Virtu MatchIt ATS

amendment_reason

Changes have been made to Part III Item 8(a) to include human participant size thresholds and Exhibit 1 to reflect changes to the Firm's For BD. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Items 7(a) and 11(c) to reflect the completion of the symbol by symbol rollout of changes to the manner of operation of the Continuous Crossing Session. These changes reflect the removal of the rollout schedule as well as the removal of language pertaining to the previous manner of operation. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Item 1a to amend the MPID used by the High Touch Portfolio Trading desk to VALR. Revisions to this item apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Exhibit 1 to reflect updates to the Firm's Form BD. Revisions to this item applies to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II Item 2a to name VAL's foreign affiliates, Part III Item 14a to add indirect subscribers to the Self-Match prevention, Part III Item 19a to provide details on CAT Fees and Part II Item 6b, Part III Items 21a and 22a to change references of the NYSE TRF to the NASDAQ Chicago TRF and Part III Items 20 and 21a to note that in the event that MatchIt is unable to report transactions to the TRF, it will cease trading, cancel existing orders, and reject new orders. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Item 9(a) to clarify that when a request to firm up message is sent to an electronic participant, their original conditional order gets automatically canceled. Changes have also been made to Part II, Items 1(a), 2(a) and 3(a) to remove MPIDs that are no longer used to submit orders to POSIT. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III Item 6a to provide additional details on the migration of Subscriber fix sessions in NY4 to direct matching engine connection in NY5. Revisions to this item apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part I, Item 7 to remove a secondary location. Revisions to this item applies to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Item 1a to remove the NITE MPID that is no longer in use and Part II, Item 6a to standardize language around access to ATS information. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III Item 19(a) to update the lower bound of the fee range. Revisions to this item apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Item 9(a) to remove the exception to the Invitation to Firm-Up invitation sequence. Revisions to this item apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Items 19(a) to update fees. Revisions to this item apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Item 23(a) to provide additional clarity around the proprietary market data system used. Revisions to this item apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Item 19 to adjust the lower bound of fees the Firm charges. Revisions to this item apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Items 1(a) and 2(a) to remove references to the ITGI MPID which no longer routes orders to the MatchIt ATS, as well as Part II Item 4(a) to remove a trading center. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II Item 6b, Part III Item 5a and Part III Item 6a to reflect the migration of Subscriber fix sessions in NY4 to direct matching engine connection in NY5, which will occur on a first come first served basis over several months. Changes have also been made to Part III, Item 11c to remove the option to configure risk checks for Subscribers. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III Item 14(a) to reflect that POSIT Alert human participants can request to block individual symbols. Revisions to this item apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II Items 3(a) and 6(a) as well as Part III Items 7(a), 9(a), 11(a), 11(c), 13(a), 13(b), 13(d), 13(e), 14(a), 17(a), 20(a) and 23(a). These changes reflect new matching rules, revised segmentation logic, changes to counterparty blocking and the discontinuation of the Agency Close Crossing Session. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Item 6a to note that the finance and management reporting team have access to real time ATS information and members of the US executive management team have access to ATS information. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Items 19(a) to update fees and 23(a) to update market data disclosures. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Item 9(a) to adjust Electronic Participants' response time to the Invitation to Firm-Up from 2 seconds to 1 second. Changes have also been made to Part III, Item 14(a) to include an automated symbol block between Electronic Participants. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Items 1,2 and 3 to reflect the migration of market making activities of the broker-dealer Virtu Financial BD into Virtu Americas. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Item 9 to describe how Human Participants may configure the Alert software to automatically route any remaining quantity of an order from the POSIT ATS to VAL's algorithms. Conforming changes have also been made to Part III, Item 5(c). Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Item 7(a) to reflect removal of POSIT aggregated anonymous data from firm-wide trade advertisements and Part III, Item 14a to update the blocking functionality performed in POSIT Alert. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Item 1a to remove the NITE MPID that is no longer in use, Part II, Item 6a to standardize language around access to ATS information, and Part III, Item 7a to note that Alert accepts IOC orders, which can be canceled upon submission. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Items 1a and 2a to remove MPIDs that are no longer used to submit orders to MatchIt. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Item 7a to remove default peg instructions for day orders. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Item 1(a) to clarify that ALTX cannot enter or direct the entry of orders into the Alert Crossing Session. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III Items 8(a), 8(c), 8(d) and 8(e) to reflect that POSIT will begin accepting and executing odd lot orders as well as the odd lot portion of mixed lots. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III Items 8(a) to update the contra side order dollar notional value threshold for Human Participants, 19(a) to clarify that VAL and VAL Affiliates are not assessed a fee for POSIT trades, and 23(a) to update market data disclosures. Changes have also been made to Part III Items 19(a), 19(b), 19(c) and 20(a) to align descriptions to those in the Form ATS-N for VAL's MatchIt ATS. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

