FISD Principles
Member Engagement on Controversial Issues
Updated and reviewed by FISD Executive Committee September 18, 2026
FISD’s approach to managing member engagement on controversial issues is guided by the following principles:
- In its working groups and events, FISD welcomes productive discussion, including of controversial issues and issues where individual member firms have distinct and controversial approaches or views. However, FISD does not encourage collective criticism or adverse action against any member. Collective actions in FISD forums or groups by FISD members that target individual companies for adverse treatment are prohibited. The purpose of all discussions, including on controversial topics is learning, better understanding, and facilitating a healthy and competitive dynamic business environment. With those ends in view, FISD working groups (as opposed to Constituent Groups) are open to participation by all members and every member is entitled to access notes from those meetings.
- To the extent any member determines that public criticism of another member is warranted, criticism of a member in an FISD forum should always be fair, informed, constructive, and professional. When possible and appropriate, the FISD member should be made aware of the criticism. Criticism and other comments should be considered “off the record” by the media. FISD will not encourage or endorse specific criticism of members; and neither FISD nor its representatives will become involved in any way in such criticism.
- While members should meet their contractual requirements to each other regarding confidentiality, FISD has no role in the policing of confidentiality agreements.
- All FISD members should engage in good faith dealings with one another and to adhere to the data usage principles and licensing policies of other members. Notwithstanding, FISD plays no role in the policing of such activity.
- FISD and FISD staff will not support or endorse criticism of members — criticism, to the extent a member determines to provide it, must come from members. The ability of FISD staff to present and promote anonymous members’ concerns and positions is limited. FISD staff can serve as a conduit for the transmission of information among members in order to help facilitate productive discussion. FISD cannot and will not be an advocate for some members in disputes that they have with other members.
- It is appropriate for one constituency to use the FISD constituency group as a forum to productively discuss challenges and concerns facing the relevant constituency, and the content and concerns raised during those discussions may be shared with other members who are not part of the constituency group. This could involve consumers discussing and raising concerns to a data vendor, data vendors discussing and raising concerns to an exchange, or exchanges discussing and raising concerns to a specific user firm.
- Controversies and disagreements between constituent groups and other members should not be aired to media. FISD management or constituent group leadership may not communicate specific criticisms to media. To the extent that FISD facilitates productive discussions between constituent groups and other members, FISD will facilitate discussion with the relevant management of the relevant market data department instead of escalating discussions on controversial issues to company leadership.
- FISD, through the direction of the FISD Executive Committee, exercises independent judgment on policy, advocacy, and other public issues. FISD will generally NOT take official public positions that have significant opposition within the membership. Public positions would include media statements, advocacy positions with government bodies, and best practice recommendations. In the event that FISD decides to take an official public position, FISD will ensure that this has been approved by the FISD Executive Committee.
- FISD members participating in working groups, constituent groups, or committees should not share details of those meetings with the media unless first cleared with FISD management.
- Individual FISD constituent groups may promote positions provided that their source is made very clear and the constituent group position is the result of the formal decision-making process provided in the FISD Bylaws. While the proceedings of constituent groups are only open to the members of the constituent group, the Chairs of the constituent groups must regularly apprise the Executive Committee, and by extension the membership, of the general types of discussion and activity occurring within the group.
- FISD and its members are required to fully comply with global competition law. FISD prohibits discussion of pricing level and fees.
