IBKR EOS ATS

amendment_reason

Part II Item 2 is amended to remove Interactive Brokers Central Europe from the list of IBKR affiliates who are permitted to enter or direct the entry of orders into the ATS. This change applies to IBKR as ATS operator and to all subscribers. Part II Items 1 and 5 and Part III Items 5 and 15 are amended to disclose that IBKR has enabled the ATS as a possible routing destination for Brokerage Customers' non-directed orders being handled by the IBKR SOR (only if the customer opts to make the order eligible for the overnight session). This change applies to IBKR as ATS operator, is directly applicable to Brokerage Customers and otherwise impacts all subscribers. Part II Item 5 is also amended to update the list of Trading Products that allow Brokerage Customers to direct orders to the ATS via the SOR. This change applies to IBKR as ATS operator and to Brokerage Customers. Part III Items 2 and 5 are amended to disclose that Brokerage Customers are required to acknowledge IBKR's overnight-trading risk disclosures before accessing the ATS. This change applies to IBKR as ATS operator and is otherwise solely applicable to Brokerage Customers. Part III Item 19 is amended to describe certain fees that are passed through to subscribers. This change applies to IBKR as ATS operator and to all classes of subscribers.

amendment_reason

Part III Items 4, 15 and 21 are being amended to change the closing time of the ATS' regular trading hours from 3:30 AM ET to 3:50 AM ET. There are no other changes in this amendment. The changes herein impact all ATS subscribers. The changes are not applicable to IBKR as ATS operator.

amendment_reason

Part II Items 1, 2 and 6 and Part III Item 5, 7, 11, 12, 13 and 14, are being amended to allow Liquidity Providers to both add and remove liquidity from the ATS (currently, Liquidity Providers may only add liquidity). Separately, Part II Item 5 and Part III Items 13 and 15 are being amended to allow subscribers using IBKR's REST/Web API offering to elect to receive top of book ATS market data that excludes Liquidity Providers' resting orders. The above changes impact all ATS subscribers and directly impact Liquidity Providers and subscribers receiving ATS market data via IBKR's REST/Web API offering. Separately, Part II Items 1, 2, 3, 5, 6 and 7 and Part III Items 2, 5, 12, 14 and 19 are being amended to allow IBKR's affiliate, Interactive Brokers Corp., to act as a Liquidity Provider in the ATS. This change impacts all ATS subscribers. There are no other changes in this amendment. The changes herein are not applicable to IBKR as ATS operator.

amendment_reason

Part III Items 4, 15 and 21 are being amended to change the closing time of the ATS' regular trading hours from 4:00 AM ET to 3:30 AM ET. There are no other changes in this amendment. The changes herein impact all ATS subscribers. The changes herein are not applicable to IBKR as ATS operator.

amendment_reason

Part II Items 1, 2, 5, 6 and 7 and Part III Items 5, 7, 11 and 15 are being amended to allow the ATS to accept Non-Displayed Orders. Non-Displayed Orders will not be included in the Top of Book Data disseminated to Brokerage Customers and Liquidity Providers, although such orders will be included in Top of Book Data disseminated to the IBKR SOR. Information regarding transactions involving Non-Displayed Orders will be included in Last Sale Data. Non-Displayed Orders will be ranked behind Displayed Orders on price parity. There are no other changes in this amendment. The changes herein impact all ATS subscribers and IBKR as ATS operator.

amendment_reason

Part III Items 7, 11, 20 and 23 are being amended to remove the price bands employed by the ATS. There are no other changes in this amendment. The changes herein impact all ATS subscribers. The changes are not applicable to IBKR as ATS operator.

amendment_reason

Part III Item 19 is amended to allow IBKR to charge commissions to Liquidity Providers. The commission IBKR charges a Liquidity Provider will not exceed the highest base commission rate charged under IBKR's Unbundled commission model. Liquidity Providers are currently not charged any commission. This change applies to IBKR as ATS operator. This change is directly applicable to Liquidity Providers and otherwise impacts all classes of ATS subscribers.

amendment_reason

This Updating Amendment to a Material Amendment filed on December 15, 2022, includes (i) changes to Part II Item 7 to clarify that individuals responsible for liquidity provision and/or trading activities on behalf of affiliated Liquidity Providers are not permitted to access confidential trading information of the ATS and (ii) Part II Item 2 to clarify the criteria used in determining whether to allow an Affiliate to act a Liquidity Provider. There are no other changes in this amendment. The changes herein impact all ATS subscribers. The changes are not applicable to IBKR as ATS operator.

amendment_reason

Part III Item 11 is being amended to provide different price bands for leveraged exchange-traded products relative to non-leveraged securities. There are no other changes in this amendment. The changes herein impact all ATS subscribers. The changes are not applicable to IBKR as ATS operator.

amendment_reason

Part III Item 19 is amended to address the manner in which fees that are charged to subscribers to offset CAT fees assessed to IBKR as CAT Executing Broker are calculated by IBKR. This change applies to IBKR as ATS operator and to all classes of subscribers.

amendment_reason

Exhibit 2 has been amended to reflect T. Peterffy's existing interest in IBG Holdings. There are no other changes in this amendment. This change is not applicable to ATS subscribers. This change is not applicable to IBKR as ATS operator.

amendment_reason

This is an Updating Amendment to a Material Amendment filed on January 8, 2026 (accession no. 0000902664-26-000093). As noted herein, Part II Items 1, 2, 5, 6 and 7 and Part III Items 5, 7, 11 and 15 are being amended to allow the ATS to accept Non-Displayed Orders. Non-Displayed Orders will not be included in the Top of Book Data disseminated to Brokerage Customers and Liquidity Providers, although such orders will be included in Top of Book Data disseminated to the IBKR SOR. Information regarding transactions involving Non-Displayed Orders will be included in Last Sale Data. Non-Displayed Orders will be ranked behind Displayed Orders on price parity. There are no other changes in this amendment. The changes herein impact all ATS subscribers and IBKR as ATS operator.

amendment_reason

Part III Item 19 is amended to allow IBKR to charge a venue fee to Unbundled Brokerage Customers. This change applies to IBKR as ATS operator. This change is directly applicable to Unbundled Brokerage Customers and otherwise impacts all classes of ATS subscribers. Part III Item 19 is also amended to identify the range of commission rates IBKR charges Liquidity Providers. This change applies to IBKR as ATS operator. This change is directly applicable to Liquidity Providers and otherwise impacts all classes of ATS subscribers.

ats_name

INTERACTIVE BROKERS LLC

operator_crd

000036418

operator_name

INTERACTIVE BROKERS LLC

order_types

Order Types The ATS only accepts limit orders. For clarity, the ATS does not accept market orders and the ATS does not offer pegged order instructions. The ATS rejects any order with a limit price outside the prevailing price band for the relevant security, including, for clarity, buy or sell orders priced either above the upper band or below the lower band. See Part III Item 11 for a further discussion of the ATS' price bands. By default, orders submitted to the ATS may both add and remove liquidity from the ATS. Both Brokerage Customers and Liquidity Providers may designate their orders as "add liquidity only" ("ALO") orders. Orders that include ALO instructions will never remove liquidity from the ATS. Where, upon receipt, an ALO order is marketable against resting orders on the ATS, the ATS will accept the ALO order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day" (i.e., good for the duration of the trading session), (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Orders submitted with TIF instructions of longer than day (e.g., GTT with an expiration time after ATS trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading session. Priority The ATS ranks resting orders based on the following factors in the following order: (i) price; (ii) time; and (iii) size. Where a Brokerage Customer's order is on price parity with a Liquidity Provider's order, the Brokerage Customer's order will have priority. For purposes of time priority, order receipt time for an order received prior to the start of trading is the order's actual time of receipt by the ATS (that is, order receipt time is not adjusted to the start of trading hours). Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Interaction The ATS will apply the priorities detailed above with respect to eligible orders and prices only. To the extent an order entered into the ATS may not, by law, rule, regulation or the terms of the order, (i) be crossed with another order or (ii) be crossed at a particular price, then such orders will be ineligible for matching or, where applicable, the price adjusted to a permissible price. In the event of a match, the order deemed to be removing liquidity receives all available price improvement. For two given orders to a match, the order received first by the ATS is deemed to be adding liquidity. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber.