This is an updating amendment to the material amendment filed on June 9, 2021. Changes have been made to Part II Items 3(a) and 6(a) as well as Part III Items 7(a), 9(a), 11(a), 11(c), 13(a), 13(b), 13(d), 14(a), 17(a), 20(a) and 23(a). These changes reflect new matching rules, revised segmentation logic, changes to counterparty blocking and the discontinuation of the Agency Close Crossing Session. New matching rules include changing order priority to price/size/time, giving liquidity providers 100% of potential price improvement, and allowing orders to match at any permissible price point within the NBBO. The change to POSIT's segmentation is the introduction of a new segmentation logic that segments subscribers based on markouts after the time of fill. Changes to counterparty blocking include providing Subscribers with the option to block participants that fall into certain segments based on markouts after the fill, and the discontinuation of Liquidity Guard and individual contra blocking. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Items 1(a), 2(a) and 3(a) to remove references to the ITGI MPID which no longer routes orders to the POSIT ATS and adjust general language to align to the Firm's disclosures for its other ATS, MatchIt. Changes have also been made to Part II Item 4a to remove a trading center, and Part III Item 19(a) to adjust the fees paid by direct subscribers. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Item 7a as a correction to the current filing to include default peg instructions for day and IOC orders. Changes have also been made to Part III, Item 11c to clarify descriptions around order types available to clients. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III, Item 13a to amend order types that remove liquidity and explain that for a liquidity removal order that includes a Liquidity Profile blocking instruction, the order will be accepted but the instruction ignored. Changes have also been made to Part III, Item 13d to describe information included in Subscriber post-trade reports. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Item 3(a) and Part III, Items 7(a) and 14(a) to update the criteria for the principal opt out. Changes have also been made to Part II, Items 2(a) and 5(c) to address the migration of algorithms and routing services from Virtu Financial Capital Markets LLC ("VFCM") to VAL under Virtu Electronic Trading ("VET"). Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III Item 9(a) to update the number of seconds electronic participants have to respond to an Invitation to Firm-up and to clarify that requests to aggregate an Alert participant's orders for execution are only available to human participants. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part III Item 19(a) to update the range of rates charged to Direct Subscribers not using other products. Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

amendment_reason

Changes have been made to Part II, Item 7a to reflect an end to trade advertisements originating from executions in MatchIt. Changes have also been made to Part II to address the consolidation of Virtu ITG LLC ("VITG") and Alternet Securities LLC ("AlterNet") with VAL, including Items: 1a (migration of High Touch Portfolio Trading business to VAL), 2a and 5c (removal of VITG and Alternet as VAL affiliates), and 4a and 6a (migration of POSIT ATS to VAL). Revisions to these items apply to the Broker Dealer Operator and its Subscribers.

