tZERO ATS

amendment_reason

tZERO ATS, LLC updated Part II Item 5 and Part III Item 19. The changes clarify that tZERO ATS, LLC does not charge Subscribers, as defined in Part II, Item 2(a), or third parties for Market Data. The changes affect the broker-dealer operator of the ATS, but do not affect the Subscribers.

amendment_reason

tZERO ATS LLC revised Part II, Item 2a, Items 6a and 6b, and Part III, Item 11a, to clarify certain aspects of its expense sharing agreements, including that tZERO Group, Inc. provides personnel to tZERO ATS, LLC through its wholly-owned subsidiary, tZERO Broker Services, LLC. The revisions also clarify certain defined terms where appropriate. The changes do not affect the broker-dealer operator or the subscribers of the ATS.

amendment_reason

Parts I, II, III of Form ATS-N have been updated for changes set forth below. Where changes impact Subscribers, such impacts apply equally to all Subscribers (as defined in Part II, Item 2a). The following changes do not affect the broker-dealer operator or the Subscribers. -Part I Item 6: Updates the website of tZERO ATS. -Part II Item 5a & Part III Item 15b: Defines "Market Data." -Part II Items 6a, 6b & 7a, Part III Item 11a: Updates name of tZERO ATS, LLC's affiliate technology provider. -Part II Item 6b, Part III Items 2b & 22: Updates the current business name of the ATS's clearing firm. -Part II Items 6b & 7a: Clarifies obligations of the ATS versus the ATS's broker-dealer operator. The following changes do not affect Subscribers, but affect the staffing of the broker-dealer operator of the ATS. -Part III Item 11c: Updates responsibilities of the CCO and President. -Part III Item 2b & 7a: Updates responsibilities of the CCO. -Part II Items 6a & 7a: Updates responsibilities of tZERO ATS, LLC staff. -Part II Item 6a: Updates the number and description of "Shared Representatives" and "Shared NRFs". The following changes affect both Subscribers and the broker-dealer operator of the ATS. -Part III Item 2b: Clarifies Subscriber eligibility requirements and the Subscriber on boarding process. -Part III, Item 15b: Updates the time Market Data is available on tZERO ATS, LLC's website. The following change affects the broker-dealer operator of the ATS but not the Subscribers. -Part II Items 2a & 6a: Updates the direct owner of tZERO ATS, LLC. The following changes affect the broker-dealer operator of the ATS, but do not affect the Subscriber's access to Market Data. -Part II Item 5a, Part III Item 19b: Permits tZERO ATS, LLC to determine whether to allow third parties to retransmit Market Data and whether to charge third parties for Market Data or retransmission. -Part II Item 5a, Part III Item 15: Updates availability and location of Market Data.

amendment_reason

tZERO ATS, LLC updated Part II, Item 5(a) and Part III, Item 15(b). tZERO ATS, LLC will no longer publicly display real-time best bid and offer data on its website, ats.tzero.com. The change does not affect the broker-dealer operator of the ATS, but does affect Subscribers.

amendment_reason

tZERO ATS, LLC ("tZERO ATS") has updated Part III, Item 11(a) to disclose its plans to file a Form ATS-N-C, on or prior to June 1, 2021. The Form ATS-N-C will give notice of the cessation of operations of its NMS Stock ATS on June 18, 2021 (the "Date of Cessation"). From the date of this filing until the Date of Cessation, the NMS Stock ATS will only execute trades in the twenty seven (27) symbols set forth in the amended Item 11(a). This change affects all Subscribers. It will also affect the tZERO ATS, as the broker-dealer operator of its NMS Stock ATS, because it will limit the symbols it accepts to the twenty-seven (27) symbols set forth in the amended Item 11(a) and cease the operations of its NMS Stock ATS on the Date of Cessation.

amendment_reason

Part I Items 2, 3, and 6; Part II Items 2, 5, 6 and 7; and Part III Items 2, 3, 4, 5, 6, 7, 8, 10, 11, 15, 19, 20, 21, 22, and 23 of Form ATS-N have been amended in response to a change to the name of the NMS Stock ATS and the Broker-Dealer Operator. This change will not affect the subscribers of the ATS. This change will not affect the Broker-Dealer Operator aside from the name change.

ats_name

tZERO ATS, LLC

ats_name

PRO Securities, L.L.C.

operator_crd

000123421

operator_name

PRO SECURITIES, L.L.C.

operator_name

TZERO ATS, LLC

operator_name

TZERO ATS, LLC.

order_types

Order Types PRO ATS only accepts limit day orders ("orders"). Orders that are not marketable are held until the order is canceled or until it becomes marketable and is matched with a contra Order in the system and executed. All orders on the ATS order book are canceled at the end the trading session. The only time-in-force instruction accepted by the ATS is Day. Routing PRO ATS does not route orders to any other Trading Center. Message Priority Incoming orders and related messages are processed in the order in which they are received by the ATS. Match Priority Orders are time-stamped to the millisecond by the ATS upon receipt, as are cancel/replaces. Orders are matched by the ATS on a price/time priority basis, with the exception of orders entered as "broker priority." Orders that are entered as "broker priority" are matched by the ATS on a price/broker/time priority basis. A Subscriber/sponsored access client elects broker priority for all transactions, not on a transaction-by-transaction basis. Broker priority is never a default setting on PRO ATS. If a Subscriber/sponsored access client elects broker priority and routes both buy and sell orders for the same NMS Stock to the ATS, those order are matched against each other, absent a better-priced order. If there is a better-priced order on the ATS, the broker priority order executes against the better-priced order. The orders of a Subscriber/sponsored access client that has not elected broker priority, but that enters both buy and sell orders in the same NMS Stock into the ATS will be matched against each other, but only if there is not an existing order on the order book at the same or a better price. For example, assume the ATS receives the following orders: - ORDER A: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT1, a LIMIT DAY buy order to buy 500 shares of ABC @ $15.10 at 11:00 p.m.; - ORDER B: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT2, a LIMIT DAY buy order to buy 550 shares of ABC @ $15.10 at 11:01 p.m.; - ORDER C: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT3, a LIMIT DAY buy order to buy 600 shares of ABC @ $15.10 at 11:02 p.m.; - ORDER D: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT3, a LIMIT DAY buy order to buy 100 shares of ABC @ $15.10 at 11:03 p.m.; and - ORDER E: from Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT3, a LIMIT DAY sell order to sell 800 shares of ABC @ $15.10 at 11:04 p.m. Where CLIENT 3 has elected broker priority, Order E is matched, based on broker priority, first with Order C and Order D (based on time priority) and the balance of 100 will be matched, based on price-time priority, against Order A. Because the ATS's Operating Hours (8 p.m. ET to 4 a.m. ET) are after the Core Market Hours (9:30 a.m. ET to 4 p.m. ET, Monday through Friday), trades executed on the ATS are not priced according to and do not relate to the NBBO, which is not available during the Operating Hours. Rather, reference prices for trades executed on the ATS are based on the best available bid and offer on the ATS at the time of the trade. Order Cancellation and Amendment All orders entered into PRO ATS are considered firm orders. An order is actionable and eligible for execution at any time until such order has expired by its terms, is canceled, or is executed and, when executed, is binding on the Subscriber placing the order (executed orders entered by sponsored access clients are binding against the Subscriber providing sponsored access because PRO ATS's contractual relationship is with the Subscriber providing sponsored access, not the sponsored access client). Subscribers/sponsored access clients may cancel their pending orders at any time before execution at their discretion. A reduction in an order's size through a cancel/replace instruction will not affect the order's original time priority. Changes that increase an orders size will lose priority to existing orders at the same price and result in a new time priority. A change in an order's price, however, will result in a new time priority being assigned to the order. Orders will be rejected if they contain instructions or order attributes that are not supported by the ATS, such as an invalid stock symbol. Subscribers are also subject to pre-trade credit and risk controls to prevent certain orders from reaching the ATS. Each Subscriber is subject to a daily notional value limit, a maximum notional value per order, a maximum quantity per order, a maximum number of orders per second, and a maximum number of duplicate orders (same ticker symbol, size, side, order type and price). The COO or his or her designee determines the limits for each Subscriber based on a credit risk assessment before the Subscriber is permitted to commence trading on the ATS. These controls will reject Subscriber orders that exceed pre-set credit thresholds or that contain a sub-penny price, among others. Required Fields - Sending time (Time of order creation expressed in UTC) - Client Order ID (unique identifier per order/per session) - Side (Buy, Sell, Sell Short, Sell Short Exempt) - Symbol - Time In Force = DAY - Order Type = Limit - Price