order_types

Order Types The ATS only accepts limit orders. For clarity, the ATS does not accept market orders and the ATS does not offer pegged order instructions. By default, orders submitted to the ATS may both add and remove liquidity from the ATS. Both Brokerage Customers and Liquidity Providers may designate their orders as "add liquidity only" ("ALO") orders. Orders that include ALO instructions will never remove liquidity from the ATS. Where, upon receipt, an ALO order is marketable against resting orders on the ATS, the ATS will accept the ALO order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day" (i.e., good for the duration of the trading session), (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Orders submitted with TIF instructions of longer than day (e.g., GTT with an expiration time after ATS trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading session. Priority The ATS ranks resting orders based on the following factors in the following order: (i) price; (ii) time; and (iii) size. Where a Brokerage Customer's order is on price parity with a Liquidity Provider's order, the Brokerage Customer's order will have priority. For purposes of time priority, order receipt time for an order received prior to the start of trading is the order's actual time of receipt by the ATS (that is, order receipt time is not adjusted to the start of trading hours). Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Interaction The ATS will apply the priorities detailed above with respect to eligible orders and prices only. To the extent an order entered into the ATS may not, by law, rule, regulation or the terms of the order, (i) be crossed with another order or (ii) be crossed at a particular price, then such orders will be ineligible for matching or, where applicable, the price adjusted to a permissible price. In the event of a match, the order deemed to be removing liquidity receives all available price improvement. For two given orders to a match, the order received first by the ATS is deemed to be adding liquidity. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber.

order_types

Order Types The ATS only accepts limit orders. For clarity, the ATS does not accept market orders and the ATS does not offer pegged order instructions. By default, orders submitted to the ATS may both add and remove liquidity from the ATS. Both Brokerage Customers and Liquidity Providers may designate their orders as "add liquidity only" ("ALO") orders. Orders that include ALO instructions will never remove liquidity from the ATS. Where, upon receipt, an ALO order is marketable against resting orders on the ATS, the ATS will accept the ALO order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Display Instructions By default, all orders submitted to the ATS are eligible to be included in the ATS market data distributed to Brokerage Customers, Liquidity Providers and the SOR. However, both Brokerage Customers and Liquidity Providers may include instructions that an order(s) not be eligible for display in Top of Book Data distributed to Brokerage Customers and Liquidity Providers (such orders, "Non-Displayed Orders", all other orders, "Displayed Orders"). Top of Book Data made available to the SOR includes both Displayed Orders and Non-Displayed Orders. Executions involving Non-Displayed Orders are included in Last Sale Data. Accordingly, where an order submitted to the ATS includes instructions that it be displayed in Top of Book Data distributed to Brokerage Customers and Liquidity Providers (i.e., a Displayed Order), such order, if the highest priced buy order in the ATS (or lowest priced sell order), will be identified, on a non-attributed basis, as the "top of book" for the relevant security in the Top of Book Data made available to Brokerage Customers, Liquidity Providers and the SOR. Where, instead, an order submitted to the ATS includes instructions that it not be displayed in Top of Book Data distributed to Brokerage Customers and Liquidity Providers (i.e., a Non-Displayed Order), such order, if the highest price buy order in the ATS (or lowest priced sell order), will be identified, on a non-attributed basis, as the "top of book" for the relevant security in the Top of Book Data made available to the SOR, but will not be included in the Top of Book Data made available to Brokerage Customers and Liquidity Providers; rather, in such instances, Top of Book Data made available to Brokerage Customers and Liquidity Providers will, on a security-by-security basis, identify the aggregate size and limit price of the highest (lowest) limit price of buy (sell) Displayed Orders resting in the ATS. Accordingly, assume there are two competing buy orders in the ATS for security XYZ. Buy order A is a Displayed Order for 100 shares of XYZ with a limit price of $10.00. Buy order B is a Non-Displayed Order for 200 shares of XYZ with a limit price of $10.05. The Top of Book Data distributed to Brokerage Customers and Liquidity Providers will identify, for buy orders, the "top of book" for XYZ as 100 shares at $10.00. The Top of Book Data distributed to the SOR will identify, for buy orders, the "top of book" for XYZ as 200 shares at $10.05. For clarity, and as noted in Part II Item 5, Top of Book Data does not include depth-of-book. Accordingly, the Top of Book Data distributed to the SOR will not, in the above fact pattern, identify buy order A. As noted in Part II Item 5, Top of Book Data will aggregate size at the top of book. Accordingly, assume there are two competing sell orders in the ATS for security ABC: (i) Sell order X, which is a Displayed Order for 100 shares of XYZ with a limit price of $20.00 and (ii) Sell order Y, which is a Non-Displayed Order for 200 shares of XYZ that also has a limit price of $20.00. The Top of Book Data distributed to the SOR will identify, for sell orders, the "top of book" for ABC as 300 shares at $20.00 (that is, the aggregate size of Sell orders X and Y at $20.00). The Top of Book Data distributed to Brokerage Customers and Liquidity Providers will identify, for sell orders, the "top of book" for ABC as 100 shares at $20.00 (that is, as Sell order Y is a Non-Displayed Order, information regarding that order will not be included in the Top of Book Data distributed to Brokerage Customers and Liquidity Providers). See Part II Item 5 and Part III Item 15 for additional information regarding ATS market data. Non-Displayed Orders may include all of the same order attributes available to Displayed Orders. Display instructions apply to the entirety of an order (that is, an order cannot include an instruction that only a portion of the order be non-displayed). Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day" (i.e., good for the duration of the trading session), (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Orders submitted with TIF instructions of longer than day (e.g., GTT with an expiration time after ATS trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading session. Priority The ATS ranks resting orders based on the following factors in the following order: (i) price; (ii) display (where on price parity, Displayed Orders have priority over Non-Displayed Orders); (iii) subscriber categorization (where on price parity and with the same display instructions, Brokerage Customers' orders have priority over Liquidity Provider's orders); (iv) time; and (v) size. For purposes of time priority, order receipt time for an order received prior to the start of trading is the order's actual time of receipt by the ATS (that is, order receipt time is not adjusted to the start of trading hours). Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Interaction The ATS will apply the priorities detailed above with respect to eligible orders and prices only. To the extent an order entered into the ATS may not, by law, rule, regulation or the terms of the order, (i) be crossed with another order or (ii) be crossed at a particular price, then such orders will be ineligible for matching or, where applicable, the price adjusted to a permissible price. In the event of a match, the order deemed to be removing liquidity receives all available price improvement. For two given orders to a match, the order received first by the ATS is deemed to be adding liquidity. For clarity, order display instructions (that is, whether an order is a Displayed Order or a Non-Displayed Order) do not impact when an order is deemed received by the ATS or whether an order is otherwise deemed to be adding or removing liquidity. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber.

order_types

Order Types The ATS only accepts limit orders. For clarity, the ATS does not accept market orders and the ATS does not offer pegged order instructions. The ATS rejects any order with a limit price outside the prevailing price band for the relevant security, including, for clarity, buy or sell orders priced either above the upper band or below the lower band. See Part III Item 11 for a further discussion of the ATS' price bands. By default, orders submitted to the ATS by Brokerage Customers may both add and remove liquidity from the ATS. Brokerage Customers may, however, designate their orders as "add liquidity only" ("ALO") orders. Orders that include ALO instructions will never remove liquidity from the ATS. Where, upon receipt, an ALO order is marketable against resting orders on the ATS, the ATS will accept the ALO order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). All orders submitted to the ATS by Liquidity Providers are treated as ALO orders and, as such, will never remove liquidity from the ATS. Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day" (i.e., good for the duration of the trading session), (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Orders submitted with TIF instructions of longer than day (e.g., GTT with an expiration time after ATS trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading session. Priority The ATS ranks resting orders based on the following factors in the following order: (i) price; (ii) time; and (iii) size. Where a Brokerage Customer's order is on price parity with a Liquidity Provider's order, the Brokerage Customer's order will have priority. For purposes of time priority, order receipt time for an order received prior to the start of trading is the order's actual time of receipt by the ATS (that is, order receipt time is not adjusted to the start of trading hours). Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Interaction The ATS will apply the priorities detailed above with respect to eligible orders and prices only. To the extent an order entered into the ATS may not, by law, rule, regulation or the terms of the order, (i) be crossed with another order or (ii) be crossed at a particular price, then such orders will be ineligible for matching or, where applicable, the price adjusted to a permissible price. In the event of a match, the order deemed to be removing liquidity receives all available price improvement. For two given orders to a match, the order received first by the ATS is deemed to be adding liquidity. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber.

