A Bloomberg review is not an exchange audit with a different letterhead. Bloomberg is your vendor, and for exchange data delivered through the terminal it is also the channel through which your professional and nonprofessional declarations reach the exchanges. A review can therefore produce findings in two currencies at once: Bloomberg’s own license terms, and exchange fees that Bloomberg passes through. They are priced differently, they settle differently, and the first job is to keep them apart.
The five moves from the first note in this series still apply: read the audit and redistribution clauses of the agreement before the questionnaire, appoint one point of contact, reconstruct the record, answer what was asked, and time-box the review. What follows is where, in our experience, the findings actually come from.
1. Access that does not match the license type.
Bloomberg licenses access in named forms: Bloomberg Anywhere is tied to a named user, an Open Terminal to a serial number and access point. Reviews look for logins used by more than one person, generic desk logins, and credentials of people who have left the firm and are still active. The joiner, mover, and leaver process is the control; the customer service portal’s own account records are the evidence.
2. Data that left the terminal.
Terminal data is licensed for the user at the terminal. Once Excel or desktop API output feeds a shared workbook, a pricing model, a server, or another application, it has become redistribution or derived use, and that is a different license. This is the most common finding we see, because it grows quietly: one analyst’s spreadsheet becomes the desk’s spreadsheet, then the firm’s.
3. Data License scope.
Data License products are licensed for a use case, an entity, and a footprint, and priced on what is requested. Reviews compare the fields and securities pulled with the applications and entities entitled to use them. Usage that migrated to a second system, a second legal entity, or a second region after the agreement was signed is where the scope gap appears.
4. Enterprise feeds and non-display use.
Applications, algorithms, and risk engines consuming enterprise feed data without the corresponding entitlement. The system inventory is the record here: which applications receive the feed, what they do with it, and whether that use was declared.
5. Exchange declarations made through Bloomberg.
Professional versus nonprofessional status, user location, and exchange entitlements are reported to the exchanges on your behalf, and the fees are the exchange’s. Inaccuracies here surface in a Bloomberg review first and can be followed by the exchange’s own audit later. Treat these declarations as exchange records, with the same evidence standard an exchange auditor would apply.
6. AI and machine consumers.
Model inference, agent tools, and machine-consumer applications drawing on terminal or Data License output are now a licensing category, and vendors are reviewing for it. If an internal model has been trained or prompted on licensed data, it belongs in the inventory before the review asks about it.
How to respond.
- Pull your own records first. Account, serial-number, and entitlement reports from the customer service portal, reconciled to HR joiners and leavers, before the vendor’s version of the same data arrives.
- Map the outputs. Every API, export, and feed leaving a terminal or a Data License endpoint, and where it lands.
- Read the agreement as one document. Audit rights, redistribution, derived-data, and assignment clauses together, with amendments and the current schedule.
- Separate the currencies. When a liability is presented, split exchange pass-through from Bloomberg license fees line by line. They are negotiated with different people and settle on different terms.
- Fold the settlement into the renewal where you can. A finding settled inside a renewal is cheaper than one settled after it, and the corrected entitlements go into the new term.
The record decides the number. A vendor reviewing a firm that can show who used what, where, and under which clause is negotiating; a vendor reviewing a firm that cannot is assessing.
The practitioners at Paraxis have defended 40+ exchange and vendor audits over the last decade, from both sides of the table. If Bloomberg has asked for a usage review, or you want the file ready before it does, book a scoping call or write to info@paraxisids.com and mark the subject line Audit.
Bloomberg does not publish an audit procedure. License types and account records referenced above follow the Bloomberg Market Data Manual (December 2020 edition); the review patterns are drawn from Paraxis engagements and are described at team level.