order_types

Order Types tZERO ATS only accepts limit day orders ("orders"). Orders that are not marketable are held until the order is canceled or until it becomes marketable and is matched with a contra Order in the system and executed. All orders on the ATS order book are canceled at the end the trading session. The only time-in-force instruction accepted by the ATS is Day. Routing tZERO ATS does not route orders to any other Trading Center. Message Priority Incoming orders and related messages are processed in the order in which they are received by the ATS. Match Priority Orders are time-stamped to the millisecond by the ATS upon receipt, as are cancel/replaces. Orders are matched by the ATS on a price/time priority basis, with the exception of orders entered as "broker priority." Orders that are entered as "broker priority" are matched by the ATS on a price/broker/time priority basis. A Subscriber/sponsored access client elects broker priority for all transactions, not on a transaction-by-transaction basis. Broker priority is never a default setting on tZERO ATS. If a Subscriber/sponsored access client elects broker priority and routes both buy and sell orders for the same NMS Stock to the ATS, those order are matched against each other, absent a better-priced order. If there is a better-priced order on the ATS, the broker priority order executes against the better-priced order. The orders of a Subscriber/sponsored access client that has not elected broker priority, but that enters both buy and sell orders in the same NMS Stock into the ATS will be matched against each other, but only if there is not an existing order on the order book at the same or a better price. For example, assume the ATS receives the following orders: - ORDER A: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT1, a LIMIT DAY buy order to buy 500 shares of ABC @ $15.10 at 11:00 p.m.; - ORDER B: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT2, a LIMIT DAY buy order to buy 550 shares of ABC @ $15.10 at 11:01 p.m.; - ORDER C: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT3, a LIMIT DAY buy order to buy 600 shares of ABC @ $15.10 at 11:02 p.m.; - ORDER D: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT3, a LIMIT DAY buy order to buy 100 shares of ABC @ $15.10 at 11:03 p.m.; and - ORDER E: from Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT3, a LIMIT DAY sell order to sell 800 shares of ABC @ $15.10 at 11:04 p.m. Where CLIENT 3 has elected broker priority, Order E is matched, based on broker priority, first with Order C and Order D (based on time priority) and the balance of 100 will be matched, based on price-time priority, against Order A. Because the ATS's Operating Hours (8 p.m. ET to 4 a.m. ET) are after the Core Market Hours (9:30 a.m. ET to 4 p.m. ET, Monday through Friday), trades executed on the ATS are not priced according to and do not relate to the NBBO, which is not available during the Operating Hours. Rather, reference prices for trades executed on the ATS are based on the best available bid and offer on the ATS at the time of the trade. Order Cancellation and Amendment All orders entered into tZERO ATS are considered firm orders. An order is actionable and eligible for execution at any time until such order has expired by its terms, is canceled, or is executed and, when executed, is binding on the Subscriber placing the order (executed orders entered by sponsored access clients are binding against the Subscriber providing sponsored access because tZERO ATS's contractual relationship is with the Subscriber providing sponsored access, not the sponsored access client). Subscribers/sponsored access clients may cancel their pending orders at any time before execution at their discretion. A reduction in an order's size through a cancel/replace instruction will not affect the order's original time priority. Changes that increase an orders size will lose priority to existing orders at the same price and result in a new time priority. A change in an order's price, however, will result in a new time priority being assigned to the order. Orders will be rejected if they contain instructions or order attributes that are not supported by the ATS, such as an invalid stock symbol. Subscribers are also subject to pre-trade credit and risk controls to prevent certain orders from reaching the ATS. Each Subscriber is subject to a daily notional value limit, a maximum notional value per order, a maximum quantity per order, a maximum number of orders per second, and a maximum number of duplicate orders (same ticker symbol, size, side, order type and price). The CCO or his or her designee determines the limits for each Subscriber based on a credit risk assessment before the Subscriber is permitted to commence trading on the ATS. These controls will reject Subscriber orders that exceed pre-set credit thresholds or that contain a sub-penny price, among others. Required Fields - Sending time (Time of order creation expressed in UTC) - Client Order ID (unique identifier per order/per session) - Side (Buy, Sell, Sell Short, Sell Short Exempt) - Symbol - Time In Force = DAY - Order Type = Limit - Price

order_types

Order Types tZERO ATS only accepts limit day orders ("orders"). Orders that are not marketable are held until the order is canceled or until it becomes marketable and is matched with a contra Order in the system and executed. All orders on the ATS order book are canceled at the end the trading session. The only time-in-force instruction accepted by the ATS is Day. Routing tZERO ATS does not route orders to any other Trading Center. Message Priority Incoming orders and related messages are processed in the order in which they are received by the ATS. Match Priority Orders are time-stamped to the millisecond by the ATS upon receipt, as are cancel/replaces. Orders are matched by the ATS on a price/time priority basis, with the exception of orders entered as "broker priority." Orders that are entered as "broker priority" are matched by the ATS on a price/broker/time priority basis. A Subscriber/sponsored access client elects broker priority for all transactions, not on a transaction-by-transaction basis. Broker priority is never a default setting on tZERO ATS. If a Subscriber/sponsored access client elects broker priority and routes both buy and sell orders for the same NMS Stock to the ATS, those order are matched against each other, absent a better-priced order. If there is a better-priced order on the ATS, the broker priority order executes against the better-priced order. The orders of a Subscriber/sponsored access client that has not elected broker priority, but that enters both buy and sell orders in the same NMS Stock into the ATS will be matched against each other, but only if there is not an existing order on the order book at the same or a better price. For example, assume the ATS receives the following orders: -ORDER A: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT1, a LIMIT DAY buy order to buy 500 shares of ABC @ $15.10 at 11:00 p.m.; -ORDER B: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT2, a LIMIT DAY buy order to buy 550 shares of ABC @ $15.10 at 11:01 p.m.; -ORDER C: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT3, a LIMIT DAY buy order to buy 600 shares of ABC @ $15.10 at 11:02 p.m.; -ORDER D: from a Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT3, a LIMIT DAY buy order to buy 100 shares of ABC @ $15.10 at 11:03 p.m.; and -ORDER E: from Sponsored Access broker customer of SpeedRoute, tagged with identifier CLIENT3, a LIMIT DAY sell order to sell 800 shares of ABC @ $15.10 at 11:04 p.m. Where CLIENT 3 has elected broker priority, Order E is matched, based on broker priority, first with Order C and Order D (based on time priority) and the balance of 100 will be matched, based on price-time priority, against Order A. Because the ATS's Operating Hours (8 p.m. ET to 4 a.m. ET) are after the Core Market Hours (9:30 a.m. ET to 4 p.m. ET, Monday through Friday), trades executed on the ATS are not priced according to and do not relate to the NBBO, which is not available during the Operating Hours. Rather, reference prices for trades executed on the ATS are based on the best available bid and offer on the ATS at the time of the trade. Order Cancellation and Amendment All orders entered into tZERO ATS are considered firm orders. An order is actionable and eligible for execution at any time until such order has expired by its terms, is canceled, or is executed and, when executed, is binding on the Subscriber placing the order (executed orders entered by sponsored access clients are binding against the Subscriber providing sponsored access because tZERO ATS's contractual relationship is with the Subscriber providing sponsored access, not the sponsored access client). Subscribers/sponsored access clients may cancel their pending orders at any time before execution at their discretion. A reduction in an order's size through a cancel/replace instruction will not affect the order's original time priority. Changes that increase an orders size will lose priority to existing orders at the same price and result in a new time priority. A change in an order's price, however, will result in a new time priority being assigned to the order. Orders will be rejected if they contain instructions or order attributes that are not supported by the ATS, such as an invalid stock symbol. Subscribers are also subject to pre-trade credit and risk controls to prevent certain orders from reaching the ATS. Each Subscriber is subject to a daily notional value limit, a maximum notional value per order, a maximum quantity per order, a maximum number of orders per second, and a maximum number of duplicate orders (same ticker symbol, size, side, order type and price). The COO or his or her designee determines the limits for each Subscriber based on a credit risk assessment before the Subscriber is permitted to commence trading on the ATS. These controls will reject Subscriber orders that exceed pre-set credit thresholds or that contain a sub-penny price, among others. Required Fields -Sending time (Time of order creation expressed in UTC) -Client Order ID (unique identifier per order/per session) -Side (Buy, Sell, Sell Short, Sell Short Exempt) -Symbol -Time In Force = DAY -Order Type = Limit -Price

