Fidelity ATS

amendment_reason

Part 1, Identifying Information, is amended to reflect the reordering of the Firm's ATS Matching Systems as part of a migration which moved entity Equinix to Primary and entity Cyxtera to Secondary. Additionally, Part 2 Item 4b is amended to remove Credit Suisse Securities as a subscriber. These amendments apply to all Subscribers and the Broker Dealer Operator.

amendment_reason

Part 2 Item 2, Affiliates Trading on the ATS, is amended to replace one affiliate name in light of a merger, and to remove two affiliate names that are no longer affiliates of the Broker Dealer Operator's ATS. Part 3 Item 20 is amended to change the Broker Dealer Operator's procedures around trading suspension for symbols approaching Fair Access thresholds. These amendments apply to all Subscribers and the Broker Dealer Operator.

amendment_reason

Part 2 Item 2, Affiliates Trading Activities on the ATS, is amended to reflect a name change of an Affiliate of Broker Dealer-Operator from Kezar Markets LLC to Level Markets LLC. This amendment applies to all Subscribers and the Broker Dealer Operator.

amendment_reason

Part 3 Item 19, Fees, is amended to document CAT and SEC Section 31 fee charges to Subscribers of the Firm's ATS. This amendment applies to all Subscribers and the Broker Dealer Operator.

amendment_reason

Update to contact information Part 2, Item 2: Addition of Green Pier Fintech and Fidelity Diversifying Solutions as affiliates (Change to Broker-Dealer Operator) Part 2, Item 6: Removal of shared employee access to Luminex infrastructure (Change to Broker-Dealer Operator) Part 3, Item 9: Change to length of time to firm up a conditional order (All subscribers)

amendment_reason

Amendments are made to Part 2 Item 5a, Part 3 Item 5d, Part 3 Item 7, Part 3 Item 9a, Part 3 Item 9b, Part 3 Item 11c, Part 3 Item 13a, Part 3 Item 13b, and Part 3 Item 14a to reflect changes to the Firm ATS's matching logic including updates to Continuous Cross matching logic and updates to tiering for the Conditional Cross and Continuous Cross that will go into effect in May 2025. These changes apply to all Subscribers and the Broker Dealer Operator.

amendment_reason

Part 2 Item 2 is amended to include new affiliates to the ATS. This amendment applies to all Subscribers and the Broker Dealer Operator.

amendment_reason

Amending Part II Item 6 and Part III Item 23 to reflect change in service provider from which market data is received. The changes apply to all subscribers and the Broker-Dealer Operator.

amendment_reason

An amendment is made to Part 2 Item 2 to remove Fidelity Personal and Workplace Advisors LLC as an affiliate to the Firm's ATS. This change applies to all Subscribers and the Broker Dealer Operator.

amendment_reason

Part I Item 6 update to Broker-Dealer website with link to Commission ATS-N Filings landing site. Part II Item 2 Affiliates Trading Activity on the ATS update to reflect that Fidelity Brokerage Services, LLC is a non-subscriber broker-dealer affiliate (previously listed as a subscriber), the addition of Digital Brokerage Services, LLC as a non-subscriber broker-dealer affiliate, and the additional of Fidelity Institutional Wealth Adviser LLC as an SEC registered investment advisor affiliate. Part III Item 26 Question answer changed from Yes to No and removed Exhibits 4 and 5. All changes relate only to the broker-dealer operator.

ats_name

CrossStream (the Continuous Cross), CrossStream BLOX (the Conditional Cross)

operator_crd

000013041

operator_name

NATIONAL FINANCIAL SERVICES LLC

order_types

Standard Cross Order Types. The Standard Cross supports three basic firm order types: (i) limit orders, (ii) market orders, and (iii) pegged orders, which includes unpriced pegged orders, pegged limit orders and pegged discretionary orders. Orders may also be designated as add liquidity only orders ("ALO Orders"). Orders may have a time-in-force of "day" or immediate-or-cancel ("IOC"). Pegged orders are derived limit orders pegged to the national best bid ("NBB"), national best offer ("NBO") or midpoint of the NBBO. A subscriber may designate an ultimate limit price for each pegged order. Pegged discretionary orders are pegged orders with an additional higher (buy) or lower (sell) price at which the order may be executed if the order cannot be executed with a contra side order at the pegged order's derived limit price (e.g., peg order to buy at the midpoint of the NBBO with discretion to the NBO). Pegged discretionary orders may only permit discretion to the NBB, NBO or midpoint of the NBBO. At no time will a peg or discretion instruction violate a client's ultimate limit price. ALO Orders may only add liquidity to the ATS and will not be matched with a contra-side order if the effect would be to remove liquidity from the ATS. ALO Orders may not cross with other orders during a locked market, even if adding liquidity. Where, upon receipt, an ALO order is marketable against trading interest on the ATS the ATS will accept the ALO order for further processing (e.g., potential matching). ALO Orders will remain in the system until cancelled or matched with a counterparty. Generally, for two given orders, the order received first will be deemed to be adding liquidity. Where orders have a discretionary instruction, activation of the discretionary price will be deemed to be removing liquidity regardless whether the order was received first or second. However, if both orders in a cross have their discretionary prices activated, then order receipt time again determines which order adds or removes liquidity. Orders that are derivatively priced will be treated as if cancelled and replaced for each price change and, accordingly, will vary from adding to removing liquidity without regard to whether such order was originally received first or second. A cancel replace will reset the order's time stamp. Conditional Cross Order Types. The Conditional Cross supports conditional, or "non-firm," orders ("Conditional Orders") and "Firm-Up Orders" submitted in response to proposed matches (as further discussed herein). Neither Conditional Orders nor Firm-Up Orders may be designated as ALO Orders. Conditional Orders and Firm-Up Orders may be designated as day or IOC. Additionally, subscribers may direct Conditional Orders and Firm-Up Orders to automatically cancel upon expiration of a time period specified by the ATS of one second or less ("Slow IOC Orders"). Conditional Orders and Firm-Up Orders must be pegged to the midpoint of the NBBO and may include an ultimate limit price. Subscribers may specify a minimum acceptable quantity ("MAQ") for orders submitted to the Conditional Cross. Display. The ATS does not display orders or trading interest entered into the Continuous Cross. In the Conditional Cross, where a Conditional Order is eligible to cross, whether with a Firm-Up Order or another Conditional Order, the ATS will systematically send a notice to the subscriber notifying it of the initial match (via FIX). Only direct Subscribers or the broker-dealer operator can receive invites messages. The invite message is a standard FIX execution report and contains the Client's Order ID, NFS Order ID, Leaves Quantity, Conditional Order Quantity, Conditional Order Limit Price, Side, Symbol, Invite Message Timestamp, Executing Broker, and a custom field indicating that the message is an invite message. There is no information pertaining to the counterparty or potential execution size. The subscriber will then have a system-determined time period of less than 1 second to "firm-up" by submitting a firm order, either manually or systematically, in response to the proposed match (such orders, "Firm-Up Orders"). No orders are eligible to route to other trading centers. Cancelling and replacing an order will result in a new time stamp. Standard Cross Order Interaction. The Standard Cross prioritizes orders based on the following factors, in the following order: (i) price and (ii) tier, (iii) size, (iv) time. Orders with the highest (buy) or lowest (sell) price have priority over lower (buy) or higher (sell) priced orders. When two or more orders, neither of which have price priority, may be executed at the same execution price, the subscriber with the higher tier will take priority. When neither order has price or tier priority, the larger order will be executed. And when neither order has price, tier, or size priority, the order which arrived earlier will take priority. Conditional Cross Order Interaction. The Conditional Cross prioritizes orders based on the following factors, in the following order: (i) price and (ii) order type, with Firm-Up Orders having priority over Conditional Orders. Amongst Firm-Up Orders on price parity, orders are prioritized based on the following factors, in the following order (a) tier, (b) size, and (c) time. Amongst Conditional Orders on price parity, orders are invited to firm-up based on the following factors, in the following order ("Invitation Logic"): (w) tier, (x) imbalance, (y) size and (z) time. Where two Firm-Up Orders are eligible to cross, the orders will be executed immediately at the midpoint of the NBBO. Where a Conditional Order is eligible to cross, whether with a Firm-Up Order or another Conditional Order, the ATS will send a notice to the subscriber notifying it of the initial match. The subscriber will then have a system-determined time period of less than 1 second to "firm-up" by submitting a firm order in response to the proposed match (such orders, "Firm-Up Orders"). The Firm-Up Order may include a different size, MAQ, time-in-force and/or ultimate limit price from the original Conditional Order. If each side of the proposed match, as relevant, submits a Firm-Up Order within the required time period, and provided that each side meets any specified MAQ associated with the contra-side order, the ATS will execute the orders at the midpoint of the NBBO at the time of execution (assuming the midpoint of the NBBO remains an eligible execution price). Orders entered into the Conditional Cross, including Firm-Up Orders, may only be executed against other orders in the Conditional Cross. Only Eligible Orders Matched. To the extent that any ATS order may not, by law, rule, regulation or the terms of the order, be crossed with another order, or may not be crossed at a particular price, then such orders will be ineligible for matching or the price adjusted to a permissible price. The ATS will apply the priorities detailed above with respect to eligible orders and prices only. In certain circumstances, orders may be ineligible to interact with certain other orders. The ATS will not execute any order outside the NBBO, except when the quotation being traded through is from an automated trading center to which the Firm has declared self-help. In each such instance, the ATS will disregard these quotations in determining the best bid or offer. The ATS accepts orders marked "short exempt" and may execute such orders at the NBB when a circuit breaker is in effect. Orders within the ATS are not eligible for routing to other Trading Centers.

