity to various data
feeds.  We  launched  WorkX  in  2021,  an  upgraded  version  of  Nasdaq  ACT
Workstation, a web-based, front-end interface that allows market participants
to  view  data,  utilize  risk  management  tools,  and  submit  and  review  trade
reports. WorkX enables a seamless workflow and enhanced trade intelligence.
All Workstation users were migrated to WorkX in 2022. In addition, we offer a
variety  of  add-on  compliance  tools  to  help  market  participants  comply  with
regulatory requirements.

3

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.

We  completed  the  previously  announced  wind-down  of  our  broker  services
operations  business  during  2022.  This  business  primarily  offered  technology
and customized securities administration solutions to financial participants in
the Nordic market. Such services and solutions primarily consisted of flexible
back-office  systems,  which  allowed  customers 
to  efficiently  manage
safekeeping,  settlement  and  corporate  actions  and  reporting,  and  included
connectivity to exchanges and central securities depositories.

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,  and  powers  over  120  market  infrastructure  operators  and  new
market  clients  in  more  than  55  countries.  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  by  non-capital  markets  customers,  including  those  in  insurance
liabilities  securitization,  cryptocurrencies  and  sports  wagering,  as  discussed
further below.

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.

During  2022,  we  continued  to  build  out  our  SaaS  business  portfolio  by
extending  and  migrating  our  current  offerings  to  SaaS,  where  we  added  11
new  SaaS  customers.  Our  market  technology  business  has  evolved  from  its
origins  serving  the  capital  markets,  as  we  have  leveraged  NFF,  our  flexible
and  modular  architecture  technology  that  provides  next  generation  capital
markets  capabilities  in  an  open  and  agile  environment,  to  develop  our  SaaS
platform and offerings. We expect to continue to expand adoption of this SaaS
model by our clients in the future.

For  market  infrastructure  operators,  which  include  exchanges,  regulators,
clearinghouses  and  central  securities  depositories,  we  provide  and  deliver
mission-critical solutions across the trade lifecycle via NFF, which 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  services
outside  of  the  traditional  capital  markets.  Our  market  technology  business
currently  offers  its  services  to  several  digital  assets  exchanges,  commercial
real estate markets, the reinsurance market and sports wagering operators. Our
Marketplace  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  Marketplace  Services  Platform  is
targeted  at  new  markets  and  enables  end-to-end  marketplace  implementation
without the resources required for on-premise solutions.

Numerous market technology projects involve complex delivery management
and  systems  integration.  Through  our  integration  services,  we  can  assume
responsibility  for  projects  that  involve  migration  to  a  new  system  and  the
establishment  of  entirely  new  marketplaces.  We  also  offer  operation  and
support  for 
the  applications,  systems  platforms,  networks  and  other
components  included  in  an  information  technology  solution,  as  well  as
advisory  services.  Our  successful  Nasdaq  MRX  migration  to  the  cloud,
discussed  above,  created  a  blueprint  for  our  Marketplace  Technology  clients
that will be used to demonstrate, guide and migrate their markets to the cloud,
as well as for our own future market migrations.

Capital Access Platforms

Our  Capital  Access  Platforms  segment  delivers  liquidity,  transparency  and
integrity  to  the  corporate  issuer  and  investment  community  by  empowering
our  clients  to  effectively  navigate  the  capital  markets,  achieve  their
sustainability  goals,  and  drive  governance  excellence.  As  we  operate  in  the
center  of  the  capital  markets  ecosystem,  we  are  able  to  serve  as  a  bridge
between investors and corporates focused on enhancing the client experience
by  providing  efficient  routes  to  capital,  delivering  more  holistic,  actionable
insights and intelligence, modernizing workflows, and navigating the climate
and  ESG  landscape.  We  offer  a  suite  of  products  to  assist  companies  in
managing  corporate  governance  standards,  discussed  below  in  Workflow  &
Insights.

Our Capital Access Platforms segment includes our Data & Listing Services,
Index and Workflow & Insights businesses.

Data & Listing Services

Our U.S. and European data products enhance transparency of market activity
within our exchanges and provide critical information to professional and non-
professional  investors  globally.  Our  Data  business  sells  and  distributes
historical  and  real-time  market  data  to  sell-side  customers,  the  institutional
investing  community,  retail  online  brokers,  proprietary  trading  firms,  and
other venues, as well as internet portals and data distributors.

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 to market participants and to data distributors who
in  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.

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 offer TotalView
products for our Nasdaq BX, Nasdaq PSX and Nordic markets. We also offer
Nordic  Equity  TotalView,  Nordic  Derivatives  TotalView  and  Nordic  Fixed
Income TotalView for 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  U.S.  equities  and  options  exchanges  and  Nordic  equities,
derivatives, fixed income, futures and commodities.

Additionally, our Nasdaq Cloud Data Service provides a flexible and efficient
method  of  delivery  for  real-time  exchange  data  and  other  financial
information.  Data 
through  a  suite  of  application
programming  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.

is  made  available 

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,
healthcare,  consumer  products,  telecommunication  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.

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.

4

As  of  December  31,  2022,  379  ETPs  listed  on  26  exchanges  in  over  20
countries  tracked  a  Nasdaq  index  and  accounted  for  $315  billion  in  AUM.
This  includes  approximately  $85  billion  in  ETP  AUM,  or  27%  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 $200 billion in assets tracking the index
as of December 31, 2022.

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.

Workflow & Insights

Our  Workflow  &  Insights  business  includes  our  analytics  and  corporate
solutions businesses.

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.

As of December 31, 2022, a total of 4,230 companies listed securities on The
Nasdaq  Stock  Market,  with  1,566  listings  on  The  Nasdaq  Global  Select
Market,  1,298  on  The  Nasdaq  Global  Market  and  1,366  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. The 2022 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

The Nasdaq Stock Market IPO win rates:

2022 total
Operating companies
SPACs

161

14
46
145

366

89 %
92 %
86 %

During 2022, we had 14 new listings resulting from companies switching their
listings  from  NYSE  or  NYSE  American  to  join  The  Nasdaq  Stock  Market.
Together with companies that transferred additional securities to The Nasdaq
Stock Market during 2022, an aggregate of $36 billion in global equity market
capitalization switched to The Nasdaq Stock Market.

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,  2022,  a  total  of  1,251  companies  listed
securities on our Nordic and Baltic exchanges.

Our  European  listing  customers  include  companies,  funds  and  governments.
Customers  issue  securities  in  the  form  of  cash  equities,  depository  receipts,
warrants,  ETPs,  convertibles,  rights,  options,  bonds  or  fixed-income  related
products. In 2022, a total of 63 new companies listed on our Nordic and Baltic
exchanges.  In  addition,  12  companies  upgraded  their  listings  from  Nasdaq
First North to Nasdaq Main Market.

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.

5

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.

Our corporate solutions business serves both public and private companies and
organizations 
through  our  Investor  Relations  Intelligence,  Governance
Solutions  and  ESG  Solutions  products.  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,  and  various  non-profit  organizations  to  hospitals  and  healthcare
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,
and consulting services. We also advise clients on a range of governance and
sustainability-related issues.

Our Investor Relations Intelligence offerings include a global team of expert
consultants  that  deliver  advisory  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.

Through our Governance Solutions products, we provide a global technology
offering and consulting services that streamline the meeting process for board
of  directors  and  executive  leadership  teams  and  enable  them  to  accelerate
decision  making  and  strengthen  governance.  Our  solutions  help  protect
sensitive  data  and  facilitate  productive  collaboration,  which  enables  board
members and teams to work faster and more effectively.

Our ESG Solutions includes our ESG Advisory practice and our ESG software
offering.  Our  ESG  Advisory  practice  helps  companies  analyze,  assess  and
action  best  practices  to  attract  long-term  capital.  Our  ESG  Software  offering
includes  OneReport,  a  SaaS  solution,  that  helps  organizations  navigate
corporate  responsibility  frameworks,  manage 
information  capture  and
response  process,  and  deliver  ESG  data  to  ratings  agencies  and  other
stakeholders.  In  June  2022,  we  acquired  Metrio  Software  Inc.,  or  Metrio,  a
cloud-based solution that helps firms manage ESG data, perform greenhouse
gas  emissions  calculations  and  accounting,  and  optimize  granular  data
collection, report publication and dashboarding against targets. Both solutions
support audit and assurance requirements.

Anti-Financial Crime

Our Anti-Financial Crime segment delivers leading platforms that improve the
integrity and transparency of the financial world by providing SaaS solutions
for fraud detection, anti-money laundering, and trade and market surveillance.

The  financial  services  industry  has  seen  a  growing  demand  for  products  and
services  focused  on  anti-financial  crime.  Our  FRAML  solution  provides  a
cloud-based platform to help detect, investigate, and report money laundering
and financial fraud to more than 2,300 financial institutions in North America.

Our  surveillance  solutions  include  a  SaaS  platform  designed  for  banks,
brokers and other market participants to assist in complying with market rules,
regulations and internal market surveillance policies and serves more than 170
clients. We also provide a solution to regulators and exchanges with a robust
platform  to  manage  cross-market,  cross-asset  and  multi-venue  surveillance.
This  offering  powers  surveillance  for  more  than  50  exchanges  and  15
regulators.

In  2022,  we  expanded  our  anti-financial  crime  technology  with  new
capabilities and coverage for the digital assets ecosystem, allowing us to play
a  central  role  in  combating  the  rising  threat  of  fraud,  money  laundering  and
market manipulation across the digital assets landscape.

Enablers, Differentiators and Competition

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  education  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.

6

Nasdaq's shift to utilizing and deploying cloud infrastructure continued during
2022. In the fourth quarter of 2022, we migrated Nasdaq MRX to the cloud,
which  is  the  first  exchange  moved  to  an  exclusively  cloud-enabled
infrastructure and the first exchange solely in the cloud of any regulated public
market  in  the  world.  We  believe  that  migrating  our  exchanges  to  the  cloud,
through our partnership with AWS, our preferred cloud provider, will result in
improved performance and increased flexibility for our customers. We expect
to move additional North American markets to the cloud with AWS during the
next  several  years.  The  shift  to  cloud-based  markets  will  enable  Nasdaq  to
provide  its  clients  access  to  cloud-based  capabilities,  including  virtual
connectivity services, market analytics and machine learning, at a lower cost.
We  also  expect  to  leverage  the  cloud-based  infrastructure  for  our  market
technology  clients,  assisting  such  clients  in  developing  their  own  platforms
and  customizing  their  offerings  for  their  local,  rapidly  changing  industry
dynamics.

To  facilitate  the  exchange  migration  to  AWS,  Nasdaq  will  also  leverage  its
Fusion  technology  platform.  Fusion  positions  Nasdaq’s  North  American  and
European markets to manage, operate and deploy a common platform that can
be  used  across  our  nine  Nasdaq  derivative  markets,  while  enabling  our
markets for cloud deployment.

We  continue  to  utilize  NFF  for  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 that ties 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,  NFF  enables  end  users  to
leverage recent technology developments.

Competitive Strengths

We  are  a  global,  client-focused  technology  company  with  expertise  in
markets.  We  deploy  robust  technology  capabilities  and  have  developed  a
leading anti-financial crime and corporate and investor franchise. Our business
segments complement each other and we believe that our strong competitive
position in large, high-growth markets positions us for sustained growth.

A Unique Value Proposition

We operate leading platforms that can improve the liquidity, transparency, and
integrity of the global economy, allowing us to:

• Develop  efficient  and  reliable  technologies  to  facilitate  and  protect  the

financial system across asset classes;

• Empower  our  clients  to  effectively  navigate  the  capital  markets,  achieve
their  sustainability  goals,  and  maintain  corporate  governance  excellence;
and

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

Technological Strength

The  strength  and  resiliency  of  our  technology,  enhanced  by  our  Marketplace
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 Across the Global Financial Ecosystem

We strive to serve a diverse range of clients that participate across the global
financial ecosystem, including:

• Brokers  and  Traders  -  Helping  brokers  and  traders  to  confidently  plan,

optimize and execute their business vision.

• Market  Participants  -  Providing  market  participants  with  access  to
liquidity  and  enabling  them  to  efficiently  consume,  monitor,  analyze,  and
capitalize on real-time market changes.

• Listed  Companies  -  Enabling  companies  to  access  capital  markets

effectively and manage stakeholders.

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

• Market  Infrastructure  Operators  -  Assisting  market  infrastructure
operators  in  increasing  efficiency,  meeting  customer  needs,  and  growing
revenue.

• Banks and Financial Institutions - Providing safety and integrity through
a suite of trade surveillance and cloud-native anti-financial crime solutions.

Competition

Market Platforms

We  face  intense  competition  in  North  America  and  Europe  for  our  Trading
Services  businesses.  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.

7

Traditionally,  exchanges  and  exchange-related  businesses  would  internally
develop technology, sometimes aided by consultants. However, this model has
gradually 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  business:  exchange
operators  and  technology  providers  unaffiliated  with  exchanges.  These
organizations  make  available  a  range  of  off-the-shelf  technology,  including
trading,  clearing,  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 enables us to compete with
other  companies  that  are  developing  cloud-based  exchanges  and  market
technology offerings.

Capital Access Platforms

Our  Data  business  includes  proprietary  data  products.  Proprietary  data
products  are  made  up  exclusively  of  data  derived  from  each  exchange’s
systems.  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  other  exchanges  and  third-party  vendors  to
provide  information  to  market  participants.  Examples  of  our  competitors  in
proprietary data products are ICE, Cboe, TSX, and Dow Jones & Company.

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.

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  BOX  Options  Market.  In  cash
equities  in  the  U.S.,  we  compete  with  exchanges  operated  by  Cboe,  ICE,
MIAX,  The  Investors  Exchange,  Members  Exchange  and  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.

Our U.S. Tape plans earn revenue from consolidated data products which are
distributed by SEC-mandated consolidators (one for Nasdaq-listed stocks and
another  for  NYSE  and  other-listed  stocks)  that  share  the  revenue  among  the
exchanges  that  contribute  data.  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.

In  Europe,  our  cash  equities  markets  compete  with  exchanges  such  as
Euronext  N.V.,  Deutsche  Börse  AG,  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  markets  in  Europe,  we  face  competition  from  other
broker-owned systems, dark pools, Systematic Internalizers, or SIs, and other
types  of  OTC  trading.  Competition  among  exchanges  for  trading  European
equity derivatives tends to occur where there is competition in the trading of
the  underlying  equities.  In  addition  to  exchange-based  competition,  we  face
competition from OTC derivative markets.

The  implementation  of  MiFID  II  and  MiFIR  has  resulted  in  further
competitive  pressure  on  our  European  trading  business.  SIs  are  attracting  a
significant share of electronically matched volume and 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.  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  Marketplace  Technology  business  includes  our  trade  management
services  and  market  technology  businesses.  Our  trade  management  services
business competes with other exchange operators, extranet providers, and data
center providers.

8

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.

Our Index business offers Nasdaq-branded indexes and financial products and
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.

Workflow  &  Insights 
includes  our  analytics  and  corporate  solutions
businesses.  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  analytics
business offerings compete with other analytics providers, including Addepar
and Caissa.

Our  corporate  solutions  business  faces  competition  that  can  be  varied  and
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. Our ESG Solutions, including
Nasdaq  OneReport,  Metrio  and  ESG  Advisory,  are  positioned  in  evolving
markets with competitors offering multiple point solutions providing software,
data  or  consulting  services.  The  competitive  landscape  for  our  Governance
Solutions  products  varies  by  customer  segment  and  geography.  Most
competitors offer SaaS solutions that are supported by a data centered strategy,
while  certain  firms  offer  specialized  services  that  focus  on  a  single  niche
segment.  Customers  frequently  seek  single-source  providers  that  are  able  to
address a broad range of needs within a single platform.

Anti-Financial Crime

For  our  Anti-Financial  Crime  segment,  which  includes  solutions  for  fraud
detection, anti-money laundering or AML and trade and market surveillance,
competitors  include  core  banking  solution  providers  ranging  from  small  to
large  independent  solution  providers,  FinTech  start-ups  and  in-house  custom
builds.  We  compete  against  enterprise  solution  providers  and  point  solutions
for  clients  with  larger  AUM.  Competitors  also  include  companies  that  serve
multiple industries in addition to financial services with generalized solutions,
such  as  business  intelligence  tools,  data  integrators,  investigation  platforms
and  software  covering  the  boarder  compliance  lifecycle.  Recently,  there  has
been  an  increase  of  FinTech  start-ups  shifting  into  the  surveillance,  fraud
detection  and  AML  space  offering  highly-specialized  solutions  for  advanced
data  analytics,  artificial  intelligence  and  machine  learning  technology.  The
anti-financial  crime  and  surveillance  offerings  compete  on  a  number  of
factors, including but not limited to, increased workflow efficiency, quality of
the data, quality of alerts and pricing.

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

Intellectual Property

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

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

9

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

Corporate Venture Program

We  operate  a  corporate  venture  program  to  make  minority  investments
primarily  in  emerging  growth  FinTech  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 in size
and  has  invested  in  companies  covering  various  sectors,  including  data,
analytics  and  workflow,  digital  assets,  market  infrastructure,  anti-financial
crime,  new  marketplaces,  enabling  technologies  and  ESG.  As  of  December
31,  2022,  our  investments,  which  include  equity  and  debt  investments,  were
valued at $180 million.

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  2022,  we  deepened  our
corporate  and  community  ESG  efforts,  including  furthering  our  commitment
to greater sustainability and climate change awareness.

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.

We  continued  to  be  committed  to  carbon  neutrality,  and  for  the  fifth
consecutive year, achieved that goal across all business operations through the
purchase  of  green  power,  carbon  offsets,  and  renewable  energy  certificates.
We were named to the Dow Jones Sustainability North America Index for the
seventh  consecutive  year  and  received  recognition  from  the  Bloomberg
Gender-Equity Index and The Human Rights Campaign’s Corporate Equality
Index.  In  addition,  Nasdaq’s  ESG  scores  improved  across  multiple  rating
agencies during 2022, including four significant sustainability rating upgrades:

• MSCI:  a  two-tier  rating  increase  to  “AA,”  from  our  “BBB”  rating  in  the

prior year, placing Nasdaq in MSCI’s “Leaders” category.

• CDP: a score improvement to an “A” from the prior year’s “B”, earning us a

place on CDP’s “A List” for climate disclosures and actions.

• EcoVadis:  status  upgrade  to  “Gold  Medal,”  a  recognition  reserved  for  the
top 5% of all rated companies, as compared to our “Silver Medal” status in
the prior year.

• 2022  S&P  Corporate  Sustainability  Assessment  (CSA):  a  score  of  60,
representing  an  20%  year-over-year  score  increase,  placing  Nasdaq  in  the
95th percentile of our industry group.

In 2022, Nasdaq also continued to be a signatory to the United Nations Global
Compact  and  the  United  Nations  Principles  of  Responsible  Investment  and
became  a  signatory  to  the  World  Economic  Forum  Stakeholder  Capitalism
Metrics.

While  our  business  operations  account 
for  a  comparatively  small
environmental  impact,  we  focus  our  environmental  efforts  on  several  key
areas,  including  the  way  we  use  energy  resources,  manage  our  workspaces,
engage our value chain 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.  Nasdaq  has  approved  near-term  and  long-term  science-
based emissions reduction targets with the Science Based Targets initiative, or
SBTi. In 2022, the SBTi verified Nasdaq’s 2050 net-zero science-based target.

th

Nasdaq  has  obtained  the  LEED  Platinum  certification  for  our  New  York
headquarters  office  in  Times  Square,  which  complements  the  LEED  Gold
certification for our 10   Floor  Client  Experience  Center,  our  space  for  client
events  in  our  New  York  headquarters.  We  also  achieved  LEED  Gold
certifications  for  our  new  Greensboro,  North  Carolina  office  and  existing
office locations in Copenhagen, Reykjavik, San Francisco, Stockholm, Umeå,
Vilnius and Washington, D.C. We continue to look for additional opportunities
to transition to green offices across the globe as part of our strategy to reduce
office operation-related emissions.

We help companies of all ESG maturity levels through our robust combination
of technology, tools, data, insights and capital market solutions. During 2022,
we  maintained,  and  continued  to  expand,  our  portfolio  of  ESG  services  and
solutions for our clients and stakeholders, including:

• the  Nasdaq  ESG  Advisory  Program,  which  pairs  companies  with  ESG
consulting  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
provides data to ratings agencies;

10

• the  Metrio  platform,  which  provides  tools  to  address  corporate  issuers’

Regulation

expanding ESG data collection, analytics, and reporting needs;

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

• 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 Nordic companies;

• the  Nasdaq  ESG  Footprint,  a  tool  that  helps  both  institutional  and  retail

investors analyze the impact of their portfolios;

• the  eVestment  ESG  Questionnaire,  which  provides  a  standard  approach  to
ESG  reporting  thereby  allowing  for  greater  transparency  into  how  ESG
strategies work, providing deeper ESG data for allocator consumption, and
enabling asset managers to better articulate their approach to ESG; and

• 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 2022, we requested our existing leading suppliers by spend to attest to our
updated  Supplier  Code  of  Ethics.  The  Supplier  Code  of  Ethics,  which  is
available  on  our  website,  encourages  our  suppliers  and  vendors  to  adopt
sustainability  and  environmental  practices  in  line  with  our  published
Environmental  Practices  Statement,  to  promote  a  diverse  and  inclusive
workforce  and  to  engage  diverse-owned  business  in  their  supply  chain.
Additionally, our new suppliers are required to attest to the Supplier Code of
Ethics in connection with the commencement of their engagement.

Effective August 8, 2022, Nasdaq’s new listing rule requires companies listed
on  our  U.S.  exchange  to  publicly  disclose  consistent,  transparent  diversity
statistics  regarding  their  board  of  directors  using  a  standardized  template.
Companies are also required to choose whether to meet recommended board
diversity objectives or disclose their reasons for not doing so under new listing
rules  effective  in  2023,  2025  and  2026  (depending  on  the  company’s  listing
tier and board size). The diversity rules are currently being challenged by two
advocacy groups in the U.S. Court of Appeals for the Fifth Circuit.

For more information regarding our ESG efforts in 2022, both internally and
externally,  please  see  the  section  entitled  “Human  Capital  Management”
below and our Proxy Statement.

U.S. Regulation

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

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

National Securities Exchanges. SROs in the securities industry are an essential
component  of  the  regulatory  scheme  of  the  Exchange  Act  responsible  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,  as  applicable.  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.

11

revisions 

including 

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, 
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,
enforcement  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. In 2019, Nasdaq received
SEC  approval  to  reclaim  from  FINRA  the  responsibility  and  opportunity  to
bring enforcement actions against member firms for violating certain Nasdaq
exchange rules governing conduct on the Nasdaq exchanges. 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 seeking to list their securities on The Nasdaq
Stock  Market  to  determine  whether  the  quantitative  and  qualitative  listing
standards  have  been  satisfied.  Once  securities  are  listed,  the  listing
qualifications  department  monitors  each  issuer’s  on-going  compliance  with
The Nasdaq Stock Market’s continued listing standards.

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

Our registered broker-dealers are subject to regulatory requirements intended
to  ensure  their  general  financial  soundness  and  liquidity,  which  require  that
they comply with certain minimum capital requirements. As of December 31,
2022, each of our broker-dealers were in compliance with all of the applicable
capital requirements.

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

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

12

• joint 

industry  agreements  with  FINRA  covering  responsibility  for

enforcement of insider trading rules;

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

• joint  industry  agreement  covering  enforcement  of  rules  related  to  options

sales practices.

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

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

The UTP Plan was filed with and approved by the SEC as a national market
system  plan  in  accordance  with  the  Exchange  Act  and  Regulation  NMS  to
provide  for 
the  collection,  consolidation  and  dissemination  of  such
information for Nasdaq-listed securities. The Nasdaq Stock Market serves as
the  processor  for  the  UTP  Plan  pursuant  to  a  contract  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  system,  hardware,  software  and
communications infrastructure to provide processing for the UTP Plan. As the
administrator,  The  Nasdaq  Stock  Market  manages  the  distribution  of  market
data, the collection of the resulting market data revenue, and the dissemination
of that revenue to plan members in accordance with the terms of the UTP Plan
and of Regulation NMS.

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
July 2022, the Court of Appeals vacated portions of the governance order that
would have provided voting rights to persons other than SROs. At this time,
the  SEC  has  not  directed  implementation  of  the  remaining  portions  of  the
governance order, but may do so in the future.

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, 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.  In  May  2022,  the  Court  of  Appeals  rejected  a
challenge  to  the  rule  brought  by  Nasdaq  and  several  other  exchanges.  In
September  2022,  the  SEC  disapproved  fees  proposed  by  Nasdaq  and  other
exchanges to implement the rule but did not direct exchanges to take further
action  to  implement  the  rule.  Accordingly,  a  schedule  for  implementing  the
rule has not been imposed 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.

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 compliance obligations, with the goals of reducing the occurrence of
technical  issues  that  disrupt  the  securities  markets  and  improving  recovery
time when disruptions occur. We  implemented  an  inter-disciplinary  program
to ensure compliance with Regulation SCI. We have also created Regulation
SCI  policies  and  procedures,  updated  internal  policies  and  procedures,  and
developed  an 
to  ensure
compliance.

technology  governance  program 

information 

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.

13

CFTC  Regulation.  The  Dodd-Frank  Wall  Street  Reform  and  Consumer
Protection  Act  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.

In addition, proposed rules under MiFID II and MiFIR rules are expected to
include  provisions  for  the  establishment  of  a  European  consolidated  tape  of
pre- and/or post-trade data. These rules may affect our ability to offer market
data products in the same manner as we currently provide such offerings.

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.

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

European Regulation

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

In  July  2016,  the  European  Union’s  Market  Abuse  Regulation,  which  is
intended  to  prevent  market  abuse,  entered  into  force.  MiFID  II  and  MiFIR
entered into force in January 2018 and primarily affect our European trading
businesses. Many of the provisions of MiFID II and MiFIR are implemented
through  technical  standards  drafted  by  the  European  Securities  and  Markets
Authority  and  approved  by  the  European  Commission.  In  addition,  in  2016,
the  European  Union  adopted  legislation  on  governance  and  control  of  the
production and use of benchmark indexes. The Benchmark Regulation applies
in the European Union from early 2018. However, due to transitional clauses
in the Benchmark Regulation, Nasdaq as a benchmark provider, did not need
to be in compliance with the Benchmark Regulation until January 1, 2020 in
relation to benchmarks provided by Nasdaq’s European subsidiaries, or until
January 1, 2026, 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 of the exchange market is carried out
by the Nasdaq Stockholm exchange, through its surveillance function.

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

With respect to ongoing operations, the SSMA requires exchanges to conduct
their activities in an honest, fair and professional manner, and in such a way as
to  maintain  public  confidence  in  the  securities  markets.  When  operating  a
regulated  market,  an  exchange  must  apply  the  principles  of  free  access  (i.e.,
that each person which meets the requirements established by law and by the
exchange may participate in trading), neutrality (i.e., that the exchange’s rules
for  the  regulated  market  are  applied  in  a  consistent  manner  to  all  those  who
participate  in  trading)  and  transparency  (i.e.,  that  the  participants  must  be
given  prompt,  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.

14

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

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

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.

We operate a licensed exchange, Nasdaq Oslo ASA, in Norway that trades and
lists commodity derivatives. Although Norway is not a member of the EU, as
a  result  of  the  European  Economic  Area,  or  EEA,  agreement  (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.

Confidence  in  capital  markets  is  paramount  for  trading  to  function  properly.
Nasdaq  Nordic  carries  out  market  surveillance  through  an  independent  unit
that  is  separate  from  the  business  operations.  The  surveillance  work  is
conceptually organized into two functions: one for the review and admission
of  listing  applications  and  surveillance  activities  related  to  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  in  Stockholm.  In  addition,  there  are  designated
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  four  years.  We  have  submitted  our  application  for
permanent recognition.

Human Capital Management

Nasdaq  has  continued  to  strengthen  our  commitment  to,  and  investment  in,
attracting, retaining, developing and motivating our employees during 2022.

In  2022,  we  introduced  the  Nasdaq  Culture  Book,  which  consolidates  and
explains Nasdaq’s culture, including Nasdaq’s vision and purpose; our values;
and  behavioral  attributes  that  we  believe  successful  employees  at  Nasdaq
share.  We  believe  that  being  clear  and  descriptive  regarding  our  culture
energizes and helps align employees, and also enables us to allow prospective
employment  candidates  to  better  understand  the  organization  they  are
considering joining.

We also continued to bolster our efforts to create a diverse and inclusive work
environment of equal opportunity, where employees feel respected and valued
for 
its  employees  have
opportunities  to  make  positive  contributions  to  our  local  communities.  See
“Diversity, Equity and Inclusion” below for further discussion of these efforts.

their  contributions,  and  where  Nasdaq  and 

As  of  December  31,  2022,  Nasdaq  had  6,377 full  and  part-time  employees,
including employees of non-wholly owned consolidated subsidiaries.

15

Employee Safety

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.  Our  employees  may  work  from  our  offices  or  work  from
home,  with  most  of  our  employees  continuing  to  utilize  a  hybrid  work
schedule of both working in an office and remotely during each week.

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.

Our  internal  employee  engagement  score,  based  on  our  biannual  employee
engagement  surveys,  increased  year-over-year  from  2021.  Our  workforce
voluntary  attrition  rate  during  2022  was  approximately  11%,  which  was
comparable to 2021.

Our  Talent  Attraction  Team  focused  on  strategic  marketing  and  branding  to
position  Nasdaq  as  a  leading  employer  of  choice  for  talent  in  our  industry,
helping to increase our pool of top candidates for open positions, particularly
diverse candidates. We ran targeted attraction campaigns in our major markets
using (with permission) local employee stories and photos, and partnered with
diverse talent organizations, such as the National Society of Black Engineers,
AfroTech,  the  Society  of  Women  Engineers,  Women  in  Technology,  Grace
Hopper  and  the  Society  of  Hispanic  Professional  Engineers  to  help  improve
brand awareness of Nasdaq and attract a higher number of diverse candidates
compared to 2021.

During  2022,  we  launched  a  year-long  series  called  the  Manager  Forum,
facilitated  by  our  CEO  and  other  senior  and  mid-career  leaders,  to  engage
managers in sustained leadership development, alongside our existing formal
leadership development curriculum.

We  also  launched  a  new  artificial  intelligence-driven  career  development
platform called the Career Hub that matches employees, based on their career
aspirations, to internal training, potential mentors, short-term projects and full-
time  internal  roles.  This  helped  us  increase  our  career  satisfaction  scores  in
our biannual employee engagement survey and supported employee retention.

We  have  invested  in  professional  development  for  our  employees,  including
offering  access  to  more  than  26,000  professional  development  programs;
providing  tuition  assistance  to  employees  enrolled  in  degree-granting
academic  programs;  holding  internal  career  fairs  and  career  development
programs;  connecting  employees  to  our  formal  mentoring  programs  and
providing one-on-one professional coaching opportunities. We welcomed 156
interns to Nasdaq during 2022.

To  reward  our  employees  at  various  stages  of  their  tenure  with  Nasdaq,  we
continued our anniversary recognition program that includes Nasdaq-branded
merchandise, and, for major milestones, recognition on our Nasdaq Tower in
Times  Square.  Additionally,  our  peer-to-peer  employee  recognition  program
rewards employees and highlights recognized employees on our internal social
media channels, further amplifying the recognition.

Diversity, Equity and Inclusion

At  Nasdaq,  three  pillars  guide  our  diversity,  equity  and  inclusion  efforts:
Workforce,  Workplace  and  Marketplace.  Workforce  seeks  to  ensure  that  our
employee  population  is  representative  of  the  communities  in  which  we
operate. Workplace seeks to create a positive, equitable workplace experience
for all employees of Nasdaq, and Marketplace aims to positively influence our
peers in the capital market ecosystem, and to invest in our local communities
in which we operate.

Nasdaq  sponsors  eleven  employee-led  internal  affinity  networks.  These
networks  include  more  than  2,400  employee  members,  representing  37%  of
our  employees  and  contractors.  Nasdaq’s  Employee  Networks  support  the
diverse  communities  that  comprise  our  workforce,  including  Black,  Asian
American,  Hispanic,  LGBTQ+, 
and
parent/caregiver  communities.  Nasdaq’s  Employee  Networks  provide  both
formal and informal development programs and guidance for their members.
The networks benefit the entire Nasdaq workforce through educational events,
guest speakers, and volunteering opportunities.

disabled, 

veteran, 

female, 

Nasdaq  regularly  and  proactively  reviews  and  monitors  diversity  data  across
its businesses, including workforce composition, talent pipeline, and sentiment
by  business  unit.  In  2022,  we  offered  two  diversity  trainings,  “Conscious
Inclusion”  and  “Inclusive  Leadership,”  for  non-managers  and  managers,
respectively.  All  of  our  executives  completed  this  course,  increasing
understanding  of  diversity  and  equity  priorities  at  the  highest  level.  We  also
added  customized  developmental  programs  for  underrepresented  talent,
including  executive  mentoring  and  accelerated  leadership  development
programs.  In  2022,  we  launched  a  high-potential  leadership  program  for  our
female  employees 
increase  advancement
opportunities.

their  skills  and 

to  enhance 

We  continue  to  seek  to  improve  our  diversity  metrics,  both  through
development  of  our  internal  talent  pool  and  by  focusing  on  interviewing
diverse  candidates  externally  for  new  employment  opportunities.  During  our
annual  executive  succession  planning  exercise  with  our  Board  of  Directors,
we realized a 26% increase, as compared to 2021, in the diversity of our senior
executive  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.  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.

16

Additionally,  Nasdaq  has  been  named  to  the  Human  Rights  Campaign
Corporate Equality Index, Coqual Black Equity Index, and several Seramount
indexes,  including  100  Best  Companies  and  Best  Companies  for  Dads.  We
were also named to the Bloomberg Gender Equality Index again in 2022.

Workplace Demographics

During 2022, we continued our progress to increase the diversity of our global
workforce.  Our  global  female  employee  base  increased  from  2021  and  has
grown each year since 2019, and in the United States, our minority employee
base  also  grew,  continuing  a  trend  since  2019.  Nasdaq  has  increased  our
underrepresented  minority  representation 
includes
Black/African  American,  Hispanic/Latino,  Multiracial,  Native  American,
Native  Hawaiian,  and  Pacific  Islander  employees,  from  14.9%  in  2019  to
16.8% in 2022.

the  U.S.,  which 

in 

Gender  and  Ethnicity  Performance  Data  as  of  December  31,  2022  and
2021

Gender:

17

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. In response to the
pandemic  we  introduced,  and  have  continued  to  offer,  additional  benefits  to
support  our  employees,  including  caregiver  support,  back-up  childcare,  “flex
days”  (extra  time  off  in  addition  to  vacation),  and  hybrid  work  schedules,
allowing our employees to focus on mental well-being.

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.  In  2022,  Nasdaq  employees  raised  over  $1  million  including
donations and matches, supporting almost 650 charities worldwide.

Nasdaq’s  “Purpose”  comprises  our  philanthropic,  community  outreach,
entrepreneurial support 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  2022,  Nasdaq  held  two  Purpose  roundtables,  which  convened
corporate  peers  from  companies  at  the  forefront  of  these  issues,  sharing
insights  on  the  importance  of  purpose  in  their  organization,  and  how  it  is
embedded  and  communicated  within  their  company  and  among  stakeholders
to drive impact.

Nasdaq  also  held  its  second  annual  “Purpose  Week”  to  further  champion
economic progress for all, which included a series of company-wide webinars,
volunteer  opportunities,  an  innovation  challenge  and  other  events  involving
and recognizing company employees. In addition to those events, we launched
a set of digital campaigns, accompanied by virtual conversations, spotlighting
several  of  the  Nasdaq  Foundation’s  community  partners.  These  discussions
explored 
for
underrepresented  communities  and  innovative  approaches  needed  to  tackle
investor identity as one of the overlooked barriers to partaking in the capital
markets.

topics  such  as  creating  a  stronger 

investor 

identity 

18

* In the charts above, not disclosed percentage includes employees that have

chosen not to disclose and race and ethnicities that are less than 0.3%.

In  2022,  we  conducted  a  pay  equity  analysis,  which  supplements  our  annual
multifaceted  compensation  review  program,  successfully  concluding  that
review in the second quarter of the year. Our pay equity analysis for 2023 has
already  begun  as  part  of  the  annual  compensation  review  program  to  be
completed in the same cycle next year.

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 grants. 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.

The  mission  of  the  Nasdaq  Foundation  is  focused  on  two  primary  goals:
reimagining  investor  engagement  to  equip  under-represented  communities
with  the  financial  knowledge  to  share  in  the  wealth  that  markets  create;  and
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.

During 2022, the Nasdaq Foundation provided 14 grants to organizations that
seek  to  fulfill  that  mission.  These  grants  were  awarded  to,  among  others,
Black  Girl  Ventures,  an  ecosystem  of  Black/Brown  woman-identifying
leaders,  assisting  them  through  the  early-stages  of  entrepreneurship;  Change
Labs, a community-led organization providing access to capital and resources
to  the  next  generation  of  Native  American  change  makers;  and  Hispanic
Access  Foundation,  which  provides  financial  and  investment  training  to
Spanish-speaking Latinos.

Nasdaq Website and Availability of SEC Filings

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

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  may  be  negatively
impacted. Adverse market conditions could reduce customer demand for our
services and the ability of our customers, lenders and other counterparties to
meet  their  obligations  to  us.  Poor  economic  conditions  may  result  in  a
reduction  in  the  demand  for  our  products  and  services,  including  our  market
technology, FRAML solutions, data, indexes and corporate solutions, or could
result in a decline in the number of IPOs, reduced trading volumes or values
and  deterioration  of  the  economic  welfare  of  our  listed  companies,  which
could cause an increase in delistings.

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  Platforms  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. The number of IPOs on our exchanges decreased in 2022
and the number of delistings increased compared to 2021.

Our  Capital  Access  Platforms  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.

19

There may be less demand for our corporate solutions, market technology and
FRAML  products  and  services  if  global  economic  conditions  remain  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.

Additionally,  during  a  global  economic  downturn,  or  periods  of  economic,
political or regulatory uncertainty, our sales cycle may become longer or more
unpredictable due to customer budget constraints or unplanned administrative
delays to approve purchases

A reduction in trading volumes or values, market share of trading, the number
of our listed companies, or demand for market technology or Capital Access
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  Platforms,  Capital  Access
Platforms  and  Anti-Financial  Crime  businesses 
from  other  market
participants.  We  face  intense  competition  from  other  exchanges  and  markets
for  market  share  of  trading  activity  and  listings.  This  competition  includes
both product and price competition.

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

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

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

We face intense price competition in all areas of our business. In particular, the
trading  industry  is  characterized  by  price  competition.  We  have  in  the  past
lowered  prices,  and  in  the  U.S.,  increased  rebates  for  trade  executions  to
attempt  to  gain  or  maintain  market  share.  These  strategies  have  not  always
been  successful  and  have  at  times  hurt  operating  performance.  Additionally,
we  have  also  been,  and  may  once  again  be,  required  to  adjust  pricing  to
respond  to  actions  by  competitors  and  new  entrants,  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.

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.  We  could  experience  a  systems
failure due to human error by our employees, contractors or vendors, electrical
or telecommunications failures or disruptions, hardware or software failures or
defects,  cyberattacks,  sabotage  or  similar  unexpected  events.  These
consequences could result in service outages, lower trading volumes or values,
financial  losses,  decreased  customer  satisfaction,  litigation  and  regulatory
sanctions.  Our  markets  and  the  markets  that  rely  on  our  technology  have
experienced  systems  failures  and  delays  in  the  past  and  could  experience
future systems failures and delays.

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

20

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

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

We intend to launch new products and initiatives and continue to explore and
pursue  opportunities  to  strengthen  our  business  and  grow  our  company.  We
may spend substantial time and money developing new products, such as our
digital  assets  offering,  initiatives  and  enhancements  to  existing  products.  If
these products and initiatives are not successful or their launches are delayed,
including  for  regulatory  uncertainty  related  to  our  digital  assets  offering,  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, including cloud-based infrastructure for certain
of our offerings. 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. We may allocate significant
amounts  of  cash  and  other  resources  to  product  technologies  or  business
models  for  which  market  demand  is  lower  than  anticipated.  In  addition,  the
introduction of new products by competitors, the emergence of new industry
standards or the development of entirely new technologies to replace existing
product offerings could render our existing or future products obsolete.

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

Trading  and  clearing  volumes  and  values  are  directly  affected  by  economic,
political  and  market  conditions,  broad  trends  in  business  and  finance,
unforeseen  market  closures  or  other  disruptions  in  trading,  the  level  and
volatility  of  interest  rates,  inflation,  changes  in  price  levels  of  securities  and
the  overall  level  of  investor  confidence.  Beginning  in  2020,  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 U.S. Tape plans business.

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

Our  systems  and  operations  are  vulnerable  to  damage  or  interruption  from
security breaches. As a result of our adoption of a hybrid work environment,
we  have  a  broader  and  more  distributed  network  footprint  and  increased
reliance  on  the  home  networks  of  employees,  and  such  remote  work  may
cause  heightened  cybersecurity  and  operational  risks.  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  of  human  error  or
malicious  activity  and  criminal  organizations  may  seek  to  profit  from  stolen
data.  Computer  malware,  such  as  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 and invest additional 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, or due to a cybersecurity breach of a customer that results in a
loss of our data or compromises our systems or those of our other customers
utilizing the same products, could damage our reputation and result in: a loss
of  customers;  disrupted  customer  relationships;  the  loss  of  our  intellectual
property or sensitive data; lower trading volumes

21

or values, incur significant liabilities or otherwise have a negative impact on
our  business,  our  products  and  services,  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. There can be no assurance we will be able to identify and
mitigate every incident involving cybersecurity attacks, breaches or incidents.
A system breach may go undetected for an extended period of time.

cybersecurity 

cybersecurity
regulations,  and 
Expanded 
infrastructure  and  compliance  costs,  may  adversely  impact  our  results  of
operations.

increased 

As cybersecurity threats continue to increase in frequency and sophistication,
and  as  the  domestic  and  international  regulatory  and  compliance  structure
related to information and cybersecurity; data privacy and data usage; and our
digital  assets  offering,  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
regulations  concerning
vulnerabilities.  Compliance  with 
cybersecurity, data privacy and data usage could result in significant expense,
and any failure to comply could result in proceedings against us by regulatory
authorities or other third parties. Additional costs for bolstering cybersecurity
capabilities,  and  increased  cybersecurity  and  data  privacy  compliance  costs,
could adversely impact our business, financial condition and operating results.
Additionally,  our  clients 
rigorous  contractual,
certification and audit provisions regarding cybersecurity, data protection and
data usage, which may also increase our overall compliance burden and costs
in meeting such obligations.

increasingly  demand 

laws  and 

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

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.