ats_name

Virtu MatchIt

order_types

Continuous Crossing Session POSIT accepts Peg orders and Immediate or Cancel ("IOC") orders. Peg orders may execute against contra-side Peg orders or against IOC orders. IOC orders may only execute against contra-side Peg orders. These order types may be entered with other instructions, as described below, that will be used by the matching algorithm to determine whether and how they will interact with other orders. (1) Peg Orders: Peg orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Peg orders can be designated with the following execution instruction: (i) Market: A Market instruction designates that a buy order can be executed up to the national best offer and a sell order can be executed down to the national best bid. (ii) Mid-Point: A Mid-Point instruction designates that an order can be executed up to the mid-point between the national best bid and national best offer ("NBBO"). (iii) Primary: A Primary instruction designates that the order can only be executed at the national best bid in the case of a buy order and the national best offer in the case of a sell order. (iv.) Limit Price: A Limit Price instruction specifies a price above which a buy order and below which a sell order that the order will not be eligible for execution. (2) IOC Orders: IOC orders will either execute if an eligible contra side order exists against which the order can be executed or if not the order is canceled. Subscribers may enter IOC orders with Market, Mid-Point and Limit Price instructions. Subscribers can include Minimum Execution Quantity ("MEQ") instructions on their orders via FIX, which specifies the minimum number of shares that must be available for a contra side order to be eligible for execution. Subscribers can also request to apply the following instructions on their orders at the session level: (i) Locked Market: Direct and Indirect Subscribers may request a Locked Market instruction, which specifies that an order is not eligible for execution during locked markets. IOC orders entered with a Locked Market instruction will be rejected if the NBBO is locked. Peg orders will be accepted but ineligible for execution until the NBBO unlocks. (ii) Virtu Principal Opt-Out: Direct and Indirect Subscribers may request to have their orders not interact with Virtu principal. This instruction will only prevent interaction against orders entered by VAL under the MPID's NITE, VIRT and VALX. Principal orders entered by VAL or the Affiliates using other MPIDs will not be subject to this opt out. See Part 2, Item 3b for more detail. (iii) MEQ Instruction Non-Aggregation: Direct and Indirect Subscribers may request that multiple orders are not aggregated to meet a MEQ instruction. By default, POSIT will aggregate orders to meet a Subscriber's MEQ instruction. (iv) Cancel Residual if Below MEQ Instruction: Direct and Indirect Subscribers may request that a residual quantity be canceled back to the Subscriber if the residual quantity is less than the Subscriber's MEQ instruction. By default, POSIT will not cancel back an order if the residual is less than the MEQ instruction. (v) Default Peg Instructions: Direct and Indirect Subscribers may request that their IOC and/or Day orders have a Default Peg instruction. An order that contains a value in a utilized FIX field other than a value recognized by VAL (as described in its FIX specifications) will be rejected. An order containing a value in a non- utilized FIX field will be accepted, but that instruction will not be processed. Subscribers can route orders to the