order_types

Standard Cross Order Types. The Standard Cross supports three basic firm order types: (i) limit orders, (ii) market orders, and (iii) pegged orders, which includes unpriced pegged orders, pegged limit orders and pegged discretionary orders. Orders may also be designated as add liquidity only orders ("ALO Orders"). Orders may have a time-in-force of "day" or immediate-or-cancel ("IOC"). Pegged orders are derived limit orders pegged to the national best bid ("NBB"), national best offer ("NBO") or midpoint of the NBBO. A subscriber may designate an ultimate limit price for each pegged order. Pegged discretionary orders are pegged orders with an additional higher (buy) or lower (sell) price at which the order may be executed if the order cannot be executed with a contra side order at the pegged order's derived limit price (e.g., peg order to buy at the midpoint of the NBBO with discretion to the NBO). Pegged discretionary orders may only permit discretion to the NBB, NBO or midpoint of the NBBO. At no time will a peg or discretion instruction violate a client's ultimate limit price. ALO Orders may only add liquidity to the ATS and will not be matched with a contra-side order if the effect would be to remove liquidity from the ATS. ALO Orders may not cross with other orders during a locked market, even if adding liquidity. Where, upon receipt, an ALO order is marketable against trading interest on the ATS the ATS will accept the ALO order for further processing (e.g., potential matching). ALO Orders will remain in the system until cancelled or matched with a counterparty. Generally, for two given orders, the order received first will be deemed to be adding liquidity. Where orders have a discretionary instruction, activation of the discretionary price will be deemed to be removing liquidity regardless whether the order was received first or second. However, if both orders in a cross have their discretionary prices activated, then order receipt time again determines which order adds or removes liquidity. Orders that are derivatively priced will be treated as if cancelled and replaced for each price change and, accordingly, will vary from adding to removing liquidity without regard to whether such order was originally received first or second. A cancel replace will reset the order's time stamp. Conditional Cross Order Types. The Conditional Cross supports conditional, or "non-firm," orders ("Conditional Orders") and "Firm-Up Orders" submitted in response to proposed matches (as further discussed herein). Neither Conditional Orders nor Firm-Up Orders may be designated as ALO Orders. Conditional Orders and Firm-Up Orders may be designated as day or IOC. Additionally, subscribers may direct Conditional Orders and Firm-Up Orders to automatically cancel upon expiration of a time period specified by the ATS of one second or less ("Slow IOC Orders"). Conditional Orders and Firm-Up Orders must be pegged to the midpoint of the NBBO and may include an ultimate limit price. Subscribers may specify a minimum acceptable quantity ("MAQ") for orders submitted to the Conditional Cross. Display. The ATS does not display orders or trading interest entered into the Continuous Cross. In the Conditional Cross, where a Conditional Order is eligible to cross, whether with a Firm-Up Order or another Conditional Order, the ATS will systematically send a notice to the subscriber notifying it of the initial match (via FIX). Only direct Subscribers or the broker-dealer operator can receive invites messages. The invite message is a standard FIX execution report and contains the Client's Order ID, NFS Order ID, Leaves Quantity, Conditional Order Quantity, Conditional Order Limit Price, Side, Symbol, Invite Message Timestamp, Executing Broker, and a custom field indicating that the message is an invite message. There is no information pertaining to the counterparty or potential execution size. The subscriber will then have a system-determined time period of less than 1 second to "firm-up" by submitting a firm order, either manually or systematically, in response to the proposed match (such orders, "Firm-Up Orders"). No orders are eligible to route to other trading centers. Cancelling and replacing an order will result in a new time stamp. Standard Cross Order Interaction. The Standard Cross prioritizes orders based on the following factors, in the following order: (i) price and (ii) PWAP. Orders with the highest (buy) or lowest (sell) price have priority over lower (buy) or higher (sell) priced orders. When two or more orders, neither of which have price priority, may be executed at the same execution price, the order selected based on its PWAP has priority (see examples 2 through 3). An order's PWAP is a ranking provided by the ATS based on the percentage of shares to buy or sell that an order represents in a given security, at a given price. Upon receipt of an incoming order, the competing orders on the ATS are ranked, within the same price level, based on iterative, random selection. For example, if there were three buy orders in the ATS for a security at the same price level, order A with 5,000 shares, order B with 3,000 shares and order C with 2,000 shares, the probability that order A is selected first (and assigned priority at that price) is 50% (5,000 shares / total 10,000 shares at that price). The probabilities that orders B or C are selected first are 30% and 20%, respectively. If order A is selected first, the probabilities that orders B or C are selected second are 60% (3,000 shares / remaining 5,000 shares) and 40%, respectively. If order B is selected first, the probabilities that order A or C are selected second are 71% (5,000 shares / remaining 7,000 shares) and 29%, respectively. Please see examples 2 and 3. Example 1: NBBO is $20.00 x $20.05. ATS receives limit order to buy 1,000 shares at $20.01. ATS receives limit order to buy 5,000 shares at $20.00. ATS receives limit order to sell 500 shares at $20.00. First buy limit order has limit price priority and receives fill of 500 