means_of_entry

General Operation of the ATS Subscribers access PRO ATS via a Financial Information Exchange ("FIX") connection. Such access is available to Subscribers through an internet protocol address via communications that are compliant with the FIX API provided by the ATS. The ATS supports FIX 4.2. Sponsored access clients access PRO ATS through the sponsoring Subscriber. PRO ATS only accepts orders via FIX. It does not accept orders via telephone, email, instant message, or other form of communication. PRO ATS does not support the routing of orders to any other venue.

means_of_entry

General Operation of the ATS Subscribers access tZERO ATS via a Financial Information Exchange ("FIX") connection. Such access is available to Subscribers through an internet protocol address via communications that are compliant with the FIX API provided by the ATS. The ATS supports FIX 4.2. Sponsored access clients access tZERO ATS through the sponsoring Subscriber. tZERO ATS only accepts orders via FIX. It does not accept orders via telephone, email, instant message, or other form of communication. tZERO ATS does not support the routing of orders to any other venue.

pricing_methodology

PRO ATS obtains last print data from QUODD Financial Information Services that provides a reference price as of 7:50 p.m. ET on each trading day for each NMS Stock that trades on the ATS. That reference price is the last sale price for each security printed on a national securities exchange. PRO ATS receives halt information from exchange member alerts and Bloomberg email alerts.

pricing_methodology

tZERO ATS obtains last print data from QUODD Financial Information Services that provides a reference price as of 7:50 p.m. ET on each trading day for each NMS Stock that trades on the ATS. That reference price is the last sale price for each security printed on a national securities exchange. tZERO ATS receives halt information from exchange member alerts and Bloomberg email alerts.

counterparty_selection

As described in Part III, Item 7, a Subscriber/sponsored access client can choose broker priority, where the Subscriber's/sponsored access client's orders interact with its own contra orders for the same NMS Stock at the same price. The ATS's matching engine will respect that preference unless resting orders in the ATS's order book are better priced. A Subscriber/sponsored access client that chooses broker priority cannot designate that its orders execute or not execute against the orders of other specified Subscribers or sponsored access clients if such orders are better priced. For example, Subscriber A cannot designate its order to execute against/not execute against Subscriber B's orders.

financial_condition_summary

PRO ATS charges SpeedRoute a fixed fee of $15,000 for its access to the ATS. SpeedRoute is not charged a transaction-based fee. For all other Subscribers, PRO ATS charges the Subscriber a transaction-based fee of $0.008 per share, irrespective of whether the Subscriber or its sponsored access client enters the orders underlying the transactions. That is, PRO ATS does not charge Subscribers' sponsored access clients directly for transactions.

financial_condition_summary

tZERO ATS charges SpeedRoute a fixed fee of $15,000 for its access to the ATS. SpeedRoute is not charged a transaction-based fee. For all other Subscribers, tZERO ATS charges the Subscriber a transaction-based fee of $0.008 per share, irrespective of whether the Subscriber or its sponsored access client enters the orders underlying the transactions. That is, tZERO ATS does not charge Subscribers' sponsored access clients directly for transactions.

financial_condition_summary

tZERO ATS charges SpeedRoute a fixed fee of $15,000 for its access to the ATS. SpeedRoute is not charged a transaction-based fee. For all other Subscribers, tZERO ATS charges the Subscriber a transaction-based fee of $0.008 per share, irrespective of whether the Subscriber or its sponsored access client enters the orders underlying the transactions. That is, tZERO ATS does not charge Subscribers' sponsored access clients directly for transactions. tZERO ATS, LLC provides the real-time Market Data feeds to non-Subscribers and other third parties, including, but not limited to, sponsored access clients and Market Data vendors that redistribute the data through direct Market Data feeds in the same manner as such data is made available to Subscribers. Third parties can use this data for their own purposes, or they can retransmit the data to other third parties, subject to tZERO ATS, LLC's approval. tZERO ATS, LLC does not charge Subscribers or other third parties for Market Data.

conflict_description

SpeedRoute, LLC ("SpeedRoute") (MPID: SPDR) is a U.S.-registered broker-dealer and affiliate of tZERO ATS, LLC through common ownership; SpeedRoute and tZERO ATS, LLC are wholly-owned subsidiaries of tZERO Broker Services, LLC. ("tZERO"). tZERO is a wholly-owned subsidiary of tZERO Group, Inc. ('tZERO Group'). SpeedRoute is a subscriber to tZERO ATS (SpeedRoute and all other subscribers to the tZERO ATS, "Subscribers" and, each a "Subscriber"). In that capacity, it provides sponsored access to tZERO ATS for certain approved broker-dealer clients. SpeedRoute's sponsored access clients enter orders into tZERO ATS using SpeedRoute's MPID. Orders that a sponsored access client enters for execution are routed to tZERO ATS through the Subscriber's order management system. All orders that are entered by a sponsored access client using SpeedRoute's MPID are entered into tZERO ATS in an agency capacity. SpeedRoute is a routing broker and does not itself execute trades for clients, nor does it trade on a principal basis, whether on tZERO ATS or otherwise.

conflict_description

SpeedRoute, LLC ("SpeedRoute") (MPID: SPDR) is a U.S.-registered broker-dealer and affiliate of PRO Securities through common ownership; SpeedRoute and PRO Securities are wholly-owned subsidiaries of tZERO Group, Inc. ("tZERO"). SpeedRoute is a subscriber to PRO ATS. In that capacity, it provides sponsored access to PRO ATS for certain approved broker-dealer clients. SpeedRoute's sponsored access clients enter orders into PRO ATS using SpeedRoute's MPID. Orders that a sponsored access client enters for execution are routed to PRO ATS through the Subscriber's order management system. All orders that are entered by a sponsored access client using SpeedRoute's MPID are entered into PRO ATS in an agency capacity. SpeedRoute is a routing broker and does not itself execute trades for clients, nor does it trade on a principal basis, whether on PRO ATS or otherwise.