Agency Close Crossing Session, which are subject to specific time-in-force and order type attributes, as described in Part III, Item 17. For resting Peg orders, priority in POSIT is based on the price instruction, i.e. market, mid, or primary. Resting Peg orders that can be executed at the same price receive a pro rata share allocation. However, POSIT will always attempt to execute at the midpoint of the NBBO, prior to executing at the NBB or NBO. Resting Peg orders with market instructions on the same side of the market will execute at the midpoint in a pro rata share allocation along with resting Peg orders with midpoint instructions also on the same side of the market. Peg orders with primary instructions, cannot execute at the midpoint, and would not participate and receive shares in a pro rata allocation when there are resting Peg orders with market and or midpoint price instructions on the same side. For IOC orders and Peg orders that remove liquidity, these orders are processed one at a time in time sequence. The following examples illustrate the matching process, assuming there are no instructions that would prevent an execution such as MEQ or a Limit Price that would be an order ineligible based upon the current NBBO. Example 1: Market bid/offer: $10.00 x $10.10 In POSIT, Order 1 is a Midpoint Peg order to buy 1,000 shares and Order 2 is a Market Peg order to buy 1,000 shares. An in-bound Peg order or IOC order with market or midpoint instructions to sell 1,000 shares is entered into POSIT. An execution of 1000 shares will occur at midpoint, with Order 1 receiving 500 shares, and Order 2 receiving 500 shares. Example 2: Market bid/offer: $10.00 x $10.10 In POSIT, Order 1 is a Midpoint Peg order to buy 1,000 shares and Order 2 is a Primary Peg order to buy 1,000 shares. An in-bound Peg order or IOC order with market or midpoint instructions to sell 1,000 shares is entered into POSIT. An execution of 1000 shares will occur at midpoint of the NBBO, with Order 1 receiving 1000 shares and Order 2 receiving no shares. Alert Crossing Session The Alert Crossing Session supports all of the order types and instructions described in the Continuous Crossing Session section in Part III, Item 7(a), with the exception that the Alert Crossing Session does not accept IOC orders. Additionally, the below order type instructions are only available in the Alert Crossing Session. (i) Conditional Indicator: Peg orders entered into the Alert Crossing Session are by default designated as Conditional Orders. Conditional Orders are not firm and must respond affirmatively to an Invitation to Firm-Up from the Alert Crossing Session by transmitting a Firm-Up Response Order to be eligible to be executed against contra-side orders. (ii) Firm-Up Response Order: These orders are entered in response to invitations from the Alert Crossing Session. (iii) Auto-Ex: Human Participants, as described in Part III, Item 9(a), can designate a Conditional Order as Auto-Ex. If the Auto-Ex instruction is enabled for a Conditional Order, the Human Participant will not receive a pop up window requesting to Firm-Up, as described in Part III, Item 9(a), but instead the Conditional Order from the Human Participant will automatically Firm-Up against a contra side order. See Part III, Item 9a for more detail on the Alert Crossing Session. Agency Close Crossing Session For the Agency Close Crossing session, Subscribers can only submit Peg orders with a Market Peg instruction and a time in force of close. See Part III, Item 11(c) for more detail on the Agency Close Crossing Session.