shares at $20.01. Example 2: NBBO is $20.00 x $20.05. ATS receives limit order A to buy 1,000 shares at $20.05. ATS receives limit order B to buy 5,000 shares at $20.05. ATS receives limit order to sell 500 shares at $20.05. Each buy order will be assigned a PWAP. Order A will have a 17% (1,000 shares / total shares of 6,000) chance of being randomly selected by the ATS and order B will have an 83% (5,000 shares / total shares of 6,000) chance of being randomly selected by the ATS. If order A is matched with the incoming order, order A will buy 500 shares. The remaining shares of orders A and B will be assigned a new PWAP to determine priority for any subsequent executions. Example 3: NBBO is $20.00 x $20.05. ATS receives limit order to buy 1,000 shares at $20.05 (Order A). ATS receives limit order to buy 5,000 shares at $20.05 (Order B). ATS receives limit order to sell 500 shares at $20.05. Each buy order will be assigned a PWAP: Order A will have a 17% (1,000 shares / Total shares of 6,000) chance of being randomly selected by the ATS and Order B will have an 83% (5,000 shares / Total shares of 6,000) chance of being randomly selected by the ATS. Order B is matched with the sell order. ATS then receives limit order to sell 300 shares at $20.04. Each buy order will be assigned a PWAP. Order A will have an 18% (1,000 shares / total shares of 5,500) chance of being randomly selected by the ATS and Order B will have an 82% (4,500 shares / total shares of 5,500) chance of being randomly selected by the ATS. The ATS will match the sell order with whichever buy order has higher priority based on its PWAP. The remaining shares of orders A and B will be reassigned PWAPs. Where two orders may be matched, the order deemed to be removing liquidity will, subject to the terms of the orders and any applicable laws, rules or regulations, receive all available price improvement. Example 4: NBBO is $20.00 x $20.05. ATS receives a day order with market pricing to buy. ATS then receives a day order with market pricing to sell. Orders are executed at $20.05. Example 5: NBBO is $20.00 x $20.05. ATS receives a day order with market pricing to buy. ATS then receives a day order with limit pricing to sell at $20.02. Orders are executed at $20.05. Example 6: NBBO is $20.00 x $20.05. ATS receives limit order to buy at $20.03. ATS then receives limit order to sell at $20.01. Orders are executed at $20.03. Example 7: NBBO is $20.00 x $20.05. ATS receives a buy order pegged to the NBB, with discretion to the midpoint of the NBBO. ATS then receives a sell order pegged to midpoint of the NBBO. Orders are executed at $20.025. Example 8: NBBO is $20.00 x $20.05. ATS receives a buy order pegged to the midpoint of the NBBO. ATS then receives a sell order pegged to the NBO, with discretion to the midpoint of the NBBO. Orders are executed at $20.025. Conditional Cross Order Interaction. The Conditional Cross prioritizes orders based on the following factors, in the following order: (i) price and (ii) order type, with Firm-Up Orders having priority over Conditional Orders. Amongst Firm-Up Orders on price parity, orders are prioritized based on the following factors, in the following order (a) tier, (b) size, and (c) time. Amongst Conditional Orders on price parity, orders are invited to firm-up based on the following factors, in the following order ("Invitation Logic"): (w) tier, (x) imbalance, (y) size and (z) time. Where two Firm-Up Orders are eligible to cross, the orders will be executed immediately at the midpoint of the NBBO. Where a Conditional Order is eligible to cross, whether with a Firm-Up Order or another Conditional Order, the ATS will send a notice to the subscriber notifying it of the initial match. The subscriber will then have a system-determined time period of less than 1 second to "firm-up" by submitting a firm order in response to the proposed match (such orders, "Firm-Up Orders"). The Firm-Up Order may include a different size, MAQ, time-in-force and/or ultimate limit price from the original Conditional Order. If each side of the proposed match, as relevant, submits a Firm-Up Order within the required time period, and provided that each side meets any specified MAQ associated with the contra-side order, the ATS will execute the orders at the midpoint of the NBBO at the time of execution (assuming the midpoint of the NBBO remains an eligible execution price). Orders entered into the Conditional Cross, including Firm-Up Orders, may only be executed against other orders in the Conditional Cross. Only Eligible Orders Matched. To the extent that any ATS order may not, by law, rule, regulation or the terms of the order, be crossed with another order, or may not be crossed at a particular price, then such orders will be ineligible for matching or the price adjusted to a permissible price. The ATS will apply the priorities detailed above with respect to eligible orders and prices only. In certain circumstances, orders may be ineligible to interact with certain other orders. The ATS will not execute any order outside the NBBO, except when the quotation being traded through is from an automated trading center to which the Firm has declared self-help. In each such instance, the ATS will disregard these quotations in determining the best bid or offer. The ATS accepts orders marked "short exempt" and may execute such orders at the NBB when a circuit breaker is in effect. Orders within the ATS are not eligible for routing to other Trading Centers.

means_of_entry

Subscribers may directly access the ATS via Financial Information eXchange ("FIX") protocol. The ATS operator supports FIX version 4.2. All other means of entry ultimately access the ATS via FIX connection as well, albeit through another electronic trading product (described in Part II, Item 5a). While the firm does not offer any co-location services, the data center provider used by the ATS does offer such services and subscribers who have a point-of-presence in the same data center may cross-connect through the data center provider.