conflict_description

SpeedRoute, LLC ("SpeedRoute") (MPID: SPDR) is a U.S.-registered broker-dealer and affiliate of tZERO ATS, LLC through common ownership; SpeedRoute and tZERO ATS, LLC are wholly-owned subsidiaries of tZERO Broker Services, LLC. ("tZERO"). SpeedRoute is a subscriber to tZERO ATS (SpeedRoute and all other subscribers to the tZERO ATS, "Subscribers" and, each a "Subscriber"). In that capacity, it provides sponsored access to tZERO ATS for certain approved broker-dealer clients. SpeedRoute's sponsored access clients enter orders into tZERO ATS using SpeedRoute's MPID. Orders that a sponsored access client enters for execution are routed to tZERO ATS through the Subscriber's order management system. All orders that are entered by a sponsored access client using SpeedRoute's MPID are entered into tZERO ATS in an agency capacity. SpeedRoute is a routing broker and does not itself execute trades for clients, nor does it trade on a principal basis, whether on tZERO ATS or otherwise.

conflict_description

SpeedRoute, LLC ("SpeedRoute") (MPID: SPDR) is a U.S.-registered broker-dealer and affiliate of tZERO ATS, LLC through common ownership; SpeedRoute and tZERO ATS, LLC are wholly-owned subsidiaries of tZERO Group, Inc. ("tZERO"). SpeedRoute is a subscriber to tZERO ATS. In that capacity, it provides sponsored access to tZERO ATS for certain approved broker-dealer clients. SpeedRoute's sponsored access clients enter orders into tZERO ATS using SpeedRoute's MPID. Orders that a sponsored access client enters for execution are routed to tZERO ATS through the Subscriber's order management system. All orders that are entered by a sponsored access client using SpeedRoute's MPID are entered into tZERO ATS in an agency capacity. SpeedRoute is a routing broker and does not itself execute trades for clients, nor does it trade on a principal basis, whether on tZERO ATS or otherwise.

compliance_officer

PRO ATS has implemented written safeguards and written procedures to protect CTI, consistent with Rule 301(b)(10) of Regulation ATS. Specifically, PRO ATS has established internal controls at the trading system and personnel levels intended to prevent CTI from passing from PRO Securities/PRO ATS to any other Subscriber or sponsored access client, and to prevent Shared Representatives, Shared NRFs, and FI Personnel from improperly using such CTI. Although SpeedRoute personnel, including NRFs who support SpeedRoute in its capacity as a Subscriber, have access to the CTI of other Subscribers or sponsored access clients, all such personnel are prohibited from improperly using CTI, and PRO ATS applies the controls described in this section to Shared Representatives and Shared NRFs to prevent improper use of such CTI. Compliance personnel review samples of emails of both Shared Representatives and Shared NRFs. Compliance reviews such emails for any indication of improper use of CTI. Neither PRO Securities nor SpeedRoute uses instant messaging, and personnel of those two entities are prohibited from using text messaging for business purposes. Because PRO ATS operates outside of Core Market Hours, executions on the ATS are not reported to the consolidated tape. PRO ATS personnel review the PRO ATS trade data for suspicious activity, such as wash trading, self-matching and front running that might indicate misuse of CTI. Because all trading in NMS stocks on the PRO ATS occurs outside of Core Market Hours, it is unlikely that any CTI to which SpeedRoute has access could be of benefit to its routing clients. Note as well that Trade Support personnel do not earn transaction-based compensation, so there is no incentive for them to promote trading by SpeedRoute's sponsored access clients. That is, the PRO ATS's Operating Hours help to minimize the potential for misuse of CTI. The internal controls that PRO ATS employs include the following: Control and Supervision of Access to Confidential Trading Information - PRO ATS has procedures and safeguards in place to protect CTI. In accordance with Rule 301(b)(10), the President of PRO Securities ensures that access to CTI is limited to Shared Representatives, Shared NRFs and FI Personnel identified in Part II, Items 6(a) and (b), and that such personnel have access only to the CTI for which they have been permissioned as described in Part II, 6(a). The PRO Securities COO supervises Shared NRFs and FI Personnel who have access to CTI. As discussed in Part II, Item 6(a), the COO of PRO Securities, subject to the President of PRO Securities' approval, determines on a case-by-case basis whether to grant access to CTI to any additional PRO Securities, SpeedRoute, t0 Technologies or FI Personnel, and such access is granted only if necessary to support the operation of PRO ATS based on the job functions of those being granted access. The Shared Representatives responsible for supporting PRO ATS operations have controlled access via login credentials to view orders and trades in the ATS system. Shared Representatives with trade support and IT/operations responsibilities may view real-time order and trade information through a front-end graphic user interface ("GUI"). Shared NRFs with IT/operations responsibilities may access order and trade information by means of querying a database. Additionally, Shared Representatives and Shared NRFs described in Items 6(a) and (b) have access to historical CTI through access to a shared drive. If an order has been entered into PRO ATS, it resides on the PRO ATS server, but such data is only accessible by the Shared Representatives responsible for PRO ATS operations, or Shared NRFs or FI Personnel who support PRO ATS operations as supervised by the PRO Securities COO. PRO Securities requires Shared Representatives and Shared NRFs to understand the authorized uses of CTI and requires such personnel to acknowledge this understanding by attesting in writing that they have reviewed and understood PRO Securities' written supervisory procedures. These personnel undergo annual compliance training that includes materials related to protecting CTI. Shared Representatives and Shared NRFs with access to CTI are required to complete an annual attestation regarding the proper use of CTI. The COO, subject to the approval of the President, is also responsible for determining whether to grant FI Personnel, as that term is defined in Part II, Item 6(b), access to CTI, either on a temporary or permanent basis, and for determining to what CTI such persons may be granted access. FI Personnel's access to servers is limited to specific IP addresses using Network Address Translation and explicit firewall access rules. Limited user remote server access is allowed only via Secure Shell (SSH) and the FI console (GUI), both of which are limited to specific users and are password protected. FI Personnel are subject to strict contractual prohibitions on the use of any of PRO ATS's CTI, and FI Personnel's access to CTI is supervised by the PRO Securities COO. Share Representatives, Shared NRFs and FI Personnel therefore understand that they cannot misuse CTI. PRO Securities and SpeedRoute both maintain servers at Equinix NY 4, but those servers are separate from each other. The PRO Securities and SpeedRoute servers do not share data with each other. Requests for access to real-time order and trading information is strictly monitored and such requests must be approved by PRO Securities' President. Access will be granted only if the requesting individuals are Shared Representatives, Shared NRFs or FI Personnel involved in the operations or compliance functions of the ATS. PRO Securities conducts periodic reviews of access to CTI to ensure PRO ATS's continued compliance with Rule 301(b)(10). As part of the review, PRO Securities confirms that individuals with access to CTI continue to have a valid need to access such information based on the access standards set out for a given position in this Part II, Item 7(a). Trading Systems Controls - Shared NRFs and FI Personnel help to maintain the operability of PRO ATS's trading system and related market data feed and display functionality. System access to the ATS server is regulated by secure log-ins and monitored by compliance personnel. FI provides the infrastructure and technology for PRO ATS through its license agreements with t0 Technologies, but PRO Securities, utilizing that licensed technology, is responsible for the maintenance and support of the order book and Subscriber/sponsored access client information. The ATS utilizes a dynamic and real-time application to monitor intraday trading from a trade support perspective. As an additional protection, PRO Securities, SpeedRoute, t0 Technologies, and FI do not, nor do any other PRO Securities affiliates/services providers, conduct any principal trading or market making activity. Restricted Access to Network Infrastructure - The ATS servers and networking equipment is located in PRO Securities' Data Center which is Equinix NY4. FI Personnel provide technical support regarding the operation of the software used by the ATS for its matching engine and its market data distribution and publication. When needed, FI Personnel work with Shared NRFs to resolve software systems issues that may require access to PRO ATS's network infrastructure and CTI, specifically, historical order and execution data, subject to the supervision of Shared Representatives. Personal Securities Transactions - PRO Securities' policies and procedures require Shared Representatives and Shared NRFs to hold any securities acquired in personal securities transactions for 30 days. PRO Securities' Chief Compliance Officer ("CCO") and his or her designees receive duplicate copies of all brokerage statements and trade confirmations of such personnel. Compliance personnel review these documents when they are received and look for unusual trading patterns, e.g., trades involving unusual quantities and trading in certain types of securities. We note that given the trading in NMS stocks on the PRO ATS occurs outside of Core Market Hours, it is unlikely that Shared Representatives or Shared NRFs could use CTI for personal trading either on the PRO ATS, where they could not trade in their personal capacities, or for trading on markets during Core Market Hours, at which time the CTI likely would be stale. The policies and procedures cover all securities transactions in outside brokerage accounts directed by the personnel referenced in the preceding paragraph, including but not limited to, transactions in securities issued by a company (e.g. stocks, bonds), transactions in any reference securities (e.g. options, preferred stock, futures), and transactions in any packaged products including but not limited to mutual funds and exchange traded funds.