order_types

Continuous Crossing Session POSIT accepts Peg orders, Day orders and Immediate or Cancel ("IOC") orders. Peg and Day orders may execute against contra-side Peg orders, contra-side Day orders or against IOC orders. IOC orders may only cross against contra-side Peg orders or contra-side Day orders. These order types may be entered with other instructions that will be used by the matching algorithm to determine whether and how they will interact with other orders. Priority in the POSIT Continuous Crossing Session for all order types is price, then size, then time. For orders without a peg instruction, the limit price submitted is used to determine the price portion of the queue priority. For orders with a peg instruction, the less aggressive price between the current peg price and limit price submitted is used to determine the price portion of the queue priority. If the algorithm modifies the terms of a previously transmitted order, the order will receive a new order time stamp for matching purposes (i.e. the order will lose queue spot). The only exception is a reduction in order quantity which, absent any other changes to the terms of the order, will not update the order time stamp for matching purposes. The following instructions are available for orders entered in the POSIT Continuous Crossing Session. The instructions placed on orders will affect whether an order is eligible to be executed against contra-side orders. (1) Peg Orders: Peg orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Peg orders can be designated with the following execution instruction: (i) Market: A Market instruction designates that a buy order can be executed up to the national best offer and a sell order can be executed down to the national best bid. (ii) Mid-Point: A Mid-Point instruction designates that an order can be executed up to the mid-point between the national best bid and national best offer ("NBBO"). (iii) Primary: A Primary instruction designates that the order can only be executed at the national best bid in the case of a buy order and the national best offer in the case of a sell order. A Limit Price instruction can be specified for Peg orders in conjunction with the above referenced execution instruction. (2) Day Orders: Day orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Day orders can also include a Market, Mid-Point, Primary Peg or Limit Price instruction. (3) IOC Orders: IOC orders will either execute if an eligible contra side order exists against which the order can be executed or if not the order is canceled. Subscribers may enter IOC orders with Market, Mid-Point, Primary Peg or Limit Price instructions. Other available Instructions and Designations for the Continuous Crossing Session: The following instructions may be applied to the above order types unless otherwise indicated. These instructions may be implemented by either transmitting a specified value over a FIX tag on an order by order basis, or requesting a session level configuration that will apply the requested instruction across all orders sent to the session specified by the Direct Subscriber, unless otherwise indicated: (i) Minimum Execution Quantity (MEQ): An MEQ instruction specifies the minimum number of shares that must be available for a contra side order to be eligible for execution. POSIT does not aggregate multiple contra side orders to satisfy a MEQ instruction on a single order. POSIT will cancel back an order to the Direct Subscriber if the residual quantity of an order falls below the MEQ instruction. (ii) Locked Market: A Locked Market instruction specifies that an order is not eligible for execution during locked markets. IOC orders entered with a Locked Market instruction will be accepted if the NBBO is locked, but will receive a 'Nothing Done' message. Peg orders will be accepted but ineligible for execution until the NBBO unlocks. (iii) Peg Order Add-Only Liquidity Instruction ("Add Only"): An Add-Only instruction specifies that the order is only eligible for execution when it adds liquidity to POSIT upon entry. Peg orders that would remove liquidity from POSIT will be accepted by POSIT and remain open but ineligible for execution until such a time as the order adds liquidity to POSIT. Contra-side Peg orders on the book at the time a Peg order with an Add Only instruction is entered will not interact with the Peg Add Only order. The Add Only instruction will be ignored if specified for an IOC order. (iv) Virtu Principal Opt Out: Direct and Indirect Subscribers may request to have their orders not interact with Virtu principal orders. This instruction will only prevent interaction against orders entered by VAL under the MPID's NITE, VIRT and VALX. Principal orders entered by VAL or the Affiliates, as defined in Part II, Item 2a, using other MPIDs will not be subject to this opt out. See Part II, Item 3a for more detail. This order instruction can only be specified at the session level, and cannot be specified on an order by order basis via a FIX tag. (v) POSIT Liquidity Profiles and Limits on Interaction: This instruction specifies the types of counterparties that an order may interact with based on the counterparty's Liquidity Profile. POSIT uses quantitative metrics to create one or more Liquidity Profiles for each POSIT Subscriber. The metrics include execution performance relative to the market over different time horizons for all fills in POSIT. POSIT makes discretionary decisions in assigning a Liquidity Profile to a new or previously uncategorized Subscriber. POSIT will inform Subscribers about their own profile information upon request. See Part III, Item 13a for more detail on POSIT Liquidity Profiles. (vi) Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. This order instruction can only be specified at the session level, and cannot be specified on an order by order basis via a FIX tag. An order that contains a value in a utilized FIX field other than a value recognized by VAL (as described in its FIX specifications) will be rejected. An order containing a value in a non- utilized FIX field will be accepted, but that instruction will not be processed. Alert Crossing Session The Alert Crossing Session supports all of the order types and instructions described in the Continuous Crossing Session section in Part III, Item 7(a), with the exception that the Alert Crossing Session does not accept IOC orders. Additionally, the below order type instructions are only available in the Alert Crossing Session. (i) Conditional Indicator: Peg orders entered into the Alert Crossing Session are by default designated as Conditional Orders. Conditional Orders are not firm and must respond affirmatively to an Invitation to Firm-Up from the Alert Crossing Session by transmitting a Firm-Up Response Order to be eligible to be executed against contra-side orders. (ii) Firm-Up Response Order: These orders are entered in response to invitations from the Alert Crossing Session. (iii) Auto-Ex: Human Participants, as described in Part III, Item 9(a), can designate a Conditional Order as Auto-Ex. If the Auto-Ex instruction is enabled for a Conditional Order, the Human Participant will not receive a pop up window requesting to Firm-Up, as described in Part III, Item 9(a), but instead the Conditional Order from the Human Participant will automatically Firm-Up against a contra side order. See Part III, Item 9a for more detail on the Alert Crossing Session.