pricing_methodology

The ATS uses the "SIP" consolidated quote to determine the NBBO. The market data is received though Activ Financial. The "SIP" is used to price, prioritize, and execute, all orders and trading interest (e.g. pegged orders are priced using the SIP).

pricing_methodology

The ATS uses the "SIP" consolidated quote to determine the NBBO. The "SIP" is used to price, prioritize, and execute, all orders and trading interest (e.g. pegged orders are priced using the SIP).

counterparty_selection

Counterparty Permissioning. A subscriber may elect that its orders not interact with other orders entered by the subscriber. Additionally, a subscriber may elect that a subset of its orders not interact with other orders entered by the subscriber. Additionally, on an order-by-order or categorical basis, a subscriber may opt to interact only with, or to not interact with, orders from certain other subscribers or types of subscribers (each a "Counterparty Group"). The Firm provides certain default Counterparty Groups ("Default Counterparty Groups"), including: - Orders submitted to the ATS only by NFS' primary automated routing system, FBSI (or any successor system) ("Channel SOR Orders"). - Orders marked as agent submitted by non-NFS broker-dealers who are subscribers to the system ("Broker-Dealer Agency"). - Orders marked as principal submitted by non-NFS broker-dealers who are subscribers to the system ("Broker-Dealer Principal"). - NFS orders marked as agency ("NFS Agency"). - NFS orders marked as principal ("NFS Principal"). The ATS utilizes a subscriber's Default Counterparty Group designation when tiering order interest. The tiers, in order of priority, are as follows: (i) NFS Agency and Channel SOR Orders (first priority, shared priority); (ii) Broker-Dealer Agency; and (iii) NFS Principal and Broker-Dealer Principal (shared priority). A subscriber may request that its order(s) not interact with, or interact only with, a custom-designed Counterparty Group ("Custom Counterparty Group"), based on characteristics of the subscriber (e.g., broker-dealer subscribers (registered or foreign)), money managers that manage in excess of a given sum of assets or report a portfolio turnover of less than or more than a given percentage) or whose ATS orders or executions meet one or more specified criteria supported by NFS, including without limitation, subscribers whose: (i) average ATS order size is less than (or more than) 1,000 shares, (ii) average ATS orders are for a size less than (or more than) the size of the inside bid or offer with a given frequency; (iii) average ATS contra-party price improvement is more than (or less than) a given amount per share or (iv) average ATS execution is less than (or more than) a given price below (above) the midpoint at a given interval following execution, or (v) responses to requests to "firm-up" meet certain metrics, such as (a) frequency of responses, (b) latency of responses, (c) sizes of orders sent in response to requests to firm up or (d) average price changes following firm-ups or declines. In all such cases, a subscribers' ability to utilize a proposed Custom Counterparty Group is dependent on the Firm's willingness and ability to support such a proposed Custom Counterparty Group. Both direct and indirect subscribers are eligible to be considered for counterparty permissioning. NFS considers factors such as but not limited to a subscriber's business type and observed trading behavior and may not make available to certain subscribers, or limit the configuration of, the counterparty permissioning.

counterparty_selection

Counterparty Permissioning. A subscriber may elect that its orders not interact with other orders entered by the subscriber. Additionally, a subscriber may elect that a subset of its orders not interact with other orders entered by the subscriber. Additionally, on an order-by-order or categorical basis, a subscriber may opt to interact only with, or to not interact with, orders from certain other subscribers or types of subscribers (each a "Counterparty Group"). The Firm provides certain default Counterparty Groups ("Default Counterparty Groups"), including: - Orders submitted to the ATS only by NFS' primary automated routing system, FBSI (or any successor system) ("Channel SOR Orders"). - Orders submitted by non-NFS broker-dealers who are subscribers to the system (includes orders marked as "agent" or "principal") ("Broker-Dealer Subscribers"). - NFS orders marked as agency ("NFS Agency"). - NFS orders marked as principal ("NFS Principal"). A subscriber's inclusion in a Default Counterparty Group does not impact priority of trading interest in the Standard Cross. However, the Conditional Cross utilizes a subscriber's Default Counterparty Group designation when tiering order interest. The Conditional Cross' tiers, in order of priority, are as follows: (i) NFS Agency and Channel SOR Orders (first priority, shared); (ii) Broker-Dealer Subscriber; and (iii) NFS Principal. A subscriber may request that its order(s) not interact with, or interact only with, a custom-designed Counterparty Group ("Custom Counterparty Group"), based on characteristics of the subscriber (e.g., broker-dealer subscribers (registered or foreign)), money managers that manage in excess of a given sum of assets or report a portfolio turnover of less than or more than a given percentage) or whose ATS orders or executions meet one or more specified criteria supported by NFS, including without limitation, subscribers whose: (i) average ATS order size is less than (or more than) 1,000 shares, (ii) average ATS orders are for a size less than (or more than) the size of the inside bid or offer with a given frequency; (iii) average ATS contra-party price improvement is more than (or less than) a given amount per share or (iv) average ATS execution is less than (or more than) a given price below (above) the midpoint at a given interval following execution, or (v) responses to requests to "firm-up" meet certain metrics, such as (a) frequency of responses, (b) latency of responses, (c) sizes of orders sent in response to requests to firm up or (d) average price changes following firm-ups or declines. In all such cases, a subscribers' ability to utilize a proposed Custom Counterparty Group is dependent on the Firm's willingness and ability to support such a proposed Custom Counterparty Group. Both direct and indirect subscribers are eligible to be considered for counterparty permissioning. NFS considers factors such as but not limited to a subscriber's business type and observed trading behavior and may not make available to certain subscribers, or limit the configuration of, the counterparty permissioning.

financial_condition_summary

The ATS charges no connectivity fee. The ATS may pass through the connectivity costs, with no additional mark-up, to a subscriber from the subscriber's service provider if the subscriber's order flow does not meet a minimum revenue target. The ATS generally charges per-share ATS fees. The ATS fees are separately negotiated with each individual subscriber and may vary. ATS fees can range from $0.00 to $0.01. In some cases factors such as but not limited to those listed below may affect negotiated ATS fees: i. The use of ATS features (e.g. Conditional Session); ii. Volume Executed in ATS (e.g. a high volume subscriber may be charged a lower fee than a low volume subscriber); iii. Business type of the subscriber (e.g. Broker-Dealer subscriber may be charged lower fee than an institutional subscriber); iv. Overall relationship with the subscriber (e.g. bilateral rate may be negotiated if the subscriber operates an ATS). NFS is assessed certain Consolidated Audit Trail (CAT) regulatory fees relating to trading on the CrossStream ATS as an execution venue. NFS, as the broker-dealer operator of the CrossStream ATS, is the CAT executing broker on both buyside and sellside transactions on the CrossStream ATS and is assessed a CAT fee as such. NFS does not pass through these CAT fees to subscribers. In addition to fees described above, NFS will pass through SEC Section 31 fees it is assessed to direct broker-dealer subscribers.