means_of_entry

Liquidity Providers access the ATS via FIX protocol. The ATS is compliant with version 4.2 of the FIX Protocol. Liquidity Providers can connect via cross connects within Equinix NY5 or CH4 or, alternatively, through dedicated FIX connections. In the event a Liquidity Provider cross-connects with the ATS, the hardware used for connection is provided, installed, and maintained by the Liquidity Provider and/or datacenter operator. IBKR does not charge a fee for cross-connects.

pricing_methodology

IBKR's systems utilize direct market data feeds received from each national securities exchange solely to determine the permitted price band for the ATS.

pricing_methodology

The ATS does not use market data in connection with its trading operations.

counterparty_selection

Orders submitted by IBKR's affiliate, Covestor Ltd, are configured to interact only with orders of Unaffiliated Liquidity Providers, generally (that is, orders submitted by Covestor Ltd may only interact with the orders of Unaffiliated Liquidity Providers as a group, and are not configured to only interact with, or not interact with, any particular Unaffiliated Liquidity Provider(s)). Such counter-party permissioning functionality is not available to other subscribers. Further, only Covestor Ltd may restrict its orders from interacting with orders of an Affiliated Liquidity Provider. Orders submitted to the ATS by Liquidity Providers may not interact with orders submitted to the ATS by other Liquidity Providers (including, for clarity, other orders submitted by such Liquidity Provider). Orders submitted to the ATS by Brokerage Customers may interact with both orders submitted to the ATS by Liquidity Providers and orders submitted to the ATS by other Brokerage Customers, but may not interact with other orders submitted by the same Brokerage Customer.

counterparty_selection

Orders submitted by IBKR's affiliate, Covestor Ltd, are configured to interact only with orders of Liquidity Providers, generally (that is, orders submitted by Covestor Ltd may only interact with the orders of Liquidity Providers as a group, and are not configured to only interact with, or not interact with, any particular Liquidity Provider(s)). Such counter-party permissioning functionality is not available to other subscribers. Orders submitted to the ATS by Liquidity Providers may only add liquidity. Orders submitted to the ATS by Brokerage Customers may add or remove liquidity. Brokerage Customers may designate their orders as only being eligible to add liquidity to the ATS. Where a Brokerage Customer designates its order as only being eligible to add liquidity to the ATS, such order is otherwise treated as a Brokerage Customer order (e.g., for priority purposes). By their terms, orders submitted to the ATS by Liquidity Providers may not interact with orders submitted to the ATS by other Liquidity Providers (including, for clarity, other orders submitted by such Liquidity Provider). Orders submitted to the ATS by Brokerage Customers may interact with both orders submitted to the ATS by Liquidity Providers and orders submitted to the ATS by other Brokerage Customers, but may not interact with other orders submitted by the same Brokerage Customer.

financial_condition_summary

Brokerage Customers are charged commissions for all executions effected through IBKR, including executions in the ATS. Such subscribers may select between a cost-plus ("Unbundled") commission model (which involves a base commission plus the pass-through of any venue fee or rebate (e.g., any "maker/taker" fee or rebate)) and a fixed-rate ("Bundled") commission model. Customers are free to elect the Bundled or Unbundled commission model at their discretion, and may switch (i.e., change from Bundled to Unbundled or vice versa) that election at any time. With the exception of IBKR's Affiliate IBKR Financial Services, AG (which pays no commission for fills in the ATS), IBKR Affiliates acting as Brokerage Customers and other Unbundled Brokerage Customers pay a base commission rate (distinct from the venue fee or rebate) ranging from $0.0005 to $0.005/share. IBKR's standard commission rates for Unbundled Brokerage Customers vary based on customer volume. In the Bundled model, IBKR charges customers a fixed rate commission that covers the majority of exchange and regulatory fees, although certain fees are passed-through to the customers. Bundled Brokerage Customers pay commission rates ranging from $0.0013 to $0.01/share for fills in the ATS. Brokerage Customers may negotiate Bundled and Unbundled commission rates with IBKR. IBKR typically takes into account anticipated volume and totality of the business relationship (e.g., whether a customer anticipates engaging in margin trading or stock loan activities) in such negotiations. IBKR and its Affiliates do not charge Liquidity Providers (including any Affiliated Liquidity Provider) any fees in connection with their use of the ATS (e.g., no commissions or connectivity fees). Liquidity Providers are responsible for any connectivity fees or other costs associated with their use of the ATS (i.e., fees not charged by IBKR and its Affiliates). Notwithstanding the foregoing, IBKR charges Liquidity Providers fees designed to offset CAT fees assessed to IBKR as CAT Executing Broker (as further described below). For clarity, to the extent IB Corp. acts as a Liquidity Provider, it is responsible for its own connectivity fees and other costs associated with its use of the ATS as a Liquidity Provider. IBKR is the CAT Executing Broker for both the buyer and the seller on all transactions executed in the ATS. In all instances, IBKR charges the buyer and seller (including any Liquidity Provider that is party to a trade on the ATS) fees designed to offset CAT fees assessed to IBKR as CAT Executing Broker; for clarity, such fees are charged to both Bundled and Unbundled Customers. ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge.

financial_condition_summary

Brokerage Customers are charged commissions for all executions effected through IBKR, including executions in the ATS. Such subscribers may select between a cost-plus ("Unbundled") commission model (which involves a base commission plus the pass-through of any venue fee or rebate (e.g., any "maker/taker" fee or rebate)) and a fixed-rate ("Bundled") commission model. Customers are free to elect the Bundled or Unbundled commission model at their discretion, and may switch (i.e., change from Bundled to Unbundled or vice versa) that election at any time. With the exception of IBKR's Affiliate IBKR Financial Services, AG (which pays no commission for fills in the ATS), IBKR Affiliates and other Unbundled customers pay a base commission rate (distinct from the venue fee or rebate) ranging from $0.0005 to $0.005/share. IBKR's standard commission rates for Unbundled customers vary based on customer volume. In the Bundled model, IBKR charges customers a fixed rate commission that covers the majority of exchange and regulatory fees, although certain fees are passed-through to the customers. Bundled customers pay commission rates ranging from $0.0013 to $0.01/share for fills in the ATS. Brokerage Customers may negotiate Bundled and Unbundled commission rates with IBKR. IBKR typically takes into account anticipated volume and totality of the business relationship (e.g., whether a customer anticipates engaging in margin trading or stock loan activities) in such negotiations. IBKR and its Affiliates do not charge Liquidity Providers any fees in connection with their use of the ATS (e.g., no commissions or connectivity fees). Liquidity Providers are responsible for any connectivity fees or other costs associated with their use of the ATS (i.e., fees not charged by IBKR and its Affiliates). ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge.