order_types

For both the Main and Conditional Sessions, MatchIt accepts Peg orders and Immediate or Cancel ("IOC") orders. Peg orders may cross with contra-side Peg orders or with IOC orders. IOC orders may only cross with contra-side Peg orders. These order types may be entered with other instructions that will be used by the matching algorithm to determine whether and how they will interact with other orders. Priority in the MatchIt Main Session for all order types is price, then time. If a Subscriber modifies the terms of a previously transmitted order, the order will receive a new order time stamp for matching purposes (i.e. the order will lose queue spot). The only exception is a reduction in order quantity which, absent any other changes to the terms of the order, will not update the order time stamp for matching purposes. Priority in the MatchIt Conditional Session for all order types is price, then size, then time. If the algorithm modifies the terms of a previously transmitted order, the order will receive a new order time stamp for matching purposes (i.e., the order will lose queue spot). The only exception is a reduction in order quantity which, absent any other changes to the terms of the order, will not update the order time stamp for matching purposes. The following instructions are available for orders entered in both the Main Session and the Conditional Session. The instructions placed on orders will affect whether an order is eligible to be executed against contra-side orders. (1) Peg Orders: Peg orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Peg orders can be designated with the following execution instruction: (i) Market: A Market instruction designates that the order can pay the full spread. For example, a buy order can be executed up to the national best offer and a sell order can be executed down to the national best bid. (ii) Mid-Point: A Mid-Point instruction designates that an order can pay up to the mid-point between the national best bid and national best offer ("NBBO"). (iii) Primary: A Primary instruction designates that the order can only be executed at the national best bid in the case of a buy order and the national best offer in the case of a sell order. (iv.) Limit Price: A Limit Price instruction specifies a price above which a buy order and below which a sell order that the order will not be eligible for execution. (2) IOC Orders: IOC orders will either execute if an eligible contra side order exists against which the order can be executed or if not the order is canceled. IOC orders can also include a Market, Mid-Point, Primary, or Limit Price instruction. Other available Instructions and Designations for the Main and Conditional Sessions: The following instructions may be applied to the above order types unless otherwise indicated. These instructions may be implemented by transmitting specified values on the order or by requesting configurations that will apply particular instructions after receipt of the order: (i) Minimum Execution Quantity ("MEQ"): An MEQ instruction specifies the minimum number of shares that must be available for a contra side order to be eligible for execution. (ii) Locked Market: A Locked Market instruction specifies that an order is not eligible for execution during locked markets. IOC orders entered with a Locked Market instruction will be rejected if the NBBO is locked. Peg orders will be accepted but ineligible for execution until the NBBO unlocks. (iii) Peg Order Add-Only Liquidity Instruction ("Add Only"): An Add-Only instruction specifies that the order is only eligible for execution when it adds liquidity to MatchIt upon entry. Peg orders that would remove liquidity from MatchIt will be accepted by MatchIt and remain open but ineligible for execution until such a time as the order adds liquidity to MatchIt. Contra-side Peg orders on the book at the time a Peg order with an Add Only instruction is entered will not interact with the Peg Add Only order. (iv) Soft Dollar Instruction: A Soft Dollar instruction will only allow riskless principal or agency crossing. To the extent that an order with a Soft Dollar instruction interacts with an order submitted by VCMM, MatchIt will pass information on the execution message so that the market maker's systems transact with its underlying client according to FINRA's definition of "riskless principal," i.e., at the same price, as the execution received in MatchIt. (v) Virtu Principal Opt Out: VAL and VAL Affiliates may submit instructions on orders that prevent interactions with Virtu principal orders, as described in Part II, item 3(a). This instruction is not available to Direct Subscribers. (vi) MatchIt Subscriber Profiles and Limits on Interaction: This instruction specifies the types of counterparties that an order may interact with based on the counterparty's Liquidity Profile. MatchIt uses quantitative metrics to create one or more Liquidity Profiles for each MatchIt Subscriber. The metrics include execution performance relative to the market over different time horizons when removing liquidity from MatchIt. MatchIt makes discretionary decisions in assigning a Liquidity Profile to a new or previously uncategorized Subscribers. MatchIt will inform Subscribers about their own profile information upon request. (vii) Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. See Attachment for Part III, 7a for details on available instructions and designations for the Conditional Session only.