financial_condition_summary

The ATS charges no connectivity fee. The ATS may pass through the connectivity costs, with no additional mark-up, to a subscriber from the subscriber's service provider if the subscriber's order flow does not meet a minimum revenue target. The ATS generally charges per-share ATS fees. The ATS fees are separately negotiated with each individual subscriber and may vary. ATS fees can range from $0.00 to $0.01. In some cases factors such as but not limited to those listed below may affect negotiated ATS fees: i. The use of ATS features (e.g. Conditional Session); ii. Volume Executed in ATS (e.g. a high volume subscriber may be charged a lower fee than a low volume subscriber); iii. Business type of the subscriber (e.g. Broker-Dealer subscriber may be charged lower fee than an institutional subscriber); iv. Overall relationship with the subscriber (e.g. bilateral rate may be negotiated if the subscriber operates an ATS).

conflict_description

The following Affiliates are subscribers of the ATS (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Clearing Canada ULC (FIDT & FCCU, Agency, Canadian entity engaged in broker-dealer activities); (ii) FMR Co., Inc (N/A, Agency, Investment advisor registered with the SEC); and (iii) Fidelity Management and Research Company (N/A, Agency, Investment advisor registered with the SEC). Affiliate orders routed to the ATS via Fidelity Capital Markets would reflect an MPID of NFSC. The following Affiliates may access the ATS indirectly by routing trading interest through other ATS subscribers, including the Affiliate-subscribers listed above (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Personal and Workplace Advisors LLC (N/A, Agency, Investment advisor registered with the SEC); (ii) Luminex Trading & Analytics LLC (LMNX), Agency & Principal, Broker-dealer registered with the SEC); (iii) Impresa Management (Agency, Investment advisor registered with the SEC); (iv) Fidelity Personal Trust Company (Agency, Domestic trust company); (v) Fidelity SelectCo, LLC (Agency, Investment advisor registered with the SEC); (vi) Fidelity Management & Research (Japan) Limited (Agency, Investment advisor registered with the SEC); (vii) Fidelity Management & Research (Hong Kong) Limited (Agency, Investment advisor registered with the SEC); (viii) Fidelity (Canada) Asset Management ULC (Agency, Canadian entity engaged in investment advisory activities); (ix) Fidelity Institutional Asset Management Trust Company (Agency, Domestic trust company); (x) FIAM LLC (Agency, Investment advisor registered with the SEC); (xi) Ballyrock Investment Advisors LLC (Agency, Investment advisor registered with the SEC); (xii) Fidelity Global Brokerage Group, Inc. (Domestic entity engaged in securities activities); (xiii) Fidelity Investments Canada, ULC (Agency, Canadian entity engaged in investment advisory activities.); (xiv) Fidelity Management Trust Company (Agency, Domestic Trust Company);(xv) Fidelity Distributors Corporation (Agency, Investment advisor registered with the SEC); (xvi) Fidelity Investments Money Management, Inc. (Agency, Investment advisor registered with the SEC); (xvii) FMR Investment Management (UK) Limited (Agency, Investment advisor registered with the SEC); (xviii) Strategic Advisers LLC (Agency, Investment advisor registered with the SEC); (xix) Fidelity Investments Institutional Services Company, Inc. (Agency, Investment advisor registered with the SEC); (xx) Fidelity Institutional Wealth Adviser LLC (Agency, Investment advisor registered with the SEC); (xxi) Fidelity Brokerage Services LLC (FIBS, Agency, Broker-dealer registered with the SEC); and (xxii) Digital Brokerage Services LLC (DIBS, Agency, Broker-dealer registered with the SEC). Affiliate orders routed to the ATS via another Subscriber would reflect the MPID of that Subscriber.

conflict_description

The following Affiliates are subscribers of the ATS (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Clearing Canada ULC (FIDT & FCCU, Agency, Canadian entity engaged in broker-dealer activities); (ii) FMR Co., Inc (N/A, Agency, Investment advisor registered with the SEC); and (iii) Fidelity Management and Research Company (N/A, Agency, Investment advisor registered with the SEC). Affiliate orders routed to the ATS via Fidelity Capital Markets would reflect an MPID of NFSC. The following Affiliates may access the ATS indirectly by routing trading interest through other ATS subscribers, including the Affiliate-subscribers listed above (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Personal and Workplace Advisors LLC (N/A, Agency, Investment advisor registered with the SEC); (ii) Kezar Markets LLC (Agency & Principal, Broker-dealer registered with the SEC); (iii) Impresa Management (Agency, Investment advisor registered with the SEC); (iv) Fidelity Personal Trust Company (Agency, Domestic trust company); (v) Fidelity Management & Research (Japan) Limited (Agency, Investment advisor registered with the SEC); (vi) Fidelity Management & Research (Hong Kong) Limited (Agency, Investment advisor registered with the SEC); (vii) Fidelity (Canada) Asset Management ULC (Agency, Canadian entity engaged in investment advisory activities); (viii) Fidelity Institutional Asset Management Trust Company (Agency, Domestic trust company); (ix) FIAM LLC (Agency, Investment advisor registered with the SEC); (x) Ballyrock Investment Advisors LLC (Agency, Investment advisor registered with the SEC); (xi) Fidelity Global Brokerage Group, Inc. (Domestic entity engaged in securities activities); (xii) Fidelity Investments Canada, ULC (Agency, Canadian entity engaged in investment advisory activities.); (xiii) Fidelity Management Trust Company (Agency, Domestic Trust Company);(xiv) Fidelity Distributors Corporation (Agency, Investment advisor registered with the SEC); (xv) FMR Investment Management (UK) Limited (Agency, Investment advisor registered with the SEC); (xvi) Strategic Advisers LLC (Agency, Investment advisor registered with the SEC); (xvii) Fidelity Investments Institutional Services Company, Inc. (Agency, Investment advisor registered with the SEC); (xviii) Fidelity Institutional Wealth Adviser LLC (Agency, Investment advisor registered with the SEC); (xix) Fidelity Brokerage Services LLC (FIBS, Agency, Broker-dealer registered with the SEC); and (xx) Digital Brokerage Services LLC (DIBS, Agency, Broker-dealer registered with the SEC). (xxi) Green Pier Fintech LLC, (PIER) (Agency, Broker-Dealer registered with the SEC); (xxii) Fidelity Diversifying Solutions LLC (Agency, Investment Advisor registered with the SEC). Affiliate orders routed to the ATS via another Subscriber would reflect the MPID of that Subscriber.