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,
including from companies that we acquire, 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 business
strategy  and  identify  and  pursue  strategic  opportunities  and  initiatives.  In
particular, we may have to incur costs to replace senior officers or other key
employees  who  leave,  and  our  ability  to  execute  our  business  strategy  could
be impaired if we are unable to replace such persons in a timely manner or at
all.

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

industry 

evolving 

standards, 

regulatory 

The  markets  in  which  we  compete  are  characterized  by  rapidly  changing
technology, 
frequent
and 
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

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
enforcement actions.

regulatory  consequences, 

litigation  or 

including 

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

22

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  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  financial  losses  from
defaults by our 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.

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

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

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

Nasdaq,  as  technology  provider  to  the  UTP  Operating  Committee,  has
implemented  measures  to  enhance  the  resiliency  of  the  existing  processor
system.  Nasdaq  transferred  the  processor  technology  platform  to  our  INET
platform  and  this  migration  further  enhanced  the  resiliency  of  the  processor
systems.  We  further  improved  the  systems'  resiliency  by  adding  the  UTP
SnapShot service. However, if 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,  new  listings  from  IPOs,
including SPACs, decreased in 2022. A prolonged decrease in the number of
listings,  or  failure  of  existing  SPACs  to  successfully  complete  transactions
with target companies and dissolve, could negatively impact the growth of our
revenues. Our Corporate Solutions business is also impacted by declines in the
listings  market  or  increases  in  acquisitions  activity  as  there  may  be  fewer
publicly-traded customers that need our products.

RISKS  RELATED  TO  TRANSACTIONAL  ACTIVITIES  AND
STRATEGIC RELATIONSHIPS

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

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

• difficulties, costs or complications in combining the companies’ operations,
including  technology  platforms,  which  could  lead  to  us  not  achieving  the
synergies we anticipate or customers not renewing their contracts with us as
we migrate platforms;

• incompatibility of systems and operating methods;

• reliance on, or provision of, transition services;

• inability  to  use  capital  assets  efficiently  to  develop  the  business  of  the

combined company;

• difficulties of complying with government-imposed regulations in the U.S.

and abroad, which may be conflicting;

• resolving  possible  inconsistencies  in  standards,  controls,  procedures  and

policies, business cultures and 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;

23

• 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;

providers  are  unavailable  to  us  for  any  reason,  or  there  are  cloud  service
disruptions or a delay or inability to access our exchanges, platforms or certain
of our cloud products or features, such unavailability or delays may adversely
affect our clients, which could significantly impact our reputation, operations,
business, and financial results.

• the coordination of geographically separate organizations;

• the  coordination  and  consolidation  of  ongoing  and  future  research  and

development efforts;

• possible tax costs or inefficiencies associated with integrating the operations

of a combined company;

• pre-tax restructuring and revenue investment costs;

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

• negative  impacts  on  employee  morale  and  performance  as  a  result  of  job

changes and reassignments.

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

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

For  example,  in  2022,  we  began  to  migrate  our  North  American  markets  to
AWS  in  a  phased  approach,  starting  with  Nasdaq  MRX  in  December  2022.
AWS  operates  a  platform  that  we  use  to  provide  services  to  our  clients,  and
therefore we are vulnerable to service outages on the AWS platform that affect
Nasdaq  workloads  running  or  stored  in  the  AWS  environment.  If  AWS  does
not deliver our system requirements on time, fails to provide maintenance and
support to our specifications or a migration experiences 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.

We also rely on members of our trading community to maintain markets and
add  liquidity.  To  the  extent  that  any  of  our  largest  members  experience
difficulties, materially change their business relationship with us or are 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, 2022, goodwill totaled $8.1 billion
and  intangible  assets,  net  of  accumulated  amortization,  totaled  $2.6  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 2022, 2021 and 2020.

24

We may experience future events that may result in asset impairments. Future
disruptions to our business, prolonged economic weakness, due to pandemics
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.

• 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

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

joint 

divesting businesses or assets;

• declines in the value of investments;

Over  the  past  several  years,  acquisitions  have  been  significant  factors  in  our
growth.  We  have  divested  businesses  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.  Other
potential  purchasers  of  assets  in  our  industry  may  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 to
additional  capital  requirements  in  certain  circumstances  and  financial  and
reputational risks if there are operational failures.

We  may  finance  future  transactions  by  issuing  additional  equity  and/or  debt.
The  issuance  of  additional  equity  in  connection  with  any  such  transaction
could  be  substantially  dilutive  to  existing  shareholders.  In  addition,  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  results  in  significant  incremental  leverage.  Additional  debt  may  reduce
our liquidity, curtail our access to financing markets, impact our standing with
credit  rating  agencies  and  increase  the  cash  flow  required  for  debt  service.
Any  incremental  debt  incurred  to  finance  a  transaction  could  also  place
significant constraints on the operation of our business.

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

• the inability to maintain key pre-transaction business relationships;

• increased operating costs;

• 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.

to  earnings  resulting  from  acquisitions, 

integrations  and
Charges 
restructuring costs may materially adversely affect the market value of our
common stock.

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

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

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

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

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

• we  may  incur  restructuring  costs  in  connection  with  the  reorganization  of

any of our businesses.

25

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 on our exchanges, broker-dealers,
central  securities  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.

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

Under current U.S. federal securities laws, changes in the rules and operations
of  our  securities  markets,  including  our  pricing  structure,  must  be  reviewed
and in many cases

explicitly  approved  by  the  SEC.  The  SEC  may  approve,  disapprove,  or
recommend  changes  to  proposals  that  we  submit.  In  addition,  the  SEC  may
delay  either  the  approval  process  or  the  initiation  of  the  public  comment
process.  Favorable  SEC  rulings  and  interpretations  can  be  challenged  in  and
reversed  by  federal  courts  of  appeals,  reducing  or  eliminating  the  value  of
such prior interpretations. 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.

In 2016, the SEC approved a plan for Nasdaq and other exchanges to establish
a CAT, to improve regulators’ ability to monitor trading activity. In addition to
increased regulatory obligations, implementation of a consolidated audit trail
has resulted in significant additional expenditures, including to implement the
new technology to meet any 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.  As  of
December  31,  2022,  we  have  accrued  a  net  receivable  of  $85  million  in
connection with our portion of expenses related to the CAT implementation. In
addition,  the  ongoing  failure  to  timely  launch  or  properly  operate  such
technology exposes Nasdaq and other exchanges to SEC fines.

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

26

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

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.

the  securities  markets, 

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 
including  market  structure,
technological oversight and fees for proprietary market data, connectivity and
transactions.  The  SEC,  FINRA  and  the  national  securities  exchanges  have
introduced  several  initiatives  to  ensure  the  oversight,  integrity  and  resilience
of  markets.  In  December  2022,  the  SEC  proposed  significant  rule  changes
that, if adopted in their current form, would substantially alter how stocks are
traded in the United States. While we and other market participants have the
opportunity  to  submit  comments  on  the  proposal,  and  we  will  adjust  our
business  model  in  accordance  with  any  new  SEC  regulations  implemented,
these  changes  regarding  trading  may  negatively  impact  our  business  and
revenue.

With respect to our regulated businesses, our business model can be severely
impacted  by  policy  decisions.  In  May  2020,  the  SEC  adopted  an  order  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.  In  2022,  the  U.S.  Court  of  Appeals  for  District  of
Columbia  Circuit  vacated  portions  of  the  governance  order  but  upheld  the
remainder of the SEC’s 2022 actions. If the remaining aspects of the order and
rule  are  fully  implemented,  they  may  adversely  affect  our  revenues.  The
timing for the implementation is currently unknown, and we believe they may
take two or more years to fully implement.

If the remaining aspects of the order and rule 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  for  professional  uses  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 rules and regulations promulgated
by regulatory agencies.

27

We face risks related to compliance with economic sanctions (including those
administered  by  the  U.S.  Office  of  Foreign  Assets  Control),  export  controls,
corruption  (including  the  U.S.  Foreign  Corrupt  Practices  Act)  and  money
laundering.  While  we  maintain  compliance  programs  to  prevent  and  detect
potential  violations,  such  programs  cannot  completely  eliminate  the  risk  of
non-compliance.  Because  anti-financial  crime  management 
solutions
comprises  one  of  our  primary  business  offerings,  a  significant  compliance
event involving one of these areas could more negatively impact our business
than a comparable business without this service offering.

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  business,  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.  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.

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

Our  business  operates  certain  systems  that  may  be  considered  “critical
infrastructure” under certain regulations and licenses or sells certain systems
or  services  to  customers  that  are  used  by  customers  to  fulfill  certain  core
business requirements or process certain sensitive data. In response to recent
events involving cybersecurity breaches, including ransomware

attacks,  regulatory  authorities  are  engaging  in  rulemaking  to  heighten
cybersecurity  requirements  and  obligations  to  notify  authorities  and/or  take
other action in response to a suspected incident. Such regulations may impact
the requirements and cost of delivery for impacted systems and services and,
in the event of an incident, increase the cost and complexity of our response
and  the  potential  financial  and  reputation  impact  from  fines  or  private
litigation.  New  regulations  may  also  impact  customer  decision  making  and
conditions on contracting for our services.

Our businesses and internal operations rely on the processing of data in many
jurisdictions  and  the  movement  of  data,  including  personal  data,  across
national  borders.  Legal  and  contractual  requirements  relating 
the
processing,  including,  but  not  limited  to,  collection,  storage,  handling,  use,
disclosure,  transfer  and  security,  of  personal  data  continue  to  evolve  and
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.

to 

Laws  and  regulations  such  as  the  European  Union  and  United  Kingdom
General Data Protection Regulation, or GDPR, the California Privacy Rights
Act,  or  CPRA,  and  other  comparable  laws  and  regulations  adopted  globally
and within the United States and Canada can apply to our processing of their
residents' personal data by Nasdaq legal entities regardless of the location of
such  entities;  such  laws  may  also  require  our  customers  located  in  such
jurisdictions to contractually obligate Nasdaq to comply.

In  addition  to  directly  applying  to  certain  Nasdaq  business  activities,  these
laws  and  industry-specific  regulations,  such  as  the  Health  Insurance
Portability and Accountability Act (HIPAA) and the Gramm Leach Bliley Act,
impact many of our customers, which may affect their decisions to purchase
our  services.  Under  certain  laws  and  regulations,  as  a  supplier  to  such
customers,  regulators  may  engage  in  direct  enforcement  actions  or  seek  to
impose  liability  on  Nasdaq  if  we  do  not  comply  with  them.  Our  efforts  to
comply with 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.  The  enactment  of  more  restrictive  laws,  rules  or
regulations,  future  enforcement  actions  or  investigations,  or  the  creation  of
new  rights  to  pursue  damages  could  impact  us  through  increased  costs  or
restrictions  on  our  business,  and  noncompliance  could  result  in  regulatory
penalties and significant legal liability.

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

Like other corporations, we are subject to taxes at the federal, state and local
levels, as well as in non-U.S. jurisdictions. Changes in tax laws, regulations or
policies could result in us having to pay higher taxes, which may reduce our
net income, or could adversely affect our ability to continue our

28

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

A  downgrade  of  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, 2022 was $5.4 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 and reliance on the capital markets 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 repayment of all amounts outstanding.

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

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

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

29

RISKS  RELATED  TO  INTELLECTUAL  PROPERTY  AND  BRAND
REPUTATION

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

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

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

• the quality and reliability of our technology platforms and systems;

• the ability to fulfill our regulatory obligations;

• the  ability  to  execute  our  business  plan,  key  initiatives  or  new  business

ventures and the ability to keep up with changing customer demand;

• the representation of our business in the media;

• the  accuracy  of  our  financial  statements,  other  financial  and  statistical

information or ESG-related disclosures;

• the accuracy of our financial guidance or other information provided to our

investors;

• the quality of our corporate governance structure;

• the quality of our products, including the reliability of our transaction-based,
Corporate  Services  and  marketplace  technology  products,  the  accuracy  of
the  quote  and  trade  information  provided  by  our  Data  &  Listing  Services
business and the accuracy of calculations used by our Indexes business for
indexes and unit investment trusts;

• the  quality  of  our  disclosure  controls  or  internal  controls  over  financial

reporting, including any failures in supervision;

• extreme price volatility on our markets;

• any negative publicity surrounding our listed companies 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  employees  or  other

persons formerly or currently associated with us.

risk 

to  our  brand  and 

Although  we  monitor  developments,  including  social  media,  for  areas  of
reputation,  negative  publicity  or
potential 
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.  This  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  or  switch  to  a
different exchange. Reputational damage may also reduce trading volumes or
values on our exchanges or cause us to lose customers in our Data & Listing
Services, Index, Workflow & Insights or Marketplace 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.

We generally mutually agree with our customers on the duration, budget and
costs  associated  with  the  implementation  of  certain  of  our  products,
particularly  our  market  technology  large-scale  market  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 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
satisfaction,  harm  to  our  reputation,  and  opportunities  for  competitors  to
displace  us,  each  of  which  could  have  an  adverse  effect  on  our  reputation,
business and results of operations.

Our  reputation  or  business  could  be  negatively  impacted  by  ESG  matters
and our reporting of such matters.

We  communicate  certain  ESG-related  initiatives,  goals,  and/or  commitments
regarding  environmental  matters,  diversity,  vendors  and  suppliers  and  other
matters  in  our  annual  Sustainability  Report,  Task  Force  on  Climate-related
Financial Disclosures, or TCFD, Report, on our website, in our filings with the
SEC,  and  elsewhere.  These  initiatives,  goals,  or  commitments  could  be
difficult to achieve and costly to implement. For example, in November 2022,
we  announced  our  commitment  to  achieve  net-zero  for  Scope  3  greenhouse
gas emissions by 2050, the achievement of which relies, in large part, on the
accuracy  of  our  estimates  and  assumptions,  on  the  engagement  of  our  value
chain  to  reduce  emissions  and  set  their  net-zero  targets,  and  procuring
renewable energy for our real estate and data center portfolios. We could fail
to  achieve,  or  be  perceived  to  fail  to  achieve,  this  or  other  ESG-related
initiatives, goals, or commitments. In addition, we could be criticized for the
timing, scope or nature of these initiatives, goals, or commitments, or for any
revisions to them. We could be subject to litigation or regulatory enforcement
actions regarding the accuracy, adequacy, or completeness of our ESG-related
disclosures.  Our  actual  or  perceived  failure  to  achieve  our  ESG-related
initiatives,  goals,  or  commitments  could  negatively  impact  our  reputation  or
otherwise materially harm our business.

30

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.

jurisdictions.  However,  effective 

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
trademark,
States  and  other  foreign 
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.

GENERAL RISK FACTORS

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

As  a  holding  company,  we  require  dividends  and  other  payments  from  our
subsidiaries  to  meet  cash  requirements.  Minimum  capital  requirements
mandated  by  regulatory  authorities  having  jurisdiction  over  some  of  our
regulated  subsidiaries  indirectly  restrict  the  amount  of  dividends  that  can  be
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,  or  if  regulators  or  counterparties  require  us  to  increase  capital
deployed in certain of our regulated subsidiaries, 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;

• inflation;

• 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; and

• the perceived attractiveness of the U.S. or European capital markets.

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.

31

Additionally,  since  borrowings  under  our  credit  facilities  bear  interest  at
variable rates and commercial paper is issued at prevailing interest rates, any
increase  in  interest  rates  on  debt  that  we  have  not  fixed  using  interest  rate
hedges will increase our interest expense, reduce our cash flow or increase the
cost  of  future  borrowings  or  refinancings.  Other  than  variable  rate  debt,  we
believe  our  business  has  relatively  large  fixed  costs  and  low  variable  costs,
which magnifies the impact of revenue fluctuations on our operating results.
As a result, a decline in our revenue may lead to a relatively larger impact on
operating results. A substantial portion of our operating expenses is related to
personnel  costs,  regulation  and  corporate  overhead,  none  of  which  can  be
adjusted quickly and some of which cannot be adjusted at all. Our operating
expense  levels  are  based  on  our  expectations  for  future  revenue.  If  actual
revenue  is  below  management’s  expectations,  or  if  our  expenses  increase
before  revenues  do,  both  revenues  less  transaction-based  expenses  and
operating results would be materially and adversely affected. Because of these
factors, it is possible that our operating results or other operating metrics may
fail  to  meet  the  expectations  of  stock  market  analysts  and  investors.  If  this
happens, the market price of our common stock may be adversely affected.

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

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

implementation.  Additionally, 

the 

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,  operating  results  and
financial condition.

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  regulators,  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  market
conditions, including trading volatility beyond historical levels, any of which
could  adversely  affect  our  business,  reputation,  financial  condition  and
operating results. Additionally, if the SEC or other federal regulatory agencies
impose  comprehensive  reporting  obligations  regarding  climate  change  on
public  companies,  there  may  be  a  decrease  in  new  listings  or  an  increase  in
delistings  of  our  listed  companies,  which  may  adversely  affect  our  business,
financial condition and operating results. Such new regulations, whether in the
U.S.  or  in  other  countries  in  which  we  operate,  could  also  cause  us  to  incur
additional compliance and reporting costs.

32

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

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  to  the  risk  inherent  in  the  international
environment.  Political,  economic  or  social  events  or  developments  in  one  or
more  of  our  non-U.S.  locations  could  adversely  affect  our  operations  and
financial results. Some locations, such as Lithuania, India and the Philippines,
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 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  east  coast  of  the  U.S.,  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 against 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  dividends  and  the
establishment  of  future  record  and  payment  dates  are  subject  to  approval  by
Nasdaq’s  board  of  directors.  The  board’s  determination  to  declare  dividends
will  depend  upon  our  profitability  and  financial  condition,  contractual
restrictions, restrictions imposed by applicable law and other factors that the
board  deems  relevant.  Based  on  an  evaluation  of  these  factors,  the  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.

33

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

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  have  reopened  all  our  global  offices  and  our  employees
have transitioned to a hybrid work environment. 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

For a description of our legal proceedings, if any, see “Legal and Regulatory
Matters  -  Litigation,”  of  Note  18,  “Commitments,  Contingencies  and
Guarantees,”  to  the  consolidated  financial  statements,  which  is  incorporated
herein by reference.

Item 4. Mine Safety Disclosures

Not applicable.

PART II

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

taken at annual meetings; and

Market Information

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

Our  common  stock  is  listed  on  The  Nasdaq  Stock  Market  under  the  ticker
symbol  “NDAQ.”  As  of  February  13,  2023,  we  had  approximately  209
holders of record of our common stock.

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.

Issuer Purchases of Equity Securities

Share Repurchase Program

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

34

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, 2022:

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

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

(a) 
Total Number of
Shares Purchased

(b) Average
Price Paid Per
Share

—  $

—  $

27,913  $

Period
October 2022
Share repurchase
program
Employee
transactions
November 2022
Share repurchase
program
Employee
transactions
December 2022
Share repurchase
program
Employee
transactions
Total Quarter Ended December 31, 2022
Share repurchase
program
Employee
transactions

56,480  $

84,624  $

231  $

—  $

—  $

— 

—  $

293 

59.76 

 N/A

 N/A

— 

—  $

293 

66.52 

 N/A

 N/A

— 

—  $

650 

61.76 

 N/A

 N/A

— 

—  $

61.11 

 N/A

650 

N/A

In the preceding table:

• N/A - Not applicable.

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

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

35

 
 
 
The  following  performance  graph  and  related  information  shall  not  be  deemed  “filed”  for  purposes  of  Section  18  of  the  Exchange  Act  or  incorporated  by
reference into any of our other filings under the Securities Act or the Exchange Act, except as shall be expressly set forth by specific reference in such filing.

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:

PERFORMANCE GRAPH

•
•
•
•
•

ASX Limited
B3 S.A.
Bolsas Mexicana de Valores, S.A.B. de C.V.
Cboe
CME Group Inc.

• Deutsche Börse AG
• Euronext N.V.
• Hong Kong Exchanges and Clearing Limited
• ICE
• Japan Exchange Group, Inc.

• LSE
• Singapore Exchange Limited
• TMX Group Limited

Peer Group

The figures represented below assume an initial investment of $100 in the common stock or index at the closing price on December 31, 2017 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 12/31/2017 in stock or index, including reinvestment of dividends.

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

Fiscal Year Ended December 31,

2017

2018

2019

2020

2021

2022

$

100  $
100 
100 
100 

108  $
97 
96 
112 

145  $
133 
126 
149 

$

183 
192 
149 
186 

293  $
235 
192 
208 

260 
159 
157 
184 

36

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, 2022 and December 31, 2021. Discussion of fiscal year
2021  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, 2021 and December 31, 2020 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, 2021, which was previously filed with the SEC on February 23,
2022, with the exception of certain discussions impacted by the new corporate
structure.

Business Segments

In September 2022, we announced a new organizational structure which aligns
our  businesses  more  closely  with  the  foundational  shifts  that  are  driving  the
evolution of the global financial system. The new corporate structure includes
three  business  segments:  Market  Platforms,  Capital  Access  Platforms  and
Anti-Financial Crime. All prior periods have been restated to conform to the
current  period  presentation.  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 three separate segments. See “Part I, Item 1.
Business” for additional discussion on recent developments and highlights.

Nasdaq's Operating Results

The following tables summarize our financial performance for the year ended
December  31,  2022  when  compared  to  the  same  period  in  2021  and  for  the
year  ended  December  31,  2021  when  compared  to  the  same  period  in  2020.
The  comparability  of  our  results  of  operations  between  reported  periods  is
impacted  by  the  acquisition  of  Verafin  in  February  2021.  See  “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.

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions, except per share amounts)

3,582  $

3,420  $

2,903 

4.7 %

17.8 %

2,018 

1,979 

1,669 

2.0 %

18.6 %

1,564 

1,441 

1,234 

8.5 %

16.8 %

1,125  $

1,187  $

933 

(5.2)%

27.2 %

2.26  $

2.35  $

1.86 

(3.8)%

26.3 %

0.78  $

0.70  $

0.65 

11.4 %

7.7 %

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.”

The following chart summarizes our ARR (in millions):

37

 
 
 
 
 
 
The  following  chart  summarizes  our  quarterly  annualized  SaaS  revenues  for
our  Solutions  Businesses,  which  are  comprised  of  the  Capital  Access
Platforms  and  Anti-Financial  Crime  segments  and 
the  Marketplace
Technology  business  within  the  Market  Platforms  segment,  for  the  three
months ended December 31, 2022, 2021 and 2020 (in millions):

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.  Also  excluded  are  contracts  that  are  signed  but  not  yet
commenced. ARR is 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:

▪

▪

▪

Anti-Financial Crime support and SaaS subscription contracts

Proprietary  market  data  subscriptions  and  annual  listing  fees
within  our  Data  &  Listing  Services  business,  index  data
subscriptions  and  guaranteed  minimum  on  futures  contracts
within  our  Index  business  and  subscription  contracts  under  our
Workflow & Insights business.
Market  technology  support  and  SaaS  subscription  contracts  as
well as trade management services contracts, excluding one-time
service requests.

38

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

Segment Operating Results

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

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

$

4,225  $

4,048  $

4,179 

4.4 %

(3.1)%

1,684 

1,568 

1,287 

7.4 %

21.8 %

306 
11 
6,226 

231 
39 
5,886 

116 
43 
5,625 

32.5 %
(71.8)%
5.8 %

99.1 %
(9.3)%
4.6 %

(2,092)

(2,168)

(2,028)

(3.5)%

6.9 %

(552)

(298)

(694)

85.2 % (57.1)%

$

3,582  $

3,420  $

2,903 

4.7 %

17.8 %

Market
Platforms
Capital Access
Platforms
Anti-Financial
Crime
Other revenues
Total revenues
Transaction
rebates
Brokerage,
clearance and
exchange fees
Total revenues
less
transaction-
based
expenses

The following charts present our Market Platforms, Capital Access Platforms
and Anti-Financial Crime segments as a percentage of our total revenues, less
transaction-based expenses.

39

 
 
 
 
 
 
 
 
 
 
 
 
 
 
40

MARKET PLATFORMS

The following tables present revenues from our Market Platforms segment:

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

U.S. Equity
Derivative
Trading
Revenues

$

1,252  $

1,367  $ 1,122 

(8.4)%

21.8 %

3,663  $

3,503  $

3,654 

4.6 %

(4.1)%

Section 31 fees

89 

32 

69 

178.1 %

(53.6)%

Trading Services $
Marketplace
Technology
Total Market
Platforms

$

562 

545 

525 

3.1 %

3.8 %

4,225  $

4,048  $

4,179 

4.4 %

(3.1)%

Transaction-based expenses:
Transaction
rebates

(878)

(1,018)

(32)

(6)

(828)

(69)

(13.8)%

178.1 %

22.9 %

(53.6)%

(7)

(50.0)%

(14.3)%

(89)

(3)

Transaction-based expenses:

Transaction
rebates
Brokerage,

clearance and
exchange fees

Total Market

Platforms, net

(2,092)

(2,168)

(2,028)

(3.5)%

6.9 %

(552)

(298)

(694)

85.2 %

(57.1)%

$

1,581  $

1,582  $

1,457 

(0.1)%

8.6 %

Trading Services

Our Trading Services business includes equity derivatives trading, cash equity
trading,  Nordic  fixed  income  trading  &  clearing,  U.S.  Tape  plans  and  other
revenues.  The  following  tables  present  net  revenues  by  product  from  our
Trading Services business:

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

U.S. Equity
Derivative
Trading
Cash Equity
Trading

U.S. Tape plans
Other
Trading Services,

net

$

371  $

343  $

287 

8.2 %

19.5 %

397 
149 
102 

429 
155 
110 

381 
162 
102 

(7.5)%
(3.9)%
(7.3)%

12.6 %
(4.3)%
7.8 %

$

1,019  $

1,037  $

932 

(1.7)%

11.3 %

In  the  table  above,  Other  includes  Nordic  fixed  income  trading  &  clearing,
Nordic derivatives, Nordic commodities, and Canadian cash equities trading.

U.S. Equity Derivative Trading

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

Section 31 fees
Brokerage and
clearance fees

U.S. Equity
derivative
trading
revenues, net

$

371  $

343  $

287 

8.2 %

19.5 %

Section  31  fees  are  recorded  as  equity  derivative  and  cash  equity  derivative
trading  revenues  with  a  corresponding  amount  recorded  in  transaction-based
expenses. 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  traded.  The  SEC  implemented  a  fee  increase  in  May  2022  and  a
decrease in February 2021. Since the amount recorded in revenues is equal to
the  amount  recorded  as  Section  31  fees,  there  is  no  impact  on  our  net
revenues.

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,

2022

2021

2020

38.2 

37.2 

27.7 

11.6 %

12.4 %

12.7 %

8.0 %

2.8 %

5.7 %

2.3 %

1.6 %

8.1 %

1.4 %

6.6 %

4.3 %

1.6 %

9.8 %

0.2 %

7.8 %

5.6 %

0.7 %

32.0 %

34.4 %

36.8 %

41

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
U.S.  equity  derivative  trading  revenues  decreased  in  2022  compared  with
2021  primarily  due  to  lower  overall  matched  market  share  executed  on
Nasdaq's  exchanges  and  lower  gross  capture  rate,  partially  offset  by  higher
industry trading volumes.

U.S.  equity  derivative  trading  revenues  less  transaction-based  expenses
increased  in  2022  compared  with  2021  primarily  due  to  higher  capture  rates
and  higher  industry  trading  volumes,  and  lower  transaction  rebates,  partially
offset  by  lower  overall  matched  market  share  executed  on  Nasdaq's
exchanges.

U.S. equity derivative trading and clearing revenues and U.S. 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.

Transaction  rebates,  in  which  we  credit  a  portion  of  the  execution  charge  to
the market participant, decreased in 2022 compared with 2021 primarily due
to lower overall U.S. matched market share executed on Nasdaq's exchanges
and  lower  rebate  capture  rate,  partially  offset  by  higher  industry  trading
volumes. Transaction rebates 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
rebate capture rate.

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

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

Cash Equity
Trading
Revenues

$

1,605  $

1,578  $

1,582 

1.7 %

(0.3)%

Section 31 fees
Transaction-
based expenses:  
Transaction
rebates

Section 31 fees
Brokerage and
clearance fees

Cash equity
trading
revenues, net

436 

229 

586 

90.4 %

(60.9)%

(1,184)

(1,118)

(1,169)

5.9 %

(4.4)%

(436)

(229)

(586)

90.4 %

(60.9)%

(24)

(31)

(32)

(22.6)%

(3.1)%

$

397  $

429  $

381 

(7.5)%

12.6 %

See  discussion  in  "U.S.  Equity  Derivative  Trading"  for  an  explanation  of
Section 31 fees and the period over period analysis.

Year Ended December 31,

2022

2021

2020

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

11.9 

522.8 

11.4 

491.9 

10.9 

508.3 

16.2 %

15.8 %

16.8 %

0.5 %

0.8 %

0.6 %

0.7 %

0.9 %

0.6 %

17.5 %

17.1 %

18.3 %

35.2 %
52.7 %

34.9 %
52.0 %

31.8 %
50.1 %

Nasdaq Nordic and Nasdaq Baltic securities
Average daily number of
equity trades executed on
Nasdaq’s exchanges
Total average daily value of
shares traded (in billions)
Total market share executed
on Nasdaq’s exchanges

908,813

$

5.4 

71.5 %

1,036,523

933,822 

$

6.4 

$

5.6 

76.9 %

78.1 %

In the tables 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 increased in 2022 compared with 2021 primarily
due to higher U.S. industry trading volumes and higher overall U.S. matched
market  share  executed  on  Nasdaq's  exchanges,  partially  offset  by  an
unfavorable impact of changes in foreign exchange rates of $16 million, lower
U.S. gross capture rate, lower European trading volumes and lower European
market share executed on Nasdaq's exchanges.

Cash  equity  trading  revenues  less  transaction-based  expenses  decreased  in
2022 compared with 2021 primarily due to lower capture rate, the unfavorable
impact  of  changes  in  foreign  exchange  rates  of  $16  million,  lower  European
trading  volumes  and  lower  European  market  share  executed  on  Nasdaq's
exchanges, partially offset by higher U.S. industry trading volumes.

42

 
 
 
 
 
 
Cash equity trading revenues decreased in 2021 compared with 2020 primarily
due  to  lower  overall  U.S.  matched  market  share  executed  on  Nasdaq's
exchanges,  partially  offset  by  higher  U.S.  gross  capture  rates,  higher  U.S.
industry  trading  volumes,  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.  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.

Transaction  rebates  increased  in  2022  compared  with  2021.  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  increase  was  primarily  due  to  higher
U.S.  industry  volumes  and  higher  U.S.  matched  market  share  executed  on
Nasdaq's exchanges, partially offset by lower rebate capture rate. Transaction
rebates decreased in 2021 compared with 2020, 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.

U.S. Tape Plans

The following tables present revenues from our U.S. Tape plans business:

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

U.S. Tape plans $

149  $

155  $

162 

(3.9)%

(4.3)%

U.S. Tape plans revenues decreased in 2022 compared with in 2021 and 2021
compared with 2020 primarily due to lower market share and usage.

Other

Other includes Nordic fixed income trading and clearing, Nordic derivatives,
Nordic commodities and Canadian cash equities trading. The following tables
present revenue and key driver from our Other business:

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

Other

$

102  $

110  $

102 

(7.3)%

7.8 %

In  the  table  above,  other  includes  transaction  rebates  of  $30  million,  $32
million and $31 million in 2022, 2021 and 2020 respectively.

Year Ended December 31,

2022

2021

2020

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

296,626

287,182

320,204 

In  the  tables  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.

Other  revenues  decreased  in  2022  compared  with  2021  primarily  due  to  the
unfavorable  impact  of  changes  in  foreign  exchange  rates  of  $14  million  and
lower  commodities  products  revenues,  partially  offset  by  higher  European
trading  volumes  and  higher  collateral  management  services  revenues.  Other
revenues increased in 2021 compared with 2020 primarily due to the favorable
impact of changes in foreign exchange rates of $5 million, higher capture rate
and  higher  European  clearing  products  revenues,  partially  offset  by  lower
European trading volumes.

Marketplace Technology

Marketplace Technology includes our trade management services and market
technology businesses.

The following tables present revenues and key drivers from our Marketplace
Technology business:

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

Marketplace
Technology

$

562  $

545  $

525 

3.1 %

3.8 %

As of or 
Three Months Ended December 31,

2022

2021

(in millions)

2020

ARR
Quarterly annualized SaaS
revenues
Order intake

$

$

503  $

479  $

39 
264  $

31 
304  $

468 

27 
167 

In  the  table  above,  order  intake  is  for  our  market  technology  business  and
represents the total contract value of orders signed during the period.

Marketplace technology revenues increased in 2022 compared with 2021 and
2021 compared with 2020 primarily due to higher trade management services
revenues associated with increased demand for connectivity services, partially
offset  by  lower  market  technology  revenues.  The  decrease  in  market
technology  revenues  in  2022  was  due  to  the  successful  completion  of  long-
term  contracts  in  2021  and  the  unfavorable  impact  of  changes  in  foreign
exchange  rates  of  $10  million,  partially  offset  by  growth  in  SaaS-based
revenues. The decrease in market technology revenues in 2021 was primarily
due to lower professional services revenues, partially offset by an increase in
SaaS revenues.

43

 
 
 
 
 
 
 
 
CAPITAL ACCESS PLATFORMS

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

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021 2021 vs. 2020

(in millions)

$

729  $
486 

680  $
459 

469 

429 

574 
324 

389 

7.2 %
5.9 %

18.5 %
41.7 %

9.3 %

10.3 %

$

1,684  $

1,568  $

1,287 

7.4 %

21.8 %

Data & Listing
Services
Index
Workflow &
Insights
Total Capital
Access
Platforms

As of or 
Three Months Ended December 31,

2022

2021

(in millions)

2020

ARR
Quarterly annualized SaaS revenues

$
$

1,192  $
388  $

1,113  $
356  $

986 
323 

Data & Listing Services Revenues

The  following  tables  present  key  drivers  from  our  Data  &  Listing  Services
business:

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

In the tables above:

Year Ended December 31,

2022

2021

2020

161 

38 

752 

174 

366 

1,000 

63 

207 

316

45

454

67

4,230 

4,178 

3,392 

1,251 

1,235 

1,071 

• 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, 2022, 2021 and 2020, IPOs included 74, 433 and 132
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, 2022, 2021 and 2020 included 528, 441 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.

Data & Listing Services revenues increased in 2022 compared with 2021 and
2021  compared  with  2020.  The  increase  in  2022  was  primarily  due  to  an
increase  in  annual  listing  fees,  due  to  an  increase  in  the  overall  number  of
listed  companies,  and  an  increase  in  proprietary  data  revenues  driven  by
higher international demand, partially offset by lower initial listings fees and
the  unfavorable  impact  of  changes  in  foreign  exchange  rates  of  $21  million.
The  increase  in  2021  was  primarily  due  to  an  increase  in  annual  and  initial
listing fees due to the increase in the overall number of listed companies and
an  increase  in  proprietary  data  revenues  driven  by  higher  international
demand.

Index Revenues

The following tables present key drivers from our Index business:

As of or 
Three Months Ended December 31,

2022

2021

2020

Number of licensed ETPs
TTM change in period end ETP AUM tracking Nasdaq
indexes (in billions)
Beginning balance

379 

$

$

Net (depreciation) appreciation
Net impact of ETP sponsor
switches
Net inflows
Ending balance
Quarterly average ETP AUM
tracking Nasdaq indexes (in
billions)
Quarterly annualized SaaS revenues
(in millions)

$

$

$

362 

339

359  $
83 

(92)
74 
424  $

400  $

208  $

233 
80 

— 
46 
359 

334 

179 

424 
(142)

(1)
34 
315 

326 

220 

$

$

$

In the table above, TTM represents trailing twelve months.

Index  revenues  increased  in  2022  compared  with  2021  and  2021  compared
with  2020.  The  increase  in  2022  was  primarily  due  to  higher  licensing
revenues from futures trading linked to the Nasdaq-100 Index, partially offset
by lower AUM in ETPs linked to Nasdaq indexes. The increase in 2021 was
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.

44

 
 
 
 
 
Workflow & Insights Revenues

OTHER REVENUES

Workflow  &  Insights  revenues  increased  in  2022  compared  with  2021  and
2021 compared with 2020. The increase in both periods was due to an increase
in  both  analytics  and  corporate  solutions  revenues.  The  increase  in  analytics
revenues  for  both  periods  was  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.  The  increase  in  corporate
solutions for both periods was due to higher adoption of our investor relations
intelligence products as well as new ESG solutions, with ESG solutions being
the primary driver of the increase in 2022.

ANTI-FINANCIAL CRIME

The following tables present revenues and key drivers from our Anti-Financial
Crime segment:

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

Anti-Financial Crime $

306  $

231  $

116 

32.5 %

99.1 %

As of or 
Three Months Ended December 31,

2022

2021

(in millions)

2020

ARR
Signed ARR
Quarterly annualized SaaS revenues

$

312  $
338 
298 

269  $
288 
253 

111 
— 
97 

In  the  table  above,  signed  ARR  reflects  ARR  recognized  as  revenue  in  the
current  period  as  well  as  ARR  for  new  contracts  signed  but  not  yet
commenced.  We  began  tracking  signed  ARR  in  2021  following  our
acquisition of Verafin, and thus there is no available metric for 2020.

Anti-financial  crime  revenues  increased  in  2022  compared  with  2021
primarily  due  to  an  increase  in  demand  for  fraud  detection  and  anti-money
laundering  solutions  and  strong  performance  by  our  surveillance  business  in
new sales to existing clients and new customer acquisitions. The increase was
also  driven  by  a  $28  million  purchase  price  adjustment  on  Verafin  deferred
revenue in 2021 and the inclusion of a full year of Verafin revenues in 2022.
The  increase  in  2021  compared  with  2020  was  due  to  the  inclusion  of
revenues  from  our  acquisition  of  Verafin  and  growth  in  our  surveillance
solutions.

Other  revenues  include  revenues  related  to  our  Nordic  broker  services
business,  for  which  we  completed  the  wind-down  in  June  2022,  as  well  as
revenues associated with our U.S. Fixed Income business, which was sold in
June  2021.  Prior  to  the  closing  of  the  transaction,  these  revenues  were
included in our Market Platforms and Capital Access Platforms segments. See
“2021  Divestiture,”  of  Note  4,  “Acquisitions  and  Divestiture,”  to  the
consolidated  financial  statements  for  further  discussion  of  this  divestiture.
Additionally, for the years ended December 31, 2021 and 2020, other revenues
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  third-party  financial
institutions.  Prior  to  July  2021,  these  revenues  were  included  in  our  Capital
Access Platforms segment. For the twelve months ended December 31, 2022,
other revenues also include a transitional services agreement associated with a
divested business.

EXPENSES

Operating Expenses

The following table presents our operating expenses:

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

$

1,003  $

938  $

786 

6.9 %

19.3 %

140 

144 

137 

(2.8)%

5.1 %

207 
104 

125 

51 

258 
33 

82 
15 

186 
109 

85 

57 

278 
64 

87 
31 

151 
107 

11.3 %
(4.6)%

23.2 %
1.9 %

142 

47.1 %

(40.1)%

39 

(10.5)%

46.2 %

202 
24 

33 
48 

(7.2)%
(48.4)%

(5.7)%
(51.6)%

37.6 %
166.7 %

163.6 %
(35.4)%

$

2,018  $

1,979  $

1,669 

2.0 %

18.6 %

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

The  increase  in  compensation  and  benefits  expense  in  2022  compared  with
2021  was  primarily  driven  by  continued  investment  in  employees  to  drive
growth and inflationary pressures, partially offset by a favorable impact from
foreign exchange rates of $42 million.

45

 
 
 
 
 
 
 
Headcount, 
including  employees  of  non-wholly  owned  consolidated
subsidiaries,  increased  to  6,377  employees  as  of  December  31,  2022  from
5,814  as  of  December  31,  2021  reflecting  growth  across  each  of  our  three
segments.

Professional and contract services expense decreased in 2022 compared with
2021  primarily  due  to  a  favorable  impact  from  foreign  exchange  rates  and  a
decrease in legal fees, partially offset by an increase in consulting costs.

Computer  operations  and  data  communications  expense  increased  in  2022
compared  with  2021  primarily  due  to  higher  software  costs  and  higher  costs
related to new cloud initiatives.

Occupancy expense decreased in 2022 compared with 2021 primarily due to a
favorable impact from foreign exchange rates.

General,  administrative  and  other  expense  increased  in  2022  compared  with
2021  primarily  due  to  an  accrual  related  to  a  legal  matter  and  higher  travel
costs.

Marketing  and  advertising  expense  decreased  in  2022  compared  with  2021,
reflecting lower IPO activity.

Depreciation  and  amortization  expense  decreased  in  2022  compared  with
2021 due to 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 and a favorable impact from foreign exchange
rates.

Regulatory expense decreased in 2022 compared with 2021 due to a charge in
2021 associated with an administrative fine issued by the SFSA. See “Nasdaq
Commodities  Clearing  Default,”  of  Note  15,  “Clearing  Operations,”  to  the
consolidated  financial  statements  for  further  discussion  of  the  SFSA
administrative fine.

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
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  2022  divisional  alignment  program  and  2019
restructuring plans and charges associated with these plans.