financial_condition_summary

Brokerage Customers are charged commissions for all executions effected through IBKR, including executions in the ATS. Such subscribers may select between a cost-plus ("Unbundled") commission model (which involves a base commission plus the pass-through of any venue fee or rebate (e.g., any "maker/taker" fee or rebate)) and a fixed-rate ("Bundled") commission model. Customers are free to elect the Bundled or Unbundled commission model at their discretion, and may switch (i.e., change from Bundled to Unbundled or vice versa) that election at any time. With the exception of IBKR's Affiliate IBKR Financial Services, AG (which pays no commission for fills in the ATS), IBKR Affiliates acting as Brokerage Customers and other Unbundled Brokerage Customers pay a base commission rate (distinct from the venue fee or rebate) ranging from $0.0005 to $0.005/share. IBKR's standard commission rates for Unbundled Brokerage Customers vary based on customer volume. In the Bundled model, IBKR charges customers a fixed rate commission that covers the majority of exchange and regulatory fees, although certain fees are passed-through to the customers. Bundled Brokerage Customers pay commission rates ranging from $0.0013 to $0.01/share for fills in the ATS. Brokerage Customers may negotiate Bundled and Unbundled commission rates with IBKR. IBKR typically takes into account anticipated volume and totality of the business relationship (e.g., whether a customer anticipates engaging in margin trading or stock loan activities) in such negotiations. IBKR and its Affiliates do not charge Liquidity Providers (including any Affiliated Liquidity Provider) any fees in connection with their use of the ATS (e.g., no commissions or connectivity fees). Liquidity Providers are responsible for any connectivity fees or other costs associated with their use of the ATS (i.e., fees not charged by IBKR and its Affiliates). For clarity, to the extent IB Corp. acts as a Liquidity Provider, it is responsible for its own connectivity fees and other costs associated with its use of the ATS as a Liquidity Provider. ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge.

financial_condition_summary

Brokerage Customers are charged commissions for all executions effected through IBKR, including executions in the ATS. Such subscribers may select between a cost-plus ("Unbundled") commission model (which involves a base commission plus the pass-through of any venue fee or rebate (e.g., any "maker/taker" fee or rebate)) and a fixed-rate ("Bundled") commission model. Customers are free to elect the Bundled or Unbundled commission model at their discretion, and may switch (i.e., change from Bundled to Unbundled or vice versa) that election at any time. With the exception of IBKR's Affiliate IBKR Financial Services, AG (which pays no commission or venue fee for fills in the ATS), IBKR Affiliates acting as Brokerage Customers and other Unbundled Brokerage Customers pay a base commission rate ranging from $0.0005 to $0.005/share. IBKR's standard commission rates for Unbundled Brokerage Customers vary based on customer volume. Unbundled Brokerage Customers (excluding, for clarity, IBKR Financial Services, AG) separately pay a $0.001/share venue fee when removing liquidity from the ATS. Such venue fee is in addition to the base commission rate noted above. Unbundled Brokerage Customers are not charged a venue fee when adding liquidity to the ATS. See Part III Item 7 for discussion of when an order is deemed to add or remove liquidity from the ATS. In the Bundled model, IBKR charges customers a fixed rate commission that covers the majority of exchange and regulatory fees, although certain fees are passed-through to the customers. Bundled Brokerage Customers pay commission rates ranging from $0.0013 to $0.01/share for fills in the ATS. Bundled Brokerage Customers are not charged a venue fee in connection with their executions in the ATS. Brokerage Customers may negotiate Bundled and Unbundled commission rates with IBKR and, where applicable, ATS venue fees. IBKR typically takes into account anticipated volume and totality of the business relationship (e.g., whether a customer anticipates engaging in margin trading or stock loan activities) in such negotiations. IBKR may charge a Liquidity Provider (including any Affiliated Liquidity Provider) a commission in connection with its use of the ATS. Liquidity Providers are charged a commission ranging from $0.00 to $0.001/share where the Liquidity Provider's order is deemed to add liquidity to the ATS. Liquidity Providers are charged a $0.001/share commission where the Liquidity Provider's order is deemed to remove liquidity from the ATS; provided, however, Liquidity Providers that are not charged a commission when adding liquidity to the ATS are also not charged a commission when removing liquidity from the ATS. IBKR takes into account a variety of factors, including historical and anticipated order and transaction activity and totality of the business relationship (e.g., whether a Liquidity Provider has other business relationships with IBKR, such as where a Liquidity Provider engages in stock loan transactions with IBKR ) in determining the commission, if any, charged a Liquidity Provider. Additionally, IBKR charges Liquidity Providers fees designed to offset CAT fees assessed to IBKR as CAT Executing Broker (as further described below). IBKR and its Affiliates do not otherwise charge Liquidity Providers (including any Affiliated Liquidity Provider) any fees (e.g., connectivity fees) in connection with their use of the ATS. Liquidity Providers are responsible for any connectivity fees or other costs associated with their use of the ATS (i.e., fees not charged by IBKR and its Affiliates). For clarity, to the extent IB Corp. acts as a Liquidity Provider, it is responsible for its own connectivity fees and other costs associated with its use of the ATS as a Liquidity Provider. IBKR is the CAT Executing Broker for both the buyer and the seller on all transactions executed in the ATS. In all instances, IBKR charges the buyer and seller (including any Liquidity Provider that is party to a trade on the ATS) fees designed to offset CAT fees assessed to IBKR as CAT Executing Broker; for clarity, such fees are charged to both Bundled and Unbundled Customers. ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge.

financial_condition_summary

Brokerage Customers are charged commissions for all executions effected through IBKR, including executions in the ATS. Such subscribers may select between a cost-plus ("Unbundled") commission model (which involves a base commission plus the pass-through of any venue fee or rebate (e.g., any "maker/taker" fee or rebate)) and a fixed-rate ("Bundled") commission model. Customers are free to elect the Bundled or Unbundled commission model at their discretion, and may switch (i.e., change from Bundled to Unbundled or vice versa) that election at any time. With the exception of IBKR's Affiliate IBKR Financial Services, AG (which pays no commission for fills in the ATS), IBKR Affiliates acting as Brokerage Customers and other Unbundled Brokerage Customers pay a base commission rate (distinct from the venue fee or rebate) ranging from $0.0005 to $0.005/share. IBKR's standard commission rates for Unbundled Brokerage Customers vary based on customer volume. In the Bundled model, IBKR charges customers a fixed rate commission that covers the majority of exchange and regulatory fees, although certain fees are passed-through to the customers. Bundled Brokerage Customers pay commission rates ranging from $0.0013 to $0.01/share for fills in the ATS. Brokerage Customers may negotiate Bundled and Unbundled commission rates with IBKR. IBKR typically takes into account anticipated volume and totality of the business relationship (e.g., whether a customer anticipates engaging in margin trading or stock loan activities) in such negotiations. IBKR and its Affiliates do not charge Liquidity Providers (including any Affiliated Liquidity Provider) any fees in connection with their use of the ATS (e.g., no commissions or connectivity fees). Liquidity Providers are responsible for any connectivity fees or other costs associated with their use of the ATS (i.e., fees not charged by IBKR and its Affiliates). Without limiting the foregoing, IBKR charges Liquidity Providers fees designed to offset CAT fees assessed to IBKR as CAT Executing Broker (as further described below). For clarity, to the extent IB Corp. acts as a Liquidity Provider, it is responsible for its own connectivity fees and other costs associated with its use of the ATS as a Liquidity Provider. IBKR is the CAT Executing Broker for both the buyer and the seller on all transactions executed in the ATS. In all instances, IBKR charges the buyer and seller (including any Liquidity Provider that is party to a trade on the ATS) fees designed to offset CAT fees assessed to IBKR as CAT Executing Broker; for clarity, such fees are charged to both Bundled and Unbundled Customers (on a pass-through basis). ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge.