conflict_description

The following Affiliates are subscribers of the ATS (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Clearing Canada ULC (FIDT & FCCU, Agency, Canadian entity engaged in broker-dealer activities); (ii) FMR Co., Inc (N/A, Agency, Investment advisor registered with the SEC); and (iii) Fidelity Management and Research Company (N/A, Agency, Investment advisor registered with the SEC). Affiliate orders routed to the ATS via Fidelity Capital Markets would reflect an MPID of NFSC. The following Affiliates may access the ATS indirectly by routing trading interest through other ATS subscribers, including the Affiliate-subscribers listed above (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Level Markets LLC (Agency & Principal, Broker-dealer registered with the SEC); (ii) Impresa Management (Agency, Investment advisor registered with the SEC); (iii) Fidelity Personal Trust Company (Agency, Domestic trust company); (iv) Fidelity Management & Research (Japan) Limited (Agency, Investment advisor registered with the SEC); (v) Fidelity Management & Research (Hong Kong) Limited (Agency, Investment advisor registered with the SEC); (vi) Fidelity (Canada) Asset Management ULC (Agency, Canadian entity engaged in investment advisory activities); (vii) Fidelity Institutional Asset Management Trust Company (Agency, Domestic trust company); (viii) FIAM LLC (Agency, Investment advisor registered with the SEC); (ix) Ballyrock Investment Advisors LLC (Agency, Investment advisor registered with the SEC); (x) Fidelity Global Brokerage Group, Inc. (Domestic entity engaged in securities activities); (xi) Fidelity Investments Canada, ULC (Agency, Canadian entity engaged in investment advisory activities.); (xii) Fidelity Management Trust Company (Agency, Domestic Trust Company);(xiii) Fidelity Distributors Corporation (Agency, Investment advisor registered with the SEC); (xiv) FMR Investment Management (UK) Limited (Agency, Investment advisor registered with the SEC); (xv) Strategic Advisers LLC (Agency, Investment advisor registered with the SEC); (xvi) Fidelity Investments Institutional Services Company, Inc. (Agency, Investment advisor registered with the SEC); (xvii) Fidelity Institutional Wealth Adviser LLC (Agency, Investment advisor registered with the SEC); (xviii) Fidelity Brokerage Services LLC (FIBS, Agency, Broker-dealer registered with the SEC); and (xix) Digital Brokerage Services LLC (DIBS, Agency, Broker-dealer registered with the SEC); (xx) Green Pier Fintech LLC, (PIER) (Agency, Broker-Dealer registered with the SEC); (xxi) Fidelity Diversifying Solutions LLC (Agency, Investment Advisor registered with the SEC); (xxii) Fidelity Venture Capital Fund I GP LLC (Agency, Domestic General Partner of Venture Capital Funds), (xxiii) F-Prime HiLabs LLC (Agency, Venture Capital Fund). Affiliate orders routed to the ATS via another Subscriber would reflect the MPID of that Subscriber.

conflict_description

The following Affiliates are subscribers of the ATS (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Clearing Canada ULC (FIDT & FCCU, Agency, Canadian entity engaged in broker-dealer activities); (ii) FMR Co., Inc (N/A, Agency, Investment advisor registered with the SEC); (iii) Fidelity Management and Research Company (N/A, Agency, Investment advisor registered with the SEC); and (iv) Fidelity Brokerage Services LLC (FIBS, Agency, Broker-dealer registered with the SEC). Affiliate orders routed to the ATS via Fidelity Capital Markets would reflect an MPID of NFSC. The following Affiliates may access the ATS indirectly by routing trading interest through other ATS subscribers, including the Affiliate-subscribers listed above (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Personal and Workplace Advisors LLC (N/A, Agency, Investment advisor registered with the SEC); (ii) Luminex Trading & Analytics LLC (LMNX), Agency & Principal, Broker-dealer registered with the SEC); (iii) Impresa Management (Agency, Investment advisor registered with the SEC); (iv) Fidelity Personal Trust Company (Agency, Domestic trust company); (v) Fidelity SelectCo, LLC (Agency, Investment advisor registered with the SEC); (vi) Fidelity Management & Research (Japan) Limited (Agency, Investment advisor registered with the SEC); (vii) Fidelity Management & Research (Hong Kong) Limited (Agency, Investment advisor registered with the SEC); (viii) Fidelity (Canada) Asset Management ULC (Agency, Canadian entity engaged in investment advisory activities); (ix) Fidelity Institutional Asset Management Trust Company (Agency, Domestic trust company); (x) FIAM LLC (Agency, Investment advisor registered with the SEC); (xi) Ballyrock Investment Advisors LLC (Agency, Investment advisor registered with the SEC); (xii) Fidelity Global Brokerage Group, Inc. (Domestic entity engaged in securities activities); (xiii) Fidelity Investments Canada, ULC (Agency, Canadian entity engaged in investment advisory activities.); (xiv) Fidelity Management Trust Company (Agency, Domestic Trust Company);(xv) Fidelity Distributors Corporation (Agency, Investment advisor registered with the SEC); (xvi) Fidelity Investments Money Management, Inc. (Agency, Investment advisor registered with the SEC); (xvii) FMR Investment Management (UK) Limited (Agency, Investment advisor registered with the SEC); (xviii) Strategic Advisers LLC (Agency, Investment advisor registered with the SEC); and (xix) Fidelity Investments Institutional Services Company, Inc. (Agency, Investment advisor registered with the SEC). Affiliate orders routed to the ATS via another Subscriber would reflect the MPID of that Subscriber.