Non-operating Income and Expenses

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

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

$

7  $

1  $

(129)

(125)

4 
(101)

600.0 %
3.2 %

(75.0)%
23.8 %

(122)

(124)

(97)

(1.6)%

27.8 %

— 
2 

84 
81 

— 
5 

(100.0)%
(97.5)%

N/M
1,520.0 %

31 

52 

70 

(40.4)%

(25.7)%

$

(89) $

93  $

(22)

(195.7)%

(522.7)%

Interest income
Interest expense
Net interest
expense
Net gain on
divestiture of
business
Other income
Net income from
unconsolidated
investees
Total non-operating
income
(expenses)

_______
N/M Not meaningful.

The following table presents our interest expense:

Year Ended December 31,

Percentage Change

2022

2021

2020

2022 vs. 2021

2021 vs. 2020

(in millions)

120  $

115  $

93 

4.3 %

23.7 %

7 
2 
129  $

7 
3 
125  $

6 
2 
101 

— %
(33.3)%

3.2 %

16.7 %
50.0 %

23.8 %

$

Interest expense
on debt
Accretion of debt
issuance costs
and debt
discount
Other fees
Interest expense $

Interest  income  increased  in  2022  compared  with  2021  primarily  due  to  an
increase in interest rates.

Interest  expense  increased  in  2022  compared  with  2021  primarily  due  to  an
increase  in  interest  rates  related  to  borrowings  under  our  commercial  paper
program.

The net gain on divestiture of business 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 decreased in 2022 compared with 2021 primarily due to gains
from  strategic  investments  related  to  our  corporate  venture  program  in  the
prior year.

46

 
 
 
 
 
 
 
Net income from unconsolidated investees decreased in 2022 compared with
2021  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

2022

2021

2020

2022 vs. 2021 2021 vs. 2020

(in millions)

Income tax
provision
Effective tax

rate

$

352 $

347 $

279

1.4 %

24.4 %

23.9 %

22.6 %

23.0 %

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

NON-GAAP FINANCIAL MEASURES

In  addition  to  disclosing  results  determined  in  accordance  with  U.S.  GAAP,
we also provide 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 
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  provides 

investors  with  greater 

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.
We believe that excluding the following items from the non-GAAP net income
attributable  to  Nasdaq  provides  a  more  meaningful  analysis  of  Nasdaq’s
ongoing  operating  performance  and  comparisons  in  Nasdaq’s  performance
between periods:

• Amortization expense of acquired intangible assets: We amortize intangible
assets  acquired  in  connection  with  various  acquisitions.  Intangible  asset
amortization  expense  can  vary  from  period  to  period  due  to  episodic
acquisitions  completed,  rather  than  from  our  ongoing  business  operations.
As  such,  if  intangible  asset  amortization  is  included  in  performance
measures, it is more difficult to assess the day-to-day operating performance
of  the  businesses  and  the  relative  operating  performance  of  the  businesses
between periods.

• 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.
The frequency and the amount of such expenses vary significantly based on
the size, timing and complexity of the transaction. These expenses primarily
include  integration  costs,  as  well  as  legal,  due  diligence  and  other  third-
party transaction costs.

• Restructuring charges: In 2022, following our September announcement to
realign  our  segments  and  leadership,  we  initiated  a  divisional  alignment
program  with  a  focus  on  realizing  the  full  potential  of  this  structure.  In
2019, we initiated the transition of certain technology platforms to advance
our  strategic  opportunities  as  a  technology  and  analytics  provider  and
continue 
the  realignment  of  certain  business  areas.  See  Note  20,
“Restructuring Charges,” to the consolidated financial statements for further
discussion  of  our  2022  divisional  alignment  program  as  well  as  our  2019
restructuring plan, which was completed in June 2021.

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

47

• Other  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.  For  the  year  ended  December  31,  2022,
other  items  include  accruals  related  to  a  legal  matter,  included  in  general,
administrative and other expense in our Consolidated Statements of Income
and a regulatory matter offset by the release of $5 million in relation to the
reduction  of  the  administrative  fine  issued  by  the  SFSA  both  recorded  in
regulatory expense in our Consolidated Statements of Income. For the years
ended  December  31,  2022  and  2021  other  items  also  include  a  loss  on
extinguishment  of  debt,  included  in  general,  administrative  and  other
expense in our Consolidated Statements of Income and net gains and losses
from  strategic  investments  entered  into  through  our  corporate  venture
program,  included  in  other  income  in  our  Consolidated  Statements  of
Income.  For  the  year  ended  December  31,  2021,  other  items  included  a
charge related to an administrative fine imposed by the SFSA. The 2022 and
2021  SFSA  charges  associated  with  the  default  that  occurred  in  2018,  are
included  in  regulatory  expense  in  our  Consolidated  Statements  of  Income.
See  “Nasdaq  Commodities  Clearing  Default,”  of  Note  15,  “Clearing
Operations,” to the consolidated financial statements for further discussion.
For the year ended December 31, 2021, other items also included a net gain
on  divestiture  of  businesses,  which  represents  our  pre-tax  net  gain  of  $84
million on the sale of our U.S. Fixed Income business.

• Significant  tax  items:  The  non-GAAP  adjustment  to  the  income  tax
provision  for  the  years  ended  December  31,  2022  and  2021  primarily
includes the tax impact of each non-GAAP adjustment. In addition, for the
year  ended  December  31,  2021,  the  non-GAAP  adjustment  to  the  income
tax provision includes adjustments related to return-to-provision and a prior
year tax benefit.

The following tables present 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
business
Charitable donations
Other
Total non-GAAP adjustments
Total non-GAAP tax
adjustments

Total non-GAAP adjustments,
net of tax

Non-GAAP net income
attributable to Nasdaq

Year Ended December 31,

2022

2021

2020

(in millions, except per share amounts)

$

1,125 

$

1,187 

$

933 

153 

82 
15 

(29)
1 
— 
16 

— 
— 
27 
265 

(66)

199 

170 

87 
31 

(52)
33 
— 
33 

(84)
— 
(71)
147 

(61)

86 

103 

33 
48 

(70)
(6)
6 
36 

— 
17 
14 
181 

(83)

98 

$

1,324 

$

1,273 

$

1,031 

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

Non-GAAP effective tax rate

23.9 %

22.6 %

23.0 %

0.1 %
24.0 %

1.7 %
24.3 %

3.0 %
26.0 %

Weighted-average common shares
outstanding for diluted earnings
per share

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

Non-GAAP diluted earnings per
share

$

48

497.9 

505.1 

500.7 

$

2.26 

$

2.35 

$

1.86 

0.40 

0.17 

0.20 

2.66 

$

2.52 

$

2.06 

 
LIQUIDITY AND CAPITAL RESOURCES

Cash and Cash Equivalents

Historically,  we  have  funded  our  operating  activities  and  met  our
commitments  through  cash  generated  by  operations,  augmented  by  the
periodic  issuance  of  debt.  Currently,  our  cost  and  availability  of  funding
remain  healthy.  We  continue  to  prudently  assess  our  capital  deployment
strategy 
investments,  debt
repayments,  and  shareholder  return  activity,  including  share  repurchases  and
dividends.

through  balancing  acquisitions, 

internal 

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

The  value  of  various  assets  and  liabilities,  including  cash  and  cash
equivalents,  receivables,  accounts  payable  and  accrued  expenses,  the  current
portion of long-term debt, and commercial paper, can fluctuate from month to
month.  Working  capital  (calculated  as  current  assets  less  current  liabilities)
was $(231) million as of December 31, 2022, compared with $(449) million as
of  December  31,  2021,  an  increase  of  $218  million.  The  increase  was
primarily  driven  by  a  decrease  in  short-term  debt  and  increases  in  cash  and
cash equivalents and receivables, net, partially offset by increases in Section
31  fees  payable  to  the  SEC  and  deferred  revenue  and  decreases  in  other
current assets and financial investments.

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

•    deterioration of our revenues in any of our business segments;

•    changes in regulatory and working capital requirements; and

• an increase in our expenses.

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

•        operating  covenants  contained  in  our  credit  facilities  that  limit  our  total

borrowing capacity;

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

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

•    volatility or disruption in the public debt and equity markets.

The following table summarizes our financial assets:

Cash and cash equivalents
Financial investments

Total financial assets

$

$

December 31, 2022

December 31, 2021

(in millions)
502  $
181 
683  $

393 
208 
601 

Cash and cash equivalents includes all non-restricted cash in banks and highly
liquid  investments  with  original  maturities  of  90  days  or  less  at  the  time  of
purchase.  The  balance  retained  in  cash  and  cash  equivalents  is  a  function  of
anticipated  or  possible  short-term  cash  needs,  prevailing  interest  rates,  our
investment  policy,  and  alternative  investment  choices.  As  of  December  31,
2022, our cash and cash equivalents of $502 million were primarily invested
in bank deposits, money market funds and commercial paper. In the long-term,
we may use both internally generated funds and external sources to satisfy our
debt obligations and other long-term liabilities. Cash and cash equivalents as
of December 31, 2022 increased $109 million from December 31, 2021.

Repatriation of Cash

Our  cash  and  cash  equivalents  held  outside  of  the  U.S.  in  various  foreign
subsidiaries totaled $275 million as of December 31, 2022 and $266 million as
of December 31, 2021. The remaining balance held in the U.S. totaled $227
million as of December 31, 2022 and $127 million as of December 31, 2021.

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

Cash Flow Analysis

The following table summarizes the changes in cash flows:

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

$

$

$

$

Year Ended December 31,

2022

2021

2020

(in millions)

1,706  $
49 
1,036 

1,083  $
(2,653)
1,418 

1,252 
(122)
1,910 

(1,293)

(331)

353 

1,498 

5,496 

(483)

5,979 

6,994  $

5,496  $

502  $
22 

6,470 

6,994  $

393  $
29 

5,074 

5,496  $

3,393 

2,586 

5,979 

2,745 
37 

3,197 

5,979 

49

 
 
 
 
We have adjusted the presentation of the 2020 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;  expense  associated  with  extinguishment  of  debt;  net
gain on divestiture of 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  personnel  costs,  which  are
impacted by employee 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 changes in SEC fee rates and the timing of collections from
customers and payments to the SEC.

Net cash provided by operating activities increased $623 million for the year
ended  December  31,  2022  compared  with  the  same  period  in  2021.  The
increase  was  primarily  driven  by  Section  31  fees  payable  to  the  SEC  due  to
higher SEC fee rates in 2022 and cash payments made in the second quarter of
2021 related to the acquisition of Verafin, including a tax obligation paid on
behalf  of  Verafin  of  $221  million  and  a  cash  payment  of  $102  million,  the
release  of  which  was  subject  to  certain  employment-related  conditions
following the closing of the acquisition of Verafin. During the fourth quarter
of 2022, the remaining amount of the $102 million was accelerated and paid to
the  eligible  former  Verafin  employees.  The  remaining  change  was  primarily
due to other fluctuations in our working capital.

Net Cash Provided by (Used in) Investing Activities

Net  cash  provided  by  investing  activities  for  the  year  ended  December  31,
2022  primarily  related  to  net  proceeds  from  sales  and  redemptions  of
investments related to default funds and margin deposits of $211 million and
proceeds  of  $33  million  from  other  investing  activities,  partially  offset  by
purchases  of  property  and  equipment  of  $152  million  and  $41  million  cash
used for acquisitions, net of cash and cash equivalents acquired.

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

Net Cash Provided by Financing Activities

Net  cash  provided  by  financing  activities  for  the  year  ended  December  31,
2022 primarily related to an increase in default funds and margin deposits of
$2,440 million, proceeds of $541 million from the issuance of long-term-debt
and proceeds of $238 million from the issuances of our commercial paper, net,
partially  offset  by  $1,097  million  related  to  the  repayment  of  our  2022  and
2024  Notes,  $383  million  of  dividend  payments  to  our  shareholders,  $325
million of repurchases of common stock pursuant to the ASR agreement and
$308 million in other repurchases of common stock.

Net  cash  provided  by  financing  activities  for  the  year  ended  December  31,
2021 primarily related to an 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  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.

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

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

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

50

Financial Investments

Other Capital Requirements

Our financial investments totaled $181 million as of December 31, 2022 and
$208 million as of December 31, 2021. Of these securities, $161 million as of
December 31, 2022 and $162 million December 31, 2021, are assets primarily
utilized  to  meet  regulatory  capital  requirements,  mainly  for  our  clearing
operations at Nasdaq Clearing. See Note 6, “Investments,” to the consolidated
financial statements for further discussion.

Regulatory Capital Requirements

Clearing Operations Regulatory Capital Requirements

We  are  required  to  maintain  minimum  levels  of  regulatory  capital  for  the
clearing  operations  of  Nasdaq  Clearing.  The  level  of  regulatory  capital
required to be maintained is dependent upon many factors, including market
conditions and creditworthiness of the counterparty. As of December 31, 2022,
our required regulatory capital of $125 million was comprised of highly rated
European  government  debt  securities 
in  financial
investments in the Consolidated Balance Sheets.

that  are 

included 

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, 2022, other required regulatory capital of $10 million, primarily related to
Nasdaq  Central  Securities  Depository,  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.

Equity and dividends

Stock Split Effected in the Form of a Stock Dividend

On  August  26,  2022,  we  effected  a  3-for-1  stock  split  of  the  Company's
common stock in the form of a stock dividend to shareholders of record as of
August 12, 2022. The par value per share of our common stock remains $0.01
per share. All references made with respect to a number of shares or per share
amounts throughout this Annual Report on Form 10-K have been retroactively
adjusted to reflect the stock split.

Broker-Dealer Net Capital Requirements

Share Repurchase Program

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, 2022, the combined required minimum net
capital totaled $1 million and the combined excess capital totaled $18 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 and Baltic Exchange Regulatory Capital Requirements

The entities that operate trading venues in the Nordic and Baltic countries are
each  subject  to  local  regulations  and  are  required  to  maintain  regulatory
capital  intended  to  ensure  their  general  financial  soundness  and  liquidity.  As
of  December  31,  2022,  our  required  regulatory  capital  of  $34  million  was
primarily  invested  in  European  mortgage  bonds  and  Icelandic  government
bonds 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.

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

ASR Agreement

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

Cash Dividends on Common Stock

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

outstanding 

common 

our 

on 

First quarter
Second quarter
Third quarter
Fourth quarter

Total

2022

2021

0.18 
0.20 
0.20 
0.20 
0.78 

$

$

0.16 
0.18 
0.18 
0.18 
0.70 

$

$

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

51

Debt Obligations

The following table summarizes our debt obligations by contractual maturity:

Maturity Date

December 31, 2022

December 31, 2021

Short-term debt:

Commercial paper
2022 Notes
2024 Notes

December 2022
June 2024

Total short-term debt
Long-term debt - senior unsecured notes:

2022 Credit
Facility
2026 Notes
2029 Notes
2030 Notes
2031 Notes
2033 Notes
2040 Notes
2050 Notes
2052 Notes

Total long-term debt

Total debt obligations

December 2027
June 2026
March 2029
February 2030
January 2031
July 2033
December 2040
April 2050
March 2052

$

$

$
$

(in millions)

664  $
— 
— 
664  $

(5)
498 
637 
637 
644 
653 
644 
486 
541 
4,735  $
5,399  $

420 
598 
499 
1,517 

(4)
498 
676 
676 
643 
694 
644 
486 
— 
4,313 
5,830 

In the table above, the 2024 Notes were reclassified to short-term debt as of
March 31, 2022, and were repaid in April 2022.

In  December  2022,  Nasdaq  amended  and  restated  the  2020  Credit  Facility
with a new maturity date of December 16, 2027. In addition to the 2022 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 $184 million as of December 31, 2022 and $212 million as
of December 31, 2021 in available liquidity, none of which was utilized.

As of December 31, 2022, 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.

Contractual Obligations and Contingent Commitments

Nasdaq  has  contractual  obligations  to  make  future  payments  under  debt
obligations  by  contract  maturity,  operating  lease  payments,  and  other
obligations.  The  following  table  summarizes  material  cash  requirements  for
known  contractual  and  other  obligations  as  of  December  31,  2022,  and  the
estimated timing thereof.

(in millions)
Debt obligation by
contractual maturity
Operating lease obligations
Purchase obligations

Total

In the table above:

Payments Due by Period

Total

<1 year

1-3 years

3-5 years

5+ years

$

$

7,188  $
665 
453 
8,306  $

765  $
77 
86 
928  $

224  $
142 
104 
470  $

685  $
110 
91 
886  $

5,514 
336 
172 
6,022 

• Debt obligations by contractual maturity include both principal and interest
obligations. As of December 31, 2022, an interest rate of 4.4% was used to
compute the amount of the contractual obligations for interest on the 2022
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, 2022. 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,  2022,  as  well  as  legally  binding  minimum
lease  payments  for  leases  signed  but  not  yet  commenced.  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,
2022  is  primarily  comprised  of  our  multi-year  AWS  partnership  contract,
which replaces our previous shorter term contracts, including 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.

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,”  to  the

consolidated financial statements for further discussion of:

◦ Guarantees issued and credit facilities available;

◦ Other guarantees;

◦ Routing brokerage activities;

◦ Legal and regulatory matters; and

◦ Tax audits.

52

 
 
 
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, 2022, 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,  2022,  the  fair  value  of  this
portfolio would decline by $3 million.

Debt Obligations

As of December 31, 2022, 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 borrowings under our 2022 Credit Facility, as this facility has a
variable  interest  rate.  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,  which  have  variable  interest  rates.  As  of
December 31, 2022, we had principal amounts outstanding of $664 million of
commercial paper and no amounts outstanding under our 2022 Credit Facility.
A  hypothetical  100  basis  points  increase  in  interest  rates  on  our  outstanding
commercial  paper  would 
interest  expense  by
approximately $7 million based on borrowings as of December 31, 2022.

increase  our  annual 

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

Foreign Currency Exchange Rate Risk

We  are  subject  to  foreign  currency  exchange  rate  risk.  Our  primary
transactional  exposure  to  foreign  currency  denominated  revenues  less
transaction-based  expenses  and  operating  income  for  the  years  ended
December 31, 2022 and 2021 are presented in the following tables:

Euro

Swedish
Krona

Other Foreign
Currencies

U.S. Dollar

Total

(in millions, except currency rate)

Year Ended December 31, 2022
Average foreign
currency rate to
the U.S. dollar

1.054

0.099

#

N/A

N/A

Percentage of
revenues less
transaction-
based expenses

Percentage of
operating
income

6.2 %

5.1 %

4.1 %

84.6 %

100.0 %

10.1 %

(2.8)%

(10.6)%

103.3 %

100.0 %

Impact of a 10%

adverse
currency
fluctuation on
revenues less
transaction-
based expenses
Impact of a 10%

adverse
currency
fluctuation on
operating
income

$

(22)

$

(18)

$

(15)

$

— 

$

(55)

$

(16)

$

(4)

$

(17)

$

— 

$

(37)

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

1.183

0.117

#

N/A

N/A

Percentage of
revenues less
transaction-
based expenses

Percentage of
operating
income

7.1 %

6.2 %

4.9 %

81.8 %

100.0 %

10.4 %

(4.6)%

(9.1)%

103.3 %

100.0 %

Impact of a 10%

adverse
currency
fluctuation on
revenues less
transaction-
based expenses
Impact of a 10%

adverse
currency
fluctuation on
operating
income

$

(24)

$

(21)

$

(17)

$

— 

$

(62)

$

(15)

$

(7)

$

(13)

$

— 

$

(35)

____________
#    Represents multiple foreign currency rates.
N/A    Not applicable.

53

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,
2022 is presented in the following table:

Net Assets

Impact of a 10% Adverse
Currency Fluctuation

$

Swedish Krona
British Pound
Norwegian Krone
Canadian Dollar
Australian Dollar
Euro

(in millions)

2,941  $
155 
150 
107 
99 
53 

294 
15 
15 
11 
10 
5 

In  the  table  above,  Swedish  Krona  includes  goodwill  of  $2,153  million  and
intangible assets, net of $495 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  investment  grade  ratings,  well-capitalized  financial
institutions and other creditworthy counterparties.

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

leaving  Nasdaq  Execution  Services  susceptible 

thereby 

clearinghouse  officially  accepts  the  trade  for  novation,  Nasdaq  Execution
Services is legally removed from trade execution risk. However, Nasdaq has
membership obligations to NSCC independent of Nasdaq Execution Services’
arrangements.

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

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 in the status of our counterparties’ creditworthiness. Credit
losses such as those described above could adversely affect our consolidated
financial position and results of operations.

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 institutions,
highly  rated  government  debt 
instruments  and  other  creditworthy
counterparties.

54

 
 
• 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.  In  addition,  the  clearinghouse  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.

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

Critical Accounting Policies and Estimates 

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

Revenue Recognition

Market technology revenues

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

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

Accounting for our long-term contracts requires judgment relative to assessing
risks and their impact on the estimate of revenues and costs. Our estimates are
impacted  by  factors  such  as  the  potential  for  schedule  and  technical  issues,
productivity  and  the  complexity  of  work  performed.  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  -  Marketplace
Technology,” of Note 2, “Summary of Significant Accounting Policies,” to the
consolidated financial statements.

55

Goodwill,  Indefinite-Lived  Intangible  Assets  and  Related  Impairment
Testing

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.

In September 2022, we announced a new organizational structure which aligns
our  businesses  more  closely  with  the  foundational  shifts  that  are  driving  the
evolution  of  the  global  financial  system.  Our  four  previous  reportable
segments, Market Services, Corporate Platforms, Investment Intelligence and
Market  Technology  have  been  changed  to  align  with  our  new  corporate
structure  that  includes  three  segments:  Market  Platforms,  Capital  Access
Platforms  and  Anti-Financial  Crime.  Under  ASC  350-20,  “Intangibles
Goodwill and Other,” when a company reorganizes its reporting structure, an
impairment  test  must  be  performed  both  before  and  after  the  change,  and
goodwill  must  be  reassigned  to  reporting  units.  Accordingly,  goodwill  was
reassigned based on relative fair value of each reporting unit.

We perform our goodwill impairment test at the reporting unit level. For 2022,
we performed the goodwill impairment test under our previous organizational
structure:  Market  Services  segment,  the  two  businesses  comprising  the
Corporate  Platforms  segment:  Listing  Services  and  Corporate  Solutions,  the
Investment Intelligence segment, and the Market Technology segment, which
represented  our  five  reporting  units.  We  also  performed  the  test  under  our
current  organization  structure,  which  includes  three  reporting  units:  Market
Platforms  segment,  Capital  Access  Platforms  segment  and  Anti-Financial
Crime 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  exceeds  their  respective  estimated  fair  values,  a  quantitative
test is required. Our decision to perform a qualitative impairment assessment
in a given year is influenced by a number of factors, including but not limited
to, the size of the reporting unit’s goodwill, the significance of the excess of
the  reporting  unit’s  estimated  fair  value  or  the  indefinite-lived  intangible
asset’s fair value over their respective carrying amounts at the last quantitative
assessment  date,  and  the  amount  of  time  in  between  quantitative  fair  value
assessments.

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,  which  incorporates  relevant
trading  multiples  of  comparable  companies  and  other  factors.  The  estimates
and assumptions used consider historical performance and are consistent with
the assumptions used in determining future profit plans for each reporting unit,
which  are  approved  by  our  board  of  directors.  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 pre-segment realignment at the time of our 2022 annual impairment
test:

Market Technology
Investment Intelligence
Corporate Platforms
Market Services

56

October 1, 2022

(in millions)

2,122 
2,256 
471 
3,097 
7,946 

$

$

 
 
The  following  table  presents  the  balances  of  goodwill  for  our  reportable
segments post segment realignment at the time of our 2022 annual impairment
test.  The  carrying  value  of  goodwill  was  reassigned  to  our  new  reportable
segments based on a relative fair value allocation approach.

Market Platforms
Capital Access Platforms
Anti-Financial Crime

October 1, 2022

(in millions)

2,819 
4,122 
1,005 
7,946 

$

$

In  2022  and  2021,  we  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 any of those years.

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.

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,
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.  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.

There  were  no  material  finite-lived  intangible  assets  impairment  charges  in
2022  and  2020.  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.

We  recorded  pre-tax,  non-cash  property  and  equipment  asset  impairment
charges  of  $8  million  in  2022,  $4  million  in  2021  and  $14  million  in  2020.
The  asset  impairment  charges  in  2022  and  2020  primarily  related  to
capitalized software that was retired and are included in restructuring charges
in  the  Consolidated  Statements  of  Income.  See  Note  20,  “Restructuring
Charges,”  to  the  consolidated  financial  statements  for  a  discussion  of  these
plans.

No  material  impairments  were  recorded  to  reduce  the  carrying  value  of  our
other long-lived assets during 2022, 2021 or 2020.

Income Taxes

Estimates  and  judgments  are  required  in  the  calculation  of  certain  tax
liabilities and in the determination of the recoverability of certain deferred tax
assets,  which  arise  from  net  operating  loss  carryforwards,  tax  credit
carryforwards  and  temporary  differences  between  the  tax  and  financial
statement  recognition  of  revenues  and  expenses.  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.

57

 
 
Recent Accounting Pronouncements Not Yet Adopted

Management’s Report on Internal Control Over Financial Reporting

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.

Item 7A. Quantitative and Qualitative Disclosures About Market Risk

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

Nasdaq’s  consolidated  financial  statements,  including  Consolidated  Balance
Sheets  as  of  December  31,  2022  and  2021,  Consolidated  Statements  of
Income for the years ended December 31, 2022, 2021 and 2020, Consolidated
Statements of Comprehensive Income for the years ended December 31, 2022,
2021 and 2020, Consolidated Statements of Changes in Stockholders' Equity
for  the  years  ended  December  31,  2022,  2021  and  2020,  Consolidated
Statements of Cash Flows for the years ended December 31, 2022, 2021 and
2020 and notes to our consolidated financial statements, together with a report
thereon of Ernst & Young LLP, dated February 23, 2023, are attached hereto
as pages F-1 through F-44 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  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 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, 2022 that have materially affected, or
are  reasonably  likely  to  materially  affect,  Nasdaq’s  internal  control  over
financial reporting.

is  responsible  for 

Management 
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.

the  preparation  and 

integrity  of 

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

Our  management  assessed  the  effectiveness  of  our  internal  control  over
financial reporting as of December 31, 2022, based on criteria established in
the  Committee  of
Internal  Control—Integrated  Framework 
Sponsoring  Organizations  of  the  Treadway  Commission  (COSO)  (2013
framework).  This  evaluation  included  review  of  the  documentation  of
controls,  evaluation  of  the  design  effectiveness  of  controls,  testing  of  the
operating effectiveness of controls and a conclusion on this evaluation. Based
on  its  assessment,  our  management  believes  that,  as  of  December  31,  2022,
our internal control over financial reporting is effective.

issued  by 

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.

58

Report of Independent Registered Public Accounting Firm

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

Opinion on Internal Control over Financial Reporting

We have audited Nasdaq, Inc.’s internal control over financial reporting as of
December  31,  2022,  based  on  criteria  established  in  Internal  Control—
Integrated Framework issued by the Committee of Sponsoring Organizations
of  the  Treadway  Commission  (2013  framework)  (the  COSO  criteria).  In  our
opinion,  Nasdaq,  Inc.  (the  Company)  maintained,  in  all  material  respects,
effective  internal  control  over  financial  reporting  as  of  December  31,  2022,
based on the COSO criteria.

We also have audited, in accordance with the standards of the Public Company
Accounting  Oversight  Board  (United  States)  (PCAOB),  the  consolidated
balance sheets of the Company as of December 31, 2022 and 2021, 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, 2022, and the related notes and our report dated February
23, 2023 expressed an unqualified opinion thereon.

Basis for Opinion

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

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

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

Definition and Limitations of Internal Control Over Financial Reporting

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

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

New York, New York
February 23, 2023

/s/ Ernst & Young LLP

59

 
 
 
 
 
Item 9B. Other Information

None.

Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections

Not applicable.

PART III

Item 10. Directors, Executive Officers and Corporate Governance

Information about Nasdaq’s directors, as required by Item 401 of Regulation
S-K,  is  incorporated  by  reference  from  the  discussion  under  the  caption
“Director  Nominees”  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 “Operating with Integrity” 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” and “Board Committees” in the Proxy Statement.

Item 11. Executive Compensation

Information about Nasdaq’s director and executive compensation, as required
by Items 402, 407(e)(4) and 407(e)(5) of Regulation S-K, is incorporated by
reference  from  the  discussions  under  the  headings  “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  the  heading  “Other  Items-Security
Ownership  of  Certain  Beneficial  Owners  and  Management”  in  the  Proxy
Statement.

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.

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,  2022,  all  our  employees  are  eligible  to
participate.

The  Equity  Plan  and  the  ESPP  have  been  previously  approved  by  our
stockholders. The following table sets forth information regarding outstanding
options  and  shares  reserved  for  future  issuance  under  all  of  Nasdaq’s
compensation plans as of December 31, 2022.

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)

1,420,323  $

41.79 

38,534,312 

— 

1,420,323  $

— 

41.79 

— 
38,534,312 

Plan Category
Equity compensation
plans approved by
stockholders
Equity compensation
plans not approved
by stockholders

Total

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,
2022, we also had 6,347,055 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
26,430,038  shares  of  common  stock  that  may  be  awarded  pursuant  to  the
Equity Plan and (b) 12,104,274 shares of common stock that may be issued
pursuant to the ESPP.

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

Information about certain relationships and related transactions, as required by
Item  404  of  Regulation  S-K,  is  incorporated  herein  by  reference  from  the
discussion under the heading “Other Items-Certain Relationships and Related
Transactions” 
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” in the Proxy Statement.

the  Proxy  Statement. 

in 

60

 
 
 
 
 
 
 
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  Annual  Evaluation  and  2023
Selection of the Independent Auditor” in the Proxy Statement.

PART IV

Item 15. Exhibits and 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

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).

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).

2.1

2.2

3.1

3.1.1

3.1.2

3.1.3

3.1.4

3.2

4.1

4.2

4.2.1

4.3

4.3.1

4.4

4.4.1

61

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).

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 July 20, 2022).

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).

First Amendment to Nasdaq Stockholders’ Agreement, dated
as of December 14, 2022, between Nasdaq, Inc. and Investor
AB (incorporated herein by reference to Exhibit 4.1 to the
Current Report on Form 8-K filed on December 16, 2022).

 
     
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).

62

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).

Thirteenth Supplemental Indenture, dated as of March 7, 2022,
by and between Nasdaq, Inc. and Computershare Trust
Company, N.A. (as successor to Wells Fargo Bank, National
Association), as trustee (incorporated by reference to Exhibit
4.2 to the Company's Current Report on Form 8-K filed on
March 7, 2022).

4.18

Description of Securities.

10.1

10.2

10.3

10.4

10.5

10.6

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 10.1
to the Quarterly Report on Form 10-Q for the quarter ended
June 30, 2022 filed on August 3, 2022).*

Form of Nasdaq Restricted Stock Unit Award Certificate
(directors) (incorporated herein by reference to Exhibit 10.2 to
the Quarterly Report on Form 10-Q for the quarter ended June
30, 2022 filed on August 3, 2022).*

10.7

10.8

10.9

10.10

10.10.1

10.11

10.12

10.13

10.14

10.15

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

Form of Nasdaq Three-Year Performance Share Unit
Agreement (incorporated herein by reference to Exhibit 10.3
to the Quarterly Report on Form 10-Q for the quarter ended
June 30, 2022 filed on August 3, 2022).*

Form of Nasdaq Continuing Obligations Agreement
(incorporated by reference to Exhibit 10.9 to the Company’s
Annual Report on Form 10-K for the year ended December
31, 2021 filed on February 23, 2022).

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).*

Nasdaq, Inc. Deferred Compensation Plan (incorporated by
reference to Exhibit 10.1 to the Company's Current Report on
Form 8-K filed on June 16, 2022).*

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 (incorporated by reference to
Exhibit 10.14 to the Company’s Annual Report on Form 10-K
for the year ended December 31, 2021 filed on February 23,
2022).*

Nonqualified Stock Option Award Certificate to Adena T.
Friedman from Nasdaq, Inc. in connection with grant made on
January 3, 2022 (incorporated by reference to Exhibit 10.15 to
the Company’s Annual Report on Form 10-K for the year
ended December 31, 2021 filed on February 23, 2022).*

10.16

10.17

10.18

10.19

10.20

10.21

10.22

10.23

10.24

10.25

10.26

11

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 Agreement by and between Nasdaq, Inc. and
Bradley J. Peterson, dated June 22, 2022 (incorporated herein
by reference to Exhibit 10.5 to the Quarterly Report on Form
10-Q for the quarter ended June 30, 2022 filed on August 3,
2022).

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, as amended December 6, 2022.*

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 (incorporated herein by reference to
Exhibit 10.23 to the Annual Report on Form 10-K for the year
ended December 31, 2021 filed on February 23, 2022).

Amended and Restated Credit Agreement, dated as of
December 16, 2022, among Nasdaq, Inc., the various lenders
and issuing bank party thereto and Bank of America, N.A., as
administrative agent (incorporated herein by reference to
Exhibit 10.1 to the Current Report on Form 8-K filed on
December 16, 2022).

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).

Verafin Holdings Inc. Amended and Restated Management
Incentive Plan*

Verafin Holdings Inc. Amended and Restated Management
Incentive Plan Award Agreement, by and between Verafin
Solutions ULC and Brendan Brothers, dated as of January 11,
2023*

Verafin Holdings Inc. Amended and Restated Management
Incentive Plan Award Agreement, by and between Verafin
Solutions ULC and Jamie King, dated as of October 18, 2022*

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).

63

21.1

23.1

24.1

31.1

31.2

32.1

101

List of all subsidiaries.

Consent of Ernst & Young LLP.

Powers of Attorney.

Certification of 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.

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

The following materials from the Nasdaq, Inc. Annual Report
on Form 10-K for the year ended December 31, 2022,
formatted in iXBRL (Inline eXtensible Business Reporting
Language): (i) Consolidated Balance Sheets as of December
31, 2022 and December 31, 2021; (ii) Consolidated Statements
of Income for the years ended December 31, 2022, 2021 and
2020 (iii) Consolidated Statements of Comprehensive Income
for the years ended December 31, 2022, 2021 and 2020; (iv)
Consolidated Statements of Changes in Stockholders' Equity
for the years ended December 31, 2022, 2021 and 2020; (v)
Consolidated Statements of Cash Flows for the years ended
December 31, 2022, 2021 and 2020; 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 required

information is included in the consolidated financial statements or notes.

Item 16. Form 10-K Summary

None.

64

By:
Name:

Title:

By:
Name:

Title:

By:
Name:

Title:

By:
Name:

Title:

By:
Name:

Title:

* Pursuant to Power of Attorney
By:
Name:

Title:

*
Thomas A. Kloet
Director

*
John D. Rainey
Director

*
Johan Torgeby
Director

*
Toni Townes-Whitley
Director

*
Alfred W. Zollar
Director

/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, 2023.

Nasdaq, Inc.
(Registrant)

By:
Name:
Title:
Date:

/s/ Adena T. Friedman
Adena T. Friedman
Chief Executive Officer
February 23, 2023

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, 2023.

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
Chief Executive Officer and Chair of the Board

/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
Director

*
Melissa M. Arnoldi
Director

*
Charlene T. Begley
Director

*
Steven D. Black
Director

*
Essa Kazim
Director

65

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-1

F-2
F-4

F-5

F-6

F-7

F-8

F-9

 
Critical Audit Matter

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

Report of Independent Registered Public Accounting Firm

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

Opinion on the Financial Statements

We  have  audited  the  accompanying  consolidated  balance  sheets  of  Nasdaq,
Inc.  (the  Company)  as  of  December  31,  2022  and  2021,  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, 2022, 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,  2022  and  2021,  and  the  results  of  its  operations
and  its  cash  flows  for  each  of  the  three  years  in  the  period  ended  December
31, 2022, 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,  2022,  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, 2023 expressed an unqualified
opinion thereon.

Basis for Opinion

the  responsibility  of 

These  financial  statements  are 
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

 
 
 
 
 
Description
of the
Matter

contracts 

containing 

statements, 

financial 
into 

Market Technology Revenue Recognition
As  described  in  Notes  2  and  3  to  the
consolidated 
the
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
multiple
these 
performance  obligations.  The  Company
recognized  $562  million  of  Marketplace
Technology  revenue  for 
the  year  ended
December 31, 2022. Of this amount, a portion
relates  to  market  technology  contracts  where
the Company allocates the contract transaction
price to each performance obligation using its
best estimate of the standalone selling price of
each distinct good or service in the respective
instances
technology  contract.  In 
market 
where  standalone  selling  price  is  not  directly
observable, such as when a product or service
the  Company
is  not 
separately, 
determines 
selling  price
predominantly through an expected cost plus a
margin  approach.  The  Company  recognizes
revenue over time using costs incurred to date
relative  to  total  estimated  costs  at  completion
to  measure  progress  toward  satisfying  the
performance  obligation.  Revenue  recognized
subject to such estimation was $75 million for
the year ended December 31, 2022.

standalone 

sold 

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 
is  based  on  an
standalone  selling  price 
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 

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 
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.

to  performance  obligations, 

requests,  and 

the  standalone  selling  price  and 

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  new  customer  agreements  signed  during  the  year,
tested  management’s
including  change 
determination  of 
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  and  3  to  the  consolidated
financial  statements  related  to  market  technology  revenue
recognition.

/s/ Ernst & Young LLP

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

New York, New York
February 23, 2023

F-3

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

December 31, 2022

December 31, 2021

Assets
Current assets:

Cash and cash equivalents
Restricted cash and cash equivalents
Default funds and margin deposits (including restricted cash and cash equivalents of $6,470 and $5,074,

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:

Common stock, $0.01 par value, 900,000,000 shares authorized, shares issued: 513,157,630 at December 31, 2022
and 520,256,817 at December 31, 2021; shares outstanding: 491,592,491 at December 31, 2022 and 500,038,905
at December 31, 2021
Additional paid-in capital
Common stock in treasury, at cost: 21,565,139 shares at December 31, 2022 and 20,217,912 shares at December
31, 2021
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-4

$

$

$

$

502  $
22 

7,021 
181 
677 
201 
8,604 
532 
8,099 
2,581 
444 
608 
20,868  $

185  $
243 
243 
357 
122 
7,021 
664 
8,835 
4,735 
456 
452 
226 
14,704 

5 
1,445 

(515)
(1,991)
7,207 
6,151 
13 
6,164 
20,868  $

393 
29 

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 

5 
1,949 

(437)
(1,587)
6,465 
6,395 
10 
6,405 
20,115 

Revenues:
Market Platforms
Capital Access Platforms
Anti-Financial Crime
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 business
Other income
Net income from unconsolidated investees
Income before income taxes
Income tax provision
Net income
Net loss attributable to noncontrolling interests

Net income attributable to Nasdaq

Per share information:
Basic earnings per share

Diluted earnings per share

Cash dividends declared per common share

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

Year Ended December 31,

2022

2021

2020

4,225  $
1,684 
306 
11 
6,226 

4,048  $
1,568 
231 
39 
5,886 

(2,092)
(552)
3,582 

(2,168)
(298)
3,420 

1,003 
140 
207 
104 
125 
51 
258 
33 
82 
15 
2,018 
1,564 
7 
(129)
— 
2 
31 
1,475 
352 
1,123 
2 
1,125  $

2.28  $

2.26  $

0.78  $

938 
144 
186 
109 
85 
57 
278 
64 
87 
31 
1,979 
1,441 
1 
(125)
84 
81 
52 
1,534 
347 
1,187 
— 
1,187  $

2.38  $

2.35  $

0.70  $

4,179 
1,287 
116 
43 
5,625 

(2,028)
(694)
2,903 

786 
137 
151 
107 
142 
39 
202 
24 
33 
48 
1,669 
1,234 
4 
(101)
— 
5 
70 
1,212 
279 
933 
— 
933 

1.89 

1.86 

0.65 

$

$

$

$

$

See accompanying notes to consolidated financial statements.

F-5

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

Net income

Other comprehensive income (loss):
Foreign currency translation gains (losses)
Income tax benefit (expense)
Foreign currency translation, net

(1)

Employee benefit plan adjustment gains (losses)
Employee benefit plan income tax provision

Employee benefit plan, net

Total other comprehensive income (loss), net of tax

Comprehensive income
Comprehensive loss attributable to noncontrolling interests
Comprehensive income attributable to Nasdaq

____________
(1)    

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

Year Ended December 31,

2022

2021

2020

$

1,123  $

1,187  $

(375)
(32)
(407)

5 
(2)
3 

(176)
(42)
(218)

(1)
— 
(1)

(404)
719 
2 
721  $

(219)
968 
— 
968  $

$

933 

269 
49 
318 

— 
— 
— 

318 
1,251 
— 
1,251 

See accompanying notes to consolidated financial statements.

F-6

 
 
 
Consolidated Statements of Changes in Stockholders' Equity
(in millions)

Nasdaq, Inc. 

Year Ended December 31,

2022

2021

2020

Shares
500 

$
5 

Shares
495 

$
5 

Shares
495 

$

5 

(5)
(6)
3 
—
1

(1)

1,949 
(308)
(325)
106 
— 
23 
1,445 

(437)
(78)
(515)

(1,587)
(404)
(1,991)

6,465 
— 
1,125 
(383)
7,207 

6,151 

10 
3 
13 

(9)
(7)
3 
—
19

(1)

2,544 
(468)
(475)
90 
1 
257 
1,949 

(376)
(61)
(437)

(1,368)
(219)
(1,587)

5,628 
— 
1,187 
(350)
6,465 

6,395 

3 
7 
10 

(6)
— 
3 
—
3

— 

2,629 
(222)
— 
87 
2 
48 
2,544 

(336)
(40)
(376)

(1,686)
318 
(1,368)

5,027 
(12)
933 
(320)
5,628 

6,433 

— 
3 
3 

Common stock

Additional paid-in capital
Beginning balance

(1)

Share repurchase program
ASR agreement
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 attributable to Nasdaq
Cash dividends declared per common share
Ending balance

Total Nasdaq stockholders’ equity

Noncontrolling interests
Beginning balance
Net activity related to noncontrolling interests
Ending balance

Total Equity

492  $

6,164 

500  $

6,405 

495  $

6,436 

____________
(1)

    See “ASR Agreement,” of Note 12, “Nasdaq Stockholders’ Equity,” for further discussion.
    In 2021, other issuances of common stock primarily related to shares accelerated and issued upon the sale of our U.S. Fixed Income business.