order_types

For the Main Session, MatchIt accepts Peg orders, Day orders and Immediate or Cancel (?IOC?) orders. Peg and Day orders may cross with contra-side Peg orders, contra-side Day orders or with IOC orders. IOC orders may only cross with contra-side Peg orders or contra-side Day orders. These order types may be entered with other instructions that will be used by the matching algorithm to determine whether and how they will interact with other orders. For the Conditional Session, MatchIt accepts Peg orders and IOC orders. Peg orders may cross with contra-side Peg orders or with IOC orders. IOC orders may only cross with contra-side Peg orders. These order types may be entered with other instructions that will be used by the matching algorithm to determine whether and how they will interact with other orders. Priority in the MatchIt Main Session for all order types is price, then time. If a Subscriber modifies the terms of a previously transmitted order, the order will receive a new order time stamp for matching purposes (i.e. the order will lose queue spot). The only exception is a reduction in order quantity which, absent any other changes to the terms of the order, will not update the order time stamp for matching purposes. Priority in the MatchIt Conditional Session for all order types is price, then size, then time. If the algorithm modifies the terms of a previously transmitted order, the order will receive a new order time stamp for matching purposes (i.e., the order will lose queue spot). The only exception is a reduction in order quantity which, absent any other changes to the terms of the order, will not update the order time stamp for matching purposes. The following instructions are available for orders entered in both the Main Session and the Conditional Session. The instructions placed on orders will affect whether an order is eligible to be executed against contra-side orders. (1) Peg Orders: Peg orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Peg orders can be designated with the following execution instruction: (i) Market: A Market instruction designates that the order can pay the full spread. For example, a buy order can be executed up to the national best offer and a sell order can be executed down to the national best bid. (ii) Mid-Point: A Mid-Point instruction designates that an order can pay up to the mid-point between the national best bid and national best offer (?NBBO?). (iii) Primary: A Primary instruction designates that the order can only be executed at the national best bid in the case of a buy order and the national best offer in the case of a sell order. A Limit Price instruction can be specified for Peg orders in conjunction with the above referenced execution instruction. (2) Day Orders: Day orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Day orders can also include a Market, Mid-Point, Primary or Limit Price instruction. Day orders will default to Mid-Point peg if a peg instruction is not specified. (3) IOC Orders: IOC orders will either execute if an eligible contra side order exists against which the order can be executed or if not the order is canceled. IOC orders can also include a Market, Mid-Point, Primary, or Limit Price instruction. IOC orders will default to Primary Peg if a peg instruction is not specified. Other available Instructions and Designations for the Main and Conditional Sessions: The following instructions may be applied to the above order types unless otherwise indicated. These instructions may be implemented by transmitting specified values on the order or by requesting configurations that will apply particular instructions after receipt of the order: (i) Minimum Execution Quantity (?MEQ?): An MEQ instruction specifies the minimum number of shares that must be available for a contra side order to be eligible for execution. (ii) Locked Market: A Locked Market instruction specifies that an order is not eligible for execution during locked markets. IOC orders entered with a Locked Market instruction will be rejected if the NBBO is locked. Peg orders will be accepted but ineligible for execution until the NBBO unlocks. (iii) Peg Order Add-Only Liquidity Instruction (?Add Only?): An Add-Only instruction specifies that the order is only eligible for execution when it adds liquidity to MatchIt upon entry. Peg orders that would remove liquidity from MatchIt will be accepted by MatchIt and remain open but ineligible for execution until such a time as the order adds liquidity to MatchIt. Contra-side Peg orders on the book at the time a Peg order with an Add Only instruction is entered will not interact with the Peg Add Only order. (iv) Soft Dollar Instruction: A Soft Dollar instruction will only allow riskless principal or agency crossing. To the extent that an order with a Soft Dollar instruction interacts with an order submitted by VCMM, MatchIt will pass information on the execution message so that the market maker's systems transact with its underlying client according to FINRA's definition of "riskless principal," i.e., at the same price, as the execution received in MatchIt. (v) Virtu Principal Opt Out: VAL and VAL Affiliates may submit instructions on orders that prevent interactions with Virtu principal orders, as described in Part II, item 3(a). This instruction is not available to Direct Subscribers. (vi) MatchIt Subscriber Profiles and Limits on Interaction: This instruction specifies the types of counterparties that an order may interact with based on the counterparty's Liquidity Profile. MatchIt uses quantitative metrics to create one or more Liquidity Profiles for each MatchIt Subscriber. The metrics include execution performance relative to the market over different time horizons when removing liquidity from MatchIt. MatchIt makes discretionary decisions in assigning a Liquidity Profile to a new or previously uncategorized Subscribers. MatchIt will inform Subscribers about their own profile information upon request. (vii) Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. See Attachment for Part III, 7a for details on available instructions and designations for the Conditional Session only.