compliance_officer

tZERO ATS, LLC has implemented written safeguards and written procedures to protect CTI, consistent with Rule 301(b)(10) of Regulation ATS. Specifically, tZERO ATS, LLC has established internal controls at the trading system and personnel levels intended to prevent CTI from passing from tZERO ATS, LLC/tZERO ATS to any other Subscriber or sponsored access client, and to prevent Shared Representatives, Shared NRFs, and FI Personnel from improperly using such CTI. Although SpeedRoute personnel, including NRFs who support SpeedRoute in its capacity as a Subscriber, have access to the CTI of other Subscribers or sponsored access clients, all such personnel are prohibited from improperly using CTI, and tZERO ATS, LLC applies the controls described in this section to Shared Representatives and Shared NRFs to prevent improper use of such CTI. Compliance personnel review samples of emails of both Shared Representatives and Shared NRFs. Compliance reviews such emails for any indication of improper use of CTI. Neither tZERO ATS, LLC nor SpeedRoute uses instant messaging, and personnel of those two entities are prohibited from using text messaging for business purposes. Because tZERO ATS operates outside of Core Market Hours, executions on the ATS are not reported to the consolidated tape. tZERO ATS, LLC personnel review the tZERO ATS trade data for suspicious activity, such as wash trading, self-matching and front running that might indicate misuse of CTI. Because all trading in NMS stocks on the tZERO ATS occurs outside of Core Market Hours, it is unlikely that any CTI to which SpeedRoute has access could be of benefit to its routing clients. Note as well that Trade Support personnel do not earn transaction-based compensation, so there is no incentive for them to promote trading by SpeedRoute's sponsored access clients. That is, the tZERO ATS's Operating Hours help to minimize the potential for misuse of CTI. The internal controls that tZERO ATS employs include the following: Control and Supervision of Access to Confidential Trading Information - tZERO ATS has procedures and safeguards in place to protect CTI. In accordance with Rule 301(b)(10), the President of tZERO ATS, LLC ensures that access to CTI is limited to Shared Representatives, Shared NRFs and FI Personnel identified in Part II, Items 6(a) and (b), and that such personnel have access only to the CTI for which they have been permissioned as described in Part II, 6(a). The tZERO ATS, LLC Head of Systems Support supervises Shared NRFs and FI Personnel who have access to CTI. As discussed in Part II, Item 6(a), the Head of Systems Support of tZERO ATS, LLC, subject to the President of tZERO ATS, LLC's approval, determines on a case-by-case basis whether to grant access to CTI to any additional tZERO ATS, LLC, SpeedRoute, tZERO Tech or FI Personnel, and such access is granted only if necessary to support the operation of tZERO ATS based on the job functions of those being granted access. The Shared Representatives responsible for supporting tZERO ATS operations have controlled access via login credentials to view orders and trades in the ATS system. Shared Representatives with trade support and IT/operations responsibilities may view real-time order and trade information through a front-end graphic user interface ("GUI"). Shared NRFs with IT/operations responsibilities may access order and trade information by means of querying a database. Additionally, Shared Representatives and Shared NRFs described in Items 6(a) and (b) have access to historical CTI through access to a shared drive. If an order has been entered into tZERO ATS, it resides on the tZERO ATS server, but such data is only accessible by the Shared Representatives responsible for tZERO ATS operations, or Shared NRFs or FI Personnel who support tZERO ATS operations as supervised by the tZERO ATS, LLC Head of Systems Support. tZERO ATS, LLC requires Shared Representatives and Shared NRFs to understand the authorized uses of CTI and requires such personnel to acknowledge this understanding by attesting in writing that they have reviewed and understood tZERO ATS, LLC's written supervisory procedures. These personnel undergo annual compliance training that includes materials related to protecting CTI. Shared Representatives and Shared NRFs with access to CTI are required to complete an annual attestation regarding the proper use of CTI. The Head of Systems Support , subject to the approval of the President, is also responsible for determining whether to grant FI Personnel, as that term is defined in Part II, Item 6(b), access to CTI, either on a temporary or permanent basis, and for determining to what CTI such persons may be granted access. FI Personnel's access to servers is limited to specific IP addresses using Network Address Translation and explicit firewall access rules. Limited user remote server access is allowed only via Secure Shell (SSH) and the FI console (GUI), both of which are limited to specific users and are password protected. FI Personnel are subject to strict contractual prohibitions on the use of any of tZERO ATS's CTI, and FI Personnel's access to CTI is supervised by the tZERO ATS, LLC Head of Systems Support. Share Representatives, Shared NRFs and FI Personnel therefore understand that they cannot misuse CTI. tZERO ATS, LLC and SpeedRoute both maintain servers at Equinix NY 4, but those servers are separate from each other. The tZERO ATS, LLC and SpeedRoute servers do not share data with each other. Requests for access to real-time order and trading information is strictly monitored and such requests must be approved by tZERO ATS, LLC's President. Access will be granted only if the requesting individuals are Shared Representatives, Shared NRFs or FI Personnel involved in the operations or compliance functions of the ATS. tZERO ATS, LLC conducts periodic reviews of access to CTI to ensure tZERO ATS's continued compliance with Rule 301(b)(10). As part of the review, tZERO ATS, LLC confirms that individuals with access to CTI continue to have a valid need to access such information based on the access standards set out for a given position in this Part II, Item 7(a). Trading Systems Controls - Shared NRFs and FI Personnel help to maintain the operability of tZERO ATS's trading system and related market data feed and display functionality. System access to the ATS server is regulated by secure log-ins and monitored by compliance personnel. FI provides the infrastructure and technology for tZERO ATS through its license agreements with tZERO Tech, but tZERO ATS, LLC, utilizing that licensed technology, is responsible for the maintenance and support of the order book and Subscriber/sponsored access client information. The ATS utilizes a dynamic and real-time application to monitor intraday trading from a trade support perspective. As an additional protection, tZERO ATS, LLC, SpeedRoute, tZERO Tech, and FI do not, nor do any other tZERO ATS, LLC affiliates/services providers, conduct any principal trading or market making activity. Restricted Access to Network Infrastructure - The ATS servers and networking equipment is located in tZERO ATS, LLC's Data Center which is Equinix NY4. FI Personnel provide technical support regarding the operation of the software used by the ATS for its matching engine and its market data distribution and publication. When needed, FI Personnel work with Shared NRFs to resolve software systems issues that may require access to tZERO ATS's network infrastructure and CTI, specifically, historical order and execution data, subject to the supervision of Shared Representatives. Personal Securities Transactions - tZERO ATS, LLC's policies and procedures require Shared Representatives and Shared NRFs to hold any securities acquired in personal securities transactions for 30 days. tZERO ATS, LLC's CCO and his or her designees receive duplicate copies of all brokerage statements and trade confirmations of such personnel. Compliance personnel review these documents when they are received and look for unusual trading patterns, e.g., trades involving unusual quantities and trading in certain types of securities. We note that given the trading in NMS stocks on the tZERO ATS occurs outside of Core Market Hours, it is unlikely that Shared Representatives or Shared NRFs could use CTI for personal trading either on the tZERO ATS, where they could not trade in their personal capacities, or for trading on markets during Core Market Hours, at which time the CTI likely would be stale. The policies and procedures cover all securities transactions in outside brokerage accounts directed by the personnel referenced in the preceding paragraph, including but not limited to, transactions in securities issued by a company (e.g. stocks, bonds), transactions in any reference securities (e.g. options, preferred stock, futures), and transactions in any packaged products including but not limited to mutual funds and exchange traded funds.