(2)

See accompanying notes to consolidated financial statements.

F-7

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

Year Ended December 31,

2022

2021

2020

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

Depreciation and amortization
Share-based compensation
Deferred income taxes
Extinguishment of debt
Net gain on divestiture of business
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
(1)
Other liabilities

(2)

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 business, 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
Other investing activities
Net cash provided by (used in) investing activities
Cash flows from financing activities:
Proceeds from (repayments of) commercial paper, net
Repayments of debt and credit commitment
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 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

Interest paid
Income taxes paid, net of refund

(1)

$

1,123  $

1,187  $

258 
106 
38 
16 
— 
(31)
28 

(101)
98 
19 
181 
— 
16 
(45)
1,706 

(322)
320 
— 
— 
(41)
(152)
211 
33 
49 

238 
(1,097)
(16)
541 
(308)
(325)
(383)
23 
(78)
2,440 
1 
1,036 
(1,293)
1,498 
5,496 
6,994  $

502  $
22 
6,470 
6,994  $

116  $
274  $

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)

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

393  $
29 
5,074 
5,496  $

118  $
501  $

$

$

$

$
$

933 

202 
87 
41 
36 
— 
(70)
32 

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

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

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

2,745 
37 
3,197 
5,979 

97 
290 

__________________________
(1)

    In 2021, includes payment of an acquired tax liability 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

(2)

Contributions and Margin Deposits," within Note 15, "Clearing Operations."

See accompanying notes to consolidated financial statements.

F-8

Nasdaq, Inc.

Notes to Consolidated Financial Statements

1. ORGANIZATION AND NATURE OF OPERATIONS

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

In  2022,  we  announced  a  new  organizational  structure  which  aligns  our
businesses  more  closely  with  the  foundational  shifts  that  are  driving  the
evolution of the global financial system. In order to amplify our strategy, we
aligned the Company more closely with evolving client needs. As a result, our
four previous business segments, Market Technology, Investment Intelligence,
Corporate  Platforms  and  Market  Services,  have  been  changed  to  align  with
our  new  corporate  structure  that  now  includes  three  business  segments:
Capital Access Platforms, Market Platforms, and Anti-Financial Crime.

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

Market Platforms

Our Market Platforms segment includes our Trading Services and Marketplace
Technology  businesses.  Our  Trading  Services  business  primarily  includes
revenues  from  equity  derivatives  trading,  cash  equity  trading,  Nordic  fixed
income trading & clearing, Nordic commodities and U.S. Tape plans data. 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  clearing,  settlement  and  central  depository
services.  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.

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.

In addition to our trading and clearing services business as well as our carbon
market offering, we also announced our planned launch of a new digital assets
business to power the digital asset ecosystem in September 2022. The launch
underpins  Nasdaq’s  ambition 
to  advance  and  help  facilitate  broader
trusted  and
institutional  participation 
institutional-grade  solutions,  focused  on  enhanced  custody,  liquidity  and
integrity.  Nasdaq  Digital  Assets  is  expected  to  initially  develop  an  advanced
custody  solution.  Nasdaq’s  offering  is  subject  to  regulatory  approval  in
applicable jurisdictions.

in  digital  assets  by  providing 

Our  Marketplace  Technology  business  includes  our  trade  management
services and our market technology businesses.

Trade management services provides market participants with a wide variety
of  alternatives  for  connecting  to  and  accessing  our  markets  for  a  fee.  Our
marketplaces  may  be  accessed  via  a  number  of  different  protocols  used  for
quoting, order entry, trade reporting and connectivity to various data feeds. We
also  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.  In  June  2022,  we  completed  the  wind-down  of  our
Nordic broker services business.

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 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.

Capital Access Platforms

Our Capital Access Platforms segment includes our Data & Listing Services,
Index and Workflow & Insights businesses.

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

Our listing services business operates in the U.S. and Europe on 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 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.

F-9

As of December 31, 2022, there were 4,230 total listings on The Nasdaq Stock
Market,  including  528  ETPs.  The  combined  market  capitalization  was
approximately $19.3 trillion. In Europe, the Nasdaq Nordic and Nasdaq Baltic
exchanges,  together  with  Nasdaq  First  North,  were  home  to  1,251  listed
companies  with  a  combined  market  capitalization  of  approximately  $1.9
trillion.

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,  2022,  379  ETPs  listed  on  26
exchanges  in  over  20  countries  tracked  a  Nasdaq  index  and  accounted  for
$315 billion in AUM.

investment  decisions,  deploy 

includes  our  analytics  and  corporate  solutions
Workflow  &  Insights 
businesses.  Our  analytics  business  provides  asset  managers,  investment
consultants  and  institutional  asset  owners  with  information  and  analytics  to
make  data-driven 
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.

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.

Our corporate solutions business includes our Investor Relations Intelligence,
ESG  Solutions  and  Governance  Solutions  products,  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,  and  various  non-profit  organizations  to  hospitals  and  healthcare
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  consulting  services.  In  June  2022,  we  acquired  Metrio,  a
provider  of  ESG  data  collection,  analytics  and  reporting  services  based  in
Montreal, Canada. We plan to integrate Metrio’s SaaS platform into our suite
of ESG solutions.

Anti-Financial Crime

Our Anti-Financial Crime segment provides anti-financial crime management
solutions  on  a  cloud-based  platform  to  help  detect,  investigate,  and  report
money laundering and financial fraud through Verafin, which was acquired in
February  2021.  Our  Anti-Financial  Crime  segment  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;  Nasdaq  Market  Surveillance,  a  market
surveillance  solution  for  markets  and  regulators.  See  “2021  Acquisition,”  of
Note 4, “Acquisitions and Divestiture,” for further discussion.

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, necessary for a fair statement of the
results.  These  adjustments  are  of  a  normal  recurring  nature.  All  significant
intercompany  accounts  and 
in
consolidation.

transactions  have  been  eliminated 

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

During  the  fourth  quarter  of  2021,  we  adjusted  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.

F-10

The table below presents a summary of the 2020 Statements of Cash Flows as
reported and as adjusted:

$

Net cash provided by operating activities
Net cash used in investing activities
Net cash provided by financing activities
Effect of exchange rate changes on cash,

cash equivalents, restricted cash and cash
equivalents

Net increase 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

Year Ended December 31, 2020

As Reported

Adjustment
(in millions)

Adjusted

1,252  $
(231)
1,383 

16 

2,420 

362 

—  $

109 
527 

337 

973 

1,252 
(122)
1,910 

353 

3,393 

2,224 

2,586 

$

2,782  $

3,197  $

5,979 

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)

2,745  $
37 

$

—  $
— 

— 
2,782  $

3,197 
3,197  $

Total

$

Use of Estimates

2,745 
37 

3,197 
5,979 

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.

Foreign Currency

Foreign denominated assets and liabilities are remeasured into the functional
currency  at  exchange  rates  in  effect  at  the  balance  sheet  date  and  recorded
through the income statement. Gains or losses resulting from foreign currency
transactions  are  remeasured  using  the  rates  on  the  dates  on  which  those
elements  are  recognized  during  the  period,  and  are  included  in  general,
administrative and other expense in the Consolidated Statements of Income.

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  $242  million  as  of  December  31,
2022 and $109 million as of December 31, 2021. Cash equivalents are carried
at  cost  plus  accrued  interest,  which  approximates  fair  value  due  to  the  short
maturities of these investments.

Restricted Cash

Restricted cash and cash equivalents, which was $22 million as of December
31,  2022  and  $29  million  as  of  December  31,  2021,  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,  2022  and  2021,  restricted  cash  and  cash
equivalents primarily includes funds held for regulatory capital 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
cash  or  non-cash  contributions.  Non-cash  contributions  include  highly  rated
government  debt  securities  that  must  meet  specific  criteria  approved  by
Nasdaq  Clearing.  Non-cash  contributions  are  pledged  assets  that  are  not
recorded in the Consolidated Balance Sheets as Nasdaq Clearing does not take
legal  ownership  of  these  assets  and  the  risks  and  rewards  remain  with  the
clearing members.

Receivables, net

Our  receivables  are  concentrated  with  our  member  firms,  market  data
distributors, listed companies, investor relations intelligence, governance, anti-
financial crime and marketplace 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
in  the  Consolidated  Statements  of  Income,  and  decreased  by  the  amount  of
charge-offs, net of recoveries.

F-11

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
$15 million as of December 31, 2022, $17 million as of December 31, 2021
and $21 million as of December 31, 2020. The change in the balance in 2022
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,  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,  2022,  2021  and  2020,  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.

F-12

No  impairments  were  recorded  to  reduce  the  carrying  value  of  our  equity
method investments in 2022, 2021 or 2020.

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, 2022 and 2021, 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,  3  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 in the Consolidated Balance Sheets. Capitalized software costs
are  amortized  on  a  straight-line  basis  over  the  estimated  useful  lives  of  the
software,  generally  5  to  10  years.  Amortization  of  these  costs  is  included  in
depreciation  and  amortization  expense  in  the  Consolidated  Statements  of
Income.

Implementation  costs  incurred  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.

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, or for internal use software, the fair value 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,
2022, these leases have varying lease terms with remaining maturities ranging
from  2  to  14  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.

F-13

Operating  lease  assets  represent  our  right  to  use  an  underlying  asset  for  the
lease  term  and  lease  liabilities  represent  our  obligation  to  make  lease
payments  arising  from  the  lease.  Operating  lease  assets  and  liabilities  are
recognized  at  commencement  date  based  on  the  present  value  of  lease
payments over the lease term. Since our leases do not provide an implicit rate,
we use our incremental borrowing rate based on the estimated rate of interest
for  collateralized  borrowing  over  a  similar  term  of  the  lease  payments  at
commencement date in determining the present value of lease payments. The
operating  lease  asset  also  includes  any  lease  payments  made  and  excludes
lease  incentives.  Our  lease  terms  include  options  to  extend  or  terminate  the
lease when we are reasonably certain that we will exercise that option. Lease
expense for lease payments is recognized on a straight-line basis over the lease
term.  Certain  of  our  lease  agreements  include  rental  payments  adjusted
periodically  for  inflation  based  on  an  index  or  rate.  These  payments  are
included  in  the  initial  measurement  of  the  operating  lease  liability  and
operating lease asset. However, rental payments that are based on a change in
an index or a rate are considered variable lease payments and are expensed as
incurred.

We  have  lease  agreements  with  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.

Goodwill and Indefinite-Lived Intangible Assets

identifiable 

intangibles,  such  as  customer 

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
relationships,
specifically 
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  exceeds
their respective estimated fair values, a quantitative test is required.

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.  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, 2022, 2021 and 2020. 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.

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.

There were no material finite-lived impairment charges in 2022 and 2020. We
recorded pre-tax, non-cash finite-lived intangible assets impairment charges of
$14  million  in  2021  related  to  a  finite-lived  intangible  asset  for  customer
relationships  associated  with  the  wind  down  of  a  previous  acquisition.  In
addition,  we  also  recorded  pre-tax,  non-cash  property  and  equipment  asset
impairment charges of $8 million in 2022, $4 million in 2021 and $14 million
in 2020.

F-14

 
Revenue Recognition and Transaction-Based Expenses

Revenue Recognition

Revenue From Contracts With Customers

Our  revenue  recognition  policies  under  “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 are net of an allowance for
credit  losses  of  $15  million  as  of  December  31,  2022 and $17 million  as  of
December  31,  2021.  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.”  Our  deferred  revenue  primarily
arises from contract liabilities related to our fees for annual and initial listings,
workflow  &  insights,  marketplace  technology  and  anti-financial  crime
contracts. Deferred revenue is the only significant contract asset or liability as
of December 31, 2022. 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.

Sales commissions earned by our sales force are considered incremental and
recoverable  costs  of  obtaining  a  contract  with  a  customer.  These  costs  are
deferred and amortized on a straight-line basis over the period of benefit that
we have determined to be the contract term or estimated service period. Sales
commissions  for  renewal  contracts  are  deferred  and  amortized  on  a  straight-
line basis over the related contractual renewal period. Amortization expense is
included in compensation and benefits expense in the Consolidated Statements
of Income. The balance of deferred costs and related amortization expense are
not  material  to  our  consolidated  financial  statements.  Sales  commissions  are
expensed when incurred if contract durations are one year or less. Sales taxes
are excluded from transaction prices.

Certain judgments and estimates were used in the identification and timing of
satisfaction  of  performance  obligations  and 
the  related  allocation  of
transaction  price  and  are  discussed  below.  We  believe  that  these  represent  a
faithful depiction of the transfer of services to our customers.

Our  primary  revenue  contract  classifications  are  described  below.  Although
we  may  discuss  additional  revenue  details  in  our  “Management's  Discussion
and  Analysis  of  Financial  Condition  and  Results  of  Operations,”  the
categories  below  best  represent 
that  depict  similar  economic
characteristics of the nature, amount, timing and uncertainty of our revenues
and cash flows.

those 

Market Platforms

Trading Services

Transaction-Based Trading and Clearing

Transaction-based trading and clearing includes equity 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.

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.
and  Canadian  cash  equity  trading,  including  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  are  included  in  transaction-based  expenses  in  the
Consolidated  Statements  of  Income.  These  transaction  rebates  are  paid  on  a
monthly  basis  and  the  amounts  due  are  included  in  accounts  payable  and
accrued expenses in the Consolidated Balance Sheets.

F-15

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.

U.S. Tape Plans

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.  These  revenues  are  presented  on  a  net  basis  as  all  indicators  of
principal  versus  agent  reporting  under  U.S.  GAAP  have  been  considered  in
analyzing the appropriate presentation of the revenue sharing. The following
are primary indicators of net reporting:

• We are the administrator for the UTP plan, in addition to being a participant
in the plan. In our unique role as administrator, we facilitate the collection
and  dissemination  of  revenues  on  behalf  of  the  plan  participants.  As  a
participant,  we  share  in  the  net  distribution  of  revenues  according  to  the
plan on the same terms as all other plan participants.

• The operating committee of the plan, which is comprised of representatives
from each of the participants, including us solely in our capacity as a plan
participant,  is  responsible  for  setting  the  level  of  fees  to  be  paid  by
distributors  and  subscribers  and  taking  action  in  accordance  with  the
provisions of the plan, subject to SEC approval.

• Risk  of  loss  on  the  revenue  is  shared  equally  among  plan  participants

according to the plan.

Marketplace Technology

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
offered 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  were  generally  billed  and  recognized  monthly.  As
previously disclosed, in January 2020, we commenced an orderly wind-down
of this broker services business. The wind-down was completed in the second
quarter of 2022.

Market Technology

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

We  enter  into  long-term  contracts  with  customers  to  develop  customized
technology  solutions,  license  the  right  to  use  software,  and  provide  support
and other services to our customers. We also enter into agreements to modify
the system solutions sold by Nasdaq after delivery has occurred. In addition,
we  enter  into  subscription  agreements  which  allow  customers  to  connect  to
our servers to access our software.

Our  long-term  contracts  with  customers  to  develop  customized  technology
solutions,  license  the  right  to  use  software  and  provide  support  and  other
services  to  our  customers  have  multiple  performance  obligations.  The
performance  obligations  are  generally:  (i)  software  license  and  installation
service  and  (ii)  software  support.  We  have  determined  that  the  software
license  and  installation  service  are  not  distinct  as  the  license  and  the
customized  installation  service  are  inputs  to  produce  the  combined  output,  a
functional and integrated software system.

F-16

Capital Access Platforms

Data and Listings

Data revenues are earned from U.S. and European proprietary data products.
We  earn  revenues  primarily  based  on  the  number  of  data  subscribers  and
distributors  of  our  data.  Data  revenues  are  subscription-based  and  are
recognized on a monthly basis.

Listing  services  revenues  primarily  include  initial  listing  fees  and  annual
renewal  fees.  Under  Topic  606,  the  initial  listing  fee  is  allocated  to  multiple
performance  obligations  including  initial  and  subsequent  listing  services  and
corporate  solutions  products  (when  a  company  qualifies  to  receive  certain
complimentary  IPO  products  under  the  applicable  Nasdaq  rule),  as  well  as  a
customer's  material  right  to  renew  the  option  to  list  on  our  exchanges.  In
performing  this  allocation,  the  standalone  selling  price  of  the  performance
obligations  is  based  on  the  initial  and  annual  listing  fees  and  the  standalone
selling price of the 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  amount  of  revenue  related  to  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.

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.

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.  For  the  years  ended  December  31,  2022,  2021  and  2020  we
recognized revenues of $75 million, $77 million and $90 million, respectively,
related to the contracts described above.

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.

F-17

Index

Anti-Financial Crime

are 

generally 

Transaction-based 

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. 
renewable
licenses 
agreements.  Customers  are  charged  based  on  transaction  volume  or  a
minimum  contract  amount,  or  both.  If  a  customer  is  charged  based  on
transaction  volume,  we  recognize  revenue  when  the  transaction  occurs.  If  a
customer  is  charged  based  on  a  minimum  contract  amount,  we  recognize
revenue on a pro-rata basis over the licensing term since the customer receives
and consumes the benefit as Nasdaq provides the service. Asset-based licenses
are  also  generally  renewable  agreements.  Customers  are  charged  based  on  a
percentage of AUM for licensed products, per the agreement, on a monthly or
quarterly  basis.  These  revenues  are  recognized  over  the  term  of  the  license
agreement  since  the  customer  receives  and  consumes  the  benefit  as  Nasdaq
provides the service. Revenue from index data subscriptions are recognized on
a monthly basis.

Workflow & Insights

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.

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

Corporate  solutions  revenues  primarily  include  subscription  and  transaction-
based  income  from  our  investor  relations  intelligence  and  governance
solutions  products  and  services.  Subscription-based  revenues  earned  are
recognized over time on a ratable basis over the contract period beginning on
the date that our service is made available to the customer since the customer
receives and consumes the benefit as Nasdaq provides the service. Generally,
fees are billed in advance and the contract provides for automatic renewal. As
part  of  subscription  agreements,  customers  can  also  be  charged  usage  fees
based upon actual usage of the services provided. Revenues from usage fees
are recognized at a point in time when the service is provided.

Anti-Financial  Crime  revenues  primarily  consist  of  SaaS  revenues.  We  enter
into  subscription  agreements  which  allow  customers  access  to  our  cloud
platform, or in the case of certain surveillance customers, a connection to our
servers  to  access  the  software.  Subscription  agreements  are  generally  three
years  in  term,  payable  in  advance,  with  the  option  of  automatic  renewal  for
some  products.  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.

Other Revenues

Other  revenues  include  revenues  related  to  our  Nordic  broker  services
business  for  which  we  completed  the  wind-down  in  June  2022,  as  well  as
revenues associated with our U.S. Fixed Income business, which was sold in
June  2021.  Prior  to  the  closing  of  the  transaction,  these  revenues  were
included in our Market Platforms and Capital Access Platforms segments. See
“2021  Divestiture,”  of  Note  4,  “Acquisitions  and  Divestiture,”  to  the
consolidated  financial  statements  for  further  discussion  of  this  divestiture.
Additionally, for the years ended December 31, 2021 and 2020, other revenues
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  third-party  financial
institutions.  Prior  to  July  2021,  these  revenues  were  included  in  our  Capital
Access Platforms segment. For the twelve months ended December 31, 2022,
other revenues also include a transitional services agreement associated with a
divested business.

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-18

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.

Fair Value Measurements

Fair value is defined as the price that would be received from selling an asset
or  paid  to  transfer  a  liability,  or  the  exit  price,  in  an  orderly  transaction
between market participants at the measurement date. When determining the
fair  value  measurements  for  assets  and  liabilities  required  or  permitted  to  be
either  recorded  or  disclosed  at  fair  value,  we  consider  the  principal  or  most
advantageous  market  in  which  we  would  transact,  and  we  also  consider
assumptions  that  market  participants  would  use  when  pricing  the  asset  or
liability.  Fair  value  measurement  establishes  a  hierarchy  of  valuation
techniques  based  on  whether  the  inputs  to  those  valuation  techniques  are
observable  or  unobservable.  Observable  inputs  reflect  market  data  obtained
from independent sources, while unobservable inputs reflect Nasdaq’s market
assumptions.  These  two  types  of  inputs  create  the  following  fair  value
hierarchy:

• Level 1 - Quoted prices for identical instruments in active markets.
• Level  2  -  Quoted  prices  for  similar  instruments  in  active  markets;  quoted
prices for identical or similar instruments in markets that are not active; and
model-derived valuations whose inputs are observable or whose significant
value drivers are observable.

• Level 3 - Instruments whose significant value drivers are unobservable.

This hierarchy requires the use of observable market data when available.

See Note 14, “Fair Value of Financial Instruments,” for further discussion.

F-19

Tax Matters

3. REVENUE FROM CONTRACTS WITH CUSTOMERS

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.

Stock Split Effected in the Form of a Stock Dividend

On  August  26,  2022,  we  effected  a  3-for-1  stock  split  of  the  Company's
common stock in the form of a stock dividend to shareholders of record as of
August 12, 2022. The par value per share of our common stock remains $0.01
per share. All references made with respect to a number of shares or per share
amounts throughout this Annual Report on Form 10-K have been retroactively
adjusted to reflect the stock split.

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, 2022,
2021 and 2020:

Market Platforms
Trading Services, net
Marketplace Technology
Capital Access Platforms
Data & Listing Services
Index
Workflow & Insights
Anti-Financial Crime
Other revenues
Revenues less transaction-based
expenses

Year Ended December 31,

2022

2021

2020

(in millions)

$

1,019  $
562 

1,037  $
545 

729 
486 
469 
306 
11 

680 
459 
429 
231 
39 

932 
525 

574 
324 
389 
116 
43 

$

3,582  $

3,420  $

2,903 

Substantially  all  revenues  from  the  Capital  Access  Platforms  and  Anti-
Financial  Crime  segments  as  well  as  our  Marketplace  Technology  business
were recognized over time for the years ended December 31, 2022, 2021 and
2020. For the years ended December 31, 2022, 2021 and 2020 approximately
93.1%,  93.6%,  and  94.8%  respectively,  of  Trading  Services  revenues  were
recognized  at  a  point  in  time  and  6.9%,  6.4%  and  5.2%,  respectively,  were
recognized over time.

Subsequent Events

Contract Balances

We have evaluated subsequent events through the issuance date of this Annual
Report on Form 10-K.

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 $15 million as of December 31, 2022 and $17 million as
of  December  31,  2021.  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  listing  services  contracts,  our  performance  obligations  range
from  three  months  to  three  years  and  there  is  no  significant  variable
consideration.

F-20

 
 
Deferred  revenue  is  the  only  significant  contract  asset  or  liability  as  of
December  31,  2022. 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 Annual and Initial Listings, Workflow & Insights, Market Technology
and Anti-Financial Crime contracts. See Note 8, “Deferred Revenue,” for our
discussion  on  deferred  revenue  balances,  activity,  and  expected  timing  of
recognition.

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, the transaction
price  allocated  to  remaining  performance  obligations  is  included  in  deferred
revenue. For our Market Technology, Anti-Financial Crime, and Workflow &
Insights  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.

The following table summarizes the amount of the transaction price allocated
to performance obligations that are unsatisfied, for contract durations greater
than one year, as of December 31, 2022:

Market Technology

Anti-Financial
Crime

Workflow &
Insights

Total

2023
2024
2025
2026
2027
2028+

Total

$

$

193  $
155 
127 
92 
54 
72 
693  $

(in millions)
382  $
214 
90 
27 
10 
6 
729  $

137  $
79 
30 
11 
8 
— 
265  $

712 
448 
247 
130 
72 
78 
1,687 

4. ACQUISITIONS AND DIVESTITURE

We  completed  the  following  acquisitions  and  divestiture  in  2022  and  2021.
Financial results of each transaction are included in our consolidated financial
statements from the date of each acquisition.

2022 Acquisition

In June 2022, we acquired Metrio, a provider of ESG data collection, analytics
and  reporting  services  based  in  Montreal,  Canada.  We  plan  to  integrate
Metrio’s SaaS platform into our suite of ESG solutions. Metrio is part of our
Workflow & Insight business in our Capital Access Platforms segment.

2021 Divestiture

In June 2021, we sold our U.S. Fixed Income business, which was part of our
FICC  business  within  our  Market  Platforms  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 was included in net gain on divestiture of business in
the Consolidated Statements of Income.

In  connection  with  this  sale,  we  issued  approximately  6.2  million  shares  of
Nasdaq common stock. Nasdaq used 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, in June 2021, the board of directors authorized an increase to the
share repurchase program. These share repurchases were completed during the
second  quarter  of  2022.  See  “Share  Repurchase  Program,”  of  Note  12,
“Nasdaq Stockholders' Equity,” for further discussion.

2021 Acquisition

Acquisition of Verafin

In February 2021, we completed the acquisition of Verafin, a SaaS technology
provider of anti-financial crime management solutions that provides a cloud-
based  platform  to  help  detect,  investigate,  and  report  money  laundering  and
fraud,  for  an  aggregate  purchase  price  of  $2.75  billion,  subject  to  certain
adjustments.  The  $2.75  billion  purchase  price  included  a  cash  payment  of
$102  million,  reflected  in  cash  from  operating  activities  in  our  Consolidated
Statements  of  Cash  Flows,  the  release  of  which  was  subject  to  certain
employment-related  conditions  following  the  closing  of  the  transaction.
During the fourth quarter of 2022, the parties to the transaction agreed that the
remaining amount of the $102 million initial cash payment not yet paid would
be  accelerated  and  paid  to  the  eligible  former  Verafin  employees.  The
remaining  expense  was  recorded  as  merger  and  strategic  initiatives  expense.
Verafin is part of our Anti-Financial Crime segment.

The amounts in the table below represent the final allocation of the purchase
price. The allocation of the purchase price was subject to revision during the
measurement  period,  a  period  not  to  exceed  12  months  from  the  acquisition
date. Adjustments to the provisional values, which may include tax and other
estimates, during the measurement period are recorded in the reporting period
in  which  the  adjustment  amounts  are  determined.  In  2021,  we  recorded  a
measurement period adjustment of $9 million. This adjustment resulted in an
increase to both total net liabilities acquired and goodwill. This adjustment did
not  result  in  an  impact  to  our  Consolidated  Statements  of  Income.  The
allocation of the purchase price for Verafin was finalized in the first quarter of
2022.

F-21

(in millions)

Methodology

Goodwill
Acquired Intangible Assets
Total Net Liabilities Acquired

Purchase Consideration

Intangible Assets

$

$

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.

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

Customer
Relationships

Technology

Trade
Name

Total Acquired
Intangible
Assets

$

532 
7.5 %

$

246 
7.5 %

$

37 
7.5 %

815 

22 years

7 years

20 years

The  discount  rate  used  reflects  the  amount  of  risk  associated  with  the
hypothetical  cash  flows  for  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.

Intangible asset value

(in millions)

$

Discount rate used
Estimated average

useful life

Customer Relationships

Customer  relationships  represent 
relationships with customers.

the  non-contractual  and  contractual

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

The  discount  rate  used  reflects  the  amount  of  risk  associated  with  the
hypothetical  cash  flows  for  the  customer  relationships  relative  to  the  overall
business.  In  developing  a  discount  rate  for  the  customer  relationships,  we
estimated  a  weighted-average  cost  of  capital  for  the  overall  business  and  we
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  that  the  customer
relationships would be amortized for tax purposes over a period of 20 years.

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.

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.”

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.

Pro Forma Results and Acquisition-Related Costs

The consolidated financial statements for the years ended December 31, 2022,
2021 and 2020 include the financial results of the above acquisitions from the
date  of  the  acquisitions.  Pro  forma  financial  results  have  not  been  presented
since these acquisitions 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.

F-22

5. GOODWILL AND ACQUIRED INTANGIBLE ASSETS

Acquired Intangible Assets

Goodwill

The  following  table  presents  the  changes  in  goodwill  by  business  segment
during the year ended December 31, 2022:

(in millions)

Market Platforms
Balance at December 31, 2021
Foreign currency translation adjustments

Balance at December 31, 2022
Capital Access Platforms
Balance at December 31, 2021
Goodwill acquired
Foreign currency translation and other adjustments

Balance at December 31, 2022
Anti-Financial Crime
Balance at December 31, 2021
Foreign currency translation adjustments

Balance at December 31, 2022

Total
Balance at December 31, 2021
Balance at Goodwill acquired
Foreign currency translation adjustments

Balance at December 31, 2022

$

$

$

$

$

$

$

$

3,129 
(217)
2,912 

4,292 
40 
(154)
4,178 

1,012 
(3)
1,009 

8,433 
40 
(374)
8,099 

In  the  table  above,  the  December  31,  2021  balances  reflect  the  revised
goodwill  following  our  corporate  realignment.  As  of  October  1,  2022,  as
required under ASC 350-20, the carrying value of goodwill was reassigned to
our  new  reportable  segments  based  on  a  relative  fair  value  allocation
approach.

As  of  December  31,  2022,  the  amount  of  goodwill  that  is  expected  to  be
deductible for tax purposes in future periods is $35 million.

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,  2022,  2021  and
2020;  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.

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

Finite-Lived Intangible Assets
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 finite-lived intangible assets

Indefinite-Lived Intangible Assets
Exchange and clearing registrations
Trade names
Licenses
Foreign currency translation adjustment
Total indefinite-lived intangible assets

Total intangible assets, net

December 31, 2022

December 31, 2021

(in millions)

$

$

$

$

$

$

$

$
$

304  $

2,005 
60 
(209)
2,160  $

(97) $
(778)
(17)
120 
(772) $

207  $

1,227 
43 
(89)
1,388  $

1,257  $
121 
52 
(237)
1,193  $
2,581  $

295 
2,050 
60 
(143)
2,262 

(54)
(711)
(11)
81 
(695)

241 
1,339 
49 
(62)
1,567 

1,257 
121 
52 
(184)
1,246 
2,813 

There  was  no  impairment  of  indefinite-lived  intangible  assets  for  the  years
ended December 31, 2022, 2021 and 2020. 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 2022 and
2020.

F-23

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

Year Ended December 31,

2022

2021

(in millions)

2020

Amortization expense

$

153  $

170  $

103 

The table below presents the estimated future amortization expense (excluding
the  impact  of  foreign  currency  translation  adjustments  of  $89  million  as  of
December 31, 2022) of acquired finite-lived intangible assets as of December
31, 2022:

2023
2024
2025
2026
2027
2028+

Total

(in millions)

159 
153 
151 
148 
147 
719 
1,477 

$

$

6. INVESTMENTS

The following table presents the details of our investments:

December 31, 2022

December 31, 2021

Financial investments
Equity method investments
Equity securities

$

Financial Investments

(in millions)
181  $
390 
86 

208 
363 
67 

Financial  investments  are  comprised  of  trading  securities,  primarily  highly
rated  European  government  debt  securities,  of  which  $161  million  as  of
December  31,  2022  and  $162  million  as  of  December  31,  2021,  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,  2022  and  2021,  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 impairments were
recorded for the years end December 31, 2022, 2021 and 2020.

Net income recognized from our equity interest in the earnings and losses of
these  equity  method  investments,  primarily  OCC,  was  $31  million,  $52
million  and  $70  million  for  the  years  ended  December  31,  2022,  2021  and
2020,  respectively.  For  the  year  ended  December  31,  2022,  lower  equity
interest in the earnings of OCC, as compared to 2021, was primarily driven by
a reduction in the clearing fee rate that OCC charges its customers, partially
offset by elevated U.S. industry trading volumes.

Equity Securities 

in 

the  Consolidated  Balance  Sheets.  We  elected 

The  carrying  amounts  of  our  equity  securities  are  included  in  other  non-
current  assets 
the
measurement alternative for substantially 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 years ended December 31,
2022, 2021 and 2020. As of December 31, 2022 and December 31, 2021, our
equity  securities  primarily  represent  various  strategic  investments  made
through  our  corporate  venture  program  as  well  as  investments  acquired
through various acquisitions.

7. PROPERTY AND EQUIPMENT, NET

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

Data processing equipment and software
Furniture, equipment and leasehold
improvements
Total property and equipment
Less: accumulated depreciation and
amortization and impairment charges

Total property and equipment, net

Year Ended December 31,

2022

2021

(in millions)
786  $

305 
1,091 

(559)
532  $

735 

288 
1,023 

(514)
509 

$

$

Depreciation and amortization expense for property and equipment was $105
million  for  the  year  ended  December  31,  2022,  $108  million  for  the  year
ended December 31, 2021, and $99 million for the year ended December 31,
2020. 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
$8 million in 2022, $4 million in 2021 and $14 million in 2020. These charges
are  included  in  restructuring  charges  in  the  Consolidated  Statements  of
Income. See Note 20, “Restructuring Charges,” for further discussion. There
were  no  other  material  impairments  of  property  and  equipment  recorded  in
2022, 2021 and 2020.

As of December 31, 2022 and 2021, we did not own any real estate properties.

F-24

 
 
 
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, 2022 are reflected in the following table: 

Balance at

December 31, 2021 Additions Revenue Recognized
(in millions)

Adjustments

Balance at
December 31, 2022

Market Platforms:
Market

Technology

$

Capital Access Platforms:

Initial Listing

Annual Listings
Workflow &
Insights

Anti-Financial

Crime

Other

Total

$

In the above table:

36  $

28  $

(30) $

(5) $

145 
2 

159 

81 
25 
448  $

25 
3 

166 

106 
12 
340  $

(51)
(2)

(152)

(79)
(13)
(327) $

(3)
(1)

(1)

— 
(3)
(13) $

29 

116 
2 

172 

108 
21 
448 

• Additions primarily reflect deferred revenue billed in the current period, net

of recognition.

• Revenue recognized includes revenue recognized during the current period

that was included in the beginning balance.

• Adjustments reflect foreign currency translation adjustments.

• Other  primarily  includes  deferred  revenue  from  our  Index  business,  data
contracts  and  non-U.S.  listing  of  additional  shares  fees.  These  fees  are
included in our Capital Access Platforms segment.

As  of  December  31,  2022,  we  estimate  that  our  deferred  revenue  will  be
recognized in the following years:
Fiscal year
ended:

2028+

Total

2023

2025

2027

2024

2026
(in millions)

Market Platforms:
Market

Technology

$

28  $

1  $ —  $ —  $ —  $ —  $

29 

Capital Access Platforms:

Initial Listings

Annual Listings
Workflow &
Insights

Anti-Financial

Crime

Other

Total

$

40 
2 

169 

106 
12 
357  $

30 
— 

3 

2 
5 
41  $

20 
— 

— 

— 
3 
23  $

17 
— 

— 

— 
1 
18  $

8 
— 

— 

— 
— 

1 
— 

— 

— 
— 

8  $

1  $

116 
2 

172 

108 
21 
448 

The  timing  of  recognition  of  deferred  revenue  related  to  certain  market
technology  contracts  is  primarily  dependent  upon  the  completion  of
customization  and  any  significant  modifications  made  pursuant  to  existing
market  technology  contracts.  As  such,  as  it  relates  to  market  technology
revenues, the timing represents our best estimate.

F-25

 
9. DEBT OBLIGATIONS

Senior Unsecured Notes

The following table presents the changes in the carrying amount of our debt
obligations during the year ended December 31, 2022:

December 31,
2021

Additions

Payments,
Foreign
Currency
Translation and
Accretion

December 31, 2022

(in millions)

3,685  $
— 
— 

3,685  $

$

1,517  $

420  $
598
499 

Short-term debt:
Commercial
paper
2022 Notes
2024 Notes
Total short-term
debt
$
Long-term debt - senior unsecured notes:
2026 Notes
2029 Notes
2030 Notes
2050 Notes
2031 Notes
2040 Notes
2033 Notes
2052 Notes
2022 Credit
Facility

498 
676 
676 
486 
643 
644 
694 
— 

(4)

— 
— 
— 
— 
— 
— 
— 
541 

(2)

(3,441) $
(598)
(499)

(4,538) $

— 
(39)
(39)
— 
1 
— 
(41)
— 

1 

664 
— 
— 

664 

498 
637 
637 
486 
644 
644 
653 
541 

(5)

Total long-term
debt
Total debt
obligations

$

$

4,313  $

539  $

(117) $

4,735 

5,830  $

4,224  $

(4,655) $

5,399 

In the table above, the 2024 Notes were reclassified to short-term debt as of
March 31, 2022.

The long-term debt senior unsecured notes in the table above, and discussion
below, are listed based on their issuance date.

Commercial Paper Program

Our  U.S.  dollar  commercial  paper  program  is  supported  by  our  2022  Credit
Facility  which  provides  liquidity  support  for  the  repayment  of  commercial
paper  issued  through  this  program.  See  “2022  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  January  2022,  we  issued  commercial  paper  to  partially  fund  our  ASR
agreement.  See  “ASR  Agreement,”  of  Note  12,  “Nasdaq  Stockholders'
Equity.” In December 2022, we issued commercial paper to repay in full and
redeem our 2022 Notes. For further discussion see “2022 Notes” below. As of
December 31, 2022, we had $664 million outstanding under our commercial
paper program.

Our  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, 2022, 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”  column  also
includes  the  impact  of  foreign  currency  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.

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.

Early Extinguishment of 2024 Notes

In May 2014, Nasdaq issued the 2024 Notes, which paid interest semiannually
at  a  rate  of  4.25%  per  annum.  In  April  2022,  we  primarily  used  the  net
proceeds from the 2052 Notes to repay in full and redeem our 2024 Notes. For
further  discussion  see  “2052  Notes”  below.  In  connection  with  the  early
extinguishment of the 2024 Notes, in April 2022 we recorded a pre-tax charge
of  $16  million,  which  primarily  includes  a  make-whole  redemption  price
premium.

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%.

F-26

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 $39 million noted in the “Payments, Foreign Currency Translation
and  Accretion”  column 
the
remeasurement  of  the  2029  Notes  into  U.S.  dollars  and  is  recorded  in
accumulated other comprehensive loss within Nasdaq's stockholders’ equity in
the Consolidated Balance Sheets as of December 31, 2022.

table  above  primarily 

reflects 

the 

in 

2030 Notes

In February 2020, Nasdaq issued the 2030 Notes, which pay interest annually
at a rate of 0.875% 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  $39  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  is  recorded  in  accumulated  other
comprehensive loss within Nasdaq's stockholders’ equity in the Consolidated
Balance Sheets as of December 31, 2022.

2050 Notes

In  April  2020,  Nasdaq  issued  the  2050  Notes,  which  pay  interest  semi-
annually  at  a  rate  of  3.25%  per  annum  until  April  28,  2050.  Such  rate  may
vary  with  Nasdaq's  debt  rating,  to  the  extent  Nasdaq  is  downgraded  below
investment grade, up to a rate not to exceed 5.25%.

2022, 2031 and 2040 Notes

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.”

2022 Notes

In December 2022, we used the net proceeds from commercial paper to repay,
in full, the 2022 Notes. The 2022 Notes paid interest semi-annually in arrears,
which began on June 21, 2021.

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  the  2033  Notes,  which  pay  interest  annually  in
arrears, at a rate of 0.900%, beginning on July 30, 2022.

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 $41 million noted in the “Payments, Foreign Currency Translation
and  Accretion”  column 
the
remeasurement  of  the  2033  Notes  into  U.S.  dollars  and  is  recorded  in
accumulated other comprehensive loss within Nasdaq stockholders’ equity in
the Consolidated Balance Sheets as of December 31, 2022.

table  above  primarily 

reflects 

the 

in 

2052 Notes

In  March  2022,  Nasdaq  issued  $550  million  aggregate  principal  amount  of
3.950% senior notes due in 2052, which pay interest semi-annually in arrears,
beginning on September 7, 2022. The interest rate of 3.950% may vary with
Nasdaq's  debt  rating,  to  the  extent  Nasdaq  is  downgraded  below  investment
grade,  up  to  a  rate  not  to  exceed  5.950%.  The  net  proceeds  from  the  2052
Notes  were  $541  million  after  deducting  the  underwriting  discount  and
expenses  of  the  offering.  We  used  the  net  proceeds  from  the  2052  Notes  to
redeem all of the 2024 Notes in April 2022.

Credit Facilities

2022 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).  We  amended  and  restated  the  2020  Credit
Facility in December 2022 with a new maturity date of December 16, 2027.
Nasdaq  intends  to  use  funds  available  under  the  2022  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  2022  Credit  Facility  at  any  time  in
whole or in part, without penalty.

As  of  December  31,  2022,  no  amounts  were  outstanding  on  the  2022  Credit
Facility. The $(5) million balance represents unamortized debt issuance costs
which  are  being  accreted  through  interest  expense  over  the  life  of  the  credit
facility.

F-27

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 SOFR (or a successor rate to SOFR), the base rate (as defined in the
2022  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  0.100%  to  0.250%,  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 years ended
December 31, 2022 and 2021.

The 2022 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  to  incur  additional
indebtedness,  grant  liens  on  assets,  dispose  of  assets  and  make  certain
restricted  payments.  The  facility  also  contains  customary  affirmative
covenants,  including  access  to  financial  statements,  notice  of  defaults  and
certain  other  material  events,  maintenance  of  properties  and  insurance,  and
customary  events  of  default,  including  cross-defaults  to  our  material
indebtedness.

The  2022  Credit  Facility  includes  an  option  for  Nasdaq  to  increase  the
available  aggregate  amount  by  up  to  $750  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  $184  million  as  of
December  31,  2022  and  $212  million  as  of  December  31,  2021  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, 2022 and 2021.

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

Debt Covenants

As of December 31, 2022, 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  which  is  a  voluntary  defined  contribution  savings
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 is included in compensation and benefits
expense in the Consolidated Statements of Income:

Year Ended December 31,

2022

2021

(in millions)

2020

Savings Plan expense

$

17  $

14  $

14 

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:

Year Ended December 31,

2022

2021

(in millions)

2020

Retirement Plans expense

$

24  $

26  $

23 

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.

As of December 31, 2022, the fair value of our U.S. defined-benefit pension
plan's assets was $79 million and the benefit obligation was $81 million. As a
result, the U.S. defined-benefit pension plan is underfunded by $2 million as
of December 31, 2022.