financial_condition_summary

Brokerage Customers are charged commissions for all executions effected through IBKR, including executions in the ATS. Such subscribers may select between a cost-plus ("Unbundled") commission model (which involves a base commission plus the pass-through of any venue fee or rebate (e.g., any "maker/taker" fee or rebate)) and a fixed-rate ("Bundled") commission model. Customers are free to elect the Bundled or Unbundled commission model at their discretion, and may switch (i.e., change from Bundled to Unbundled or vice versa) that election at any time. With the exception of IBKR's Affiliate IBKR Financial Services, AG (which pays no commission for fills in the ATS), IBKR Affiliates acting as Brokerage Customers and other Unbundled Brokerage Customers pay a base commission rate (distinct from the venue fee or rebate) ranging from $0.0005 to $0.005/share. IBKR's standard commission rates for Unbundled Brokerage Customers vary based on customer volume. In the Bundled model, IBKR charges customers a fixed rate commission that covers the majority of exchange and regulatory fees, although certain fees are passed-through to the customers. Bundled Brokerage Customers pay commission rates ranging from $0.0013 to $0.01/share for fills in the ATS. Brokerage Customers may negotiate Bundled and Unbundled commission rates with IBKR. IBKR typically takes into account anticipated volume and totality of the business relationship (e.g., whether a customer anticipates engaging in margin trading or stock loan activities) in such negotiations. IBKR may charge a Liquidity Provider (including any Affiliated Liquidity Provider) a commission in connection with its use of the ATS. Such commission rate will not exceed the highest base commission rate charged Brokerage Customers under the Unbundled commission model. For clarity, IBKR may elect not to charge a Liquidity Provider (including an Affiliated Liquidity Provider) a commission. IBKR takes into account a variety of factors, including historical and anticipated order and transaction activity and totality of the business relationship (e.g., whether a Liquidity Provider has other business relationships with IBKR, such as where a Liquidity Provider engages in stock loan transactions with IBKR ) in determining the commission charged a Liquidity Provider. Additionally, IBKR charges Liquidity Providers fees designed to offset CAT fees assessed to IBKR as CAT Executing Broker (as further described below). IBKR and its Affiliates do not otherwise charge Liquidity Providers (including any Affiliated Liquidity Provider) any fees (e.g., connectivity fees) in connection with their use of the ATS. Liquidity Providers are responsible for any connectivity fees or other costs associated with their use of the ATS (i.e., fees not charged by IBKR and its Affiliates). For clarity, to the extent IB Corp. acts as a Liquidity Provider, it is responsible for its own connectivity fees and other costs associated with its use of the ATS as a Liquidity Provider. IBKR is the CAT Executing Broker for both the buyer and the seller on all transactions executed in the ATS. In all instances, IBKR charges the buyer and seller (including any Liquidity Provider that is party to a trade on the ATS) fees designed to offset CAT fees assessed to IBKR as CAT Executing Broker; for clarity, such fees are charged to both Bundled and Unbundled Customers. ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge.

conflict_description

The following Affiliates may submit orders to the ATS: i. IBKR Financial Services AG (f/k/a Timber Hill Europe AG) (broker-dealer registered in Switzerland, no MPID, may submit orders as principal); ii. IBKR Securities Services LLC (U.S. registered broker-dealer, MPID=TMBR, may submit orders as principal); iii. Interactive Brokers Canada Inc. (broker-dealer registered in Canada, no MPID, may submit orders as principal or agent); iv. Interactive Brokers (UK) Ltd. (broker-dealer registered in the United Kingdom, no MPID, may submit orders as agent); v. Interactive Brokers Hong Kong Ltd. (broker-dealer and futures firm registered in Hong Kong, no MPID, may submit orders as principal or agent); vi. Interactive Brokers Australia Pty Ltd. (broker-dealer registered in Australia, no MPID, may submit orders as principal or agent); vii. Covestor Ltd (d/b/a Interactive Brokers Asset Management) (SEC Registered Investment Adviser, no MPID, may submit orders as principal or agent); viii. IB Exchange Corp. (unregistered holding company, no MPID, may submit orders as principal); and ix. IBG LLC (unregistered holding company, no MPID, may submit orders as principal); and x. Interactive Brokers Corp. ("IB Corp.")(U.S. registered broker-dealer, MPID=IBCO, may submit orders as principal). No other Affiliates of IBKR are subscribers to the ATS.

conflict_description

The following Affiliates may submit orders to the ATS: i. IBKR Financial Services AG (f/k/a Timber Hill Europe AG) (broker-dealer registered in Switzerland, no MPID, may submit orders as principal); ii. IBKR Securities Services LLC (U.S. registered broker-dealer, MPID=TMBR, may submit orders as principal); iii. Interactive Brokers Canada Inc. (broker-dealer registered in Canada, no MPID, may submit orders as principal or agent); iv. Interactive Brokers (UK) Ltd. (broker-dealer registered in the United Kingdom, no MPID, may submit orders as agent); v. Interactive Brokers Hong Kong Ltd. (broker-dealer and futures firm registered in Hong Kong, no MPID, may submit orders as principal or agent); vi. Interactive Brokers Australia Pty Ltd. (broker-dealer registered in Australia, no MPID, may submit orders as principal or agent); vii. Covestor Ltd (d/b/a Interactive Brokers Asset Management) (SEC Registered Investment Adviser, no MPID, may submit orders as principal or agent); viii. IB Exchange Corp. (unregistered holding company, no MPID, may submit orders as principal); ix. IBG LLC (unregistered holding company, no MPID, may submit orders as principal); x. Interactive Brokers Corp. ("IB Corp.")(U.S. registered broker-dealer, MPID=IBCO, may submit orders as principal); xi. Interactive Brokers Securities Japan, Inc. (broker-dealer registered in Japan, no MPID, may submit orders as principal or agent); xii. Interactive Brokers Ireland Limited (broker-dealer registered in Ireland, no MPID, may submit orders as principal or agent); xiii. Interactive Brokers Singapore Pte. Ltd. (broker-dealer registered in Singapore, no MPID, may submit orders as principal or agent); and xiv. Interactive Brokers Central Europe Zrt. (broker-dealer registered in Hungary, no MPID, may submit orders as principal or agent). No other Affiliates of IBKR are subscribers to the ATS.

conflict_description

The following Affiliates may submit orders to the ATS: i. IBKR Financial Services AG (f/k/a Timber Hill Europe AG) (broker-dealer registered in Switzerland, no MPID, may submit orders as principal); ii. IBKR Securities Services LLC (U.S. registered broker-dealer, MPID=TMBR, may submit orders as principal); iii. Interactive Brokers Canada Inc. (broker-dealer registered in Canada, no MPID, may submit orders as principal or agent); iv. Interactive Brokers (UK) Ltd. (broker-dealer registered in the United Kingdom, no MPID, may submit orders as agent); v. Interactive Brokers Hong Kong Ltd. (broker-dealer and futures firm registered in Hong Kong, no MPID, may submit orders as principal or agent); vi. Interactive Brokers Australia Pty Ltd. (broker-dealer registered in Australia, no MPID, may submit orders as principal or agent); vii. Covestor Ltd (d/b/a Interactive Brokers Asset Management) (SEC Registered Investment Adviser, no MPID, may submit orders as principal or agent); viii. IB Exchange Corp. (unregistered holding company, no MPID, may submit orders as principal); ix. IBG LLC (unregistered holding company, no MPID, may submit orders as principal); x. Interactive Brokers Corp. ("IB Corp.")(U.S. registered broker-dealer, MPID=IBCO, may submit orders as principal); xi. Interactive Brokers Securities Japan, Inc. (broker-dealer registered in Japan, no MPID, may submit orders as principal or agent); xii. Interactive Brokers Ireland Limited (broker-dealer registered in Ireland, no MPID, may submit orders as principal or agent); and xiii. Interactive Brokers Singapore Pte. Ltd. (broker-dealer registered in Singapore, no MPID, may submit orders as principal or agent). No other Affiliates of IBKR are subscribers to the ATS.

conflict_description

The following Affiliates may submit orders to the ATS: i. IBKR Financial Services AG (f/k/a Timber Hill Europe AG) (broker-dealer registered in Switzerland, no MPID, may submit orders as principal); ii. IBKR Securities Services LLC (U.S. registered broker-dealer, MPID=TMBR, may submit orders as principal); iii. Interactive Brokers Canada Inc. (broker-dealer registered in Canada, no MPID, may submit orders as principal or agent); iv. Interactive Brokers (UK) Ltd. (broker-dealer registered in the United Kingdom, no MPID, may submit orders as agent); v. Interactive Brokers Hong Kong Ltd. (broker-dealer and futures firm registered in Hong Kong, no MPID, may submit orders as principal or agent); vi. Interactive Brokers Australia Pty Ltd. (broker-dealer registered in Australia, no MPID, may submit orders as principal or agent); vii. Covestor Ltd (d/b/a Interactive Brokers Asset Management) (SEC Registered Investment Adviser, no MPID, may submit orders as principal or agent); viii. IB Exchange Corp. (unregistered holding company, no MPID, may submit orders as principal); and ix. IBG LLC (unregistered holding company, no MPID, may submit orders as principal). No other Affiliates of IBKR are subscribers to the ATS.