compliance_officer

tZERO ATS has implemented written safeguards and written procedures to protect CTI, consistent with Rule 301(b)(10) of Regulation ATS. Specifically, tZERO ATS has established internal controls at the trading system and personnel levels intended to prevent CTI from passing from tZERO ATS, LLC/tZERO ATS to any other Subscriber or sponsored access client, and to prevent Shared Representatives, Shared NRFs, and FI Personnel from improperly using such CTI. Although SpeedRoute personnel, including NRFs who support SpeedRoute in its capacity as a Subscriber, have access to the CTI of other Subscribers or sponsored access clients, all such personnel are prohibited from improperly using CTI, and tZERO ATS applies the controls described in this section to Shared Representatives and Shared NRFs to prevent improper use of such CTI. Compliance personnel review samples of emails of both Shared Representatives and Shared NRFs. Compliance reviews such emails for any indication of improper use of CTI. Neither tZERO ATS, LLC nor SpeedRoute uses instant messaging, and personnel of those two entities are prohibited from using text messaging for business purposes. Because tZERO ATS operates outside of Core Market Hours, executions on the ATS are not reported to the consolidated tape. tZERO ATS personnel review the tZERO ATS trade data for suspicious activity, such as wash trading, self-matching and front running that might indicate misuse of CTI. Because all trading in NMS stocks on the tZERO ATS occurs outside of Core Market Hours, it is unlikely that any CTI to which SpeedRoute has access could be of benefit to its routing clients. Note as well that Trade Support personnel do not earn transaction-based compensation, so there is no incentive for them to promote trading by SpeedRoute's sponsored access clients. That is, the tZERO ATS's Operating Hours help to minimize the potential for misuse of CTI. The internal controls that tZERO ATS employs include the following: Control and Supervision of Access to Confidential Trading Information - tZERO ATS has procedures and safeguards in place to protect CTI. In accordance with Rule 301(b)(10), the President of tZERO ATS, LLC ensures that access to CTI is limited to Shared Representatives, Shared NRFs and FI Personnel identified in Part II, Items 6(a) and (b), and that such personnel have access only to the CTI for which they have been permissioned as described in Part II, 6(a). The tZERO ATS, LLC COO supervises Shared NRFs and FI Personnel who have access to CTI. As discussed in Part II, Item 6(a), the COO of tZERO ATS, LLC, subject to the President of tZERO ATS, LLC's approval, determines on a case-by-case basis whether to grant access to CTI to any additional tZERO ATS, LLC, SpeedRoute, t0 Technologies or FI Personnel, and such access is granted only if necessary to support the operation of tZERO ATS based on the job functions of those being granted access. The Shared Representatives responsible for supporting tZERO ATS operations have controlled access via login credentials to view orders and trades in the ATS system. Shared Representatives with trade support and IT/operations responsibilities may view real-time order and trade information through a front-end graphic user interface ("GUI"). Shared NRFs with IT/operations responsibilities may access order and trade information by means of querying a database. Additionally, Shared Representatives and Shared NRFs described in Items 6(a) and (b) have access to historical CTI through access to a shared drive. If an order has been entered into tZERO ATS, it resides on the tZERO ATS server, but such data is only accessible by the Shared Representatives responsible for tZERO ATS operations, or Shared NRFs or FI Personnel who support tZERO ATS operations as supervised by the tZERO ATS, LLC COO. tZERO ATS, LLC requires Shared Representatives and Shared NRFs to understand the authorized uses of CTI and requires such personnel to acknowledge this understanding by attesting in writing that they have reviewed and understood tZERO ATS, LLC's written supervisory procedures. These personnel undergo annual compliance training that includes materials related to protecting CTI. Shared Representatives and Shared NRFs with access to CTI are required to complete an annual attestation regarding the proper use of CTI. The COO, subject to the approval of the President, is also responsible for determining whether to grant FI Personnel, as that term is defined in Part II, Item 6(b), access to CTI, either on a temporary or permanent basis, and for determining to what CTI such persons may be granted access. FI Personnel's access to servers is limited to specific IP addresses using Network Address Translation and explicit firewall access rules. Limited user remote server access is allowed only via Secure Shell (SSH) and the FI console (GUI), both of which are limited to specific users and are password protected. FI Personnel are subject to strict contractual prohibitions on the use of any of tZERO ATS's CTI, and FI Personnel's access to CTI is supervised by the tZERO ATS, LLC COO. Share Representatives, Shared NRFs and FI Personnel therefore understand that they cannot misuse CTI. tZERO ATS, LLC and SpeedRoute both maintain servers at Equinix NY 4, but those servers are separate from each other. The tZERO ATS, LLC and SpeedRoute servers do not share data with each other. Requests for access to real-time order and trading information is strictly monitored and such requests must be approved by tZERO ATS, LLC's President. Access will be granted only if the requesting individuals are Shared Representatives, Shared NRFs or FI Personnel involved in the operations or compliance functions of the ATS. tZERO ATS, LLC conducts periodic reviews of access to CTI to ensure tZERO ATS's continued compliance with Rule 301(b)(10). As part of the review, tZERO ATS, LLC confirms that individuals with access to CTI continue to have a valid need to access such information based on the access standards set out for a given position in this Part II, Item 7(a). Trading Systems Controls - Shared NRFs and FI Personnel help to maintain the operability of tZERO ATS's trading system and related market data feed and display functionality. System access to the ATS server is regulated by secure log-ins and monitored by compliance personnel. FI provides the infrastructure and technology for tZERO ATS through its license agreements with t0 Technologies, but tZERO ATS, LLC, utilizing that licensed technology, is responsible for the maintenance and support of the order book and Subscriber/sponsored access client information. The ATS utilizes a dynamic and real-time application to monitor intraday trading from a trade support perspective. As an additional protection, tZERO ATS, LLC, SpeedRoute, t0 Technologies, and FI do not, nor do any other tZERO ATS, LLC affiliates/services providers, conduct any principal trading or market making activity. Restricted Access to Network Infrastructure - The ATS servers and networking equipment is located in tZERO ATS, LLC's Data Center which is Equinix NY4. FI Personnel provide technical support regarding the operation of the software used by the ATS for its matching engine and its market data distribution and publication. When needed, FI Personnel work with Shared NRFs to resolve software systems issues that may require access to tZERO ATS's network infrastructure and CTI, specifically, historical order and execution data, subject to the supervision of Shared Representatives. Personal Securities Transactions - tZERO ATS, LLC's policies and procedures require Shared Representatives and Shared NRFs to hold any securities acquired in personal securities transactions for 30 days. tZERO ATS, LLC's Chief Compliance Officer ("CCO") and his or her designees receive duplicate copies of all brokerage statements and trade confirmations of such personnel. Compliance personnel review these documents when they are received and look for unusual trading patterns, e.g., trades involving unusual quantities and trading in certain types of securities. We note that given the trading in NMS stocks on the tZERO ATS occurs outside of Core Market Hours, it is unlikely that Shared Representatives or Shared NRFs could use CTI for personal trading either on the tZERO ATS, where they could not trade in their personal capacities, or for trading on markets during Core Market Hours, at which time the CTI likely would be stale. The policies and procedures cover all securities transactions in outside brokerage accounts directed by the personnel referenced in the preceding paragraph, including but not limited to, transactions in securities issued by a company (e.g. stocks, bonds), transactions in any reference securities (e.g. options, preferred stock, futures), and transactions in any packaged products including but not limited to mutual funds and exchange traded funds.