As of December 31, 2021, the fair value of our U.S. defined-benefit pension
plan's assets was $111 million and the benefit obligation was $112 million. As
a result, the U.S. defined-benefit pension plan was underfunded by $1 million
as of December 31, 2021.

F-28

Summary of Share-Based Compensation Expense

The  following  table  presents  the  total  share-based  compensation  expense
resulting  from  equity  awards  and  the  15.0%  discount  for  the  ESPP  for  the
years  ended  December  31,  2022,  2021  and  2020,  which  is  included  in
compensation and benefits expense in the Consolidated Statements of Income:

Year Ended December 31,

2022

2021

2020

(in millions)

Share-based compensation
expense before income taxes

$

106  $

90  $

87 

Common Shares Available Under Our Equity Plan

As  of  December  31,  2022,  we  had  approximately  26.4  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  grant  date,  33.3%  on  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.

During  2022  and  2021,  we  did  not  make  any  contributions  to  our  U.S.
defined-benefit pension plan. For our SERP and other post-retirement benefit
plans, the net underfunded liability was $28 million as of December 31, 2022
and  $34  million  as  of  December  31,  2021.  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, 2022, accumulated other comprehensive
loss for the Nasdaq Benefit Plans was $23 million reflecting an unrecognized
net loss of $28 million, partially offset by an income tax benefit of $5 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:

Pension

SERP

Post-retirement

Total

Fiscal Year Ended:
2023
2024
2025
2026
2027
2028 through 2032

$

$

8  $
7 
7 
8 
8 
33 
71  $

(in millions)
5  $
3 
3 
2 
2 
7 
22  $

—  $
— 
— 
— 
— 
2 
2  $

13 
10 
10 
10 
10 
42 
95 

Nonqualified Deferred Compensation Plan

In  June  2022,  we  established  the  Nasdaq,  Inc.  Nonqualified  Deferred
Compensation  Plan.  This  plan  provides  certain  eligible  employees  with  the
opportunity  to  defer  a  portion  of  their  annual  salary  and  bonus  up  to  certain
approval  limits.  All  deferrals  and  associated  earnings  are  our  general
unsecured obligations and were immaterial for the year ended December 31,
2022.

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.
Generally, annual employee awards are granted on April 1st of each year.

F-29

 
 
 
 
 
Summary of Restricted Stock Activity

Three-Year PSU Program

The  following  table  summarizes  our  restricted  stock  activity  for  the  years
ended December 31, 2022, 2021 and 2020:

Restricted Stock

Number of Awards

Weighted-Average Grant
Date Fair Value

Unvested at December 31, 2019
Granted
Vested
Forfeited
Unvested at December 31, 2020
Granted
Vested
Forfeited
Unvested at December 31, 2021
Granted
Vested
Forfeited

Unvested at December 31, 2022

4,460,268  $
2,229,900 
(1,498,071)
(274,944)
4,917,153  $
1,523,235 
(1,624,809)
(416,559)
4,399,020  $
1,785,138 
(1,525,442)
(278,203)
4,380,513  $

25.79 
29.98 
24.32 
27.06 
28.07 
50.52 
27.78 
34.04 
35.39 
57.65 
31.22 
42.07 
45.48 

As  of  December  31,  2022,  $111  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

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.  The  performance  periods  are
complete  for  all  PSUs  granted  under  the  one-year  performance-based
program,  and  all  shares  underlying  these  PSUs  have  vested  as  of  December
31, 2022.

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  ratably  on  an  annual  basis  over  a
three-year  period  commencing  with  the  end  of  the  one-year  performance
period.  Compensation  cost  was  recognized  over  the  performance  period  and
the  three-year  vesting  period  based  on  the  probability  that  such  performance
measures will be achieved, taking into account an estimated forfeiture rate.

Under  the  three-year  performance-based  program,  each  eligible  individual
receives  PSUs,  subject  to  market  conditions,  with  a  three-year  cumulative
performance  period  that  vest  at  the  end  of  the  performance  period.
Compensation  cost  is  recognized  over  the  three-year  performance  period,
taking  into  account  an  estimated  forfeiture  rate,  regardless  of  whether  the
market  condition  is  satisfied,  provided  that  the  requisite  service  period  has
been completed. Performance will be determined by comparing Nasdaq’s TSR
to  two  peer  groups,  each  weighted  50.0%.  The  first  peer  group  consists  of
exchange companies, and the second peer group consists of all companies in
the  S&P  500.  Nasdaq’s  relative  performance  ranking  against  each  of  these
groups will determine the final number of shares delivered to each individual
under  the  program.  The  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.

Grants of PSUs that were issued in 2020 with a three-year performance period
exceeded  the  applicable  performance  parameters.  As  a  result,  an  additional
764,748  units  above  the  original  target  were  granted  in  the  first  quarter  of
2023 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, 2022 and 2021:

Weighted-average risk free interest
rate
Expected volatility
Weighted-average grant date share
price
Weighted-average fair value at grant
date

$

$

Year Ended December 31,

2022

2021

2.61 %
30.04 %

60.55 

63.68 

$

$

0.33 %
30.30 %

51.88 

72.75 

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.

F-30

 
 
 
Summary of PSU Activity

The  following  table  summarizes  our  PSU  activity  for  the  years  ended
December 31, 2022, 2021 and 2020:

PSUs

One-Year Program

Three-Year Program

Number of
Awards

Weighted-
Average Grant
Date Fair
Value

Number of Awards

Weighted-
Average Grant
Date Fair Value

Unvested at
December 31,
2019
Granted
Vested
Forfeited
Unvested at
December 31,
2020
Granted
Vested
Forfeited
Unvested at
December 31,
2021
Granted
Vested
Forfeited
Unvested at
December 31,
2022

951,753  $
80,340 
(415,269)
(108,180)

508,644  $
— 
(299,292)
(60,150)

149,202  $
— 
(142,459)
(6,743)

26.96 
28.06 
26.03 
27.47 

27.78 
— 
27.66 
27.76 

28.01 
— 
28.02 
27.85 

2,392,353    $
960,984 
(902,301)
(21,069)

2,429,967    $
1,081,707 
(1,178,181)
(41,121)

2,292,372  $
1,495,092 
(1,735,842)
(85,080)

32.77 
35.81 
27.19 
32.75 

36.04 
58.66 
38.95 
47.43 

45.01 
45.66 
32.57 
52.27 

—  $

— 

1,966,542  $

56.44 

In the table above, the granted amount under the three-year program reflects
additional  awards  granted  based  on  overachievement  of  performance
parameters.

As of December 31, 2022, total unrecognized compensation cost related to the
three-year PSU program is $44 million and is expected to be recognized over
a weighted-average period of 1.3 years.

A summary of stock option activity for the years ended December 31, 2022,
2021 and 2020 is as follows:

Number of Stock
Options

Weighted-
Average Exercise
Price

Weighted-
Average
Remaining
Contractual
Term (in
years)

Aggregate
Intrinsic
Value (in
millions)

Outstanding at December

31, 2019

Exercised
Forfeited
Outstanding at December

31, 2020

Exercised
Forfeited
Outstanding at December
31, 2021
Granted
Outstanding at December
31, 2022
Exercisable at December 31,
2022

1,137,306  $
(255,585)
(1,662)

880,059  $
(73,227)
(381)

806,451  $
613,872 

18.11 
7.97 
6.98 

21.07 
8.43 
8.43 

22.23 
67.49 

1,420,323  $

41.79 

806,451  $

22.23 

5.5 $

20 

5.0 $

39 

6.2 $

4.0 $

32 

32 

The net cash proceeds from the exercise of 73,227 stock options for the year
ended  December  31,  2021  was  $1  million.  The  net  cash  proceeds  from  the
exercise of 255,585 stock options for the year ended December 31, 2020 was
$2 million. The total pre-tax intrinsic value of stock options exercised was $3
million  for  the  year  ended  December  31,  2021  and  $9  million  for  the  year
ended December 31, 2020.

As  of  December  31,  2022,  the  aggregate  pre-tax  intrinsic  value  of  the
outstanding and exercisable stock options in the above table was $32 million
and  $32  million,  respectively,  and  represents  the  difference  between  our
closing  stock  price  on  December  31,  2022  of  $61.35  and  the  exercise  price,
times the number of shares that would have been received by the option holder
had  the  option  holder  exercised  the  stock  options  on  that  date.  This  amount
can  change  based  on  the  fair  market  value  of  our  common  stock.  As  of
December  31,  2021,  0.8  million  outstanding  stock  options  were  exercisable
and the weighted-average exercise price was $22.23. 

Stock Options

ESPP

In January 2022, in connection with a new five year employment agreement,
our  Chief  Executive  Officer  received  an  aggregate  of  613,872  performance-
based non-qualified stock options, which will vest as follows:

• 50%  will  vest  contingent  upon  the  achievement  of  certain  performance

conditions; and

• 50%  will  vest  five  years  after  the  grant  date,  subject  to  continued

employment through such date.

The fair value of stock options are estimated using the Black-Scholes option-
pricing  model.  These  options  expire  10  years  after  the  date  of  grant.  There
were no stock option awards granted for the years ended December 31, 2021
and 2020.

We  have  an  ESPP  under  which  approximately  12.1  million  shares  of  our
common  stock  were  available  for  future  issuance  as  of  December  31,  2022.
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.

F-31

 
 
 
Number of shares
purchased by employees
Weighted-average price
of shares purchased
Compensation expense

(in millions)

$

$

Year Ended December 31,

2022

2021

2020

591,820 

605,274 

663,369 

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, 2022:

Year Ended December 31,
2022

43.54  $

41.41  $

31.93 

8  $

7  $

5 

Number of shares of common stock repurchased
Average price paid per share
Total purchase price (in millions)

$
$

5,465,595 
56.26 
308 

12. NASDAQ STOCKHOLDERS' EQUITY

Common Stock

As  of  December  31,  2022,  900,000,000  shares  of  our  common  stock  were
authorized,  513,157,630  shares  were  issued  and  491,592,491  shares  were
outstanding.  As  of  December  31,  2021,  900,000,000  shares  of  our  common
stock  were  authorized,  520,256,817  shares  were  issued  and  500,038,905
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 21,565,139 shares of
common stock in treasury as of December 31, 2022 and 20,217,912 shares as
of  December  31,  2021,  most  of  which  are  related  to  shares  of  our  common
stock  withheld  for  the  settlement  of  employee  tax  withholding  obligations
arising from the vesting of restricted stock and PSUs.

Share Repurchase Program

As of December 31, 2022, our board of directors authorized an increase to our
share  repurchase  program  and  the  remaining  aggregate  authorized  amount
under the existing share repurchase program was $650 million.

These repurchases may be made from time to time at prevailing market prices
in  open  market  purchases,  privately-negotiated  transactions,  block  purchase
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.

In  the  table  above,  the  number  of  shares  of  common  stock  repurchased
excludes  an  aggregate  of  1,347,227  shares  withheld  upon  the  vesting  of
restricted stock and PSUs for the year ended December 31, 2022.

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

ASR Agreement

In  January  2022,  we  entered  into  an  ASR  agreement  to  repurchase  $325
million of common stock. We received a total delivery of 5,629,161 shares of
common  stock  and  completed  the  ASR  program  during  the  first  quarter  of
2022.

Preferred Stock

Our  certificate  of  incorporation  authorizes  the  issuance  of  30,000,000  shares
of preferred stock, par value $0.01 per share, issuable from time to time in one
or more series. As of December 31, 2022 and December 31, 2021, no shares
of preferred stock were issued or outstanding.

Stock Split

See “Stock Split Effected in the Form of a Stock Dividend,” of Note 2, “Basis
of Presentation and Principles of Consolidation.”

Cash Dividends on Common Stock

During  2022,  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 26, 2022
April 20, 2022

$

July 19, 2022

October 19, 2022

March 11,
2022
June 10, 2022
September 16,
2022
December 2,
2022

0.18 
0.20 

0.20 

0.20 

$

$

88 
98 

99 

98 
383 

Payment Date

March 25,
2022
June 24, 2022
September 30,
2022
December 16,
2022

The  total  amount  paid  of  $383  million  was  recorded  in  retained  earnings
within  Nasdaq's  stockholders'  equity  in  the  Consolidated  Balance  Sheets  at
December 31, 2022.

F-32

 
 
 
 
 
14. FAIR VALUE OF FINANCIAL INSTRUMENTS

The  following  tables  present  our  financial  assets  and  financial  liabilities  that
were measured at fair value on a recurring basis as of December 31, 2022 and
December 31, 2021.

December 31, 2022

Total

Level 1

Level 2

Level 3

(in millions)

$

147  $

147  $

—  $

— 

7 

7 

— 

— 

7 

7 

20 
181  $

— 
147  $

20 
34  $

December 31, 2021

— 

— 

— 
— 

Total

Level 1

Level 2

Level 3

(in millions)

In  January  2023,  the  board  of  directors  approved  a  regular  quarterly  cash
dividend of $0.20 per share on our outstanding common stock. The dividend is
payable on March 31, 2023 to shareholders of record at the close of business
on March 17, 2023. The estimated aggregate payment of this dividend is $98
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.

13. EARNINGS PER SHARE

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

European government
debt securities

Year Ended December 31,

2022

2021

2020

(in millions, except share and per share amounts)

Corporate debt
securities

Numerator:
Net income

attributable to
common shareholders $

Denominator:
Weighted-average
common shares
outstanding for basic
earnings per share

1,125  $

1,187  $

933 

492,420,787 

497,698,377 

493,245,573 

State-owned enterprises
and municipal
securities

Swedish mortgage
bonds

Weighted-average effect of dilutive securities:

Employee equity

awards

Contingent issuance
of common stock

Weighted-average
common shares
outstanding for
diluted earnings per
share

5,436,778 

7,389,189 

6,406,596 

Total assets at fair value $

— 

— 

1,059,654 

497,857,565 

505,087,566 

500,711,823 

Basic and diluted earnings per share:
Basic earnings per

share

$

2.28  $

Diluted earnings per

share

$

2.26  $

2.38  $

2.35  $

1.89 

1.86 

European government
debt securities

Corporate debt
securities

In the table 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.

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 and 2020.

$

144  $

144  $

—  $

— 

20 

— 

20 

— 

State-owned enterprises
and municipal
securities

Swedish mortgage
bonds

Time deposits
Total assets at fair value $

11 

— 

11 

21 
12 
208  $

— 
— 
144  $

21 
12 
64  $

— 

— 
— 
— 

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
through  our  corporate  venture  program.  See  “Equity  Method
made 
Investments,”  and  “Equity  Securities,”  of  Note  6,  “Investments,”  for  further
discussion.

F-33

 
 
We  also  consider  our  debt  obligations  to  be  financial  instruments.  As  of
December  31,  2022,  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 2022 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,  2022,  we  had  no
outstanding borrowings under our 2022 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. As of December 31,
2022, we had $664 million outstanding under our commercial paper program.
The fair value of our remaining debt obligations utilizing discounted cash flow
analyses  for  our  floating  rate  debt,  and  prevailing  market  rates  for  our  fixed
rate  debt  was  $4.4  billion  as  of  December  31,  2022  and  $5.9  billion  as  of
December  31,  2021.  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, 2022
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, 2022 and December 31, 2021, 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. 

Through  our  clearing  operations  in  the  financial  markets,  which  include  the
resale  and  repurchase  market,  the  commodities  markets,  and  the  seafood
market,  Nasdaq  Clearing  is  the  legal  counterparty  for,  and  guarantees  the
fulfillment of, each contract cleared. These contracts are not used by Nasdaq
Clearing  for  the  purpose  of  trading  on  its  own  behalf.  As  the  legal
counterparty of each transaction, Nasdaq Clearing bears the counterparty risk
between the purchaser and seller in the contract. In its guarantor role, Nasdaq
Clearing  has  precisely  equal  and  offsetting  claims  to  and  from  clearing
members  on  opposite  sides  of  each  contract,  standing  as  the  CCP  on  every
contract  cleared.  In  accordance  with  the  rules  and  regulations  of  Nasdaq
Clearing,  default  fund  and  margin  collateral  requirements  are  calculated  for
each  clearing  member’s  positions  in  accounts  with  the  CCP.  See  “Default
Fund  Contributions  and  Margin  Deposits”  below  for  further  discussion  of
Nasdaq Clearing’s default fund and margin requirements.

Nasdaq Clearing maintains 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. See “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.

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.

F-34

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  $29  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.  The
most recent hearing took place in October 2022, and we received the decision
in November 2022. The court decided to reduce the administrative fine issued
by the SFSA from 300 million SEK to 250 million SEK (approximately $24
million).  In  December  2022,  Nasdaq  Clearing  appealed  the  decision  of  the
Administrative  Court  of  Appeal  to  the  Supreme  Administrative  Court  of
Appeal. While we continue to firmly believe in the merit of our appeal, due to
the 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.  A  charge  for  $29  million  was  recorded  to  regulatory  expense  in  our
Consolidated Statements of Income for the year ended December 31, 2021. As
a  result  of  the  reduced  fine  communication  in  2022,  we  have  released  $5
million to regulatory expense for the year ended December 31, 2022.

Default Fund Contributions and Margin Deposits

As  of  December  31,  2022,  clearing  member  default  fund  contributions  and
margin deposits were as follows:

Cash Contributions

December 31, 2022

Non-Cash
Contributions

(in millions)

Total Contributions

$

$

1,345 
5,676 
7,021 

$

$

115 
7,683 
7,798 

$

$

1,460 
13,359 
14,819 

Default fund

contributions
Margin deposits

Total

Of the total default fund contributions of $1,460 million, Nasdaq Clearing can
utilize  $1,377  million  as  capital  resources  in  the  event  of  a  counterparty
default.  The  remaining  balance  of  $83  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  one
year or less, reverse repurchase agreements and multilateral development bank
debt securities. Investments in

reverse  repurchase  agreements  range  in  maturity  from  2  to  10  days  and  are
secured with highly rated government securities and multilateral development
banks. 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 $7,021 million as
of  December  31,  2022  and  $5,911  million  as  of  December  31,  2021,  in
accordance with its investment policy as follows:

December 31, 2022

December 31, 2021

$

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)

4,775  $
1,695 
6,470  $
222 
192 

137 
551  $
7,021  $

3,061 
2,013 
5,074 
414 
152 

271 
837 
5,911 

In the table above, the change from December 31, 2021 to December 31, 2022
includes currency translation adjustments of $1,255 million for restricted cash
and cash equivalents and $75 million for investments.

For the years ended December 31, 2022, 2021 and 2020 investments related to
default  funds  and  margin  deposits,  net  includes  purchases  of  investment
securities  of  $47,525  million,  $41,098  million  and  $54,046  million,
respectively, and proceeds from sales and redemptions of investment securities
of $47,736 million, $40,966 million and $54,155 million, respectively.

In the investment activity related to default fund and margin contributions, we
are  exposed  to  counterparty  risk  related  to  reverse  repurchase  agreement
transactions,  which  reflect  the  risk  that  the  counterparty  might  become
insolvent  and,  thus,  fail  to  meet  its  obligations  to  Nasdaq  Clearing.  We
mitigate  this  risk  by  only  engaging  in  transactions  with  high  credit  quality
reverse  repurchase  agreement  counterparties  and  by  limiting  the  acceptable
collateral  under  the  reverse  repurchase  agreement  to  high  quality  issuers,
primarily government securities and other securities explicitly guaranteed by a
government.  The  value  of  the  underlying  security  is  monitored  during  the
lifetime  of  the  contract,  and  in  the  event  the  market  value  of  the  underlying
security  falls  below  the  reverse  repurchase  amount,  our  clearinghouse  may
require additional collateral or a reset of the contract.

Default Fund Contributions

Required contributions to the default funds are proportional to the exposures
of each clearing member. When a clearing member is active in more than one
market, contributions must be made to all markets’ default funds in which the

F-35

 
 
 
 
 
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 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, 2022, Nasdaq Clearing committed capital totaling
$125  million  to  the  liability  waterfall  and  overall  regulatory  capital,  in  the
form  of  government  debt  securities,  which  are  recorded  as  financial
investments  in  the  Consolidated  Balance  Sheets.  The  combined  regulatory
capital of the clearing members and Nasdaq Clearing is intended to secure the
obligations of a clearing member exceeding such member’s own margin and
default fund deposits and may be used to cover losses sustained by a clearing
member in the event of a default.

Margin Deposits

Nasdaq  Clearing  requires  all  clearing  members  to  provide  collateral,  which
may consist of cash and non-cash contributions, to guarantee performance on
the clearing members’ open positions, or initial margin. In addition, clearing
members must also provide collateral to cover the daily margin call if needed.
See  “Default  Fund  Contributions”  above  for  further  discussion  of  cash  and
non-cash contributions.

Similar to default fund contributions, Nasdaq Clearing maintains and manages
all  cash  deposits  related  to  margin  collateral.  All  risks  and  rewards  of
collateral  ownership,  including  interest,  belong  to  Nasdaq  Clearing  and  are
recorded  in  revenues.  These  cash  deposits  are  recorded  in  default  funds  and
margin deposits in the Consolidated Balance Sheets as both a current asset and
a current liability.

Pledged margin collateral is not recorded in our Consolidated Balance Sheets
as all risks and rewards of collateral ownership, including interest, belong to
the  counterparty.  Assets  pledged  are  held  at  a  nominee  account  in  Nasdaq
Clearing’s name for the benefit of the clearing members and are immediately
accessible by Nasdaq Clearing in the event of a default.

Nasdaq  Clearing  marks  to  market  all  outstanding  contracts  and  requires
payment from clearing members whose positions have lost value. The mark-
to-market process helps identify any clearing members that may not be able to
satisfy  their  financial  obligations  in  a  timely  manner  allowing  Nasdaq
Clearing the ability to mitigate the risk of a clearing member defaulting due to
exceptionally  large  losses.  In  the  event  of  a  default,  Nasdaq  Clearing  can
access the defaulting member’s margin and default fund deposits to cover the
defaulting member’s losses.

Regulatory Capital and Risk Management Calculations

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

As  mentioned  above,  Nasdaq  Clearing  is  the  legal  counterparty  for  each
contract  cleared  and  thereby  guarantees  the  fulfillment  of  each  contract.
Nasdaq Clearing accounts for this guarantee as a performance guarantee. We
determine  the  fair  value  of  the  performance  guarantee  by  considering  daily
settlement of contracts and other margining and default fund requirements, the
risk  management  program,  historical  evidence  of  default  payments,  and  the
estimated  probability  of  potential  default  payouts.  The  calculation  is
determined  using  proprietary  risk  management  software  that  simulates  gains
and  losses  based  on  historical  market  prices,  extreme  but  plausible  market
scenarios,  volatility  and  other  factors  present  at  that  point  in  time  for  those
particular  unsettled  contracts.  Based  on  this  analysis,  excluding  any  liability
related to the Nasdaq commodities clearing default (see discussion above), the
estimated liability was nominal and no liability was recorded as of December
31, 2022.

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.

F-36

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  and  default  fund  contribution  would  not  be  sufficient  to
cover  the  cost  to  settle  its  portfolio.  If  a  default  occurs  and  the  defaulting
clearing  member’s  collateral,  including  cash  deposits  and  pledged  assets,  is
depleted, then capital is utilized in the following amount and order:

• junior capital contributed by Nasdaq Clearing, which totaled $40 million as

of December 31, 2022;

• 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 $21 million as of December 31, 2022.

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.

During  2022,  Nasdaq  Clearing  updated  its  recovery  plan  and  rule  book  by
introducing  additional  recovery  tools,  in  line  with  the  new  European  Union
regulations  for  the  recovery  and  resolution  of  central  counterparties,  which
became effective during 2022.

In  addition  to  the  capital  held  to  withstand  counterparty  defaults  described
above,  Nasdaq  Clearing  also  has  committed  capital  of  $64  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, 2022

(in millions)

$

$

654 
2,282 
141 
43 
3,120 

• 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, 2022 and 2021:

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

Total

Year Ended December 31,

2022

2021

288,142 
21,992,124 
18,619,950 
45,616,647 
86,516,863 

536,252 
23,140,918 
20,308,811 
37,860,187 
81,846,168 

In  the  table  above,  the  total  volume  in  cleared  power  related  to  commodity
contracts  was  413  Terawatt  hours  (TWh)  and  813  TWh  for  the  years  ended
December 31, 2022 and 2021, respectively.

Resale and Repurchase Agreements Contracts Outstanding and Cleared

The outstanding contract value of resale and repurchase agreements was $120
million and $139 million as of December 31, 2022 and 2021, respectively. The
total  number  of  resale  and  repurchase  agreements  contracts  cleared  was
6,287,717  and  6,070,414  for  the  years  ended  December  31,  2022  and  2021,
respectively.

F-37

 
 
 
Leases

Assets:
Operating lease
assets

Liabilities:
Current lease
liabilities
Non-current lease
liabilities
Total lease
liabilities

16. LEASES

We have operating leases which are primarily real estate leases predominantly
for  our  U.S.  and  European  headquarters,  data  centers  and  for  general  office
space.  The  following  table  provides  supplemental  balance  sheet  information
related to Nasdaq's operating leases:

Total lease payments in the table above exclude $51 million of legally binding
minimum lease payments for leases signed but not yet commenced.

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

Balance Sheet
Classification

December 31, 2022

December 31, 2021

Weighted-average remaining lease term (in years)

(in millions)

Weighted-average discount rate

December 31, 2022

10.5

3.6 %

Operating lease
assets

Other current
liabilities
Operating lease
liabilities

$

$

$

444  $

366 

The  following  table  provides  supplemental  cash  flow  information  related  to
Nasdaq's operating leases:

54  $

452 

506  $

37 

386 

423 

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

Lease assets obtained in exchange
for operating lease liabilities

$

$

Year Ended December 31,

2022

2021

(in millions)

2020

66  $

77  $

77 

137  $

45  $

100 

The following table summarizes Nasdaq's lease cost: 

Year Ended December 31,

17. INCOME TAXES

2022

2021

2020

Income Before Income Tax Provision

Operating lease cost
Variable lease cost
Sublease income

Total lease cost

(in millions)

$

$

75  $
32 
(3)
104  $

85  $
28 
(4)
109  $

85 
26 
(4)
107 

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.

December 31, 2022

(in millions)

2023
2024
2025
2026
2027
2028+
Total lease payments

Less: interest

Present value of lease liabilities

$

$

71 
70 
60 
51 
48 
314 
614 
(108)
506 

In the table above, interest is calculated using the interest rate for each lease.
Present value of lease liabilities include the current portion of $54 million.

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

income 

tax 

Domestic
Foreign
Income before income tax
provision

$

$

Year Ended December 31,

2022

2021

(in millions)

2020

1,216  $
259 

1,299  $
235 

898 
314 

1,475  $

1,534  $

1,212 

Income Tax Provision

The 

income 

tax  provision 

consists  of 

following 

the 
Year Ended December 31,

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

Total income tax provision

$

$

2022

2021

2020

(in millions)

170  $
67 
77 
314 

36 
6 
(4)
38 
352  $

144  $
45 
64 
253 

82 
22 
(10)
94 
347  $

114 
50 
74 
238 

37 
6 
(2)
41 
279 

F-38

 
 
 
 
 
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,  2022,  the  cumulative  amount  of  undistributed  earnings  in  these
subsidiaries  is  $273  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.

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
follows:
December 

2022, 

2021 

and 

31, 

is 

as 
2020 
Year Ended December 31,

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
Non-U.S. subsidiary earnings
Tax credits and deductions
Change in unrecognized tax benefits
Other, net

Actual income tax provision

2022

2021

2020

21.0 %

21.0 %

21.0 %

3.8 %

3.9 %

4.2 %

(0.9)%
0.5 %
(0.3)%
1.1 %
(1.3)%
23.9 %

(1.3)%
0.3 %
(0.3)%
0.6 %
(1.6)%
22.6 %

(0.6)%
0.5 %
(0.2)%
(0.6)%
(1.3)%
23.0 %

The increase in our effective tax rate in 2022 compared to 2021 was primarily
due  to  an  increase  in  state  unrecognized  tax  benefits.  The  decrease  in  our
effective tax rate in 2021 compared to 2020 was primarily 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  and  excess  tax  benefits  related  to
employee share-based compensation.

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.

President  Biden  signed  into  law  the  Inflation  Reduction  Act  of  2022  on
August 16, 2022. Nasdaq does not expect any material impact to the financial
statements or our effective tax rate in future periods.

Deferred Income Taxes

The  temporary  differences,  which  give  rise  to  our  deferred  tax  assets  and
following:
(liabilities), 

consisted 

the 

of 

Deferred tax assets:
Deferred revenues
U.S. federal net operating loss
Foreign net operating loss
State net operating loss
Compensation and benefits
Tax credits
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
Unrealized gains
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,

2022

2021

(in millions)

18  $
5 
12 
3 
42 
3 
9 
118 
— 
33 
243 
(4)
239  $

12 
— 
4 
1 
32 
— 
6 
99 
2 
30 
186 
(4)
182 

(65) $

(65)

(375)
(105)
(29)
(103)
(15)
(692) $
(453) $

3  $

(456)
(453) $

(322)
(99)
— 
(84)
(16)
(586)
(404)

2 
(406)
(404)

$

$

$

$
$

$

$

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

We recognized a valuation allowance of $4 million as of December 31, 2022
and 2021 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-39

 
 
 
 
 
 
 
 
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
Federal NOL
State NOL

Unrecognized Tax Benefits

(in millions)

$

12  No expiration
5  No expiration
3  2025-2040

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,

2022

2021

2020

(in millions)

$

57  $

42  $

48 

13 

9 

(7)

16 

11 

(6)

(2)
70  $

(6)
57  $

$

9 

2 

(6)

(11)
42 

We  had  $70  million  of  unrecognized  tax  benefits  as  of  December  31,  2022,
$57  million  as  of  December  31,  2021,  and  $42  million  as  of  December  31,
2020  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 less than $1 million tax expense for the year ended December 31, 2022,
and a tax benefit of $2 million for both years ended December 31, 2021 and
2020.  Accrued  interest  and  penalties,  net  of  tax  effect  were  $5  million  as  of
December 31, 2022 and $4 million as of December 31, 2021.

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  2019
through  2021  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 2021. Non-U.S. tax returns are subject
to  examination  by  the  respective  tax  authorities  for  the  years  2017  through
2022.  We  regularly  assess  the  likelihood  of  additional  assessments  by  each
jurisdiction and have established tax reserves that we believe are adequate in
relation to the potential for additional assessments. Examination outcomes and
the timing of examination settlements are subject to uncertainty. Although the
results  of  such  examinations  may  have  an  impact  on  our  unrecognized  tax
benefits,  we  do  not  anticipate  that  such  impact  will  be  material  to  our
consolidated  financial  position  or  results  of  operations.  We  do  not  expect  to
settle any material tax audits in the next twelve months.

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  $4  million  as  of
December  31,  2022  and  $5  million  December  31,  2021.  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 $184 million as of December 31,
2022 and $212 million as of December 31, 2021 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.

F-40

Routing Brokerage Activities

CFTC Matter

to  guarantee 

require  members 

One of our broker-dealer subsidiaries, Nasdaq Execution Services, provides a
guarantee  to  securities  clearinghouses  and  exchanges  under  its  standard
membership  agreements,  which 
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.

Legal and Regulatory Matters 

Armenian Stock Exchange Investigation

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.

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,  and  that  any  monetary
fines  or  restrictions  will  not  be  material  to  our  financial  results.  We  cannot
currently predict when our discussions with OFAC will conclude or the exact
amount of any potential penalties imposed, but have accrued for an immaterial
loss contingency.

In  June  2022,  NASDAQ  Futures,  Inc.  (“NFX”),  a  non-operational,  wholly-
owned  subsidiary  of  Nasdaq,  received  a  telephonic  “Wells  Notice”  from  the
staff  of  the  CFTC  relating  to  certain  alleged  potential  violations  by  NFX  of
provisions  of  the  Commodity  Exchange  Act  and  CFTC  rules  thereunder
during  the  period  beginning  July  2015  through  October  2018.  The  Wells
Notice informed NFX that the CFTC staff has made, subject to consideration
of NFX’s response, a preliminary determination to recommend that the CFTC
authorize  an  enforcement  action  against  NFX  in  connection  with  its  former
futures exchange business. Nasdaq sold NFX’s futures exchange business to a
third-party in November 2019, including the portfolio of open interest in NFX
contracts.  During  2020,  all  remaining  open  interest  in  NFX  contracts  was
migrated  to  other  exchanges  and  NFX  ceased  operation.  A  Wells  Notice  is
neither  a  formal  charge  of  wrongdoing  nor  a  final  determination  that  the
recipient  has  violated  any  law.  NFX  has  submitted  a  response  to  the  Wells
Notice  that  contests  all  aspects  of  the  Staff’s  position,  and  is  engaged  in
discussions  with  the  CFTC  staff  concerning  a  potential  resolution  to  the
investigation,  which  could  include  a  settlement  of  the  matter.  While  Nasdaq
believes  NFX  has  a  meritorious  defense  to  any  claims  alleged  by  the  CFTC
staff, we are unable to predict the outcome of this matter and it could have a
negative effect on our operating results or reputation, which could be material.
Accordingly, we are unable to reasonably estimate any potential loss or range
of loss, and therefore, we have not accrued for a loss contingency.

Nasdaq Commodities Clearing Default

In 2022, as a result of a decision received in the fourth quarter, we recorded an
adjustment  to  reduce  a  previous  accrual  recorded  in  2021  related  to  an
administrative  fine  issued  by  the  SFSA  associated  with  the  default  which
occurred  in  2018.  The  charge  and  subsequent  adjustment  were  included  in
regulatory  expense  in  our  Consolidated  Statements  of  Income  for  the  years
ended  December  31,  2022  and  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-41

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

In  2022,  we  announced  a  new  organizational  structure  which  aligns  our
businesses  more  closely  with  the  foundational  shifts  that  are  driving  the
evolution of the global financial system. In order to amplify our strategy, we
aligned  the  Company  more  closely  with  evolving  client  needs.  During  the
fourth quarter of 2022, we began to manage, operate and provide our products
and  services  in  line  with  this  new  divisional  structure.  As  a  result,  our  four
previous  business  segments,  Market  Technology,  Investment  Intelligence,
Corporate Platforms and Market Services have been changed to align with our
new  corporate  structure  that  includes  three  business  segments:  Market
Platforms,  Capital  Access  Platforms  and  Anti-Financial  Crime.  See  Note  1,
“Organization  and  Nature  of  Operations,”  for  further  discussion  of  our
reportable segments.

This Annual Report on Form 10-K presents our results in alignment with the
new corporate structure. All periods presented are restated to reflect the new
structure.

Our management allocates resources, assesses performance and manages these
businesses  as  three  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, 2022, 2021 and 2020:

Year Ended December 31,

2022

2021

2020

$

Market Platforms
Total revenues
Transaction-based expenses
Revenues less transaction-based
expenses
Depreciation and amortization*
Operating income
Purchase of property and equipment
Capital Access Platforms
Total revenues
Depreciation and amortization*
Operating income
Purchase of property and equipment
Anti-Financial Crime
Total revenues
Depreciation and amortization*
Operating income
Purchase of property and equipment
Corporate Items
Total revenues
Depreciation and amortization
Operating loss
Consolidated
Total revenues
Transaction-based expenses
Revenues less transaction-based
expenses
$
Depreciation and amortization
Operating income
$
Purchase of property and equipment $

$

$

(in millions)

4,225  $
(2,644)

4,048  $
(2,466)

1,581 

1,582 

59 
859 
83 

1,684 
36 
916 
50 

306 
10 
80 
19 

11 
153 
(291)

64 
893 
96 

1,568 
34 
844 
50 

231 
8 
44 
17 

39 
172 
(340)

6,226  $
(2,644)

5,886  $
(2,466)

3,582  $

3,420  $

258  $
1,564  $
152  $

278  $
1,441  $
163  $

4,179 
(2,722)

1,457 

55 
784 
125 

1,287 
30 
651 
54 

116 
6 
35 
9 

43 
111 
(236)

5,625 
(2,722)

2,903 

202 
1,234 
188 

*excludes amortization of acquired intangible assets.

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:

F-42

 
 
• Amortization expense of acquired intangible assets: We amortize intangible
assets  acquired  in  connection  with  various  acquisitions.  Intangible  asset
amortization  expense  can  vary  from  period  to  period  due  to  episodic
acquisitions  completed,  rather  than  from  our  ongoing  business  operations.
As  such,  if  intangible  asset  amortization  is  included  in  performance
measures, it is more difficult to assess the day-to-day operating performance
of  the  segments,  and  the  relative  operating  performance  of  the  segments
intangible  asset
between  periods.  Management  does  not  consider 
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.

• Revenues  and  expenses  -  divested/contributed  businesses:  For  2022  and
2021, we have included in corporate items the revenues and expenses of our
U.S. Fixed Income business, which was previously included in our Market
Platforms and Capital Access Platforms results. See “2021 Divestiture,” of
Note  4,  “Acquisitions  and  Divestiture,”  for  further  discussion  of  this
divestiture.  Also  included  are  the  revenues  and  expenses  of  our  Nordic
broker  services  business  for  which  we  completed  the  wind-down  in  June
2022. For 2021 and 2020, we included in corporate items 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
Capital Access Platforms results.

• 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:  In  October  2022,  following  our  September
announcement  to  realign  our  segments  and  leadership,  we  initiated  a
divisional alignment program with a focus on realizing the full potential of
this  structure.  In  2019,  we  initiated  the  transition  of  certain  technology
platforms  to  advance  our  strategic  opportunities  as  a  technology  and
analytics  provider  and  continue  the  realignment  of  certain  business  areas.
See Note 20, “Restructuring Charges,” for further discussion of these plans.
We  believe  performance  measures  excluding  restructuring  charges  provide
management with a useful representation of our segments' ongoing activity
in each period.

• Other 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  items
include:

◦ for the year ended December 31, 2022, accruals related to a legal matter,
included in general, administrative and other expense in our Consolidated
Statements of Income and a regulatory matter offset by the release of $5
million in relation to the reduction of the administrative fine issued by the
SFSA included in regulatory expense in our Consolidated Statements of
Income;

◦

for  the  year  ended  December  31,  2021  a  charge  related  to  an
administrative fine imposed by the SFSA. The 2022 and 2021 SFSA fine
is  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.  All  charges  and  releases  have
been  included  in  regulatory  expense  in  the  Consolidated  Statements  of
Income;

◦ for  the  year  ended  December  31,  2020,  a  provision  for  notes  receivable
the

technology  development  for 

the  funding  of 

associated  with 
consolidated audit trail;

◦ for  the  years  ended  December  31,  2022,  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, 2022 and 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 and other expense,
unless otherwise noted, in our Consolidated Statements of Income.

F-43

20. RESTRUCTURING CHARGES

In  October  2022,  following  our  September  announcement  to  realign  our
segments  and  leadership,  we  initiated  a  divisional  alignment  program  with  a
focus  on  realizing  the  full  potential  of  this  structure.  In  connection  with  the
program, we expect to incur $115 million to $145 million in pre-tax charges
principally  related  to  employee-related  costs,  consulting,  asset  impairments
and  contract  terminations  over  a  two-year  period.  We  expect  to  achieve
benefits,  in  the  form  of  combined  annual  run  rate  operating  efficiencies  and
revenue  synergies  of  approximately  $30  million  annually  by  2025.  Costs
related  to  the  divisional  alignment  program  will  be  recorded  as  restructuring
charges in the Consolidated Statements of Income.

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  realignment  of  certain  business  areas.  In
connection with these restructuring efforts, we retired certain elements of our
market infrastructure and technology product offerings as we implement NFF
internally  and  externally.  This  represented  a
and  other 
fundamental  shift  in  our  strategy  and  technology  as  well  as  executive
realignment.  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.

technologies 

The  following  table  presents  a  summary  of  the  2022  and  2019  restructuring
plan  charges  in  the  Consolidated  Statements  of  Income  for  the  years  ended
December 31, 2022, 2021 and 2020.

Asset impairment charges
Consulting services
Contract terminations
Employee-related costs
Other

Total restructuring charges

Year Ended December 31,

2022

2021

(in millions)

2020

$

$

8  $
3 
— 
3 
1 
15  $

4  $

19 
— 
1 
7 
31  $

14 
22 
3 
3 
6 
48 

The following table summarizes our Corporate Items:

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,

2022

2021

2020

(in millions)

$

11  $

39  $

43 

153 

170 

103 

82 
15 
1 
— 
16 
— 

87 
31 
33 
— 
33 
— 

33 
48 
(6)
6 
36 
17 

5 
30 
302 
(291) $

16 
9 
379 
(340) $

24 
18 
279 
(236)

$

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  2022,  2021  and  2020.  Revenues  are  classified  based
upon  the  location  of  the  customer.  Property  and  equipment  information  is
based on the physical location of the assets.

Total
Revenues

Property and
Equipment, Net

2022:
United States
All other countries

Total

2021:
United States
All other countries

Total

2020:
United States
All other countries

Total

$

$

$

$

$

$

 (in millions)

5,100  $
1,126 
6,226  $

4,822  $
1,064 
5,886  $

4,662  $
963 
5,625  $

344 
188 
532 

325 
184 
509 

311 
164 
475 

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 2022, 2021 and 2020.

F-44

 
 
 
 
 
 
 
DESCRIPTION OF THE REGISTRANT’S SECURITIES
REGISTERED PURSUANT TO SECTION 12 OF THE
SECURITIES EXCHANGE ACT OF 1934

Exhibit 4.18

Nasdaq,  Inc.  (the  “Company”)  has  four  classes  of  securities  registered  under  Section  12  of  the  Securities  Exchange  Act  of

1934, as amended (the “Exchange Act”):

(1) Common Stock, par value $0.01 per share (“Common Stock”);

(2) 0.900% Senior Notes due 2033;

(3) 0.875% Senior Notes due 2030; and

(4) 1.75% Senior Notes due 2029.

As used in this summary, the terms “Nasdaq,” “the Company,” “we,” “our,” and “us” refer solely to Nasdaq, Inc. and not its

subsidiaries, unless otherwise specified.