conflict_description

The following Affiliates are subscribers of the ATS (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Clearing Canada ULC (FIDT & FCCU, Agency, Canadian entity engaged in broker-dealer activities); (ii) FMR Co., Inc (N/A, Agency, Investment advisor registered with the SEC); and (iii) Fidelity Management and Research Company (N/A, Agency, Investment advisor registered with the SEC). Affiliate orders routed to the ATS via Fidelity Capital Markets would reflect an MPID of NFSC. The following Affiliates may access the ATS indirectly by routing trading interest through other ATS subscribers, including the Affiliate-subscribers listed above (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Kezar Markets LLC (Agency & Principal, Broker-dealer registered with the SEC); (ii) Impresa Management (Agency, Investment advisor registered with the SEC); (iii) Fidelity Personal Trust Company (Agency, Domestic trust company); (iv) Fidelity Management & Research (Japan) Limited (Agency, Investment advisor registered with the SEC); (v) Fidelity Management & Research (Hong Kong) Limited (Agency, Investment advisor registered with the SEC); (vi) Fidelity (Canada) Asset Management ULC (Agency, Canadian entity engaged in investment advisory activities); (vii) Fidelity Institutional Asset Management Trust Company (Agency, Domestic trust company); (viii) FIAM LLC (Agency, Investment advisor registered with the SEC); (ix) Ballyrock Investment Advisors LLC (Agency, Investment advisor registered with the SEC); (x) Fidelity Global Brokerage Group, Inc. (Domestic entity engaged in securities activities); (xi) Fidelity Investments Canada, ULC (Agency, Canadian entity engaged in investment advisory activities.); (xii) Fidelity Management Trust Company (Agency, Domestic Trust Company);(xiii) Fidelity Distributors Corporation (Agency, Investment advisor registered with the SEC); (xiv) FMR Investment Management (UK) Limited (Agency, Investment advisor registered with the SEC); (xv) Strategic Advisers LLC (Agency, Investment advisor registered with the SEC); (xvi) Fidelity Investments Institutional Services Company, Inc. (Agency, Investment advisor registered with the SEC); (xvii) Fidelity Institutional Wealth Adviser LLC (Agency, Investment advisor registered with the SEC); (xviii) Fidelity Brokerage Services LLC (FIBS, Agency, Broker-dealer registered with the SEC); and (xix) Digital Brokerage Services LLC (DIBS, Agency, Broker-dealer registered with the SEC); (xx) Green Pier Fintech LLC, (PIER) (Agency, Broker-Dealer registered with the SEC); (xxi) Fidelity Diversifying Solutions LLC (Agency, Investment Advisor registered with the SEC); (xxii) Fidelity Venture Capital Fund I GP LLC (Agency, Domestic General Partner of Venture Capital Funds), (xxiii) F-Prime HiLabs LLC (Agency, Venture Capital Fund). Affiliate orders routed to the ATS via another Subscriber would reflect the MPID of that Subscriber.

conflict_description

The following Affiliates are subscribers of the ATS (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Clearing Canada ULC (FIDT & FCCU, Agency, Canadian entity engaged in broker-dealer activities); (ii) FMR Co., Inc (N/A, Agency, Investment advisor registered with the SEC); and (iii) Fidelity Management and Research Company (N/A, Agency, Investment advisor registered with the SEC). Affiliate orders routed to the ATS via Fidelity Capital Markets would reflect an MPID of NFSC. The following Affiliates may access the ATS indirectly by routing trading interest through other ATS subscribers, including the Affiliate-subscribers listed above (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Personal and Workplace Advisors LLC (N/A, Agency, Investment advisor registered with the SEC); (ii) Luminex Trading & Analytics LLC (LMNX), Agency & Principal, Broker-dealer registered with the SEC); (iii) Impresa Management (Agency, Investment advisor registered with the SEC); (iv) Fidelity Personal Trust Company (Agency, Domestic trust company); (v) Fidelity SelectCo, LLC (Agency, Investment advisor registered with the SEC); (vi) Fidelity Management & Research (Japan) Limited (Agency, Investment advisor registered with the SEC); (vii) Fidelity Management & Research (Hong Kong) Limited (Agency, Investment advisor registered with the SEC); (viii) Fidelity (Canada) Asset Management ULC (Agency, Canadian entity engaged in investment advisory activities); (ix) Fidelity Institutional Asset Management Trust Company (Agency, Domestic trust company); (x) FIAM LLC (Agency, Investment advisor registered with the SEC); (xi) Ballyrock Investment Advisors LLC (Agency, Investment advisor registered with the SEC); (xii) Fidelity Global Brokerage Group, Inc. (Domestic entity engaged in securities activities); (xiii) Fidelity Investments Canada, ULC (Agency, Canadian entity engaged in investment advisory activities.); (xiv) Fidelity Management Trust Company (Agency, Domestic Trust Company);(xv) Fidelity Distributors Corporation (Agency, Investment advisor registered with the SEC); (xvi) Fidelity Investments Money Management, Inc. (Agency, Investment advisor registered with the SEC); (xvii) FMR Investment Management (UK) Limited (Agency, Investment advisor registered with the SEC); (xviii) Strategic Advisers LLC (Agency, Investment advisor registered with the SEC); (xix) Fidelity Investments Institutional Services Company, Inc. (Agency, Investment advisor registered with the SEC); (xx) Fidelity Institutional Wealth Adviser LLC (Agency, Investment advisor registered with the SEC); (xxi) Fidelity Brokerage Services LLC (FIBS, Agency, Broker-dealer registered with the SEC); and (xxii) Digital Brokerage Services LLC (DIBS, Agency, Broker-dealer registered with the SEC). (xxiii) Green Pier Fintech LLC, (PIER) (Agency, Broker-Dealer registered with the SEC); (xxiv) Fidelity Diversifying Solutions LLC (Agency, Investment Advisor registered with the SEC). Affiliate orders routed to the ATS via another Subscriber would reflect the MPID of that Subscriber.

conflict_description

The following Affiliates are subscribers of the ATS (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Clearing Canada ULC (FIDT & FCCU, Agency, Canadian entity engaged in broker-dealer activities); (ii) FMR Co., Inc (N/A, Agency, Investment advisor registered with the SEC); and (iii) Fidelity Management and Research Company (N/A, Agency, Investment advisor registered with the SEC). Affiliate orders routed to the ATS via Fidelity Capital Markets would reflect an MPID of NFSC. The following Affiliates may access the ATS indirectly by routing trading interest through other ATS subscribers, including the Affiliate-subscribers listed above (parentheticals following each name lists the Affiliate' MPID(s), capacity and description): (i) Fidelity Personal and Workplace Advisors LLC (N/A, Agency, Investment advisor registered with the SEC); (ii) Kezar Markets LLC (Agency & Principal, Broker-dealer registered with the SEC); (iii) Impresa Management (Agency, Investment advisor registered with the SEC); (iv) Fidelity Personal Trust Company (Agency, Domestic trust company); (v) Fidelity Management & Research (Japan) Limited (Agency, Investment advisor registered with the SEC); (vi) Fidelity Management & Research (Hong Kong) Limited (Agency, Investment advisor registered with the SEC); (vii) Fidelity (Canada) Asset Management ULC (Agency, Canadian entity engaged in investment advisory activities); (viii) Fidelity Institutional Asset Management Trust Company (Agency, Domestic trust company); (ix) FIAM LLC (Agency, Investment advisor registered with the SEC); (x) Ballyrock Investment Advisors LLC (Agency, Investment advisor registered with the SEC); (xi) Fidelity Global Brokerage Group, Inc. (Domestic entity engaged in securities activities); (xii) Fidelity Investments Canada, ULC (Agency, Canadian entity engaged in investment advisory activities.); (xiii) Fidelity Management Trust Company (Agency, Domestic Trust Company);(xiv) Fidelity Distributors Corporation (Agency, Investment advisor registered with the SEC); (xv) FMR Investment Management (UK) Limited (Agency, Investment advisor registered with the SEC); (xvi) Strategic Advisers LLC (Agency, Investment advisor registered with the SEC); (xvii) Fidelity Investments Institutional Services Company, Inc. (Agency, Investment advisor registered with the SEC); (xviii) Fidelity Institutional Wealth Adviser LLC (Agency, Investment advisor registered with the SEC); (xix) Fidelity Brokerage Services LLC (FIBS, Agency, Broker-dealer registered with the SEC); and (xx) Digital Brokerage Services LLC (DIBS, Agency, Broker-dealer registered with the SEC); (xxi) Green Pier Fintech LLC, (PIER) (Agency, Broker-Dealer registered with the SEC); (xxii) Fidelity Diversifying Solutions LLC (Agency, Investment Advisor registered with the SEC); (xxiii) Fidelity Venture Capital Fund I GP LLC (Agency, Domestic General Partner of Venture Capital Funds), (xxiv) F-Prime HiLabs LLC (Agency, Venture Capital Fund). Affiliate orders routed to the ATS via another Subscriber would reflect the MPID of that Subscriber.