compliance_officer

DATA PROTECTION: Client data protection (including the protection of subscriber confidential trading information) is governed by formally instituted policies. Records containing clients' data stored in IBKR's databases, as well as on tape backups, are encrypted. Encryption algorithms, ciphers, and key parameters are consistent with the industry best practices. In addition to technical data protection measures, IBKR administers mandatory security awareness training to all its employees emphasizing data protection best practices. INFORMATION BARRIERS: Interactive Brokers Group ("IBG") has in place barriers designed to help ensure that confidential information relating to subscriber orders in the ATS is maintained on systems that are separate from, and inaccessible by, IBKR's affiliates. IBKR compliance personnel review various daily, monthly and quarterly reports intended to help identify potential instances of IBKR customer information (including ATS confidential trading information which, for the avoidance of doubt, includes confidential trading information of Liquidity Providers) being impermissibly accessed by employees of IBKR affiliates. IBKR compliance personnel also review a sample of communications between IBKR personnel and personnel of its affiliates to assess whether subscriber confidential trading information is being impermissibly accessed or shared. All new IBKR employees must review the IBG Information Barrier Policy, which is included in the IBG employee manual, and must acknowledge receipt of the current version of the IBG Information Barrier Policy annually. The IBG Information Barrier Policy states that employees of IBG and its affiliates (including IBKR employees) shall treat customer trading information (including subscriber trading information) as confidential and shall only share such information to the extent reasonably necessary to provide the relevant services and otherwise service the relevant account. As applied to ATS confidential trading information, the IBG Information Barrier Policy limits the sharing of such information within IBG to the extent reasonably necessary for the operation of the ATS and related systems (that is, IBKR's market data, clearing, stock borrow and audit trail systems), and to ensure the ATS' compliance with applicable law. In addition, IBG provides training regarding the confidentiality of customer orders and information. ACCESS TO SUBSCRIBER CONFIDENTIAL TRADING INFORMATION: Access to IBKR trading systems, including those that maintain ATS confidential trading information, is limited to authorized individuals. Prior to granting any employee, shared employee, or third-party service provider access (each an "Accessing Party") to ATS data, IBKR reviews the level of access requested, the roles and responsibilities of the prospective Accessing Party, and the proposed uses of the data to which the prospective Accessing Party would have access. As a threshold matter, access to ATS confidential trading information is limited to individuals responsible for either the operation of the ATS and related systems (that is, IBKR's market data, clearing, stock borrow and audit trail systems), or the ATS' compliance with applicable law. As noted above, the IBG Information Barrier Policy provides that Accessing Parties may only use ATS confidential trading information to the extent necessary to fulfill their responsibilities regarding the operation of the ATS and related systems (that is, IBKR's market data, clearing, stock borrow and audit trail systems), or the ATS' compliance with applicable law; Accessing Parties are expressly prohibited from sharing ATS confidential trading information with Brokerage Customers and other clients of IBKR (e.g., Liquidity Providers and introducing brokers), except where such confidential trading information belongs to the relevant Brokerage Customer or client (e.g., information regarding a Brokerage Customer's own orders or transactions). Individuals responsible for liquidity provision and/or trading activities on behalf of Affiliated Liquidity Providers are not permitted to access confidential trading information of the ATS. For clarity, information regarding a subscriber's own orders and executions within the ATS is displayed to such ATS subscriber, although IBKR treats the identity of the subscriber who submitted an order or was party to a transaction as subscriber confidential information. Further, certain subscriber order information is disseminated, on a non-attributed basis, to GFIS for further dissemination and display to ATS subscribers. For clarity, GFIS' role in disseminating market data to ATS subscribers is mechanical. GFIS receives non-attributed data that has already been processed by IBKR for further distribution to ATS subscribers. GFIS does not receive or otherwise have access to "attributed" ATS order and execution data (that is, GFIS does not have access to order or execution data identifying the subscriber that submitted the order or was party to a trade) or to any other ATS data that is not shared with ATS subscribers. GFIS does not have any employees. Access to internal systems and applications is provisioned on the least-privilege basis and controlled using passwords or, in some instance, multi-factor authentication (MFA). In particular, MFA is used for all remote access and also for onsite access to particularly sensitive systems. Password length and complexity requirements are established and enforced. Periodically, as prescribed by IBKR's policies and procedures, all employees, shared employees, and third party service providers are reviewed to determine whether their level of access to ATS data is appropriate. This includes assessing whether the Accessing Party continues to have responsibilities in connection with the operation of the ATS or the ATS' compliance with applicable rules. Access to IBKR office and data center spaces is strictly controlled and limited to authorized personnel. Electronic door entry systems are in use and configured to allow personnel access only to the areas required to fulfill their job functions. Additionally, video recording/surveillance systems are employed in data centers and select office locations. Activity logs, including records of permitted and denied entry attempts captured by the access control and footage of the video surveillance system, are maintained. EMPLOYEE TRADING: The IBKR Employee Trading Policy prohibits IBKR employees from trading securities or commodity futures between the hours of 8:30 a.m. and 6:00 p.m. in their time zone. All IBKR employees, at onboarding and annually thereafter, are reminded of their obligation to identify all brokerage accounts in which the employee or any related person (as noted at FINRA rule 3210/.02) maintains an interest, including any brokerage accounts subsequently opened. IBKR obtains copies of such employee's account statements and trade confirmations from the relevant brokerage firm. IBKR prohibits an employee from opening or otherwise maintaining an account with a brokerage firm that will not provide IBKR with duplicate account statements and trade confirmations. IBKR compliance and supervisory personnel review employee account statements and trade confirmations on a monthly basis. As part of these reviews, IBKR compliance and supervisory personnel assess whether an employee has violated IBKR's Employee Trading Policy, including any indication of misuse of subscriber confidential trading information (in particular, the IBKR Employee Trading Policy, among other things, prohibits employees from trading on the basis of material non-public information). Employee trading conduct specifically reviewed for includes particularly active accounts and trading in any restricted securities outside of the "open window" period (presently limited to securities issued by Interactive Brokers Group, Inc.).