Description of Common Stock

The following is a description of the material terms and provisions relating to our common stock. Because it is a summary, the
following  description  is  not  complete  and  is  subject  to  and  qualified  in  its  entirety  by  reference  to  our  Amended  and  Restated
Certificate of Incorporation, as amended, or Certificate, and by-laws, and provisions of Delaware law which define the rights of our
stockholders.

The holders of our common stock are entitled to one vote per share on all matters to be voted upon by the stockholders except that
no person may exercise voting rights in respect of any shares in excess of 5% of the then outstanding shares of our Common Stock.
Subject  to  certain  additional  conditions,  this  limitation  does  not  apply  to  persons  exempted  from  this  limitation  by  our  Board  of
Directors prior to the time such person owns more than 5.0% of the then-outstanding shares of our common stock.

At any meeting of our stockholders, a majority of the votes entitled to be cast will constitute a quorum for such meeting.

Holders of common stock are entitled to receive ratably such dividends, if any, as may be declared from time to time by our board

of directors out of funds legally available for them. In

the  event  of  our  liquidation,  dissolution,  or  winding-up,  the  holders  of  our  common  stock  are  entitled  to  share  ratably  in  all  assets
remaining after payment of liabilities, subject to prior distribution rights of preferred stock, if any, then outstanding. Our common stock
has no preemptive or conversion rights or other subscription rights. There are no redemption or sinking fund provisions applicable to
our  common  stock.  All  outstanding  shares  of  common  stock  are  fully  paid  and  non-assessable.  Future  dividends,  if  any,  will  be
determined by our board of directors.

Certain Provisions of our Certificate and By-Laws

Some provisions of our Certificate and by-laws, which provisions are summarized below, may be deemed to have an anti-takeover
effect and may delay, defer, or prevent a tender offer or takeover attempt that a stockholder might consider in its best interest, including
those attempts that might result in a premium over the market price for the shares held by stockholders.

Advance Notice Requirements for Stockholder Proposals and Directors Nominations

Our  by-laws  provide  that  stockholders  seeking  to  bring  business  before  an  annual  meeting  of  stockholders,  or  to  nominate
candidates  for  election  as  directors  at  an  annual  meeting  of  stockholders,  must  provide  timely  notice  in  writing.  To  be  timely,  a
stockholder’s notice must be delivered to or mailed and received at our principal executive offices not less than 90 nor more than 120
days  prior  to  the  anniversary  date  of  the  immediately  preceding  annual  meeting  of  stockholders;  provided,  that  in  the  event  that  the
annual meeting is called for a date that is not within 30 days before or 70 days after such anniversary date, notice by the shareholder in
order to be timely must be received not earlier than 120 days prior to the meeting and not later than the later of 90 days prior to the
meeting  and  the  close  of  business  on  the  10th  day  following  the  date  on  which  notice  of  the  date  of  the  annual  meeting  was  first
publicly announced by Nasdaq. In the case of a special meeting of stockholders called for the purpose of electing directors, notice by
the stockholder in order to be timely must be received not earlier than 120 days prior to the meeting and not later than the later of 90
days prior to the meeting or the close of business on the 10th day following the day on which public disclosure of the date of the special
meeting  and  our  nominees  was  first  made.  In  addition,  our  by-laws  specify  certain  requirements  as  to  the  form  and  content  of  a
stockholder’s notice. These provisions may preclude stockholders from bringing matters before an annual meeting of stockholders or
from making nominations for directors at an annual or special meeting of stockholders.

Proxy Access

Our by-laws include a proxy access provision that permits a stockholder, or a group of stockholders, owning at least three percent

of our outstanding shares of common stock

continuously  for  at  least  three  years  to  nominate  and  include  in  the  proxy  materials  for  an  annual  meeting  of  stockholders  director
nominees constituting up to the greater of two individuals and 25% of the total number of directors then in office, provided that the
stockholder(s) and nominee(s) satisfy the requirements specified in the by-laws.

Stockholder Action

Our Certificate provides that stockholders are not entitled to act by written consent in lieu of a meeting.

Right to Call Special Meeting

Our  by-laws  provide  that  stockholders  representing  15%  or  more  of  our  outstanding  shares  can  convene  a  special  meeting  of

shareholders.

Amendments; Vote Requirements

The  General  Corporation  Law  of  the  State  of  Delaware  provides  generally  that  the  affirmative  vote  of  a  majority  of  the  shares
entitled  to  vote  on  any  matter  is  required  to  amend  a  corporation’s  certificate  of  incorporation,  unless  a  corporation’s  certificate  of
incorporation  requires  a  greater  percentage.  Our  Certificate  imposes  majority  voting  requirements  in  connection  with  stockholder
amendments to the by-laws and in connection with the amendment of certain provisions of the Certificate, including those provisions of
the Certificate relating to the limitations on voting rights of certain persons, removal of directors and prohibitions on stockholder action
by written consent.

Authorized But Unissued Shares

The  authorized  but  unissued  shares  of  our  common  stock  will  be  available  for  future  issuance  without  stockholder  approval  in
most cases. These additional shares may be utilized for a variety of corporate purposes, including future public or private offerings to
raise  additional  capital,  corporate  acquisitions  and  employee  benefit  plans.  The  existence  of  authorized  but  unissued  shares  of  our
common stock could render more difficult, or discourage, an attempt to obtain control of us by means of a proxy contest, tender offer,
merger or otherwise.

Delaware Business Combination Statute

We are organized under Delaware law. Delaware law generally prohibits a publicly-held or widely-held corporation from engaging
in a “business combination” with an “interested stockholder” for three years after the stockholder becomes an interested stockholder.
An

 
“interested stockholder” is a person who, together with affiliates and associates, owns (or, in some cases, within three years, did own)
directly or indirectly 15% or more of the corporation’s outstanding voting stock. A “business combination” includes a merger, asset sale
or  other  transaction  that  results  in  a  financial  benefit  to  the  interested  stockholder.  However,  Delaware  law  does  not  prohibit  these
business combinations if:

1. before the stockholder becomes an interested stockholder, the corporation’s board approved either the business combination or

the transaction that resulted in the stockholder becoming an interested stockholder;

2. after the transaction that results in the stockholder becoming an interested stockholder, the interested stockholder owns at least

85% of the corporation’s outstanding voting stock (excluding certain shares); or

3.

the corporation’s board approves the business combination and the holders of at least two-thirds of the corporation’s outstanding
voting stock that the interested stockholder does not own authorize the business combination at a meeting of stockholders.

Stockholders’ Agreement

On  December  14,  2022,  we  entered  into  an  amendment  to  our  stockholders’  agreement  with  Investor  AB  (the  “Amended
Stockholders’ Agreement”), amending the original stockholders’ agreement that was entered into between Nasdaq and Investor AB on
December 16, 2010.

The  Amended  Stockholders’  Agreement  reinstated  Investor  AB’s  right  to  propose  for  nomination  one  person,  reasonably
acceptable  to  our  Nominating  &  ESG  Committee,  for  election  to  our  Board  of  Directors  so  long  as  Investor  AB  continues  to
beneficially  own  at  least  10%  of  the  outstanding  common  stock  of  Nasdaq.  We  are  obligated  by  the  terms  of  the  Amended
Stockholders’ Agreement to (i) include the Investor AB designee as a nominee to the Board of Directors on each slate of nominees for
election to the Board of Directors proposed by management of Nasdaq, (ii) recommend the election of the Investor AB designee to our
shareholders and (iii) otherwise use our reasonable best efforts (which shall include the solicitation of proxies) to cause the Investor AB
designee to be elected to the Board of Directors.

The  foregoing  summary  of  the  Amended  Stockholders’  Agreement  does  not  purport  to  be  complete  and  is  subject  to,  and
qualified in its entirety by, the full text of the Amended Stockholders’ Agreement, which was filed as Exhibit 4.1 to Nasdaq’s Current
Report on Form 8-K filed on December 16, 2022.

Transfer Agent and Registrar

The transfer agent and registrar for our common stock is Computershare. Its address is 480 Washington Boulevard, Jersey City,

New Jersey 07310 and its telephone number is (800) 736-3001.

Listing

Our common stock is listed on The Nasdaq Stock Market under the trading symbol “NDAQ.”

Description of the 0.900% Senior Notes Due 2033

The 0.900% Senior Notes due 2033 (the “2033 Notes”)  were  issued  under  an  indenture,  dated  as  of  June  7,  2013  (the  “base
indenture”) between Nasdaq, Inc. and Wells Fargo Bank, National Association, as trustee (the “Trustee”) and a twelfth supplemental
indenture dated as of July 30, 2021 (the “supplemental indenture” and, together with the base indenture, the “indenture”) by and among
Nasdaq, the Trustee and HSBC Bank USA, National Association, as registrar and transfer agent. The indenture is publicly available at
www.sec.gov.

We issued €615 million aggregate principal amount of the 2033 Notes on July 30, 2021.

This summary is subject to, and qualified in its entirety by reference to, all the provisions of the 2033 Notes and the indenture,

including definitions of certain terms used therein.

General

The 2033 Notes:

•

•

•

•

are senior unsecured obligations of ours;

rank  equally  in  right  of  payment  with  all  of  our  other  senior  unsecured  indebtedness  from  time  to  time  outstanding,
commercial paper issuances and indebtedness under our credit facility;

are  structurally  subordinated  in  right  of  payment  to  all  existing  and  future  obligations  of  our  subsidiaries,  including
claims with respect to trade payables; and

are effectively subordinated in right of payment to all of our existing and future secured indebtedness and other secured
obligations to the extent of the value of the collateral securing any such indebtedness and other obligations.

The 2033 Notes were issued in minimum denominations of €100,000 and integral multiples of €1,000 in excess thereof.

Principal, Maturity and Interest

The 2033 Notes will bear interest at a rate of 0.900% per year. Interest on the Notes is payable annually in arrears on July 30 of
each year, beginning on July 30, 2022, and will be computed on the basis of the actual number of days in the period for which interest is
being

 
calculated  and  the  actual  number  of  days  from  and  including  the  last  date  on  which  interest  was  paid  on  the  2033  Notes  (or  the
settlement date if no interest has been paid or duly provided for on the 2033 Notes), to but excluding the next date on which interest is
paid or duly provided  for.  This  payment  convention  is  referred  to  as  ACTUAL/ACTUAL (ICMA) as defined in the rulebook of the
International Capital Market Association. Interest on the 2033 Notes will accrue from and including the settlement date and will be paid
to holders of record on the day immediately prior to the applicable interest payment date.

The 2033 Notes will mature on July 30, 2033. On the maturity date of the 2033 Notes, the holders will be entitled to receive

100% of the principal amount of such 2033 Notes. The 2033 Notes will not have the benefit of any sinking fund.

If any interest payment date, redemption date or maturity date falls on a day that is not a business day, then the relevant payment
may be made on the next succeeding business day and no interest will accrue because of such delayed payment. With respect to the
2033 Notes, when we use the term “business day” we mean any day except a Saturday, a Sunday or a day on which banking institutions
in the applicable place of payment are authorized or required by law, regulation or executive order to close.

Claims against the Company for payment of principal, interest and additional amounts, if any, on the 2033 Notes will become
void unless presentment for payment is made (where so required under the indenture) within, in the case of principal and additional
amounts, if any, a period of ten years or, in the case of interest, a period of five years, in each case from the applicable original date of
payment therefor.

Euro Notes—Issuance in Euros

Initial holders of the 2033 Notes paid for the 2033 Notes in euros, and principal, premium, if any, and interest payments and
additional amounts, if any, in respect of the 2033 Notes will be payable in euros. If, on or after the date of this prospectus supplement,
the euro is unavailable to us due to the imposition of exchange controls or other circumstances beyond our control or the euro is no
longer  used  by  the  then  member  states  of  the  European  Monetary  Union  that  have  adopted  the  euro  as  their  currency  or  for  the
settlement of transactions by public institutions within the international banking community, then all payments in respect of the 2033
Notes will be made in U.S. dollars until the euro is again available to us or so used.

The amount payable on any date in euros will be converted to U.S. dollars on the basis of the most recently available market
exchange rate for euros as determined by us in our sole discretion. Any payment in respect of the 2033 Notes so made in U.S. dollars
will not constitute an event of default under the indenture or the 2033 Notes. Neither the trustee nor the paying

agent will be responsible for obtaining exchange rates, effecting conversions or otherwise handling redenominations.

Ranking

The  2033  Notes  are  general  unsecured  obligations  of  ours  and  will  rank  equally  with  all  of  our  existing  and  future

unsubordinated obligations.

Holders  of  any  secured  indebtedness  and  other  secured  obligations  of  the  Company  will  have  claims  that  are  prior  to  your
claims as holders of the 2033 Notes, to the extent of the value of the assets securing such indebtedness and other obligations, in the
event of any bankruptcy, liquidation or similar proceeding.

Further Issues

The 2033 Notes constituted a separate series of debt securities under the indenture, limited to €615 million. Under the indenture,
we may, without the consent of the holders of the 2033 Notes, issue additional 2033 Notes of the same or a different series from time to
time in the future in an unlimited aggregate principal amount; provided that if any such additional 2033 Notes are not fungible with the
2033 Notes offered hereby (or any other tranche of additional 2033 Notes) for U.S. federal income tax purposes, then such additional
2033  Notes  will  have  different  ISIN  and/or  Common  Code  numbers  than  the  Notes  offered  hereby  (and  any  such  other  tranche  of
additional 2033 Notes). The 2033 Notes and any additional 2033 Notes of the same series would rank equally and ratably and would be
treated as a single class for all purposes under the indenture. This means that, in circumstances where the indenture provides for the
holders of debt securities of any series to vote or take any action, any of the outstanding 2033 Notes, as well as any additional 2033
Notes that we may issue by reopening such series, will vote or take action as a single class.

Redemption

Optional Redemption

The 2033 Notes will be redeemable, in whole at any time or in part from time to time, at our option, prior to April 30, 2033, at a
redemption price (the “make-whole redemption price”) equal to the greater of (i) 100% of the principal amount of the 2033 Notes and
(ii) as determined by the Quotation Agent (as defined below), the sum of the present values of the remaining scheduled payments of
principal and interest on the 2033 Notes (exclusive of interest accrued and unpaid as of the date of redemption), discounted to the date
of redemption on an annual basis (ACTUAL/ACTUAL (ICMA)) at the Bund Rate (as defined below), plus 20 basis points, plus

accrued and unpaid interest thereon to the date of redemption. However, if the redemption date is after a record date and on or prior to a
corresponding interest payment date, the interest will be paid on the redemption date to the holder of record on the record date.

Notwithstanding the foregoing, at any time on or after April 30, 2033 (three months before their maturity date), the 2033 Notes
will be redeemable, in whole or in part, at our option and at any time or from time to time, at a redemption price equal to 100% of the
principal amount of the 2033 Notes to be redeemed plus accrued and unpaid interest thereon to, but excluding, the date of redemption.

Notice  of  any  redemption  will  be  mailed  at  least  10  days,  but  not  more  than  60  days,  before  the  redemption  date  to  each
registered  holder  of  2033  Notes  to  be  redeemed.  Once  notice  of  redemption  is  mailed,  the  2033  Notes  called  for  redemption  will
become due and payable on the redemption date and at the applicable redemption price, plus accrued and unpaid interest to, but not
including, the redemption date. Unless we default in payment of the redemption price, on and after the redemption date, interest will
cease to accrue on the 2033 Notes (or portion thereof) to be redeemed on such redemption date.

“Bund Rate” means, with respect to any redemption date, the rate per annum equal to the annual equivalent yield to maturity of
the  Comparable  German  Bund  Issue,  assuming  a  price  for  the  Comparable  German  Bund  Issue  (expressed  as  a  percentage  of  its
principal amount) equal to the Comparable German Bund Price for such redemption date.

“Comparable  German  Bund  Issue”  means  that  German  Bundesanleihe  security  selected  by  the  Quotation  Agent  as  having  a
maturity comparable to the remaining term of the 2033 Notes to be redeemed that would be utilized, at the time of selection and in
accordance with customary
financial practice, in pricing new issues of corporate notes of comparable maturity to the remaining term of the Notes.

“Comparable German Bund Price” means, with respect to any redemption date, (i) the average of four Reference German Bund
Dealer Quotations for such redemption date, after excluding the highest and lowest such Reference German Bund Dealer Quotations or
(ii) if the Quotation Agent obtains fewer than four such Reference German Bund Dealer Quotations, the average of all such quotations.

“Quotation Agent” means a Reference German Bund Dealer appointed by us.

“Reference German Bund Dealer” means any dealer of German Bundesanleihe securities selected by us in good faith.

 
“Reference German Bund Dealer Quotations” means, with respect to each Reference German Bund Dealer and any redemption
date, the average, as determined by us, of the bid and asked prices for the Comparable German Bund Issue (expressed in each case as a
percentage  of  its  principal  amount)  quoted  in  writing  to  the  Quotation  Agent  by  such  Reference  German  Bund  Dealer  at  3:30  p.m.,
Frankfurt, Germany time, on the third business day preceding such redemption date.

If we elect to redeem less than all of the 2033 Notes, and such 2033 Notes are at the time represented by a global note, then the
depositary will select by lot the particular interests to be redeemed. If we elect to redeem less than all of the 2033 Notes, and any of
such 2033 Notes are not represented by a global note, then the trustee will select the particular 2033 Notes to be redeemed in a manner
it deems appropriate and fair (and the depositary will select by lot the particular interests in any global note to be redeemed).

We may at any time, and from time to time, purchase the 2033 Notes at any price or prices in the open market or otherwise.

Repurchase upon Change of Control Triggering Event

If a Change of Control Triggering Event (as defined below) occurs with respect to the 2033 Notes, unless we have exercised our
right  to  redeem  the  2033  Notes,  we  will  be  required  to  make  an  offer  to  repurchase  all  or,  at  the  holder’s  option,  any  part  (equal  to
€100,000 or any integral multiple of €1,000 in excess thereof) of each holder’s 2033 Notes pursuant to the offer described below (the
“Change of Control Offer”).

In the Change of Control Offer, we will be required to offer payment in cash equal to 101% of the aggregate principal amount of
2033  Notes  repurchased  plus  accrued  and  unpaid  interest,  if  any,  on  the  2033  Notes  repurchased  to,  but  not  including,  the  date  of
purchase (the “Change of Control Payment”).

“Change of Control” means the occurrence of any of the following: (1) the direct or indirect sale, transfer, conveyance or other
disposition (other than by way of merger or consolidation), in one or a series of related transactions, of all or substantially all of the
assets  of  us  and  our  Subsidiaries  taken  as  a  whole  to  any  Person  or  group  of  related  Persons  for  purposes  of  Section  13(d)  of  the
Exchange Act (a “Group”) other than us or one of our subsidiaries; (2) the approval by the holders of our common stock of any plan or
proposal for our liquidation or

dissolution; (3) the consummation of any transaction (including, without limitation, any merger or consolidation) the result of which is
that  any  Person  or  Group  becomes  the  beneficial  owner,  directly  or  indirectly,  of  more  than  50%  of  the  then  outstanding  number  of
shares  of  our  Voting  Stock;  or  (4)  the  first  day  on  which  a  majority  of  the  members  of  our  board  of  directors  are  not  Continuing
Directors.

Notwithstanding the foregoing, a transaction will not be deemed to involve a Change of Control if (1) we become a direct or
indirect wholly owned subsidiary of a holding company and (2)(A) the direct or indirect holders of the Voting Stock of such holding
company immediately following that transaction are substantially the same as the holders of our Voting Stock immediately prior to that
transaction  or  (B)  immediately  following  that  transaction  no  Person  or  Group  (other  than  a  holding  company  satisfying  the
requirements  of  this  sentence)  is  the  beneficial  owner,  directly  or  indirectly  of  more  than  50%  of  the  Voting  Stock  of  such  holding
company.

“Change of Control Triggering Event” means the occurrence of both a Change of Control and a Below Investment Grade Rating

Event (as such term is defined in the indenture) occurring in respect of that Change of Control.

“Continuing Directors” means, as of any date of determination, any member of our board of directors who (1) was a member of
our board of directors on the date of the issuance of the 2033 Notes; or (2) was nominated or approved for election, elected or appointed
to our board of directors with the approval of a majority of the Continuing Directors who were members of our board of directors at the
time of such nomination, approval, election or appointment (either by a specific vote or by approval of the proxy statement issued by us
in which such member was named as a nominee for election as a director).

“Person”  means  any  individual,  firm,  limited  liability  company,  corporation,  partnership,  association,  joint  venture,  tribunal,
trust,  government  or  political  subdivision  or  agency  or  instrumentality  thereof,  or  any  other  entity  or  organization  and  includes  a
“person” as used in Section 13(d)(3) of the Exchange Act.

      “Voting Stock” of any specified Person as of any date means the capital stock of such Person that is at the time entitled to vote
generally in the election of the board of directors of such Person.

The definition of “Change of Control” includes a phrase relating to the sale, transfer, conveyance or other disposition of “all or
substantially all” of our consolidated assets. There is no precise, established definition of the phrase “substantially all” under applicable
law.

Accordingly, your ability to require us to purchase your 2033 Notes as a result of the sale, transfer, conveyance or other disposition of
less than all of our assets may be uncertain.

Certain Covenants

The indenture contains, among others, restrictive covenants regarding (i) our ability to consolidate or merge with another entity
or  to  sell,  transfer  or  otherwise  convey  all  or  substantially  all  of  our  assets  to  another  entity,  (ii)  create  or  permit  certain  significant
subsidiaries to create or permit to exist certain liens and (iii) certain sale and lease-back transactions involving certain subsidiaries.

Events of Default

Holders  of  the  2033  Notes  will  have  specified  rights  if  an  Event  of  Default  (as  defined  below)  occurs.  The  term  “Event  of

Default” in respect of the 2033 Notes means any of the following:

(1)

(2)

(3)

(4)

we do not pay interest on any of the 2033 Notes within 30 days of its due date;

we fail to pay the principal (or premium, if any) of any 2033 Note, when such principal becomes due and payable, at
maturity, upon acceleration, upon redemption or otherwise;

we fail to comply with certain covenants under the indenture;

we  remain  in  breach  of  a  covenant  or  warranty  in  respect  of  the  indenture  or  2033  Notes  (other  than  a  covenant

included in the indenture solely for the benefit of debt securities of another series) for 90 days after we receive a written
notice of default, which notice must be sent by either the trustee or holders of at least 25% in principal amount of the
outstanding 2033 Notes;

(5)

we file for bankruptcy, or other events of bankruptcy, insolvency or reorganization specified in the indenture;

(6)

(7)

we  default  on  any  indebtedness  of  ours  or  of  a  significant  subsidiary  having  an  aggregate  amount  of  at  least

$200,000,000,  constituting  a  default  either  of  payment  of  principal  when  due  and  payable  or  which  results  in
acceleration  of  the  indebtedness  unless  the  default  has  been  cured  or  waived  or  the  indebtedness  discharged  in  full

within 60 days after we have been notified of the default by the trustee or holders of at least 25% of the outstanding
2033 Notes; or

one  or  more  final  judgments  for  the  payment  of  money  in  an  aggregate  amount  in  excess  of  $200,000,000  above
available insurance or indemnity coverage shall be rendered against us or any significant subsidiary and the same shall
remain undischarged for a period of 60 consecutive days during which execution shall not be effectively stayed.

If an Event of Default (other than an Event of Default specified in clause (5) above) with respect to the 2033 Notes has occurred, the
trustee or the holders of at least 25% in principal amount of the 2033 Notes may declare the entire unpaid principal amount of (and
premium,  if  any),  and  all  the  accrued  interest  on,  the  Notes  to  be  due  and  immediately  payable.  This  is  called  a  declaration  of
acceleration of maturity. There is no action on the part of the trustee or any holder of the 2033 Notes required for such declaration if the
Event  of  Default  is  the  Company’s  bankruptcy,  insolvency  or  reorganization.  Holders  of  a  majority  in  principal  amount  of  the  2033
Notes may also waive certain past defaults under the indenture with respect to the 2033 Notes on behalf of all of the holders of the 2033
Notes. A declaration of acceleration of maturity may be canceled, under specified circumstances, by the holders of at least a majority in
principal amount of the 2033 Notes and the trustee.

Except in cases of default, where the trustee has special duties, the trustee is not required to take any action under the indenture at the
request of holders unless the holders offer the trustee protection from expenses and liability satisfactory to the trustee. If an indemnity
satisfactory to the trustee is provided, the holders of a majority in principal amount of 2033 Notes may direct the time, method and
place  of  conducting  any  lawsuit  or  other  formal  legal  action  seeking  any  remedy  available  to  the  trustee.  The  trustee  may  refuse  to
follow those directions in certain circumstances specified in the indenture. No delay or omission in exercising any right or remedy will
be treated as a waiver of the right, remedy or Event of Default.

Modification of the Indenture and Waiver of Rights of Holders

    
Under certain circumstances, we can make changes to the indenture and the 2033 Notes. Some types of changes require the approval of
each holder of 2033 Notes, some require approval by a vote of a majority of the holders of the 2033 Notes, and some changes do not
require any approval at all.
Description of the 0.875% Senior Notes Due 2030

The 0.875% Senior Notes due 2030 (the “2030 Notes”)  were  issued  under  an  indenture,  dated  as  of  June  7,  2013  (the  “base
indenture”) between Nasdaq, Inc. and Wells Fargo Bank, National Association, as trustee (the “Trustee”) and a seventh supplemental
indenture  dated  as  of  February  13,  2020  (the  “supplemental indenture”  and,  together  with  the  base  indenture,  the  “indenture”).  The
indenture is publicly available at www.sec.gov.

We issued €600 million aggregate principal amount of the 2030 Notes on February 13, 2020.

This summary is subject to, and qualified in its entirety by reference to, all the provisions of the 2030 Notes and the indenture,

including definitions of certain terms used therein.

General

The 2030 Notes:

•

•

•

•

are senior unsecured obligations of ours;

rank  equally  in  right  of  payment  with  all  of  our  other  senior  unsecured  indebtedness  from  time  to  time  outstanding,
commercial paper issuances and indebtedness under our credit facility;

are  structurally  subordinated  in  right  of  payment  to  all  existing  and  future  obligations  of  our  subsidiaries,  including
claims with respect to trade payables; and

are effectively subordinated in right of payment to all of our existing and future secured indebtedness and other secured
obligations to the extent of the value of the collateral securing any such indebtedness and other obligations.

The 2030 Notes were issued in minimum denominations of €100,000 and integral multiples of €1,000 in excess thereof.

Principal, Maturity and Interest

 
The 2030 Notes will bear interest at a rate of 0.875% per year. Interest on the Notes is payable annually in arrears on February
13  of each year, beginning  on  February  13,  2021,  and  will  be  computed  on  the basis of the actual number of days in the period for
which interest is being calculated and the actual number of days from and including the last date on which interest was paid on the 2030
Notes (or the settlement date if no interest has been paid or duly provided for on the 2030 Notes), to but excluding the next date on
which interest is paid or duly provided for. This payment convention is referred to as ACTUAL/ACTUAL (ICMA) as defined in the
rulebook of the International Capital Market Association. Interest on the 2030 Notes will accrue from and including the settlement date
and will be paid to holders of record on the day immediately prior to the applicable interest payment date.

The  2030  Notes  will  mature  on  February  13,  2030.  On  the  maturity  date  of  the  2030  Notes,  the  holders  will  be  entitled  to

receive 100% of the principal amount of such 2030 Notes. The 2030 2030 Notes will not have the benefit of any sinking fund.

If any interest payment date, redemption date or maturity date falls on a day that is not a business day, then the relevant payment
may be made on the next succeeding business day and no interest will accrue because of such delayed payment. With respect to the
2030 Notes, when we use the term “business day” we mean any day except a Saturday, a Sunday or a day on which banking institutions
in the applicable place of payment are authorized or required by law, regulation or executive order to close.

Claims against the Company for payment of principal, interest and additional amounts, if any, on the 2030 Notes will become
void unless presentment for payment is made (where so required under the indenture) within, in the case of principal and additional
amounts, if any, a period of ten years or, in the case of interest, a period of five years, in each case from the applicable original date of
payment therefor.

Euro Notes—Issuance in Euros

Initial holders of the 2030 Notes paid for the 2030 Notes in euros, and principal, premium, if any, and interest payments and
additional amounts, if any, in respect of the 2030 Notes will be payable in euros. If, on or after the date of this prospectus supplement,
the euro is unavailable to us due to the imposition of exchange controls or other circumstances beyond our control or the euro is no
longer  used  by  the  then  member  states  of  the  European  Monetary  Union  that  have  adopted  the  euro  as  their  currency  or  for  the
settlement of transactions by public institutions within the international banking community, then all payments in respect of the 2030
Notes will be made in U.S. dollars until the euro is again available to us or so used.

The amount payable on any date in euros will be converted to U.S. dollars on the basis of the most recently available market
exchange rate for euros as determined by us in our sole discretion. Any payment in respect of the 2030 Notes so made in U.S. dollars
will not constitute an event of default under the indenture or the 2030 Notes. Neither the trustee nor the paying agent will be responsible
for obtaining exchange rates, effecting conversions or otherwise handling redenominations.

Ranking

The  2030  Notes  are  general  unsecured  obligations  of  ours  and  will  rank  equally  with  all  of  our  existing  and  future

unsubordinated obligations.

Holders  of  any  secured  indebtedness  and  other  secured  obligations  of  the  Company  will  have  claims  that  are  prior  to  your
claims as holders of the 2030 Notes, to the extent of the value of the assets securing such indebtedness and other obligations, in the
event of any bankruptcy, liquidation or similar proceeding.

Further Issues

The 2030 Notes constituted a separate series of debt securities under the indenture, limited to €600 million. Under the indenture,
we may, without the consent of the holders of the 2030 Notes, issue additional 2030 Notes of the same or a different series from time to
time in the future in an unlimited aggregate principal amount; provided that if any such additional 2030 Notes are not fungible with the
2030 Notes offered hereby (or any other tranche of additional 2030 Notes) for U.S. federal income tax purposes, then such additional
2030  Notes  will  have  different  ISIN  and/or  Common  Code  numbers  than  the  Notes  offered  hereby  (and  any  such  other  tranche  of
additional 2030 Notes). The 2030 Notes and any additional 2030 Notes of the same series would rank equally and ratably and would be
treated as a single class for all purposes under the indenture. This means that, in circumstances where the indenture provides for the
holders of debt securities of any series to vote or take any action, any of the outstanding 2030 Notes, as well as any additional 2030
Notes that we may issue by reopening such series, will vote or take action as a single class.

Redemption

Optional Redemption

The 2030 Notes will be redeemable, in whole at any time or in part from time to time, at our option, at a redemption price (the
“make-whole redemption price”) equal to the greater of (i) 100% of the principal amount of the 2030 Notes and (ii) as determined by
the Quotation Agent

(as  defined  below),  the  sum  of  the  present  values  of  the  remaining  scheduled  payments  of  principal  and  interest  on  the  2030  Notes
(exclusive  of  interest  accrued  and  unpaid  as  of  the  date  of  redemption),  discounted  to  the  date  of  redemption  on  an  annual  basis
(ACTUAL/ACTUAL (ICMA)) at the Bund Rate (as defined below), plus 20 basis points, plus accrued and unpaid interest thereon to
the date of redemption. However, if the redemption date is after a record date and on or prior to a corresponding interest payment date,
the interest will be paid on the redemption date to the holder of record on the record date.

Notwithstanding the foregoing, at any time on or after November 13, 2029 (three months before their maturity date), the 2030
Notes will be redeemable, in whole or in part, at our option and at any time or from time to time, at a redemption price equal to 100%
of  the  principal  amount  of  the  2030  Notes  to  be  redeemed  plus  accrued  and  unpaid  interest  thereon  to,  but  excluding,  the  date  of
redemption.

Notice  of  any  redemption  will  be  mailed  at  least  30  days,  but  not  more  than  60  days,  before  the  redemption  date  to  each
registered  holder  of  2030  Notes  to  be  redeemed.  Once  notice  of  redemption  is  mailed,  the  2030  Notes  called  for  redemption  will
become due and payable on the redemption date and at the applicable redemption price, plus accrued and unpaid interest to, but not
including, the redemption date. Unless we default in payment of the redemption price, on and after the redemption date, interest will
cease to accrue on the 2030 Notes (or portion thereof) to be redeemed on such redemption date.

“Bund Rate” means, with respect to any redemption date, the rate per annum equal to the annual equivalent yield to maturity of
the  Comparable  German  Bund  Issue,  assuming  a  price  for  the  Comparable  German  Bund  Issue  (expressed  as  a  percentage  of  its
principal amount) equal to the Comparable German Bund Price for such redemption date.

“Comparable  German  Bund  Issue”  means  that  German  Bundesanleihe  security  selected  by  the  Quotation  Agent  as  having  a
maturity comparable to the remaining term of the 2030 Notes to be redeemed that would be utilized, at the time of selection and in
accordance with customary
financial practice, in pricing new issues of corporate notes of comparable maturity to the remaining term of the Notes.

“Comparable German Bund Price” means, with respect to any redemption date, (i) the average of four Reference German Bund
Dealer Quotations for such redemption date, after excluding the highest and lowest such Reference German Bund Dealer Quotations or
(ii) if the Quotation Agent obtains fewer than four such Reference German Bund Dealer Quotations, the average of all such quotations.

 
“Quotation Agent” means a Reference German Bund Dealer appointed by us.

“Reference German Bund Dealer” means any dealer of German Bundesanleihe securities selected by us in good faith.

“Reference German Bund Dealer Quotations” means, with respect to each Reference German Bund Dealer and any redemption
date, the average, as determined by us, of the bid and asked prices for the Comparable German Bund Issue (expressed in each case as a
percentage  of  its  principal  amount)  quoted  in  writing  to  the  Quotation  Agent  by  such  Reference  German  Bund  Dealer  at  3:30  p.m.,
Frankfurt, Germany time, on the third business day preceding such redemption date.

If we elect to redeem less than all of the 2030 Notes, and such 2030 Notes are at the time represented by a global note, then the
depositary will select by lot the particular interests to be redeemed. If we elect to redeem less than all of the 2030 Notes, and any of
such 2030 Notes are not represented by a global note, then the trustee will select the particular 2030 Notes to be redeemed in a manner
it deems appropriate and fair (and the depositary will select by lot the particular interests in any global note to be redeemed).

We may at any time, and from time to time, purchase the 2030 Notes at any price or prices in the open market or otherwise.

Repurchase upon Change of Control Triggering Event

If a Change of Control Triggering Event (as defined below) occurs with respect to the 2030 Notes, unless we have exercised our
right  to  redeem  the  2030  Notes,  we  will  be  required  to  make  an  offer  to  repurchase  all  or,  at  the  holder’s  option,  any  part  (equal  to
€100,000 or any integral multiple of €1,000 in excess thereof) of each holder’s 2030 Notes pursuant to the offer described below (the
“Change of Control Offer”).

In the Change of Control Offer, we will be required to offer payment in cash equal to 101% of the aggregate principal amount of
2030  Notes  repurchased  plus  accrued  and  unpaid  interest,  if  any,  on  the  2030  Notes  repurchased  to,  but  not  including,  the  date  of
purchase (the “Change of Control Payment”).

“Change of Control” means the occurrence of any of the following: (1) the direct or indirect sale, transfer, conveyance or other

disposition (other than by way of merger or

consolidation), in one or a series of related transactions, of all or substantially all of the assets of us and our Subsidiaries taken as a
whole to any Person or group of related Persons for purposes of Section 13(d) of the Exchange Act (a “Group”) other than us or one of
our subsidiaries; (2) the approval by the holders of our common stock of any plan or proposal for our liquidation or dissolution; (3) the
consummation of any transaction (including, without limitation, any merger or consolidation) the result of which is that any Person or
Group becomes the beneficial owner, directly or indirectly, of more than 50% of the then outstanding number of shares of our Voting
Stock; or (4) the first day on which a majority of the members of our board of directors are not Continuing Directors.

Notwithstanding the foregoing, a transaction will not be deemed to involve a Change of Control if (1) we become a direct or
indirect wholly owned subsidiary of a holding company and (2)(A) the direct or indirect holders of the Voting Stock of such holding
company immediately following that transaction are substantially the same as the holders of our Voting Stock immediately prior to that
transaction  or  (B)  immediately  following  that  transaction  no  Person  or  Group  (other  than  a  holding  company  satisfying  the
requirements  of  this  sentence)  is  the  beneficial  owner,  directly  or  indirectly  of  more  than  50%  of  the  Voting  Stock  of  such  holding
company.

“Change of Control Triggering Event” means the occurrence of both a Change of Control and a Below Investment Grade Rating

Event (as such term is defined in the indenture) occurring in respect of that Change of Control.

“Continuing Directors” means, as of any date of determination, any member of our board of directors who (1) was a member of
our board of directors on the date of the issuance of the 2030 Notes; or (2) was nominated or approved for election, elected or appointed
to our board of directors with the approval of a majority of the Continuing Directors who were members of our board of directors at the
time of such nomination, approval, election or appointment (either by a specific vote or by approval of the proxy statement issued by us
in which such member was named as a nominee for election as a director).

“Person”  means  any  individual,  firm,  limited  liability  company,  corporation,  partnership,  association,  joint  venture,  tribunal,
trust,  government  or  political  subdivision  or  agency  or  instrumentality  thereof,  or  any  other  entity  or  organization  and  includes  a
“person” as used in Section 13(d)(3) of the Exchange Act.

      “Voting Stock” of any specified Person as of any date means the capital stock of such Person that is at the time entitled to vote
generally in the election of the board of directors of such Person.

The definition of “Change of Control” includes a phrase relating to the sale, transfer, conveyance or other disposition of “all or
substantially all” of our consolidated assets. There is no precise, established definition of the phrase “substantially all” under applicable
law. Accordingly, your ability to require us to purchase your 2030 Notes as a result of the sale, transfer, conveyance or other disposition
of less than all of our assets may be uncertain.

Certain Covenants

The indenture contains, among others, restrictive covenants regarding (i) our ability to consolidate or merge with another entity
or  to  sell,  transfer  or  otherwise  convey  all  or  substantially  all  of  our  assets  to  another  entity,  (ii)  create  or  permit  certain  significant
subsidiaries to create or permit to exist certain liens and (iii) certain sale and lease-back transactions involving certain subsidiaries.

Events of Default

Holders  of  the  2030  Notes  will  have  specified  rights  if  an  Event  of  Default  (as  defined  below)  occurs.  The  term  “Event  of

Default” in respect of the 2030 Notes means any of the following:

(1)

(2)

(3)

(4)

we do not pay interest on any of the 2030 Notes within 30 days of its due date;

we fail to pay the principal (or premium, if any) of any 2030 Note, when such principal becomes due and payable, at
maturity, upon acceleration, upon redemption or otherwise;

we fail to comply with certain covenants under the indenture;

we  remain  in  breach  of  a  covenant  or  warranty  in  respect  of  the  indenture  or  2030  Notes  (other  than  a  covenant
included in the indenture solely for the benefit of debt securities of another series) for 90 days after we receive a written
notice of default, which notice must be sent by either the trustee or holders of at least 25% in principal amount of the
outstanding 2030 Notes;

(5)

(6)

(7)

we file for bankruptcy, or other events of bankruptcy, insolvency or reorganization specified in the indenture;

we  default  on  any  indebtedness  of  ours  or  of  a  significant  subsidiary  having  an  aggregate  amount  of  at  least
$150,000,000,  constituting  a  default  either  of  payment  of  principal  when  due  and  payable  or  which  results  in
acceleration  of  the  indebtedness  unless  the  default  has  been  cured  or  waived  or  the  indebtedness  discharged  in  full
within 60 days after we have been notified of the default by the trustee or holders of at least 25% of the outstanding
2030 Notes; or

one  or  more  final  judgments  for  the  payment  of  money  in  an  aggregate  amount  in  excess  of  $150,000,000  above
available insurance or indemnity coverage shall be rendered against us or any significant subsidiary and the same shall
remain undischarged for a period of 60 consecutive days during which execution shall not be effectively stayed.

If an Event of Default (other than an Event of Default specified in clause (5) above) with respect to the 2030 Notes has occurred, the
trustee or the holders of at least 25% in principal amount of the 2030 Notes may declare the entire unpaid principal amount of (and
premium,  if  any),  and  all  the  accrued  interest  on,  the  Notes  to  be  due  and  immediately  payable.  This  is  called  a  declaration  of
acceleration of maturity. There is no action on the part of the trustee or any holder of the 2030 Notes required for such declaration if the
Event  of  Default  is  the  Company’s  bankruptcy,  insolvency  or  reorganization.  Holders  of  a  majority  in  principal  amount  of  the  2030
Notes may also waive certain past defaults under the indenture with respect to the 2030 Notes on behalf of all of the holders of the 2030
Notes. A declaration of acceleration of maturity may be canceled, under specified circumstances, by the holders of at least a majority in
principal amount of the 2030 Notes and the trustee.

Except in cases of default, where the trustee has special duties, the trustee is not required to take any action under the indenture at the
request of holders unless the holders offer the trustee protection from expenses and liability satisfactory to the trustee. If an indemnity
satisfactory to the trustee is provided, the holders of a majority in principal amount of 2030 Notes may direct the time, method and
place  of  conducting  any  lawsuit  or  other  formal  legal  action  seeking  any  remedy  available  to  the  trustee.  The  trustee  may  refuse  to
follow those directions in certain circumstances specified in the indenture. No delay or omission in exercising any right or remedy will
be treated as a waiver of the right, remedy or Event of Default.

    
Modification of the Indenture and Waiver of Rights of Holders

Under certain circumstances, we can make changes to the indenture and the 2030 Notes. Some types of changes require the approval of
each holder of 2030 Notes, some require approval by a vote of a majority of the holders of the 2030 Notes, and some changes do not
require any approval at all.
Description of the 1.75% Senior Notes Due 2029

The  1.75%  Senior  Notes  due  2029  (the  “2029  Notes”)  were  issued  under  an  indenture,  dated  as  of  June  7,  2013  (the  “base
indenture”)  between  Nasdaq,  Inc.  and  Wells  Fargo  Bank,  National  Association,  as  trustee  (the  “Trustee”)  and  a  sixth  supplemental
indenture dated as of April 1, 2019 (the “supplemental indenture” and, together with the base indenture, the “indenture”). The indenture
is publicly available at www.sec.gov.