compliance_officer

In General. Access to subscriber confidential trading information is only granted to employees directly involved in ongoing ATS operations (product, technology, reporting, client coverage, etc.). For a complete list of employee groups that may have access to confidential trading information please see Part II Item 7d. Any access request to the ATS system or related system that would contain confidential trading information is reviewed by line supervisor and product or database owner to determine whether the employee requires access to the specified system. In addition, access to the relevant systems is reviewed twice a year by NFS management, as well as following certain employee role changes, and may be adjusted as needed. NFS has also implemented controls to ensure that certain actions, transactions and/or critical business functions that support NFS' proprietary information assets and resources are traceable to an individual user or account. The System. The ATS is operated independently from NFS's other electronic trading products (e.g. algorithms, smart order router). Firm policy prohibits unauthorized access or use of subscriber confidential trading information. Access to subscriber confidential trading information is only granted to employees directly involved in ongoing ATS operations (product, technology, reporting, etc.). Any subscriber confidential trading information accessed by employees is used only to support ATS operations. NFS maintains a system of procedures, including individual access control requests, periodic reviews of existing system access, employee trading surveillance to prevent the unauthorized access of subscriber confidential trading information and to surveil the use of such information by NFS personnel authorized to access such information. Participants access the ATS through point-to-point network cross connects, managed private networks, or over secure Internet connections. Data in transit over the Internet is encrypted. In addition, the ATS employs firewalls to isolate the ATS systems from the Internet. ATS systems are also kept current with the latest released patches to help keep the systems secure. The ATS identifies cybersecurity risk using a company-wide approach that starts with understanding the business risks and then clearly identifying the assets, systems, and capabilities we protect, and the parties dedicated to protecting them. We focus on the following areas: Asset Management (i.e. data, personnel, devices, systems and facilities), Business Environment, Governance, Risk Assessment, and Risk Management Strategy. The extensive controls and risk management programs we have in place are aligned to the cybersecurity framework established by the National Institute of Technology and Standards (NIST). The framework is Identify, Protect, Detect, Respond, and Recover. This framework is used to understand the current state of cybersecurity risks, identify opportunities to achieve a desired future state, and continuously keep up with the ever-changing threat landscape. The ATS system is hosted in Cyxtera and Equinix data centers and subject to high security standards, including video surveillance, 24x7 armed security, and multi-factor physical access. The physical and operational security controls at these data centers are assessed by independent third parties annually. The facilities maintain multiple backup power systems to help ensure continuous operation in the event of electrical power failure. FMR maintains a Rules for Employee Investing Policy (the "EIP") which covers employees of all U.S. subsidiaries, including NFS, regardless of their role or responsibilities. Employees must complete policy training at onboarding and on an annual basis are required to complete a compliance questionnaire that includes acknowledgement of their adherence to this policy. The EIP is designed to encourage long-term investments, generally prohibit employees from engaging in excessive trading, and prevent the misuse of confidential trading information. The EIP requires employees to maintain brokerage accounts only at firm that have agreed to provide NFS daily trading information for employee personal accounts. EIP covered securities, which includes a majority of symbols eligible for trading in the ATS, are subject to a 60-day holding period and NFS employees are required to preclear any trade prior to placing an order. Employees must receive confirmation approving a covered transaction before executing the transaction and employee transactions are periodically reviewed for, amongst other things, misuse of confidential information. Violation of any company policy, and any other form of misconduct, may lead to disciplinary or corrective action up to and including dismissal.

hours_of_operation

The ATS accepts orders from 8:00 a.m. to 4:00 p.m. The ATS executes orders from 9:30 a.m. to 4:00 p.m. The ATS observes NYSE's holiday and early close schedule. In addition, the ATS may not accept orders if there are system issues or market disruptions that warrant a cessation of trading.

display_best_quotes

The ATS does not display orders or trading interest entered into the Continuous Cross. In the Conditional Cross, where a Conditional Order is eligible to cross, whether with a Firm-Up Order or another Conditional Order, the ATS will systematically send a notice to the subscriber notifying it of the initial match (via FIX). Only direct Subscribers or the broker-dealer operator can receive invites messages. The invite message is a standard FIX execution report and contains the Client's Order ID, NFS Order ID, Leaves Quantity, Conditional Order Quantity, Conditional Order Limit Price, Side, Symbol, Invite Message Timestamp, Executing Broker, and a custom field indicating that the message is an invite message. There is no information pertaining to the counterparty or potential execution size. The subscriber will then have a system-determined time period of less than 1 second to "firm-up" by submitting a firm order, either manually or systematically, in response to the proposed match (such orders, "Firm-Up Orders").

execution_services

Pre-open, the ATS only accepts Day orders, IOC orders are rejected. The ATS initiates trading ("opens") on a security-by-security basis. For NMS stocks where NYSE or AMEX is the primary listing exchange, the ATS will initiate trading after the earlier of (x) receipt of the first trade report from the listing exchange and (y) 15 seconds after the first quote on the primary exchange received during regular market hours (e.g., 9:30 am to 4:00 pm ET). For all other NMS stocks, the ATS will initiate trading after the earlier of (x) receipt of the first trade report from the listing exchange and (y) 9:30:15 am ET. Once a stock is open, orders will be executed based on the crossing session (continuous or conditional) specific matching and prioritization logic; the ATS does not perform an opening cross or auction. For halted stocks, the ATS will resume trading in stocks after the primary exchange indicates that trading has resumed. Once trading has resumed, orders will be executed based on the crossing session (continuous or conditional) specific matching and prioritization logic; the ATS does not perform an opening cross or auction.