hours_of_operation

Dates and Hours of Operation tZERO ATS will operate each evening before the NYSE Trade Reporting Facility ("TRF") is open so that trades effected on the ATS can be reported. Subscribers/sponsored access clients may submit orders to the ATS beginning at 6:15 p.m. ET on the days of operation of the ATS. Matching in NMS Stocks on the ATS occurs from 8:00 p.m. ET to 4:00 a.m. ET the following day, i.e., during Operating Hours, if the TRF is open for trade reporting on that following day. For example, the ATS will operate from Sunday evening at 8:00 p.m. until 4:00 a.m. ET on Monday, and trades executed during that session will be reported to the TRF before 8:15 a.m. ET on that Monday. However, the ATS will not conduct a trading session beginning at 8:00 p.m. ET on Friday, because the TRF is not available for the reporting of trades on Saturday. Likewise, there will be no trading session on Christmas Eve because the TRF is not open on Christmas, but there could be an overnight trading session beginning on Christmas night if the TRF is open and available for trade reporting on the following day.

hours_of_operation

Dates and Hours of Operation PRO ATS will operate each evening before the NYSE Trade Reporting Facility ("TRF") is open so that trades effected on the ATS can be reported. Subscribers/sponsored access clients may submit orders to the ATS beginning at 6:15 p.m. ET on the days of operation of the ATS. Matching in NMS Stocks on the ATS occurs from 8:00 p.m. ET to 4:00 a.m. ET the following day, i.e., during Operating Hours, if the TRF is open for trade reporting on that following day. For example, the ATS will operate from Sunday evening at 8:00 p.m. until 4:00 a.m. ET on Monday, and trades executed during that session will be reported to the TRF before 8:15 a.m. ET on that Monday. However, the ATS will not conduct a trading session beginning at 8:00 p.m. ET on Friday, because the TRF is not available for the reporting of trades on Saturday. Likewise, there will be no trading session on Christmas Eve because the TRF is not open on Christmas, but there could be an overnight trading session beginning on Christmas night if the TRF is open and available for trade reporting on the following day.

display_best_quotes

PRO Securities displays in real time on its public website bids and offers for NMS Stocks submitted to PRO ATS. PRO ATS does not charge for access to its website. The information for displayed orders includes symbol, size, side and price for top of book. If a posted bid or offer is executed or canceled, it is removed from the site. PRO Securities will display best bids and offers on its website for the ATS during the Operating Hours. The posted order information is purged immediately at the end of a trading session, when all open orders in the ATS order book are canceled. PRO Securities also makes more extensive Level 2 market data, i.e., depth-of-book data, regarding orders executions on the ATS available to its Subscribers, sponsored access clients, and third parties, as discussed in Part II, Item 4(a), through its website on a restricted, password-protected basis and/or through direct market data feeds from the ATS's Data Center in Equinix NY4. Subscribers and sponsored access clients obtaining streaming direct market data feeds may take that data directly into their order or execution management systems. This Level 2 data includes all bids and offers on the ATS's order book; high and low trade prices in a symbol during a trading session on the ATS; last sale price on the ATS; opening price for the symbol on the ATS in that trading session; and the volume of trading in that symbol on the ATS during the session. This market data remains available to Subscribers, sponsored access clients and third parties on the PRO Securities restricted site until 4:00 p.m. ET the following trading day. Subscribers submit orders electronically to PRO Securities through the Gateway. This FIX order information is collected, normalized, formatted and transmitted, through the use of software provided by FI, to the PRO Securities website for posting and/or its restricted website GUI, as applicable. PRO ATS also uses FI technology and software to transmit direct market data feeds to Subscribers from the ATS's Data Center in Equinix NY4. SpeedRoute does not receive market data feeds.

display_best_quotes

tZERO ATS, LLC displays in real time on its public website bids and offers for NMS Stocks submitted to tZERO ATS. tZERO ATS, LLC does not charge for access to its website. The information for displayed orders includes symbol, size, side and price for top of book. If a posted bid or offer is executed or canceled, it is removed from the site. tZERO ATS, LLC will display best bids and offers on its website for the ATS during the Operating Hours. The posted order information is purged immediately at the end of a trading session, when all open orders in the ATS order book are canceled. tZERO ATS, LLC also makes more extensive Level 2 market data, i.e., depth-of-book data, regarding orders executions on the ATS available to its Subscribers, sponsored access clients, and third parties, as discussed in Part II, Item 4(a), through its website on a restricted, password-protected basis and/or through direct market data feeds from the ATS's Data Center in Equinix NY4. Subscribers and sponsored access clients obtaining streaming direct market data feeds may take that data directly into their order or execution management systems. This Level 2 data includes all bids and offers on the ATS's order book; high and low trade prices in a symbol during a trading session on the ATS; last sale price on the ATS; opening price for the symbol on the ATS in that trading session; and the volume of trading in that symbol on the ATS during the session. This market data remains available to Subscribers, sponsored access clients and third parties on the tZERO ATS, LLC restricted site until 4:00 p.m. ET the following trading day. Subscribers submit orders electronically to tZERO ATS, LLC through the Gateway. This FIX order information is collected, normalized, formatted and transmitted, through the use of software provided by FI, to the tZERO ATS, LLC website for posting and/or its restricted website GUI, as applicable. tZERO ATS also uses FI technology and software to transmit direct market data feeds to Subscribers from the ATS's Data Center in Equinix NY4. SpeedRoute does not receive market data feeds.