We issued €600 million aggregate principal amount of the 2029 Notes on April 1, 2019.

This summary is subject to, and qualified in its entirety by reference to, all the provisions of the 2029 Notes and the indenture,

including definitions of certain terms used therein.

General

The 2029 Notes:

•

•

•

•

are senior unsecured obligations;

rank  equally  in  right  of  payment  with  all  of  our  other  senior  unsecured  indebtedness  from  time  to  time  outstanding,
commercial paper issuances and indebtedness under our 2017 credit facility;

are structurally subordinated in right of payment to all existing and future obligations of our subsidiaries, including claims
with respect to trade payables; and

are effectively subordinated in right of payment to all of our existing and future secured indebtedness and other secured
obligations to the extent of the value of the collateral securing any such indebtedness and other obligations.

The 2029 Notes were issued in minimum denominations of €100,000 and integral multiples of €1,000 in excess thereof.

Principal, Maturity and Interest

The 2029 Notes bear interest at a rate of 1.75% per year. Interest on the 2029 Notes is payable annually in arrears on of each year,
beginning  on  March  28,  2020,  and  is  computed  on  the  basis  of  the  actual  number  of  days  in  the  period  for  which  interest  is  being
calculated  and  the  actual  number  of  days  from  and  including  the  last  date  on  which  interest  was  paid  on  the  2029  Notes  (or  the
settlement date if no interest has been paid or duly provided for on the 2029 Notes), to but excluding the next date on which interest is
paid or duly provided  for.  This  payment  convention  is  referred  to  as  ACTUAL/ACTUAL (ICMA) as defined in the rulebook of the
International Capital Market Association. Interest on the 2029 Notes accrues from and including the settlement date and will be paid to
holders of record on the day immediately prior to the applicable interest payment date.

The 2029 Notes will mature on March 28, 2029. On the maturity date of the 2029 Notes, the holders will be entitled to receive

100% of the principal amount of such 2029 Notes. The 2029 Notes will not have the benefit of any sinking fund.

If any interest payment date, redemption date or maturity date falls on a day that is not a business day, then the relevant payment
may be made on the next succeeding business day and no interest will accrue because of such delayed payment. With respect to the
2029 Notes, when we use the term “business day” we mean any day except a Saturday, a Sunday or a day on which banking institutions
in the applicable place of payment are authorized or required by law, regulation or executive order to close.

Claims against the Company for payment of principal, interest and additional amounts, if any, on the 2029 Notes will become void
unless presentment for payment is made (where so required under the indenture) within, in the case of principal and additional amounts,
if any, a period of ten years or, in the case of interest, a period of five years, in each case from the applicable original date of payment
therefor.

Euro Notes—Issuance in Euros

Initial holders of the 2029 Notes paid for the 2029 Notes in euros, and principal, premium, if any, and interest payments and
additional amounts, if any, in respect of the Notes will be payable in euros. If the euro is unavailable to us due to the imposition of
exchange controls or other circumstances beyond our control or the euro is no longer used by the then member states of the European
Monetary  Union  that  have  adopted  the  euro  as  their  currency  or  for  the  settlement  of  transactions  by  public  institutions  within  the
international banking community, then all payments in respect of the 2029 Notes will be made in U.S. dollars until the euro is again
available to us or so used.

The amount payable on any date in euros will be converted to U.S. dollars on the basis of the most recently available market
exchange rate for euros as determined by us in our sole discretion. Any payment in respect of the 2029 Notes so made in U.S. dollars
will not constitute an event of default under the indenture or the 2029 Notes. Neither the trustee nor the paying agent will be responsible
for obtaining exchange rates, effecting conversions or otherwise handling redenominations.

Interest Rate Adjustment

The interest rate payable on the 2029 Notes will be subject to adjustment from time to time if either Moody’s or S&P, or, in either

case, any substitute rating agency downgrades (or subsequently upgrades) the credit rating assigned to the 2029 Notes.

Ranking

The  2029  Notes  are  general  unsecured  obligations  of  ours  and  rank  equally  with  all  of  our  existing  and  future  unsubordinated

obligations.

Holders of any secured indebtedness and other secured obligations of the Company will have claims that are prior to claims as
holders of the 2029 Notes, to the extent of the value of the assets securing such indebtedness and other obligations, in the event of any
bankruptcy, liquidation or similar proceeding.

Further Issues

The 2029 Notes constituted a separate series of debt securities under the indenture, limited to €600 million. Under the indenture,
we may, without the consent of the holders of the 2029 Notes, issue additional 2029 Notes of the same or a different series from time to
time in the future in an unlimited aggregate principal amount; provided, that, if any such additional 2029 Notes are not fungible with
the 2029 Notes (or any other tranche of additional 2029 Notes) for U.S. federal income tax purposes, then such additional 2029 Notes
will have different ISIN and/or Common Code numbers than the 2029 Notes (and any such other tranche of additional 2029 Notes).
The 2029 Notes and any additional 2029 Notes of the same series would rank equally and ratably and would be treated as a single class
for all purposes under the indenture. This means that, in circumstances where the indenture provides for the holders of debt securities of
any series to vote or take any action, any of the outstanding 2029 Notes, as well as any additional 2029 Notes that we may issue by
reopening such series, will vote or take action as a single class.

Redemption

Optional Redemption

The 2029 Notes will be redeemable, in whole at any time or in part from time to time, at our option, at a redemption price (the
“make-whole redemption price”) equal to the greater of (i) 100% of the principal amount of the 2029 Notes, and (ii) as determined by
the Quotation Agent (as defined below), the sum of the present values of the remaining scheduled payments of principal and interest on
the  2029  Notes  (exclusive  of  interest  accrued  and  unpaid  as  of  the  date  of  redemption),  discounted  to  the  date  of  redemption  on  an
annual basis (ACTUAL/ACTUAL (ICMA)) at the Bund Rate (as defined below), plus 30 basis points, plus accrued and unpaid interest
thereon to the date of redemption. However, if the redemption date is after a record date and on or prior to a corresponding interest
payment date, the interest will be paid on the redemption date to the holder of record on the record date.

Notwithstanding  the  foregoing,  at  any  time  on  or  after  December  28,  2028  (three  months  before  their  maturity  date),  the  2029
Notes will be redeemable, in whole or in part, at our option and at any time or from time to time, at a redemption price equal to 100%
of  the  principal  amount  of  the  2029  Notes  to  be  redeemed  plus  accrued  and  unpaid  interest  thereon  to,  but  excluding,  the  date  of
redemption.

Notice of any redemption will be mailed at least 30 days, but not more than 60 days, before the redemption date to each registered
holder of 2029 Notes to be redeemed. Once notice of redemption is mailed, the 2029 Notes called for redemption will become due and
payable  on  the  redemption  date  and  at  the  applicable  redemption  price,  plus  accrued  and  unpaid  interest  to,  but  not  including,  the
redemption date. Unless we default in payment of the redemption price, on and after the redemption date, interest will cease to accrue
on the 2029 Notes (or portion thereof) to be redeemed on such redemption date.

“Bund Rate” means, with respect to any redemption date, the rate per annum equal to the annual equivalent yield to maturity of the
Comparable German Bund Issue, assuming a price for the Comparable German Bund Issue (expressed as a percentage of its principal
amount) equal to the Comparable German Bund Price for such redemption date.

“Comparable  German  Bund  Issue”  means  that  German  Bundesanleihe  security  selected  by  the  Quotation  Agent  as  having  a
maturity  comparable  to  the  remaining  term  of  the  Notes  to  be  redeemed  that  would  be  utilized,  at  the  time  of  selection  and  in
accordance with customary financial practice, in pricing new issues of corporate notes of comparable maturity to the remaining term of
the Notes.

“Comparable German Bund Price” means, with respect to any redemption date, (i) the average of four Reference German Bund
Dealer Quotations for such redemption date, after excluding the highest and lowest such Reference German Bund Dealer Quotations, or
(ii) if the Quotation Agent obtains fewer than four such Reference German Bund Dealer Quotations, the average of all such quotations.

“Quotation Agent” means a Reference German Bund Dealer appointed by us.

“Reference German Bund Dealer” means any dealer of German Bundesanleihe securities selected by us in good faith.

“Reference German Bund Dealer Quotations” means, with respect to each Reference German Bund Dealer and any redemption
date, the average, as determined by us, of the bid and asked prices for the Comparable German Bund Issue (expressed in each case as a
percentage  of  its  principal  amount)  quoted  in  writing  to  the  Quotation  Agent  by  such  Reference  German  Bund  Dealer  at  3:30  p.m.,
Frankfurt, Germany time, on the third business day preceding such redemption date.

If we elect to redeem less than all of the 2029 Notes, and such 2029 Notes are at the time represented by a global note, then the
depositary will select by lot the particular interests to be redeemed. If we elect to redeem less than all of the 2029 Notes, and any of
such 2029 Notes are not represented by a global note, then the trustee will select the particular 2029 Notes to be redeemed in a manner
it deems appropriate and fair (and the depositary will select by lot the particular interests in any global note to be redeemed).

We may at any time, and from time to time, purchase the 2029 Notes at any price or prices in the open market or otherwise.

Repurchase upon Change of Control Triggering Event

If a Change of Control Triggering Event (as defined below) occurs with respect to the 2029 Notes, unless we have exercised our
right to redeem the 2029 Notes, we are required to make an offer to repurchase all or, at the holder’s option, any part (equal to €100,000
or any integral multiple of €1,000 in excess thereof) of each holder’s 2029 Notes pursuant to the offer described below (the “Change of
Control Offer”).

In the Change of Control Offer, we will be required to offer payment in cash equal to 101% of the aggregate principal amount of
2029 Notes repurchased plus accrued and unpaid interest, if any, on the Notes repurchased to, but not including, the date of purchase

(the “Change of Control Payment”).

“Change of Control” means the occurrence of any of the following: (1) the direct or indirect sale, transfer, conveyance or other
disposition (other than by way of merger or consolidation), in one or a series of related transactions, of all or substantially all of the
assets  of  us  and  our  Subsidiaries  taken  as  a  whole  to  any  Person  or  group  of  related  Persons  for  purposes  of  Section  13(d)  of  the
Exchange Act (a “Group”) other than us or one of our subsidiaries; (2) the approval by the holders of our common stock of any plan or
proposal  for  our  liquidation  or  dissolution;  (3)  the  consummation  of  any  transaction  (including,  without  limitation,  any  merger  or
consolidation) the result of which is that any Person or Group becomes the beneficial owner, directly or indirectly, of more than 50% of
the then outstanding number of shares of our Voting Stock; or (4) the first day on which a majority of the members of our board of
directors are not Continuing Directors.

Notwithstanding  the  foregoing,  a  transaction  will  not  be  deemed  to  involve  a  Change  of  Control  if  (1)  we  become  a  direct  or
indirect wholly owned Subsidiary of a holding company and (2)(A) the direct or indirect holders of the Voting Stock of such holding
company immediately following that transaction are substantially the same as the holders of our Voting Stock immediately prior to that
transaction  or  (B)  immediately  following  that  transaction  no  Person  or  Group  (other  than  a  holding  company  satisfying  the
requirements  of  this  sentence)  is  the  beneficial  owner,  directly  or  indirectly  of  more  than  50%  of  the  Voting  Stock  of  such  holding
company.

“Change of Control Triggering Event” means the occurrence of both a Change of Control and a Below Investment Grade Rating

Event (as such term is defined in the indenture) occurring in respect of that Change of Control.

“Continuing Directors” means, as of any date of determination, any member of our board of directors who (1) was a member of
our board of directors on the date of the issuance of the Notes; or (2) was nominated or approved for election, elected or appointed to
our board of directors with the approval of a majority of the Continuing Directors who were members of our board of directors at the
time of such nomination, approval, election or appointment (either by a specific vote or by approval of the proxy statement issued by us
in which such member was named as a nominee for election as a director).

“Person” means any individual, firm, limited liability company, corporation, partnership, association, joint venture, tribunal, trust,
government or political subdivision or agency or instrumentality thereof, or any other entity or organization and includes a “person” as
used in Section 13(d)(3) of the Exchange Act.

“Voting Stock” of any specified Person as of any date means the capital stock of such Person that is at the time entitled to vote

generally in the election of the board of directors of such Person.

The definition of “Change of Control” includes a phrase relating to the sale, transfer, conveyance or other disposition of “all or
substantially all” of our consolidated assets. There is no precise, established definition of the phrase “substantially all” under applicable
law. Accordingly, the ability to require us to purchase 2029 Notes as a result of the sale, transfer, conveyance or other disposition of less
than all of our assets may be uncertain.

Certain Covenants

The indenture contains, among others, restrictive covenants regarding (i) our ability to consolidate or merge with another entity or
to  sell,  transfer  or  otherwise  convey  all  or  substantially  all  of  our  assets  to  another  entity;  (ii)  create  or  permit  certain  significant
subsidiaries to create or permit to exist certain liens and (iii) certain sale and lease-back transactions involving certain subsidiaries.

Events of Default

Holders of the 2029 Notes will have specified rights if an Event of Default (as defined below) occurs. The term “Event of Default”

in respect of the Notes means any of the following:

(1)

(2)

(3)

(4)

we do not pay interest on any of the Notes within 30 days of its due date;

we fail to pay the principal (or premium, if any) of any Note, when such principal becomes due and payable, at maturity,
upon acceleration, upon redemption or otherwise;

failure by us to comply with the covenants under the indenture;

we remain in breach of a covenant or warranty in respect of the indenture or 2029 Notes (other than a covenant included
in the indenture solely for the benefit of debt securities of another series) for 90 days after we receive a written notice of
default, which notice must be sent by either the trustee or holders of at least 25% in principal amount of the outstanding
2029 Notes;

(5)

we file for bankruptcy, or other events of bankruptcy, insolvency or reorganization specified in the indenture;

(6)

(7)

we  default  on  any  indebtedness  of  ours  or  of  a  significant  subsidiary  having  an  aggregate  amount  of  at  least
$150,000,000,  constituting  a  default  either  of  payment  of  principal  when  due  and  payable  or  which  results  in
acceleration of the indebtedness unless the default has been cured or waived or the indebtedness discharged in full within
60  days  after  we  have  been  notified  of  the  default  by  the  trustee  or  holders  of  at  least  25%  of  the  outstanding  2029
Notes; or

one  or  more  final  judgments  for  the  payment  of  money  in  an  aggregate  amount  in  excess  of  $150,000,000  above
available insurance or indemnity coverage shall be rendered against us or any significant subsidiary and the same shall
remain undischarged for a period of 60 consecutive days during which execution shall not be effectively stayed.

If an Event of Default (other than an Event of Default specified in clause (5) above) with respect to the 2029 Notes has occurred, the
Trustee or the holders of at least 25% in principal amount of
the 2029 Notes may declare the entire unpaid principal amount of (and premium, if any), and all the accrued interest on, the Notes to be
due and immediately payable. This is called a declaration of acceleration of maturity. There is no action on the part of the trustee or any
holder  of  the  2029  Notes  required  for  such  declaration  if  the  Event  of  Default  is  the  Company’s  bankruptcy,  insolvency  or
reorganization. Holders of a majority in principal amount of the Notes may also waive certain past defaults under the indenture with
respect to the 2029 Notes on behalf of all of the holders of the 2029 Notes. A declaration of acceleration of maturity may be canceled,
under specified circumstances, by the holders of at least a majority in principal amount of the 2029 Notes and the trustee.

Except in cases of default, where the trustee has special duties, the trustee is not required to take any action under the indenture at
the  request  of  holders  unless  the  holders  offer  the  trustee  protection  from  expenses  and  liability  satisfactory  to  the  trustee.  If  an
indemnity  satisfactory  to  the  trustee  is  provided,  the  holders  of  a  majority  in  principal  amount  of  2029  Notes  may  direct  the  time,
method and place of conducting any lawsuit or other formal legal action seeking any remedy available to the trustee. The trustee may
refuse to follow those directions in certain circumstances specified in the indenture. No delay or omission in exercising any right or
remedy will be treated as a waiver of the right, remedy or Event of Default.

Before holders of the 2029 Notes are allowed to bypass the trustee and bring a lawsuit or other formal legal action or take other

steps to enforce their rights or protect their interests relating to the 2029 Notes, the following must occur:

•

•

such holders must give the trustee written notice that an Event of Default has occurred and remains uncured;

holders  of  at  least  25%  in  principal  amount  of  the  2029  Notes  must  make  a  written  request  that  the  trustee  take  action
because of the default and must offer the Trustee indemnity satisfactory to the trustee against the cost and other liabilities
of taking that action; and

•

the trustee must have failed to take action for 60 days after receipt of the notice and offer of indemnity.

Holders are, however, entitled at any time to bring a lawsuit for the payment of money due on the 2029 Notes on or after the due

date.

Modification of the Indenture and Waiver of Rights of Holders

Under  certain  circumstances,  we  can  make  changes  to  the  indenture  and  the  2029  Notes.  Some  types  of  changes  require  the
approval  of  each  holder  of  2029  Notes,  some  require  approval  by  a  vote  of  a  majority  of  the  holders  of  the  2029  Notes,  and  some
changes do not require any approval at all.

 
Nasdaq, Inc.
Change in Control Severance Plan
For Non-CEO Presidents, Executive Vice Presidents and Senior Vice Presidents

Effective November 26, 2013 (as amended December 6, 2022)

Exhibit 10.19

1.

2.

Purpose. The Nasdaq Change in Control Severance Pay Plan (the “Plan”) has been established by Nasdaq, Inc. ( “Nasdaq” or “the Company”), effective as
of November 26, 2013 (as amended December 6, 2022) (“Effective Date”) to promote the long-term financial interests of the Company and its shareholders
by (i) providing key employees of the Company and its subsidiaries with assurances of fair and equitable treatment as well as severance benefits consistent
with competitive practices in the event of a Change in Control of the Company and (ii) reducing the risk of departures and distractions of such employees in
a Change in Control situation which would be detrimental to the Company and its shareholders.

Definitions. As used in this Plan, the following terms shall have the meanings set forth below:

(a)

(b)

(c)

“Board” means the Board of Directors of Nasdaq, Inc.

“Cause” means, for Executives employed in the United States, (i) the Executive’s conviction of, or pleading nolo contendere to, any crime, whether a
felony or misdemeanor, involving the purchase or sale of any security, mail or wire fraud, theft, embezzlement, moral turpitude, or Nasdaq or its
affiliates’ property (with the exception of minor traffic violations or similar misdemeanors); (ii) the Executive’s repeated neglect of his or her duties;
or (iii) the Executive’s willful misconduct in connection with the performance of his or her duties. For Executives employed outside of the United
States, “Cause” shall be defined consistent with the requirements of local law in the jurisdiction where the Executive is regularly assigned to work.

“Change in Control” means the first to occur of any one of the following events:

(i)

any “Person,” as such term is used in Sections 13(d) and 14(d) of the Securities Exchange Act of 1934 (the “Exchange Act”) is or becomes
the beneficial owner, directly or indirectly, of more than 50% of the Voting Securities (not including any securities acquired directly (or
through an underwriter) from Nasdaq), except a Person shall not include:

(A) Nasdaq;

(B)

any Person who becomes the “beneficial owner” (as defined in Rule 13d-3 under the Exchange Act) of more than 50% of Nasdaq’s
then outstanding securities eligible to vote in the election of the Board (“Voting Securities”) as a result of a reduction in the number of
Voting Securities outstanding due to the repurchase of Voting Securities by Nasdaq unless and until such Person, after becoming aware
that such Person has become the beneficial owner of more than 50% of the then outstanding Voting Securities, acquires beneficial
ownership of additional Voting Securities representing 1% or more of the Voting Securities then outstanding,

(C)

any trustee or other fiduciary holding securities under an employee benefit plan of Nasdaq, or

(D)

any entity owned, directly or indirectly, by the stockholders of Nasdaq in substantially the same proportions as their ownership of
Voting Securities is or becomes the beneficial owner, directly or indirectly, of more than 50% of the Voting Securities (not including
any securities acquired directly (or through an underwriter) from Nasdaq or the Companies;

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(ii)

(iii)

(iv)

the date on which, within any twelve (12) month period (beginning on or after the Effective Date), a majority of the directors then serving on
the Board are replaced by directors not endorsed by at least two-thirds (2/3) of the members of the Board before the date of appointment or
election;

there is consummated a merger or consolidation of Nasdaq with any other corporation or entity or Nasdaq issues Voting Securities in
connection with a merger or consolidation of any direct or indirect subsidiary of Nasdaq with any other corporation, other than:

(A)

a merger or consolidation that would result in the Voting Securities outstanding immediately prior thereto continuing to represent
(either by remaining outstanding or by being converted into Voting Securities of the surviving or parent entity) more than 50% of
Nasdaq’s then outstanding Voting Securities or more than 50% of the combined voting power of such surviving or parent entity
outstanding immediately after such merger or consolidation or

(B)

a merger or consolidation effected to implement a recapitalization of Nasdaq (or similar transaction) in which no Person, directly or
indirectly, acquired more than 50% of Nasdaq’s then outstanding Voting Securities (not including any securities acquired directly (or
through an underwriter) from Nasdaq or the Companies); or

the consummation of an agreement for the sale or disposition by Nasdaq of all or substantially all of Nasdaq’s assets (or any transaction
having a similar effect), provided that such agreement or transaction of similar effect shall in all events require the disposition, within any
twelve (12) month period, of at least 40% of the gross fair market value of all of Nasdaq’s then assets; other than a sale or disposition by
Nasdaq of all or substantially all of Nasdaq’s assets to an entity, at least 50% of the combined voting power of the voting securities of which
are owned directly or indirectly by stockholders of Nasdaq in substantially the same proportions as their ownership of Nasdaq immediately
prior to such sale.

Notwithstanding anything in this Plan to the contrary, to the extent any provision of this Plan would cause a payment or benefit not exempt from
the requirements of Code Section 409A to be made because of the occurrence of a Change in Control, then such payment or benefit shall not be
made unless such Change in Control also constitutes a “change in ownership”, “change in effective control” or “change in ownership of a
substantial portion of the Company’s assets” within the meaning of Code section 409A. Any payment that would have been made except for the
application of the preceding sentence shall be made in accordance with the payment schedule that would have applied in the absence of a
Change in Control (and other Executive rights that are tied to a Change in Control shall not be affected by this paragraph).

“Companies” shall mean Nasdaq or any of its affiliates.

“Disability” shall mean either (i) the inability of the Executive to engage in any substantial gainful activity by reason of any medically determinable
physical or mental impairment that can be expected to result in death or can be expected to last for a continuous period of not less than 12 months or
(ii) the Executive is, by reason of any medically determinable physical or mental impairment that can be expected to result in death or can be
expected to last for a continuous period of not less than 12 months, receiving income replacement benefits for a period of not less than three months
under an accident and health plan covering employees of the Companies. The Executive shall be deemed disabled if he is determined to be (i) totally
disabled by the Social Security Administration (or a similar governmental agency in the country where the Executive is regularly assigned to work)
or (ii) disabled in accordance with a disability insurance program, provided such definition of disabled under the program complies with the
definition of Disability hereunder. Otherwise, such Disability shall be certified by a physician chosen by Nasdaq and reasonably acceptable to the
Executive (unless he is then legally incapacitated, in which case such physician shall be reasonably acceptable to the Executive’s authorized legal
representative).

(d)

(e)

(f)

“Employing Entity” shall mean Nasdaq or the affiliate that employs the Executive.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(g)

(h)

“Executive” shall mean an individual who is either a Non-CEO President, an Executive Vice President or Senior Vice President of the Companies;
provided, however that in no event shall an individual be eligible to participate in the Plan if the individual is covered under an active individual
severance agreement entered into with the Companies.

“Good Reason shall mean the Employing Entity (i) reducing the Executive’s position, duties, or authority; (ii) failing to secure the agreement of any
successor entity to the Company that the Executive shall continue in his or her position without reduction in position, duties or authority; or
(iii) relocating the Executive’s principal work location beyond a 50 mile radius of his or her work location as of the date immediately preceding the
date of a Change in Control; provided that no event or condition shall constitute Good Reason unless (A) the Executive gives the Employing Entity
written notice specifying his or her objection to such event or condition within 90 days following the occurrence of such event or condition, (B) such
event or condition is not corrected, in all material respects, by the Employing Entity in a manner that is reasonably satisfactory to the Executive
within 30 days following the Employing Entity’s receipt of such notice and (C) the Executive resigns from his or her employment with the
Employing Entity not more than 30 days following the expiration of the 30-day period described in the foregoing clause (B).

(i)

“Qualifying Termination” means a termination of Executive’s employment (i) by the Employing Entity other than for Cause or (ii) by Executive for
Good Reason. Termination of Executive’s employment on account of death, Disability or voluntary termination other than for Good Reason shall not
be treated as a Qualifying Termination.

3.

Payments Upon Termination of Employment following a Change in Control. If, within the period beginning on a Change in Control and ending two
(2) years following such Change in Control, Executive’s employment with the Employing Entity terminates by the Employing Entity for a reason other than
for Cause, or within the period beginning on a Change in Control and ending one (1) year following such Change in Control, Executive’s employment with
the Employing Entity terminates by the Executive for Good Reason, Executive shall be entitled to the following payments and benefits subject to
Section 3(e).

(a)

Severance. On the sixtieth (60 ) day following the date of Executive’s Qualifying Termination, Nasdaq shall pay Executive a lump sum cash
payment in accordance with the following schedule:

th

(i)

(ii)

if Executive is a non-CEO President or an Executive Vice President (“EVP”) as of the Executive’s Qualifying Termination, then Executive’s
lump sum cash payment shall be equal to the sum of (x) 200% of Executive’s annual salary at the rate in effect on the date of Executive’s
Qualifying Termination and (y) 100% of Executive’s “Individual Target Award” (as that term is defined in the Nasdaq Inc. Executive
Corporate Incentive Plan (the “Executive Incentive Plan”)) for the Plan Year (as that term is defined in the Incentive Plan) in which
Executive’s Qualifying Termination occurs, or if such Individual Target Award has not yet been established for such Plan Year, 100% of
Executive’s Individual Target Award for the Plan Year prior to the year in which the Qualifying Termination occurs.

if Executive is a Senior Vice President (“SVP”) as of the Executive’s Qualifying Termination, then the Executive’s lump sum cash payment
shall be equal to the sum of (x) 150% of Executive’s annual salary at the rate in effect on the date of Executive’s Qualifying Termination and
(y) 100% of Executive’s “Individual Target Award” (as that term is defined in The Nasdaq Inc. Corporate Incentive Plan (the “Corporate
Incentive Plan”)) for the Plan Year (as that term is defined in the Corporate Incentive Plan) in which Executive’s Qualifying Termination
occurs, or if such Individual Target Award has not yet been established for such Plan Year, 100% of Executive’s Individual Target Award for
the Plan Year prior to the year in which the Qualifying Termination occurs.

 
 
 
 
 
 
 
 
 
 
 
 
(b)

(c)

(d)

(e)

Incentive Compensation. Notwithstanding any provision of the Incentive Plan to the contrary, Nasdaq shall pay Executive on the sixtieth (60 ) day
following the date of Executive’s Qualifying Termination a lump sum cash payment equal to the sum of (i) any unpaid “Award” (as that term is
defined in the Executive Incentive Plan or Corporate Incentive Plan, as applicable) which had been earned by Executive for a completed Plan Year
and (ii) Executive’s “Pro-Rata Individual Target Award.” The term Pro-Rata Individual Target Award means in respect to the Plan Year during which
Executive’s Qualifying Termination occurs an amount equal to the product of (i) Executive’s Individual Target Award for the Plan Year in which
Executive’s Qualifying Termination occurs, or if such Individual Target Award has not yet been established for such Plan Year, 100% of Executive’s
Individual Target Award for the Plan Year prior to the year in which the Qualifying Termination occurs and (ii) a fraction, the numerator of which
equals the number of days from and including the first day of the Plan Year during which the Qualifying Termination occurred through and including
the date of Executive’s Qualifying Termination.

th

United States Health and Welfare Benefits. Nasdaq shall pay to Executive on a monthly basis during the CIC Coverage Period a taxable monthly cash
payment equal to the COBRA premium for the highest level of coverage available under the Employing Entity’s group health plans, but reduced by
the monthly amount that Executive would pay for such coverage if the Executive was an active employee. “CIC Coverage Period” shall mean the
period (I) commencing on the first day of the month following the Release and Covenants Effective Date (provided that if the 60 day period
described in Section 3(e) below begins in one calendar year and ends in another, the CIC Coverage Period shall commence not earlier than January 1
of the calendar year following an Executive’s Qualifying Termination) and (II) ending on the earlier of (x) the expiration of 24 months from the first
day of the CIC Coverage Period in the case of an Executive who is a non-CEO President or an EVP as of the Executive’s Qualifying Termination (the
expiration of 18 months in the case of an Executive who is a SVP as of the Executive’s Qualifying Termination), and (y) the date that the Executive is
eligible for coverage under the health care plans of a subsequent employer. The payments provided by this subparagraph (c) shall be conditioned
upon the Executive being covered by the Company’s health care plans immediately prior to the Executive’s Qualifying Termination. The foregoing
payments are not intended to limit or otherwise reduce any entitlements that Executive may have under COBRA.

Non-United States Health and Welfare Benefits. Executives employed outside the United States shall receive a taxable monthly cash payment
equivalent to the Employing Entity’s share of the cost of the highest level of coverage available under the Employing Entity’s group health
plans during the CIC Coverage Period unless otherwise required by applicable local law.

Outplacement Services. Nasdaq shall provide Executive with outplacement services suitable to Executive’s position during the “Outplacement
Coverage Period”; provided that if such outplacement services are provided by a third party, Nasdaq shall pay the cost of such outplacement services
to the third party, up to a maximum amount of $50,000, no later than the last day of the third calendar year following the calendar year in which such
Qualifying Termination occurs. The “Outplacement Coverage Period” shall mean the period (I) commencing on the first day of the month following
the Release and Covenants Effective Date (provided that if the 60 day period described in Section 3(e) below begins in one calendar year and ends in
another, the CIC Coverage Period shall commence not earlier than January 1 of the calendar year following an Executive’s Qualifying Termination)
and (II) ending on the earlier of (x) the expiration of 12 months from the first day of the Outplacement Coverage Period or, if earlier, (y) the date the
Executive first accepts an offer of employment.

 
  
 
 
 
 
 
 
(f)

Release and Restrictive Covenants. Notwithstanding anything to the contrary in this Agreement, receipt of benefits under Section 3 shall be
contingent upon (i) Executive executing and delivering to Nasdaq a general release of claims following the date of the Executive’s Qualifying
Termination, in substantially the form attached as Exhibit A (“Release”) that, within 60 days of the Executive’s Qualifying Termination, has become
irrevocable by the Executive and (ii) Executive executing and delivering to Nasdaq a restrictive covenants and cooperation agreement, in
substantially the form attached as Exhibit B (“Covenants”) that, within 60 days of the Executive’s Qualifying Termination, has become irrevocable
by the Executive. The date on which the Release and Covenants become irrevocable under this subparagraph (i) shall be referred to as the Release
and Covenants Effective Date. If Executive fails to timely execute and deliver to Nasdaq the Release and Covenants, Nasdaq shall have no obligation
to pay or provide the benefits provided under this Section 3 to the Executive. Executives employed outside of the United States will be required to
execute comparable agreements consistent with the requirements of local law.

4.

Special Provisions for Executives Employed Outside of the United States: The severance payment under this Plan includes all contractual and statutory
payments that the Executive is entitled to upon termination or during or in respect of his/her notice period, including but not limited to:

i.

ii.

salary, pension, bonus, etc., payable in a notice period or in lieu of notice,

all severance payments payable under statute or collective or other agreements, and

iii.

compensation for untaken holiday.

Any part of the severance payment payable under this Plan which - pursuant to law or collective or other agreement - is to be paid into a public holiday fund,
or pension scheme, etc., will be withheld by the Employing Entity and paid towards the relevant holiday fund or pension scheme, etc. The severance payment
will be treated as advance payment for any compensation or awards which may be made to the employee by any court or tribunal (although no admission of
liability in relation to any such compensation or award is made).

If the gross value of the Executive’s contractual and statutory rights pertaining to termination of employment exceeds the severance payment under this Plan,
the Executive will be entitled to receive his or her contractual and statutory rights (less any applicable deductions for income tax withholding and Executive’s
social taxes) instead of the severance payment under this Plan. In no event will the Executive be entitled to receive severance payments under this Plan in
addition to other statutory or contractual entitlements payable in connection with the termination of employment.

5. Withholding Taxes.  Nasdaq may withhold from all payments or benefits due to Executive hereunder or under any other plan or arrangement of the

Companies all taxes which, by applicable federal, state, local or other law, Nasdaq determines it is required to withhold therefrom.

6.

Best Net. In connection with the excise tax imposed by Section 4999 of the Internal Revenue Code (“Code”), as amended, the Nasdaq will provide for the
“Best Net” so that Executive’s aggregate severance payments and benefits would be reduced to $1.00 less than that amount which would trigger the Code
Section 4999 excise tax if such reduction would result in such Executive receiving a greater after-tax benefit than Executive would receive if the full
severance benefits were paid (i.e., the aggregate severance payments and benefits that Executive receives will be either the full amount of severance
payments and benefits or an amount of severance payments and benefits reduced to the extent necessary so that Executive incurs no excise tax, whichever
results in Executive receiving the greater amount, taking into account applicable federal, state and local income, employment and other applicable taxes, as
well as the excise tax).

 
 
 
 
 
 
 
 
 
 
 
 
7.

Code Section 409A. To the extent applicable, it is intended that the Plan comply with the provisions of Code Section 409A. The Plan will be administered
and interpreted in a manner consistent with this intent, and any provision that would cause the Plan to fail to satisfy Code Section 409A will have no force
and effect until amended to comply therewith (which amendment may be retroactive to the extent permitted by Code Section 409A). Notwithstanding
anything contained herein to the contrary, for all purposes of this Plan, Executive shall not be deemed to have had a termination of employment until
Executive has incurred a separation from service as defined in Treasury Regulation §1.409A-1(h) and, to the extent required to avoid accelerated taxation
and/or tax penalties under Code Section 409A, payment of the amounts payable under the Plan that would otherwise be payable during the six-month period
after the date of termination shall instead be paid on the first business day after the expiration of such six-month period, plus interest thereon, at a rate equal
to the applicable “Federal short-term rate” (as defined in Code Section 1274(d)) for the month in which such date of termination occurs, from the respective
dates on which such amounts would otherwise have been paid until the actual date of payment. In addition, for purposes of the Plan, each amount to be paid
and each installment payment shall be construed as a separate, identified payment for purposes of Code Section 409A. With respect to expenses eligible for
reimbursement under the terms of this Plan, (i) the amount of such expenses eligible for reimbursement in any taxable year shall not affect the expenses
eligible for reimbursement in another taxable year and (ii) any reimbursements of such expenses shall be made no later than the end of the calendar year
following the calendar year in which the related expenses were incurred, except, in each case, to the extent that the right to reimbursement does not provide
for a “deferral of compensation” within the meaning of Code Section 409A.

8. Waiver of Breach. No waiver by any party hereto of a breach of any provision of the Plan by any other party, or of compliance with any condition or

provision of the Plan to be performed by such other party, will operate or be construed as a waiver of any subsequent breach by such other party of any
similar or dissimilar provisions and conditions at the same or any prior or subsequent time. The failure of any party hereto to take any action by reason of
such breach will not deprive such parry of the right to take action at any time while such breach continues

9.

Amendment and Termination. The Board may amend or terminate the Plan at any time; provided, however that no amendment of the Plan which is
adopted on or after a Change in Control or during the 180-day period immediately preceding a Change in Control shall directly or indirectly adversely
affect any Executive’s rights and benefits under the Plan without the written consent of that Executive and further provided, that the upon and after a
Change in Control, the Plan may not be terminated prior to the second anniversary of the occurrence of such Change in Control.

10. Administration. The Committee shall be responsible for administering this Plan. The Committee may employ attorneys, consultants, accountants, agents

and other individuals, any of whom may be an employee of Nasdaq, and the Committee, Nasdaq, and its officers and directors shall be entitled to rely upon
the advice, opinions or valuations of any such individuals. All actions taken and all interpretations and determinations made by the Committee shall be final
and binding upon Executives, the Companies, and all other interested individuals.

11.

Binding Agreement; Successors. In the event of any Change in Control, the provisions of this Plan shall be binding upon the surviving corporation, and
such surviving corporation shall be treated as Nasdaq hereunder. This Plan shall inure to the benefit of and be enforceable by Executive’s personal or legal
representatives, executors, administrators, successors, heirs, distributees, devisees and legatees. If Executive dies while any amounts would be payable to
Executive hereunder had Executive continued to live, all such amounts, unless otherwise provided herein, shall be paid in accordance with the terms of this
Plan to such person or persons appointed in writing by Executive to receive such amounts or, if no person is so appointed, to Executive’s estate.

12. Gender and Number. Except where otherwise indicated by the context, any masculine term used herein also shall include the feminine, the plural shall

include the singular, and the singular shall include the plural.

 
 
 
 
 
 
13. Unfunded Plan. Executives shall have no right, title or interest whatsoever in or to any investments that the Companies may make to aid it in meeting its

obligations under this Plan. Nothing contained in this Plan, and no action taken pursuant to its provisions, shall create or be construed to create a trust of any
kind, or a fiduciary relationship between the Companies and any Executive, beneficiary, legal representative or any other individual. To the extent that any
individual acquires a right to receive payments under this Plan, such right shall be no greater than the right of an unsecured general creditor of the
Companies. All payments to be made hereunder shall be paid from the general funds of Nasdaq, and no special or separate fund shall be established, and no
segregation of assets shall be made to assure payment of such amounts except as expressly set forth in this Plan.

14. Governing Law and Miscellaneous. The law of the State of New York shall govern this Plan without giving effect to its conflict of law principles. Should
a court of competent jurisdiction find that any provision of this Plan is void, voidable, illegal, or unenforceable, no other provision shall be affected thereby
and the balance shall be interpreted in a manner that gives effect to the intent of the parties. The normal rules of construction hold that all ambiguities are
construed against the drafting party will not apply to the interpretation of this Plan.

 
 
UNITED STATES GENERAL EXECUTIVE RELEASE AND WAIVER
1

Exhibit A

Reference is made to The Nasdaq Change in Control Severance Plan for Non-CEO Presidents, Executive Vice Presidents and Senior Vice

Presidents (the “CIC Plan”) that has been established by The Nasdaq, Inc. (“Nasdaq”), effective as of November 26, 2013 (as amended December 6, 2022) and
under

which (“Executive”) is covered. Capitalized terms not defined herein shall have the meaning ascribed to such terms in the CIC Plan.

FOR GOOD AND VALUABLE CONSIDERATION, as set forth in the CIC Plan (which is incorporated herein by reference as if set forth
fully herein and made a part hereof), the receipt, sufficiency and adequacy of which is hereby acknowledged by Executive’s signature below, Executive agrees as
follows:

1.

Acknowledgment and Release. Executive hereby accepts the separation package provided under the CIC Plan and hereby releases, discharges, and agrees
to hold harmless the Companies, their predecessors, successors, their boards of directors and their members, employees, officers, parent, shareholders,
employee benefit plans and their Plan Administrators, trusts, trustees, heirs, successors, and assigns (hereinafter referred to in this Release collectively as
the “Releasees”), from all claims, liabilities, demands, and causes of action at law or equity, known or unknown, fixed or contingent, which Executive have,
may have, will have, or claim to have against the Releasees as a result of Executive’s employment and/or this separation and the conclusion of Executive’s
employment with the Releasees at any time up to and including the date of the execution of this General Executive Release and Waiver, excluding all claims
that arise out of an asserted breach of the CIC Plan. Executive’s agreement pursuant to this General Executive Release and Waiver is hereinafter referred to
as the “Release”. This includes, but is not limited to, claims arising under federal, state, or local laws prohibiting employment discrimination, including
Title VII of the Civil Rights Act of 1964, as amended, the Age Discrimination in Employment Act, as amended (including the Older Workers Benefit
Protection Act), the Employment Retirement Income Security Act of 1974, as amended, the Equal Pay Act, the Fair Labor Standards Act, as amended, the
District of Columbia Human Rights Act, as amended, the Maryland Human Relations Act, the New York Executive Law, as amended, the New York City
Administrative Code, as amended, the New York Labor Law, as amended, the District of Columbia Wage Payment and Wage Collection Law, as amended,
the Maryland Wage Payment and Collection Act, as amended, claims growing out of any legal restrictions on an employer’s right to terminate its employees
in any jurisdiction, such as claims for wrongful or constructive discharge, breach of any express or implied contract, and/or any claims on any basis
whatsoever regarding Executive’s status, pay, position, or title while employed by the Releasees. Excluded from this Release are claims which cannot be
lawfully waived, including the right to file an administrative charge of discrimination with federal or state agencies. Executive is, however, waiving all
rights to monetary recovery in connection with any such charge.

Executive specifically promise not to sue the Releasees in any forum for any of the above-mentioned claims, except that Executive may bring a lawsuit to
challenge the validity of this letter agreement under the Age Discrimination in Employment Act (“ADEA”). If Executive violates this covenant,
Executive will be required to pay the Releasees’ defense costs, including its reasonable fees; alternatively, at Nasdaq’s option, Nasdaq’s remaining
obligations to pay severance money and/or benefits under the CIC Plan shall cease, and Executive will be required to repay to Nasdaq upon demand all
but $100.00 (one hundred dollars) of the payments and other benefits Executive received under the CIC Plan. The above payment/repayment provisions
do not apply in the event Executive sues the Releasees under the ADEA.

2.

Governing Law. The law of the State of New York shall govern this Release without giving effect to its conflict of law principles. Should a court of
competent jurisdiction find that any provision of this Release is void, voidable, illegal, or unenforceable, no other provision shall be affected thereby and
the balance shall be interpreted in a manner that gives effect to the intent of the parties. The parties agree that the normal rule of construction that holds that
all ambiguities are construed against the drafting party will not apply to the interpretation of this Release.