compliance_officer

DATA PROTECTION: Client data protection (including the protection of subscriber confidential trading information) is governed by formally instituted policies. Records containing clients' data stored in IBKR's databases, as well as on tape backups, are encrypted. Encryption algorithms, ciphers, and key parameters are consistent with the industry best practices. In addition to technical data protection measures, IBKR administers mandatory security awareness training to all its employees emphasizing data protection best practices. INFORMATION BARRIERS: Interactive Brokers Group ("IBG") has in place barriers designed to help ensure that confidential information relating to subscriber orders in the ATS is maintained on systems that are separate from, and inaccessible by, IBKR's affiliates. IBKR compliance personnel review various daily, monthly and quarterly reports intended to help identify potential instances of IBKR customer information (including ATS confidential trading information which, for the avoidance of doubt, includes confidential trading information of Liquidity Providers) being impermissibly accessed by employees of IBKR affiliates. IBKR compliance personnel also review a sample of communications between IBKR personnel and personnel of its affiliates to assess whether subscriber confidential trading information is being impermissibly accessed or shared. All new IBKR employees must review the IBG Information Barrier Policy, which is included in the IBG employee manual, and must acknowledge receipt of the current version of the IBG Information Barrier Policy annually. The IBG Information Barrier Policy states that employees of IBG and its affiliates (including IBKR employees) shall treat customer trading information (including subscriber trading information) as confidential and shall only share such information to the extent reasonably necessary to provide the relevant services and otherwise service the relevant account. As applied to ATS confidential trading information, the IBG Information Barrier Policy limits the sharing of such information within IBG to the extent reasonably necessary for the operation of the ATS and related systems (that is, IBKR's market data, clearing, stock borrow and audit trail systems), and to ensure the ATS' compliance with applicable law. In addition, IBG provides training regarding the confidentiality of customer orders and information. ACCESS TO SUBSCRIBER CONFIDENTIAL TRADING INFORMATION: Access to IBKR trading systems, including those that maintain ATS confidential trading information, is limited to authorized individuals. Prior to granting any employee, shared employee, or third-party service provider access (each an "Accessing Party") to ATS data, IBKR reviews the level of access requested, the roles and responsibilities of the prospective Accessing Party, and the proposed uses of the data to which the prospective Accessing Party would have access. As a threshold matter, access to ATS confidential trading information is limited to individuals responsible for either the operation of the ATS and related systems (that is, IBKR's market data, clearing, stock borrow and audit trail systems), or the ATS' compliance with applicable law. As noted above, the IBG Information Barrier Policy provides that Accessing Parties may only use ATS confidential trading information to the extent necessary to fulfill their responsibilities regarding the operation of the ATS and related systems (that is, IBKR's market data, clearing, stock borrow and audit trail systems), or the ATS' compliance with applicable law; Accessing Parties are expressly prohibited from sharing ATS confidential trading information with Brokerage Customers and other clients of IBKR (e.g., Liquidity Providers and introducing brokers), except where such confidential trading information belongs to the relevant Brokerage Customer or client (e.g., information regarding a Brokerage Customer's own orders or transactions). For clarity, information regarding a subscriber's own orders and executions within the ATS is displayed to such ATS subscriber, although IBKR treats the identity of the subscriber who submitted an order or was party to a transaction as subscriber confidential information. Further, certain subscriber order information is disseminated, on a non-attributed basis, to GFIS for further dissemination and display to ATS subscribers. For clarity, GFIS' role in disseminating market data to ATS subscribers is mechanical. GFIS receives non-attributed data that has already been processed by IBKR for further distribution to ATS subscribers. GFIS does not receive or otherwise have access to "attributed" ATS order and execution data (that is, GFIS does not have access to order or execution data identifying the subscriber that submitted the order or was party to a trade) or to any other ATS data that is not shared with ATS subscribers. GFIS does not have any employees. Periodically, as prescribed by IBKR's policies and procedures, all employees, shared employees, and third party service providers are reviewed to determine whether their level of access to ATS data is appropriate. This includes assessing whether the Accessing Party continues to have responsibilities in connection with the operation of the ATS or the ATS' compliance with applicable rules. Access to IBKR office and data center spaces is strictly controlled and limited to authorized personnel. Electronic door entry systems are in use and configured to allow personnel access only to the areas required to fulfill their job functions. Additionally, video recording/surveillance systems are employed in data centers and select office locations. Activity logs, including records of permitted and denied entry attempts captured by the access control and footage of the video surveillance system, are maintained. EMPLOYEE TRADING: The IBKR Employee Trading Policy prohibits IBKR employees from trading securities or commodity futures between the hours of 8:30 a.m. and 6:00 p.m. in their time zone. All IBKR employees, at onboarding and annually thereafter, are reminded of their obligation to identify all brokerage accounts in which the employee or any related person (as noted at FINRA rule 3210/.02) maintains an interest, including any brokerage accounts subsequently opened. IBKR obtains copies of such employee's account statements and trade confirmations from the relevant brokerage firm. IBKR prohibits an employee from opening or otherwise maintaining an account with a brokerage firm that will not provide IBKR with duplicate account statements and trade confirmations. IBKR compliance and supervisory personnel review employee account statements and trade confirmations on a monthly basis. As part of these reviews, IBKR compliance and supervisory personnel assess whether an employee has violated IBKR's Employee Trading Policy, including any indication of misuse of subscriber confidential trading information (in particular, the IBKR Employee Trading Policy, among other things, prohibits employees from trading on the basis of material non-public information). Employee trading conduct specifically reviewed for includes particularly active accounts and trading in any restricted securities outside of the "open window" period (presently limited to securities issued by Interactive Brokers Group, Inc.).

hours_of_operation

The ATS operates on an overnight basis, Sunday evening through Friday morning. The ATS accepts orders from 7:30 PM ET until 3:30 AM ET the following morning. The ATS effects transactions from 8:00 PM ET until 3:30 AM ET the following morning. For instance, during a typical week, the ATS will start accepting orders at 7:30 PM ET Sunday evening, and will effect transactions from 8:00 PM ET Sunday evening until 3:30 AM ET Monday morning. The last trading session for a standard week operates from 8:00 PM ET Thursday evening until 3:30 AM ET Friday morning (with the ATS accepting orders starting at 7:30 PM ET Thursday evening). The ATS does not operate a trading session Friday evening. The ATS observes the New York Stock Exchange's ("NYSE") holiday schedule in that the ATS will not operate a trading session where the NYSE is closed the next day (e.g., if the NYSE is closed on a Friday, the ATS will not operate a trading session that Thursday evening/Friday morning). The ATS does not adjust its hours of operation on days the NYSE has a scheduled early close.

hours_of_operation

The ATS operates on an overnight basis, Sunday evening through Friday morning. The ATS accepts orders from 7:30 PM ET until 4:00 AM ET the following morning. The ATS effects transactions from 8:00 PM ET until 4:00 AM ET the following morning. For instance, during a typical week, the ATS will start accepting orders at 7:30 PM ET Sunday evening, and will effect transactions from 8:00 PM ET Sunday evening until 4:00 AM ET Monday morning. The last trading session for a standard week operates from 8:00 PM ET Thursday evening until 4:00 AM ET Friday morning (with the ATS accepting orders starting at 7:30 PM ET Thursday evening). The ATS does not operate a trading session Friday evening. The ATS observes the New York Stock Exchange's ("NYSE") holiday schedule in that the ATS will not operate a trading session where the NYSE is closed the next day (e.g., if the NYSE is closed on a Friday, the ATS will not operate a trading session that Thursday evening/Friday morning). The ATS does not adjust its hours of operation on days the NYSE has a scheduled early close.

hours_of_operation

The ATS operates on an overnight basis, Sunday evening through Friday morning. The ATS accepts orders from 7:30 PM ET until 3:50 AM ET the following morning. The ATS effects transactions from 8:00 PM ET until 3:50 AM ET the following morning. For instance, during a typical week, the ATS will start accepting orders at 7:30 PM ET Sunday evening, and will effect transactions from 8:00 PM ET Sunday evening until 3:50 AM ET Monday morning. The last trading session for a standard week operates from 8:00 PM ET Thursday evening until 3:50 AM ET Friday morning (with the ATS accepting orders starting at 7:30 PM ET Thursday evening). The ATS does not operate a trading session Friday evening. The ATS observes the New York Stock Exchange's ("NYSE") holiday schedule in that the ATS will not operate a trading session where the NYSE is closed the next day (e.g., if the NYSE is closed on a Friday, the ATS will not operate a trading session that Thursday evening/Friday morning). The ATS does not adjust its hours of operation on days the NYSE has a scheduled early close.

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The following information is made available to Brokerage Customers and Liquidity Providers (including, for clarity, Brokerage Customers that are not permissioned to submit orders to the ATS) on a security-by-security basis during the ATS' regular trading hours (that is, from 8:00 PM ET to 3:50 AM ET): (i) highest resting bid price, lowest resting offer price and aggregate size at such price level ("Top of Book Data") and (ii) price and size of the last sale within the ATS ("Last Sale Data"). This information is also made available to the IBKR SOR and the IBKR SOR utilizes such information for routing purposes. ATS market data is provided on a non-attributed, real-time basis (that is, market data is not subject to any intentional delay, although there may be some latency in its dissemination). For clarity, this information is not disseminated from 7:30 PM ET to 8:00 PM ET (that is, when the ATS is accepting orders in a pending state prior to the start of trading). ATS market data is made available by IBKR's affiliate, GFIS. Brokerage Customers must utilize a Trading Product or the REST/Web API to view ATS market data. ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge. Subscribers receiving ATS market data via IBKR's REST/Web API offering may elect to receive Top of Book Data that excludes Liquidity Providers' orders (that is, they may elect to receive Top of Book Data that only represents resting orders of Brokerage Customers). For clarity, where a subscriber elects to receive Top of Book Data that excludes Liquidity Providers' orders, the Last Sale Data received by such subscriber will continue to include transactions involving Liquidity Providers. Other than the foregoing, there is no substantive difference in the ATS market data available via the Trading Products or other means of display.