display_best_quotes

tZERO ATS, LLC makes Market Data available to its Subscribers, sponsored access clients, and third parties, as discussed in Part II, Item 5(a), through its website on a restricted, password-protected basis and/or through direct market data feeds from the ATS's Data Center in Equinix NY4. "Market Data" means Transaction Data and Order Data with respect to securities that trade on the tZERO ATS. "Transaction Data" for NMS stocks executed on the ATS includes the following for each such NMS Stock: last print, which includes the transaction size and execution price; total daily trading volume; previous closing price; change in value from the last close (both as a percentage and nominal number); opening price; high price; low price; and, with respect to each transaction executed on the tZERO ATS, each Subscriber that is a party to the transaction. "Order Data" for orders to purchase or sell an NMS Stock that Subscribers submit to the tZERO ATS is composed of the aggregate then-best bid and offer with size (top-of-book), all other bids and offers, with size (depth-of-book) for that NMS Stock and the identity of the Subscriber posting the bid and/or offer. Subscribers and sponsored access clients obtaining streaming direct Market Data feeds may take that data directly into their order or execution management systems. This Market Data remains available to Subscribers, sponsored access clients and third parties on the tZERO ATS, LLC restricted site until 7:59 p.m. ET the following trading day. Subscribers submit orders electronically to tZERO ATS, LLC through the Gateway. This FIX order information is collected, normalized, formatted and transmitted, through the use of software provided by FI, to the tZERO ATS, LLC website for posting and/or its restricted website GUI, as applicable. tZERO ATS also uses FI technology and software to transmit direct market data feeds to Subscribers from the ATS's Data Center in Equinix NY4. SpeedRoute does not receive Market Data feeds.

display_best_quotes

tZERO ATS, LLC historically has displayed in real time on its public website bids and offers for NMS Stocks submitted to tZERO ATS, but such data is currently unavailable. tZERO ATS, LLC, however, will make this data available again to the public for free via the website on or before August 31, 2020. The information for displayed orders includes symbol, size, side and price for top of book. If a posted bid or offer is executed or canceled, it is removed from the site. tZERO ATS, LLC will display best bids and offers on its website for the ATS during the Operating Hours. The posted order information is purged immediately at the end of a trading session, when all open orders in the ATS order book are canceled. tZERO ATS, LLC also makes more extensive Market Data available to its Subscribers, sponsored access clients, and third parties, as discussed in Part II, Item 4(a), through its website on a restricted, password-protected basis and/or through direct market data feeds from the ATS's Data Center in Equinix NY4. "Market Data" means Transaction Data and Order Data with respect to securities that trade on the tZERO ATS. "Transaction Data" for NMS stocks executed on the ATS includes the following for each such NMS Stock: last print, which includes the transaction size and execution price; total daily trading volume; previous closing price; change in value from the last close (both as a percentage and nominal number); opening price; high price; low price; and, with respect to each transaction executed on the tZERO ATS, each Subscriber that is a party to the transaction. "Order Data" for orders to purchase or sell a NMS Stock that Subscribers submit to the tZERO ATS is composed of the aggregate then-best bid and offer with size (top-of-book), all other bids and offers, with size (depth-of-book) for that NMS Stock and the identity of the Subscriber posting the bid and/or offer. Subscribers and sponsored access clients obtaining streaming direct Market Data feeds may take that data directly into their order or execution management systems. This Market Data remains available to Subscribers, sponsored access clients and third parties on the tZERO ATS, LLC restricted site until 7:59 p.m. ET the following trading day. Subscribers submit orders electronically to tZERO ATS, LLC through the Gateway. This FIX order information is collected, normalized, formatted and transmitted, through the use of software provided by FI, to the tZERO ATS, LLC website for posting and/or its restricted website GUI, as applicable. tZERO ATS also uses FI technology and software to transmit direct market data feeds to Subscribers from the ATS's Data Center in Equinix NY4. SpeedRoute does not receive Market Data feeds.

execution_services

Subscribers/sponsored access clients may enter orders beginning at 6:15 p.m. ET on the days that the ATS is open for business, and tZERO ATS begins matching orders, based on the terms of the orders in its order book, at 8:00 p.m. ET. tZERO ATS employs a 15% price band at the open of its trading session. If orders entered into the ATS prior to the beginning of trading and at the open are priced at more than 15% away from the reference price for that NMS Stock, the ATS will reject the order. The reference price for the open is the last national securities exchange print, post session, as of 7:50 p.m. ET. Orders are prioritized based on the price and time of entry of such orders into the ATS. Once an order has been submitted, the ATS matches it with a matching contra order submitted to the ATS, generally on a price/time priority basis. Similarly, the orders of a Subscriber/sponsored access client that has elected broker priority and that routes simultaneous buy and sell orders to the ATS are matched against each other, but only if there is not an order on the ATS order book at a better price. The orders of an ATS Subscriber/sponsored access client that has not elected broker priority and that routes simultaneous buy and sell orders to the ATS are matched against each other, but only if there is not an existing order on the ATS order book at the same or a better price. Because the ATS does not operate during Core Market Hours, it is not impacted by trading halts in an NMS Stock during Core Market Hours. If trading in an NMS Stock that trades on tZERO ATS is halted as of the close of the exchange trading day, the ATS does not trade that NMS Stock during its immediately following trading session. If trading in an NMS Stock is halted on tZERO ATS during the ATS's trading session, the ATS notifies its Subscribers of the halt (Subscribers must inform sponsored access clients of the halt). The ATS cancels all orders for the effected NMS Stock pending on the ATS's order book at the time the ATS halts trading. Such orders are automatically cancelled based on a configuration in Subscribers' FIX connections. Once the ATS lifts the halt, tZERO ATS sends a notification to Subscribers that trading is once again available on the ATS and that they may enter orders (Subscribers must provide this notification to sponsored access clients). Those orders will be matched based on the price/time priority rules of tZERO ATS, subject to broker priority, if applicable.

execution_services

Subscribers/sponsored access clients may enter orders beginning at 6:15 p.m. ET on the days that the ATS is open for business, and PRO ATS begins matching orders, based on the terms of the orders in its order book, at 8:00 p.m. ET. PRO ATS employs a 15% price band at the open of its trading session. If orders entered into the ATS prior to the beginning of trading and at the open are priced at more than 15% away from the reference price for that NMS Stock, the ATS will reject the order. The reference price for the open is the last national securities exchange print, post session, as of 7:50 p.m. ET. Orders are prioritized based on the price and time of entry of such orders into the ATS. Once an order has been submitted, the ATS matches it with a matching contra order submitted to the ATS, generally on a price/time priority basis. Similarly, the orders of a Subscriber/sponsored access client that has elected broker priority and that routes simultaneous buy and sell orders to the ATS are matched against each other, but only if there is not an order on the ATS order book at a better price. The orders of an ATS Subscriber/sponsored access client that has not elected broker priority and that routes simultaneous buy and sell orders to the ATS are matched against each other, but only if there is not an existing order on the ATS order book at the same or a better price. Because the ATS does not operate during Core Market Hours, it is not impacted by trading halts in an NMS Stock during Core Market Hours. If trading in an NMS Stock that trades on PRO ATS is halted as of the close of the exchange trading day, the ATS does not trade that NMS Stock during its immediately following trading session. If trading in an NMS Stock is halted on PRO ATS during the ATS's trading session, the ATS notifies its Subscribers of the halt (Subscribers must inform sponsored access clients of the halt). The ATS cancels all orders for the effected NMS Stock pending on the ATS's order book at the time the ATS halts trading. Such orders are automatically cancelled based on a configuration in Subscribers' FIX connections. Once the ATS lifts the halt, PRO ATS sends a notification to Subscribers that trading is once again available on the ATS and that they may enter orders (Subscribers must provide this notification to sponsored access clients). Those orders will be matched based on the price/time priority rules of PRO ATS, subject to broker priority, if applicable.