1
    Executives assigned outside the United States shall be required to execute a comparable version of this agreement consistent with local law of the jurisdiction where the Executive is assigned.
 3.

Headings. We further acknowledge that the headings in this Release are for convenience only and have no bearing on the meaning of this Release.

 
 
 
4.

5.

6.

7.

Time to Consider. Executive acknowledges that Executive has been advised that Executive has twenty-one (21) days from the date of receipt of this
Release to consider all the provisions of the Release and do hereby knowingly and voluntarily waive said given twenty-one day period. YOU FURTHER
ACKNOWLEDGE THAT YOU HAVE READ THE RELEASE CAREFULLY, HAVE BEEN ADVISED BY NASDAQ TO, AND HAVE IN FACT,
CONSULTED AN ATTORNEY, AND FULLY UNDERSTAND THAT BY SIGNING BELOW YOU ARE GIVING UP CERTAIN RIGHTS WHICH
YOU MAY HAVE TO SUE OR ASSERT A CLAIM AGAINST THE RELEASEES AS DESCRIBED HEREIN. YOU ACKNOWLEDGE THAT YOU
HAVE NOT BEEN FORCED OR PRESSURED IN ANY MANNER WHATSOEVER TO SIGN THIS RELEASE AND AGREE TO ALL OF ITS
TERMS VOLUNTARILY.

Revocation. Executive shall have seven (7) days from the date of Executive’s execution of the Release to revoke the Release, with respect to all claims
referred to herein (including, without limitation, any and all claims arising under ADEA). If Executive revokes the Release, Nasdaq will not be obligated to
honor its obligations under the CIC Plan.

No Admission. This Release does not constitute an admission of liability or wrongdoing of any kind by Executive or the Releasees.

Coordination with Executive Restrictive Covenants and Cooperation Agreement. In addition to the timely submission to Nasdaq of an executed
Release, Executive acknowledges and agrees that the payment of any benefits under the CIC Plan to the Executive also is contingent upon the Executive’s
timely submission to Nasdaq of an executed Executive Restrictive Covenants and Cooperation Agreement in substantially the form attached as Exhibit B to
the CIC Plan. Executive acknowledges that the Executive’s failure to submit to Nasdaq on a timely basis an executed Executive Restrictive Covenants and
Cooperation Agreement shall Waiver shall cause the Companies’ obligation to make the payments and/or provide the benefits referred to in the CIC Plan to
immediately cease.

If Executive agrees to the foregoing, please sign the enclosed copy of this Release in the space provided below and return it to me.

Very truly yours,

Nasdaq, Inc.

By:    

By signing below, I,                     , certify that I have read, carefully reviewed, fully understand, and agree to all the provisions of this Release, which, along with
the CIC Plan, Restrictive Covenants Agreement and any award agreements I entered into under the Equity Plan sets forth the entire agreement and understanding
between Nasdaq and me. I acknowledge that I have not relied upon any representation or statement, written or oral, not set forth in such documents.

Date:

cc: People @ Nasdaq

Office of General Counsel

 
 
 
 
 
 
UNITED STATES EXECUTIVE RESTRICTIVE COVENANTS AND COOPERATION AGREEMENT
2

Exhibit B

Reference is made to The Nasdaq Change in Control Severance Plan for Executive Vice Presidents and Senior Vice Presidents (the “CIC

Plan”) that has been established by Nasdaq, Inc.(“Nasdaq”), effective as of November 26, 2013 and under which                      (“Executive”) is covered.
Capitalized terms not defined herein shall have the meaning ascribed to such terms in the CIC Plan.

FOR GOOD AND VALUABLE CONSIDERATION, as set forth in the CIC Plan (which is incorporated herein by reference as if set forth
fully herein and made a part hereof), the receipt, sufficiency and adequacy of which is hereby acknowledged by Executive’s signature below, Executive agrees as
follows:

1.

2.

3.

4.

5.

Acknowledgment and Agreement. Executive hereby accepts the separation package provided under the CIC Plan and hereby agrees to the
provisions set forth in this Executive Restrictive Covenants and Cooperation Agreement (“Agreement”). Executive acknowledges that failure to
submit to Nasdaq and executed Agreement during the time period specified in Section 7 of this Agreement shall cause the Companies’ obligation to
make the payments and/or provide the benefits referred to in the CIC Plan to immediately cease.

Return of Nasdaq Property. Executive agrees to promptly return all property of the Companies to Executive’s manager. This includes (i) all
documents, data, materials, details, and copies thereof in any form (electronic or hard copy) that are the property of the Companies or were created
using the Companies resources or during any hours worked for the Companies including, without limitation, any data referred to in Section 5 of this
Agreement and (ii) all other property of the Companies including, without limitation, all computer equipment, and associated passwords, property
passes, keys, hardware keys, credit cards, and identification badges.

Non-solicitation of Employees. Executive agrees that Executive shall not directly recruit or solicit any current employee of the Companies to leave
the employ of the Companies for one year following the date of Executive’s Qualifying Termination. The term “directly” as used in this Section 3
shall mean that Executive shall not initiate such discussions with a current employee of the Companies.

Post-termination Cooperation. Executive agrees to cooperate with the Companies and to provide all information that the Companies may hereafter
reasonably request with respect to any matter involving Executive’s present or former relationship with the Companies, the work Executive has
performed, or present or former employees of the Companies so long as such requests do not unreasonably interfere with any other job or important
personal activity in which Executive is engaged. Nasdaq agrees to reimburse Executive for all reasonable out-of-pocket costs Executive incurs in
connection therewith.

Non-disclosure of Proprietary Information. Executive agrees that, with regard to all confidential technical, business, tax, financial or proprietary
knowledge and information Executive has obtained while employed by any of the Companies (“Proprietary Information”), Executive will not at any
time disclose any such Proprietary Information to any person, firm, corporation, association, governmental agency, employee, or entity or use any
such Proprietary Information for Executive’s own benefit or for the benefit of any other person, firm, corporation or other entity, except the
Companies and except as may be required by court order or subpoena. Executive agrees to notify the Nasdaq Office of General Counsel at the
address noted in the CIC Plan as soon as practicable after Executive’s receipt of such a court order or subpoena. For purposes of this letter

  Executives assigned outside the United States shall be required to execute a comparable version of this agreement consistent with local law of the jurisdiction where the Executive is assigned.
2

 
 
 
 
 
 
 
 
 
 
 
 
agreement, the term “Proprietary Information” does not include information that is in the public domain. For purposes of this letter agreement, the
term “Proprietary Information” shall include, but not be limited to, non-public aspects of all information about or relating to the Companies which:

i.

relates to specific matters such as trade secrets, pricing and advertising techniques or strategies, research and development activities, software
development, market development, exchange registration, the Companies’ costs, expenses, human resources or other employment issues,
matters relating to pending litigation, any matters pertaining to pending, past or future mergers, studies, market penetration plans, listing
retention plans and strategies, marketing plans and strategies, financial information, communication and/or public relations products, plans,
programs, and strategies, financial formulas and methods relating to the Companies’ business, computer software programs, accounting
policies and practices, tax information, information from and about tax returns, tax strategies, policies and methods, and all strategic plans or
other matters, strategies, and financial or operating information pertaining to clients, lenders, customers, counsel, or transactions as they may
exist from time to time which Executive may have acquired or obtained directly or indirectly by virtue of Executive’s employment with any
of the Companies; and/or,

ii.

is known to Executive from Executive’s confidential employment relationship with the Companies.

6.

7.

The information described above shall be presumed to constitute “Proprietary Information,” except to the extent that the same information:
(i) was known to Executive prior to Executive’s employment with the Companies as evidenced by written records in Executive’s possession
prior to such disclosure; (ii) was lawfully disclosed to Executive following the end of Executive’s employment with the Companies by a third
party under no obligation of confidentiality; and (iii) is generally known and available to all persons in the securities industry.

Non-disparagement. Executive agrees that Executive shall not issue, circulate, publish or utter any false or disparaging, statement, remarks,
opinions or rumors about Nasdaq or its shareholders or any of the Companies unless giving truthful testimony under subpoena or court order.
Notwithstanding the preceding or any other provision of this letter agreement to the contrary, Executive may provide truthful information to any
governmental agency or self-regulatory organization with or without subpoena or court order. With the exception of communications made in a
private corporate communication as an employee or consultant with regard to a listing decision of Executive’s employer or Executive’s consulting
client, Executive agree that public communications regarding a preference for listing a security on a market other than Nasdaq, that the quality of
Nasdaq as a securities market is in any way inferior to any other securities market or exchange, and/or that the regulatory efforts and programs of
Nasdaq or the NASD are or have been lax in any way, are specifically defined as disparaging and will constitute a material breach of this Plan by
Executive. Notwithstanding the foregoing, nothing in this Section 5 shall prevent Executive from making good faith, factual and truthful statements
related to listing on Nasdaq as long as Executive’s statements are not based on Proprietary Information.

Non-compete. Executive agrees that for one year following the date of Executive’s Qualifying Termination, Executive will not, directly or indirectly,
(i) engage in any “Competitive Business” (as defined below) for Executive’s own account, (ii) enter the employ of, or render any services to, any
person engaged in a Competitive Business, (iii) acquire a financial interest in, or otherwise become actively involved with, any person engaged in a
Competitive Business, directly or indirectly, as an individual, partner, shareholder, officer, director, principal, agent, trustee or consultant, or
(iv) interfere with business relationships (whether formed before or after the date of this Agreement) between Nasdaq and customers or suppliers of
Nasdaq. For purposes of this Agreement, “Competitive Business” shall mean (x) any national securities exchange registered with the Securities and
Exchange Commission, (y) any electronic communications network or (z) any other entity that engages in substantially the same business as Nasdaq,
in each case in North America or in any other location in which Nasdaq operates.

 
 
 
 
 
 
 
 
 
 
8.

Breach of Agreement. If Executive materially breaches or threatens to materially breach Executive’s obligations in set forth in this Agreement
and/or commence a suit or action or complaint in contravention of the Release attached as Exhibit A to the CIC Plan, Executive acknowledges that
the Companies’ obligation to make the payments and/or provide the benefits referred to in the CIC Plan shall immediately cease, and that the
Companies shall have, in addition to all other rights or remedies provided in law or in equity by reason of Executive’s material breach, the right to
seek the return of all payments and benefits paid pursuant to the CIC Plan unless prohibited by applicable law or regulation. Executive specifically
agrees and acknowledges that the Companies, after affording Executive reasonable, written notice of the material breach or threatened material
breach of this Agreement or the Release of the reasonable opportunity to cure, has the right to cease performing their obligations under the CIC Plan
in advance of any determination of material breach by a court of competent jurisdiction. If the Companies cease performing their obligations due to
such material breach or threatened material breach and a court of competent jurisdiction later determines that such action was without right, the
Companies agree to pay Executive all monies thus withheld plus simple interest at the prime rate in effect at the time the payments ceased and
Executive’s reasonable costs and expenses incurred in such action (including attorney fees), and Executive agrees to accept this as Executive’s
exclusive remedy therefore, as follows: any benefit under Sections 3(a) and 3(b) of the CIC Plan, as applicable, that are otherwise to be paid in a
single lump sum payment, shall, to the extent not otherwise previously paid to Executive, be paid to Executive in full (together with applicable
interest) no later than the end of Executive’s first taxable year in which such determination is made. Any reimbursement to Executive of the
reasonable costs and expenses incurred in such action shall be made no later than March 15 following the end of the calendar year in which the final
decision relating to such action is rendered. If the Companies cease performing their obligations due to such material breach or threatened material
breach and a court of competent jurisdiction later determines that a breach occurred and that such action was thus appropriate and permitted under
this Plan, Executive agrees to pay, in addition to such other costs as the court may direct, all of the Companies’ reasonable costs and expenses,
including attorney’s fees, unless prohibited by applicable law or regulation.

9.

Time to Consider and Execute. Executive acknowledges that Executive has been advised that Executive has twenty-eight (28) days from the date of
receipt of this Agreement (“Executive Period”) to consider all the provisions of the Agreement and to execute this Agreement and return it to
Nasdaq.

10. Coordination with General Executive Release and Waiver. In addition to the timely submission to Nasdaq of an executed Agreement, Executive
acknowledges and agrees that the payment of any benefits under the CIC Plan to the Executive also is contingent upon the Executive’s timely
submission to Nasdaq of an executed General Executive Release and Waiver in substantially the form attached as Exhibit A to the CIC Plan.
Executive acknowledges that the Executive’s failure to submit to Nasdaq on a timely basis an executed General Executive Release and Waiver shall
cause the Companies’ obligation to make the payments and/or provide the benefits referred to in the CIC Plan to immediately cease.

If Executive agrees to the foregoing, please sign the enclosed copy of this AGREEMENT in the space provided below and return it to me.

Very truly yours,

Nasdaq, Inc.

By:    

 
 
 
 
 
 
 
By signing below, I,                     , certify that I have read, carefully reviewed, fully understand, and agree to all the provisions of this AGREEMENT, which, along
with the CIC Plan, General Executive Release and Waiver, and any award agreements I entered into under the Equity Plan sets forth the entire agreement and
understanding between Nasdaq and me. I acknowledge that I have not relied upon any representation or statement, written or oral, not set forth in such documents.

Date:

cc: People @ Nasdaq

Office of General Counsel

 
 
VERAFIN HOLDINGS INC.
AMENDED AND RESTATED MANAGEMENT INCENTIVE PLAN

Section 1.    Purpose

This Amended and Restated Verafin Holdings Inc. Management Incentive Plan (this “Plan”) is effective as of October 3, 2022,
and is designed to promote the long-term financial interests and growth of Verafin Solutions ULC, a corporation existing under the laws
of  British  Columbia  (the  “Company”),  by  motivating  management  personnel  to  achieve  Company  goals,  and  thereby  furthering  the
alignment of the interests of Plan participants with those of the Company.

Exhibit 10.24

Section 2.    Definitions

As used in this Plan, the following words shall have the following meanings:

(a)    “Acceleration Event” means, with respect to a Key Employee, the occurrence of any of the following (prior to a Forfeiture
Event with respect to such Key Employee): (i) such Key Employee’s resignation or termination of employment with the Company or
any of its Affiliates for Good Reason, (ii) termination of such Key Employee’s employment with the Company or any of its Affiliates
by the Company or its Affiliates other than for a Cause Event, or (iii) such Key Employee’s death or Permanent Disability; provided
that if the Key Employee’s employment terminates on or in connection with the occurrence of an Acceleration Event, then, subject to
applicable employment or labour standards legislation and compliance by the Company or any of its Affiliates, as applicable, with the
Key  Employee’s  termination  and  severance  entitlements  pursuant  to  the  common  law  and/or  the  Key  Employee’s  contract  of
employment with the Company or any of its Affiliates, as the case may be (in all cases, to the extent applicable), such Acceleration
Event  shall  be  treated  as  an  Acceleration  Event  for  purposes  hereof  only  if  such  Key  Employee  executes  (and  does  not  revoke)  a
standard  release  of  employment  claims  (including,  without  limitation,  claims  under  applicable  employment  or  labour  standards
legislation, human rights legislation, and occupational health and safety legislation) in a form reasonably satisfactory to the Company.

(b)    “Affiliate” shall have the meaning ascribed thereto in Rule 12b-2 promulgated under the U.S. Securities Exchange Act of

1934, as amended, as in effect on the date hereof.

(c)        “Award”  means  an  award  granted  hereunder  that  entitles  the  Key  Employee  to  a  payment  and  award  opportunity

hereunder, subject to the terms and conditions of this Plan and the applicable Award Agreement.

(d)    “Award Agreement” means any written or electronic agreement, contract or other instrument or document evidencing any

Award, which may (but need not) require execution or acknowledgment by the applicable Key Employee.

(e)    “Board” means the Board of Directors of the Company.

(f)    “Business Day” means any day on which banks are required to be open to conduct business in New York City, New York

and St. John’s, Newfoundland and Labrador.

(g)        “Cause  Event”  means,  for  the  purposes  of  a  Key  Employee’s  rights  and  entitlements  hereunder  and  not  for  any  other

purpose or entitlement, the occurrence of any one or

1

 
more of the following events: (i) any commission by such Key Employee of a criminal act, felony or other indictable offence involving
fraud,  theft  or  embezzlement,  (ii)  any  commission  by  such  Key  Employee  of  dishonesty,  misrepresentation,  conflict  of  interest  or
breach  of  trust,  or  (iii)  any  other  act(s)  or  omission(s)  by  the  Key  Employee  constituting  just  cause  for  termination  at  common  law;
provided that (x) the occurrence of any event under clause (ii) or (iii) is not cured by the Key Employee within 60 days of receipt of
written notice from the Parent to the Key Employee and (y) if a Key Employee is charged with a criminal act, felony or other indictable
offence involving fraud, theft or embezzlement, the amount, if any, that would have become payable hereunder to such Key Employee
shall be set aside and held pending the outcome of such charge, and if the Key Employee is acquitted or the charge dropped then clause
(i) shall not apply with respect to such criminal act, felony or other indictable offence involving fraud, theft or embezzlement.

(h)    “Founder” means each of Jamie King, Raymond Pretty and Brendan Brothers.

(i)    “Founder Majority” means a majority of the Founders that are employed by the Company or one of its Affiliates as of the

applicable time.

(j)        “Forfeiture  Event”  means,  with  respect  to  a  Key  Employee,  (i)  a  resignation  or  termination  of  such  Key  Employee’s
employment  with  the  Company  or  any  of  its  Affiliates  without  Good  Reason  (other  than  a  resignation  or  termination  that  occurs
subsequent  to  an  Acceleration  Event),  (ii)  the  termination  of  such  Key  Employee’s  employment  with  the  Company  or  any  of  its
Affiliates by the Company or its Affiliates for a Cause Event or (iii) a material breach by such Key Employee of such Key Employee’s
obligations  under  Article  VI  of  the  Escrow  and  Management  Incentive  Agreement,  by  and  among  Parent,  Osprey  Acquisition
Corporation,  the  Company  and  various  individual  Company  employees,  dated  as  of  November  18,  2020,  as  amended,  modified  or
supplemented from time to time (the “EMIA”), in each case during the Performance Period.

(k)        “Good Reason”  means,  with  respect  to  any  Key  Employee,  any  act(s)  or  omission(s)  constituting  or  resulting  in  (x)  a
constructive dismissal at common law, (y) a material adverse change to the Key Employee’s role or responsibilities, or (z) a material
breach by the Company of the Key Employee’s contract of employment with the Company or any of its Affiliates, as the case may be;
provided that no act or omission shall constitute Good Reason unless (i) the Key Employee gives written notice specifying the objection
to such act or omission within 90 days following the occurrence of such act or omission, (ii) such act or omission is not corrected, in all
material respects, in a manner that is reasonably satisfactory to the Key Employee within 30 days following the receipt of such notice,
and (iii) the Key Employee resigns from the Key Employee’s employment within not more than 30 days following the expiration of the
thirty (30)-day period described in the foregoing clause (ii).

(l)    “MIP Amount” means, with respect to a Key Employee, an amount determined in accordance with the formula set forth on
Annex A. Subject to Section 5, the MIP Amount of a Key Employee shall be determined as soon as reasonably practicable following
the conclusion of the Performance Period.

(m)    “Parent” means Nasdaq, Inc., a Delaware corporation.

(n)        “Parent Equity Plan”  means  the  Nasdaq,  Inc.  Equity  Incentive  Plan  (as  amended  and  restated  April  24,  2018),  or  any

successor thereto.

(o)    “Parent Price” means the Fair Market Value (as defined in the Parent Equity Plan) of one Parent Share as of the date of

grant or transfer of the applicable Parent Share.

2

(p)    “Parent Shares” means Shares (as defined in the Parent Equity Plan).

(q)    “Party” means each of Parent, the Company and each of the Key Employees.

(r)    “Performance Period” means the period commencing on February 11, 2021 and concluding on December 31, 2023.

(s)    “Permanent Disability” means a physical or mental incapacity of the Key Employee that has prevented the Key Employee
from  performing  the  duties  customarily  assigned  to  the  Key  Employee  for  twelve  consecutive  months  and  that  qualifies  the  Key
Employee for long-term disability benefits under the applicable disability plan of the Company and its Affiliates (or if there is no such
plan in effect at the time, then would have qualified such Key Employee under such plan in effect as of the date hereof).

(t)        “Person”  means  an  individual,  a  partnership,  a  corporation,  a  limited  liability  company,  an  association,  a  joint  stock
company,  a  trust,  a  joint  venture,  an  unincorporated  organization  or  a  governmental  entity  or  any  department,  agency  or  political
subdivision thereof.

(u)    “Restricted Stock Terms” shall include a vesting period of one year from the date of the end of the Performance Period and
the standard terms and conditions that apply to restricted stock awards pursuant to the Parent Equity Plan, provided, however, that in
the  event  of  i)  a  resignation  or  termination  of  a  Key  Employee’s  employment  with  the  Company  or  any  of  its  Affiliates  with  Good
Reason,  or  (ii)  the  termination  of  a  Key  Employee’s  employment  with  the  Company  or  any  of  its  Affiliates  by  the  Company  or  its
Affiliates  other  than  for  a  Cause  Event,  the  vesting  of  any  stock  award  granted  under  this  Amended  and  Restated  Management
Incentive Plan shall be fully accelerated for that Key Employee.

(v)    “Subsidiary” means, with respect to any Person, any corporation of which a majority of the total voting power of shares
entitled (without regard to the occurrence of any contingency) to vote in the election of directors, managers or trustees thereof is at the
time  owned  or  controlled,  directly  or  indirectly,  by  such  Person  or  one  or  more  of  the  other  Subsidiaries  of  such  Person  or  a
combination  thereof,  or  any  partnership,  association  or  other  business  entity  of  which  a  majority  of  the  partnership  or  other  similar
ownership interest is at the time owned or controlled, directly or indirectly, by such Person or one or more Subsidiaries of such Person
or a combination thereof. For purposes of this definition, a Person is deemed to have a majority ownership interest in a partnership,
association or other business entity if such Person is allocated a majority of the gains or losses of such partnership, association or other
business entity or is or controls the managing director or general partner of such partnership, association or other business entity.

Section 3.    Administration

This Plan shall be administered by the Board, in good faith. The Board shall have full power and authority to administer and
interpret this Plan and Awards granted hereunder, including, without limitation, the power to (i) exercise all of the powers granted to it
hereunder,  (ii)  construe,  interpret  and  implement  this  Plan  and  any  Award  Agreement,  (iii)  prescribe,  amend  and  rescind  rules  and
regulations relating to this Plan, including rules governing its own operations, (iv) make all determinations necessary or advisable in
administering  this  Plan  and  any  Awards  and  Award  Agreements,  (v)  correct  any  defect,  supply  any  omission  and  reconcile  any
inconsistency in this Plan and any Awards or Award Agreements, (vi) delegate such powers and authority to such persons as it deems
appropriate; provided that any such delegation is consistent with applicable law and any guidelines as may be established by the Board
from time to time, and (vii) waive any forfeiture, vesting or other conditions under any Awards. Subject to

3

Section 9, the determination of the Board on all matters relating to this Plan, any Award Agreement or any Awards in good faith shall
be final, binding and conclusive upon all Persons. Without limiting the generality of the foregoing, the Board may adjust the terms of
Annex  A  in  respect  of  changes  to  the  equity  structure  of  the  Company  or  in  the  event  of  other  material  corporate  transactions  or
restructuring  events,  to  the  extent  that  the  Board  in  its  good  faith  discretion  determines  necessary  or  appropriate  to  preserve  the
intended economic intent of the terms of Annex A, provided, however, that any such adjustment shall be made in consultation with the
Founder Majority.

Section 4.    MIP Amount

No  later  than  April  1,  2024,  each  Key  Employee  shall  receive  (a)  a  lump  sum  cash  payment  equal  to  50%  of  such  Key
Employee’s MIP Amount, (b) unrestricted Parent Shares pursuant to the Parent Equity Plan, with the number of such shares equal to the
quotient  of  25%  of  such  Key  Employee’s  MIP  Amount  divided  by  the  Parent  Price,  and  (c)  an  award  of  restricted  Parent  Shares
pursuant to the Parent Equity Plan, with the number of such shares equal to the quotient of 25% of such Key Employee’s MIP Amount
divided  by  the  Parent  Price  (which  award  shall  be  subject  to  the  Restricted  Stock  Terms);  provided  that  such  Key  Employee  (i)  is
employed by and providing services to the Company or one of its Affiliates as of the end of the Performance Period (such continued
services  requirement,  the  “Continued  Service  Requirement”),  provided  that  such  Continued  Service  Requirement  shall  be  deemed
satisfied if an Acceleration Event occurred during the Performance Period in respect of such Key Employee and (ii) has not experienced
a Forfeiture Event during the Performance Period.

Section 5.    Forfeiture Event

Subject to the express minimum requirements of applicable employment or labour standards legislation, if any, if a Forfeiture
Event  occurs  during  the  Performance  Period,  the  applicable  Key  Employee  shall  forfeit  any  entitlement  under  this  Plan  to  any  MIP
Amount.

Section 6.    Amendment and Termination

This Plan may only be amended, modified or supplemented, and any provision of this Plan may only be waived, in writing by
the  approval  of  each  of  Parent  and  the  Founder  Majority;  provided,  however,  that  notwithstanding  anything  to  the  contrary,  any
amendment, modification or supplement of this Plan that on its face materially adversely affects the rights or obligations of any Party
differently than those of the other Parties (and in the case of a Key Employee, materially adversely relative to other Key Employees), as
applicable, shall also require the written approval of the differentially adversely affected Party.

Section 7.    No Employment Rights

Nothing in this Plan shall confer upon any Key Employee the right to continue in the employ of the Company or its affiliates or

affect any right that the Company or its affiliates may have to terminate such employment.

Section 8.    Tax Withholding

The  Company  may  withhold  from  any  amounts  payable  hereunder  such  taxes  as  the  Company  determines  are  required  to  be

withheld pursuant to applicable law.

Section 9.    Dispute Resolution

4

Any  controversy  or  dispute  arising  in  respect  of  this  Plan,  including  without  limitation,  its  administration,  application  or  any
issue with respect to any entitlement thereunder shall be resolved by arbitration in accordance with the procedures set forth in Section
7.4 of the EMIA.

Section 10.    Governing Law

This Plan shall be construed in accordance with, and governed by, the laws of the State of Delaware without regard to conflicts

of laws principles which would result in the application of the laws of another jurisdiction.

5

VERAFIN HOLDINGS INC.
AMENDED AND RESTATED MANAGEMENT INCENTIVE PLAN
AWARD AGREEMENT

Exhibit 10.25

Dear Brendan Brothers,

This letter represents your Award Agreement under the Verafin Holdings Inc. Amended and Restated Management

Incentive Plan (the “MIP”). All capitalized terms used but not defined herein shall have the meanings ascribed to them in the MIP. Your
Target MIP Amount for purposes of the MIP is $6,259,750, subject to the terms and conditions of the MIP (including Section 3
thereof). By your signature below, you acknowledge your agreement to the terms of the MIP and this Award Agreement, and also re-
affirm your surviving obligations under the EMIA.

Thank you for your dedication to the Nasdaq and Verafin team.

Sincerely,

/s/ Jamie King    
On behalf of Verafin Solutions ULC, successor to
Osprey Acquisition Corporation and Verafin
Holdings, Inc.
By: Jamie King
Title: Director

Acknowledged and Agreed:

/s/ Brendan Brothers        
Brendan Brothers

 
 
 
 
 
 
 
 
    
Exhibit 10.26

VERAFIN HOLDINGS INC.
AMENDED AND RESTATED MANAGEMENT INCENTIVE PLAN
AWARD AGREEMENT

Dear Jamie King,

This letter represents your Award Agreement under the Verafin Holdings Inc. Amended and Restated Management

Incentive Plan (the “MIP”). All capitalized terms used but not defined herein shall have the meanings ascribed to them in the MIP. Your
Target MIP Amount for purposes of the MIP is $7,446,000, subject to the terms and conditions of the MIP (including Section 3
thereof). By your signature below, you acknowledge your agreement to the terms of the MIP and this Award Agreement, and also re-
affirm your surviving obligations under the EMIA.

Thank you for your dedication to the Nasdaq and Verafin team.

Sincerely,

/s/ Ann Dennison    
On behalf of Verafin Solutions ULC, successor to
Osprey Acquisition Corporation and Verafin
Holdings, Inc.
By: Ann Dennison
Title: Director

Acknowledged and Agreed:

/s/ Jamie King            
Jamie King

 
 
 
 
 
 
    
Subsidiaries of Nasdaq, Inc.*

As of February 15, 2023

Exhibit 21.1

U.S. Entities

1. BoardVantage, Inc (organized in Delaware)
2. Boston Stock Exchange Clearing Corporation (organized in Massachusetts)
3. Consolidated Securities Source LLC (organized in Delaware)
4. Content Services, LLC (organized in Delaware)
5. Curzon Street Acquisition, LLC (organized in Delaware)
6. Directors Desk, LLC (organized in Delaware)
7. Dorsey, Wright & Associates, LLC (organized in Virginia)
eVestment Alliance Holdings, Inc. (organized in Delaware)
8.
9.
eVestment Alliance Holdings, LLC (organized in Georgia)
10. eVestment Alliance, LLC (organized in Georgia)
11. eVestment, Inc. (organized in Delaware)
12. ExactEquity, LLC (organized in Delaware)
13. FinQloud LLC (organized in Delaware)
14. FINRA/Nasdaq Trade Reporting Facility LLC (organized in Delaware)
15. FRAMLxchange Inc. (organized in Delaware)
16. FTEN, Inc. (organized in Delaware)
17. Granite Redux, Inc. (organized in Delaware)
18. GraniteBlock, Inc. (organized in Delaware)
19. International Securities Exchange Holdings, Inc. (organized in Delaware)
20. ISE ETF Ventures LLC (organized in Delaware)
21. Longitude LLC (organized in Delaware)
22. Nasdaq BX, Inc. (organized in Delaware)
23. Nasdaq Capital Markets Advisory LLC (organized in Delaware)
24. Nasdaq Commodities Clearing LLC (organized in Delaware)
25. Nasdaq Corporate Services, LLC (organized in Delaware)
26. Nasdaq Corporate Solutions, LLC (organized in Delaware)
27. Nasdaq Digital Asset Holdings, LLC (organized in Delaware)
28. NASDAQ Energy Futures, LLC (organized in Delaware)
29. Nasdaq Execution Services, LLC (organized in Delaware)
30. Nasdaq Fund Secondaries, LLC (organized in Delaware)
31. NASDAQ Futures, Inc. (organized in Delaware)
32. Nasdaq GEMX, LLC (organized in Delaware)
33. NASDAQ Global, Inc. (organized in Delaware)
34. Nasdaq Governance Solutions, Inc. (organized in Delaware)
35. Nasdaq Information, LLC (organized in Delaware)
36. Nasdaq International Market Initiatives, Inc. (organized in Delaware)
37. Nasdaq ISE, LLC (organized in Delaware)
38. Nasdaq MRX, LLC (organized in Delaware)
39. Nasdaq PHLX LLC (organized in Delaware)
40. Nasdaq SB Holdings, LLC (organized in Delaware)
41. Nasdaq SPS, LLC (organized in Delaware)
42. Nasdaq Technology Services, LLC (organized in Delaware)
43. NFSTX, LLC (organized in Delaware)
44. Norway Acquisition LLC (organized in Delaware)
45. OneReport, Inc, (organized in Vermont)
46. Operations & Compliance Network, LLC (organized in Delaware)
47. Public Plan IQ Limited Liability Company (organized in New Jersey)
48. QDiligence LLC (organized in Illinois)
49. Solovis, Inc.
50. Stock Clearing Corporation of Philadelphia (organized in Pennsylvania)
51. Strategic Financial Solutions, LLC (organized in Nevada)
52. Sybenetix Inc. (organized in Delaware)
53. The Center for Board Evaluation, Inc. (organized in North Carolina)
54. The Nasdaq Options Market LLC (organized in Delaware)
55. The Nasdaq Stock Market LLC (organized in Delaware)

56. U.S. Exchange Holdings, Inc. (organized in Delaware)
57. Verafin AcquisitionCo LLC (organized in Delaware)
58. Verafin USA Inc. (organized in Delaware)

Non-U.S. Subsidiaries

eVestment Alliance (UK) Limited (organized in the United Kingdom)
eVestment Alliance Australia Pty Ltd (organized in Australia)
eVestment Alliance Hong Kong Limited (organized in Hong Kong)

1. AB Nasdaq Vilnius (organized in Lithuania) (96.35% owned, directly or indirectly, by Nasdaq, Inc.)
2. AS eCSD Expert (organized in Estonia)
3. AS Pensionikeskus AS (organized in Estonia)
4. Cinnober Financial Technology AB (organized in Sweden)
5. Curzon Street Holdings Limited (organized in the United Kingdom)
6. Ensoleillement Inc. (organized in Canada)
7.
8.
9.
10. Indxis Ltd (organized in the United Kingdom)
11. Metrio Software Inc. (organized in Quebec)
12. Nasdaq (Asia Pacific) Pte. Ltd. (organized in Singapore)
13. Nasdaq AB (organized in Sweden)
14. Nasdaq Australia Holding Pty Ltd (organized in Australia)
15. NASDAQ Canada Inc. (organized in Canada)
16. Nasdaq Clearing AB (organized in Sweden)
17. Nasdaq Copenhagen A/S (organized in Denmark)
18. Nasdaq Corporate Solutions (India) Private Limited (organized in India)
19. Nasdaq Corporate Solutions International Limited (organized in the United Kingdom)
20. Nasdaq CSD SE (organized in Latvia)
21. Nasdaq CXC Limited (organized in Canada)
22. Nasdaq Exchange and Clearing Services AB (organized in Sweden)
23. Nasdaq France SAS (organized in France)
24. Nasdaq Germany GmbH (organized in Germany)
25. Nasdaq Helsinki Ltd (organized in Finland)
26. Nasdaq Holding AB (organized in Sweden)
27. Nasdaq Holding Denmark A/S (organized in Denmark)
28. Nasdaq Holding Luxembourg Sárl (organized in Luxembourg)
29. Nasdaq Iceland hf. (organized in Iceland)
30. Nasdaq International Ltd (organized in the United Kingdom)
31. NASDAQ Korea Ltd (organized in South Korea)
32. Nasdaq Ltd (organized in Hong Kong)
33. Nasdaq Nordic Ltd (organized in Finland)
34. NASDAQ OMX Europe Ltd (organized in the United Kingdom)
35. Nasdaq Oslo ASA (organized in Norway)
36. Nasdaq Pty Ltd (organized in Australia)
37. Nasdaq Riga, AS (organized in Latvia) (92.98% owned, directly or indirectly, by Nasdaq, Inc.)
38. Nasdaq Spot AB (organized in Sweden)
39. Nasdaq Stockholm AB (organized in Sweden)
40. Nasdaq Tallinn AS (organized in Estonia)
41. Nasdaq Technology (Japan) Ltd (organized in Japan)
42. Nasdaq Technology AB (organized in Sweden)
43. Nasdaq Technology Energy Systems AS (organized in Norway)
44. Nasdaq Technology Italy Srl (organized in Italy)
45. Nasdaq Teknoloji Servisi Limited Sirketi (organized in Turkey)
46. Nasdaq Treasury AB (organized in Sweden)
47. Nasdaq Vilnius Services UAB (organized in Lithuania)
48. Nasdaq Wizer Solutions AB (organized in Sweden)
49. OMX Netherlands B.V. (organized in the Netherlands)
50. OMX Netherlands Holding B.V. (organized in the Netherlands)
51. OMX Treasury Euro AB (organized in Sweden) (99.9% owned, directly or indirectly, by Nasdaq, Inc.)
52. OMX Treasury Euro Holding AB (organized in Sweden)
53. Puro.earth (organized in Finland) (70% owned, directly or indirectly, by Nasdaq, Inc.)
54. Quandl, Inc. (organized in Canada, Federal)
55. RF Nordic Express AB (organized in Sweden) (50.1% owned, directly or indirectly, by Nasdaq, Inc.)
56. Shareholder.com B.V. (organized in the Netherlands)
57. Simplitium Ltd (organized in the United Kingdom)
58. SMARTS Broker Compliance Pty Ltd (organized in Australia)
59. SMARTS Market Surveillance Pty Ltd (organized in Australia)
60. Sybenetix Limited (organized in the United Kingdom)
61. Sybenetix Ukraine (organized in the Ukraine)
62. TopQ Software Limited (organized in the United Kingdom)

63. Verafin Solutions ULC (organized in Canada)
64. Whittaker & Garnier Limited (organized in the United Kingdom)

* The list of subsidiaries does not include not-for-profit entities or foreign branches of subsidiaries, or entities in which Nasdaq owns less than 50% of the entity.

Exhibit 23.1

We consent to the incorporation by reference in the following Registration Statements:           

Consent of Independent Registered Public Accounting Firm

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

Registration Statement (Form S-3 No. 333-255666) of Nasdaq, Inc.,

Registration Statement (Form S-8 No. 333-239891) pertaining to Nasdaq, Inc. Employee Stock Purchase Plan,

Registration Statement (Form S-8 No. 333-225218) pertaining to Nasdaq, Inc. Equity Incentive Plan,

Registration Statement (Form S-8 No. 333-196838) pertaining to Nasdaq, Inc. (f/k/a The NASDAQ OMX Group, Inc.) Equity
Incentive Plan,

Registration  Statement  (Form  S-8  No.  333-167724)  pertaining  to  Nasdaq,  Inc.  (f/k/a  The  NASDAQ  OMX  Group,  Inc.)
Employee Stock Purchase Plan,

Registration Statement (Form S-8 No. 333-167723) pertaining to Nasdaq, Inc. (f/k/a The NASDAQ OMX Group, Inc.) Equity
Incentive Plan,

Registration Statement (Form S-8 No. 333-110602) pertaining to The Nasdaq Stock Market, Inc. Equity Incentive Plan,

Registration  Statement  (Form  S-8  No.  333-106945)  pertaining  to  the  Employment  Agreement  with  Robert  Greifeld  of  The
Nasdaq Stock Market, Inc.,

Registration Statement (Form S-8 No. 333-76064) pertaining to The Nasdaq Stock Market, Inc. 2000 Employee Stock Purchase
Plan,

(10) Registration Statement (Form S-8 No. 333-72852) pertaining to The Nasdaq Stock Market, Inc. 2000 Employee Stock Purchase

Plan,

(11) Registration Statement (Form S-8 No. 333-70992) pertaining to The Nasdaq Stock Market, Inc. Equity Incentive Plan, and

(12) Registration Statement (Form S-8 No. 333-265824) pertaining to The Nasdaq, Inc. Deferred Compensation Plan;

of our reports dated February 23, 2023, with respect to the consolidated financial statements of Nasdaq, Inc. and the effectiveness of

internal control over financial reporting of Nasdaq, Inc. included in this Annual Report (Form 10-K) of Nasdaq, Inc. for the year ended
December 31, 2022.

/s/ Ernst & Young LLP

New York, New York
February 23, 2023

 
POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Exhibit 24.1

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for her and in her name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2022, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 23, 2023.

            /s/ Melissa M. Arnoldi
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for her and in her name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2022, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 23, 2023.

            /s/ Charlene T. Begley
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2022, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 23, 2023.

            /s/ Steven D. Black
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2022, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 23, 2023.

            /s/ Essa Kazim
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2022, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 23, 2023.

            /s/ Thomas A. Kloet
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2022, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 23, 2023.

            /s/ John D. Rainey
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2022, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 23, 2023.

            /s/ Michael R. Splinter
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2022, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 23, 2023.

            /s/ Johan Torgeby
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for her and in her name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2022, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 23, 2023.

            /s/ Toni Townes-Whitley
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2022, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 23, 2023.

            /s/ Alfred W. Zollar
            Signature

Exhibit 31.1

I, Adena T. Friedman, certify that:

1. I have reviewed this Annual Report on Form 10-K of Nasdaq, Inc.;

CERTIFICATION

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the

statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the

financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4. The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange
Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and
have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to

ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities,
particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our

supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes
in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the

effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent
fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the
registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the

registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably

likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control

over financial reporting.

Name:
Title:

 /s/    Adena T. Friedman
Adena T. Friedman
Chief Executive Officer

Date: February 23, 2023

 
 
 
 
 
 
 
 
 
CERTIFICATION

Exhibit 31.2

I, Ann M. Dennison, certify that:

1. I have reviewed this Annual Report on Form 10-K of Nasdaq, Inc.;

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the

statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the

financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4. The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange
Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and
have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to

ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities,
particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our

supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes
in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the

effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent
fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the
registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the

registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably

likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control

over financial reporting.

Name:
Title:

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

Date: February 23, 2023

 
 
 
Certification of CEO and CFO Pursuant to
18 U.S.C. Section 1350
as Adopted Pursuant to
Section 906 of the Sarbanes-Oxley Act of 2002

Exhibit 32.1

In connection with the Annual Report on Form 10-K of Nasdaq, Inc. (the “Company”) for the period ended December 31, 2022 as filed with the Securities

and Exchange Commission on the date hereof (the “Report”), Adena T. Friedman, as Chief Executive Officer of the Company, and Ann M. Dennison, as Executive
Vice President and Chief Financial Officer of the Company, each hereby certifies, pursuant to 18 U.S.C. § 1350, as adopted pursuant to § 906 of the Sarbanes-
Oxley Act of 2002, that, to the best of her knowledge:

(1) The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

(2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of the operations of the

Company.

Name:
Title:
Date:

Name:
Title:
Date:

/s/   Adena T. Friedman
Adena T. Friedman
Chief Executive Officer
February 23, 2023

/s/   Ann M. Dennison
Ann M. Dennison
Executive Vice President and Chief Financial Officer
February 23, 2023

This certification accompanies the Report pursuant to § 906 of the Sarbanes-Oxley Act of 2002 and shall not, except to the extent required by the Sarbanes-Oxley
Act of 2002, be deemed filed by the Company for purposes of § 18 of the Securities Exchange Act of 1934, as amended.