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The following information is made available to Brokerage Customers and Liquidity Providers (including, for clarity, Brokerage Customers that are not permissioned to submit orders to the ATS) on a security-by-security basis during the ATS' regular trading hours (that is, from 8:00 PM ET to 3:50 AM ET): (i) highest resting bid price, lowest resting offer price and aggregate size at such price level ("Top of Book Data") and (ii) price and size of the last sale within the ATS ("Last Sale Date"). This information is also made available to the IBKR SOR, although the IBKR SOR does not utilize such information for routing purposes (as noted above, only orders directed to the ATS by a Brokerage Customer or Liquidity Provider may access the ATS). ATS market data is provided on a non-attributed, real-time basis (that is, market data is not subject to any intentional delay, although there may be some latency in its dissemination). For clarity, this information is not disseminated from 7:30 PM ET to 8:00 PM ET (that is, when the ATS is accepting orders in a pending state prior to the start of trading). ATS market data is made available by IBKR's affiliate, GFIS. Brokerage Customers must utilize a Trading Product or the REST/Web API to view ATS market data. ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge. Subscribers receiving ATS market data via IBKR's REST/Web API offering may elect to receive Top of Book Data that excludes Liquidity Providers' orders (that is, they may elect to receive Top of Book Data that only represents resting orders of Brokerage Customers). For clarity, where a subscriber elects to receive Top of Book Data that excludes Liquidity Providers' orders, the Last Sale Data received by such subscriber will continue to include transactions involving Liquidity Providers. Other than the foregoing, there is no substantive difference in the ATS market data available via the Trading Products or other means of display.

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The following information is made available to Brokerage Customers and Liquidity Providers (including, for clarity, Brokerage Customers that are not permissioned to submit orders to the ATS) on a security-by-security basis during the ATS' regular trading hours (that is, from 8:00 PM ET to 3:50 AM ET): (i) highest resting bid price, lowest resting offer price and aggregate size at such price level ("Top of Book Data") and (ii) price and size of the last sale within the ATS ("Last Sale Data"). This information is also made available to the IBKR SOR and the IBKR SOR utilizes such information for routing purposes. ATS market data is provided on a non-attributed, real-time basis (that is, market data is not subject to any intentional delay, although there may be some latency in its dissemination). For clarity, this information is not disseminated from 7:30 PM ET to 8:00 PM ET (that is, when the ATS is accepting orders in a pending state prior to the start of trading). As described in Part III, Item 7, orders submitted to the ATS are treated as either "Displayed Orders" or "Non-Displayed Orders" (by default, all orders are designated as Displayed Orders, although Brokerage Customers and Liquidity Providers may include instructions that an order be designated as a Non-Displayed Order). Top of Book Data distributed to Brokerage Customers and Liquidity Providers only includes information regarding Displayed Orders and, for clarity, does not include information regarding Non-Displayed Orders. Top of Book Data made available to the SOR includes information regarding both Displayed Orders and Non-Displayed Orders. Last Sale Data includes transaction information regarding both Displayed Orders and Non-Displayed Orders. See Part II Item 5 and Part III Item 7 for additional information regarding Top of Book Data and Displayed Orders and Non-Displayed Orders. ATS market data is made available to Brokerage Customers and Liquidity Providers by IBKR's affiliate, GFIS. Brokerage Customers must utilize a Trading Product or the REST/Web API to view ATS market data. ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge. Subscribers receiving ATS market data via IBKR's REST/Web API offering may elect to receive Top of Book Data that excludes Liquidity Providers' orders (that is, they may elect to receive Top of Book Data that only represents resting orders of Brokerage Customers). For clarity, where a subscriber elects to receive Top of Book Data that excludes Liquidity Providers' orders, the Last Sale Data received by such subscriber will continue to include transactions involving Liquidity Providers. Other than as described above, there is no substantive difference in the ATS market data available via the Trading Products or other means of display.

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The following information is made available to Brokerage Customers and Liquidity Providers (including, for clarity, Brokerage Customers that are not permissioned to submit orders to the ATS) on a security-by-security basis during the ATS' regular trading hours (that is, from 8:00 PM ET to 3:30 AM ET): (i) highest resting bid price, lowest resting offer price and aggregate size at such price level ("Top of Book Data") and (ii) price and size of the last sale within the ATS ("Last Sale Date"). This information is also made available to the IBKR SOR, although the IBKR SOR does not utilize such information for routing purposes (as noted above, only orders directed to the ATS by a Brokerage Customer or Liquidity Provider may access the ATS). ATS market data is provided on a non-attributed, real-time basis (that is, market data is not subject to any intentional delay, although there may be some latency in its dissemination). For clarity, this information is not disseminated from 7:30 PM ET to 8:00 PM ET (that is, when the ATS is accepting orders in a pending state prior to the start of trading). ATS market data is made available by IBKR's affiliate, GFIS. Brokerage Customers must utilize a Trading Product or the REST/Web API to view ATS market data. ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge. Subscribers receiving ATS market data via IBKR's REST/Web API offering may elect to receive Top of Book Data that excludes Liquidity Providers' orders (that is, they may elect to receive Top of Book Data that only represents resting orders of Brokerage Customers). For clarity, where a subscriber elects to receive Top of Book Data that excludes Liquidity Providers' orders, the Last Sale Data received by such subscriber will continue to include transactions involving Liquidity Providers. Other than the foregoing, there is no substantive difference in the ATS market data available via the Trading Products or other means of display.

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The following information is made available to Brokerage Customers and Liquidity Providers (including, for clarity, Brokerage Customers that are not permissioned to submit orders to the ATS) on a security-by-security basis during the ATS' regular trading hours (that is, from 8:00 PM ET to 4:00 AM ET): (i) highest resting bid price, lowest resting offer price and aggregate size at such price level and (ii) price and size of the last sale within the ATS. This information is also made available to the IBKR SOR, although the IBKR SOR does not utilize such information for routing purposes (as noted above, only orders directed to the ATS by a Brokerage Customer or Liquidity Provider may access the ATS). ATS market data is provided on a non-attributed, real-time basis (that is, market data is not subject to any intentional delay, although there may be some latency in its dissemination). For clarity, this information is not disseminated from 7:30 PM ET to 8:00 PM ET (that is, when the ATS is accepting orders in a pending state prior to the start of trading). ATS market data is made available by IBKR's affiliate, GFIS. Brokerage Customers must utilize a Trading Product or the REST/Web API to view ATS market data. Liquidity Providers may only access ATS market data via the REST/Web API. ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge. There is no difference in the ATS market data available to different classes of subscribers (e.g., Liquidity Providers and Brokerage Customers), nor is there any substantive difference in the market data received based on the means of access to the market data.

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The following information is made available to Brokerage Customers and Liquidity Providers (including, for clarity, Brokerage Customers that are not permissioned to submit orders to the ATS) on a security-by-security basis during the ATS' regular trading hours (that is, from 8:00 PM ET to 3:30 AM ET): (i) highest resting bid price, lowest resting offer price and aggregate size at such price level and (ii) price and size of the last sale within the ATS. This information is also made available to the IBKR SOR, although the IBKR SOR does not utilize such information for routing purposes (as noted above, only orders directed to the ATS by a Brokerage Customer or Liquidity Provider may access the ATS). ATS market data is provided on a non-attributed, real-time basis (that is, market data is not subject to any intentional delay, although there may be some latency in its dissemination). For clarity, this information is not disseminated from 7:30 PM ET to 8:00 PM ET (that is, when the ATS is accepting orders in a pending state prior to the start of trading). ATS market data is made available by IBKR's affiliate, GFIS. Brokerage Customers must utilize a Trading Product or the REST/Web API to view ATS market data. Liquidity Providers may only access ATS market data via the REST/Web API. ATS market data is made available to Brokerage Customers and Liquidity Providers at no charge. There is no difference in the ATS market data available to different classes of subscribers (e.g., Liquidity Providers and Brokerage Customers), nor is there any substantive difference in the market data received based on the means of access to the market data.

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Orders submitted to the ATS prior to the start of trading hours (that is, orders submitted between 7:30 PM ET and 8:00 PM ET) become eligible for execution at 8:00 PM ET. The ATS does not have any special procedures to match orders at the start of trading hours; rather, all resting orders are matched in accordance with the ATS' standard matching logic and priority.