order_types

Continuous Crossing Session Beginning on July 12, 2021, VAL will make changes to the POSIT Continuous Crossing Session in terms of its manner of operations on a symbol by symbol basis. Descriptions to follow under the heading 'New Matcher' will apply to symbols that have migrated to this new manner of operation under the schedule set forth below, while descriptions under the heading 'Current Matcher' will apply to symbols that remain in the current manner of operation under the schedule set forth below. Migration Schedule July 12, 2021: New Matcher: Symbol: ZVZZT, Current Matcher: All other symbols July 14, 2021: New Matcher: Symbols: ZVZZT, ZWZZT, ZXIET, ZXYZ.A, ZXZZT, ZY, ZYME, ZYNE, ZYXI, ZZK, ZZZ Current Matcher: All other symbols July 16, 2021: New Matcher: All symbols beginning with the letter 'Z', Current Matcher: All other symbols July 19, 2021: New Matcher: All symbols beginning with the letters 'T' ? 'Z', Current Matcher: All other symbols July 21, 2021: New Matcher: All symbols beginning with the letters 'N' ? 'Z', Current Matcher: All other symbols July 23, 2021: New Matching: All symbols, Current Matcher: No symbols New Matcher POSIT accepts Peg orders, Day orders and Immediate or Cancel ("IOC") orders. Peg and Day orders may execute against contra-side Peg orders, contra-side Day orders or against IOC orders. IOC orders may only cross against contra-side Peg orders or contra-side Day orders. These order types may be entered with other instructions that will be used by the matching algorithm to determine whether and how they will interact with other orders. Priority in the POSIT Continuous Crossing Session for all order types is price, then size, then time. For orders without a peg instruction, the limit price submitted will be used to determine the price portion of the queue priority. For orders with a peg instruction, the less aggressive price between the current peg price and limit price submitted will be used to determine the price portion of the queue priority. If the algorithm modifies the terms of a previously transmitted order, the order will receive a new order time stamp for matching purposes (i.e. the order will lose queue spot). The only exception is a reduction in order quantity which, absent any other changes to the terms of the order, will not update the order time stamp for matching purposes. The following instructions are available for orders entered in the POSIT Continuous Crossing Session. The instructions placed on orders will affect whether an order is eligible to be executed against contra-side orders. (1) Peg Orders: Peg orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Peg orders can be designated with the following execution instruction: (i) Market: A Market instruction designates that a buy order can be executed up to the national best offer and a sell order can be executed down to the national best bid. (ii) Mid-Point: A Mid-Point instruction designates that an order can be executed up to the mid-point between the national best bid and national best offer ("NBBO"). (iii) Primary: A Primary instruction designates that the order can only be executed at the national best bid in the case of a buy order and the national best offer in the case of a sell order. A Limit Price instruction can be specified for Peg orders in conjunction with the above referenced execution instruction. (2) Day Orders: Day orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Day orders can also include a Market, Mid-Point, Primary Peg or Limit Price instruction. (3) IOC Orders: IOC orders will either execute if an eligible contra side order exists against which the order can be executed or if not the order is canceled. Subscribers may enter IOC orders with Market, Mid-Point, Primary Peg or Limit Price instructions. Other available Instructions and Designations for the Continuous Crossing Session: The following instructions may be applied to the above order types unless otherwise indicated. These instructions may be implemented by either transmitting a specified value over a FIX tag on an order by order basis, or requesting a session level configuration that will apply the requested instruction across all orders sent to the session specified by the Direct Subscriber, unless otherwise indicated: (i) Minimum Execution Quantity (MEQ): An MEQ instruction specifies the minimum number of shares that must be available for a contra side order to be eligible for execution. POSIT does not aggregate multiple contra side orders to satisfy a MEQ instruction on a single order. POSIT will cancel back an order to the Direct Subscriber if the residual quantity of an order falls below the MEQ instruction. (ii) Locked Market: A Locked Market instruction specifies that an order is not eligible for execution during locked markets. IOC orders entered with a Locked Market instruction will be accepted if the NBBO is locked, but will receive a 'Nothing Done' message. Peg orders will be accepted but ineligible for execution until the NBBO unlocks. (iii) Peg Order Add-Only Liquidity Instruction ("Add Only"): An Add-Only instruction specifies that the order is only eligible for execution when it adds liquidity to POSIT upon entry. Peg orders that would remove liquidity from POSIT will be accepted by POSIT and remain open but ineligible for execution until such a time as the order adds liquidity to POSIT. Contra-side Peg orders on the book at the time a Peg order with an Add Only instruction is entered will not interact with the Peg Add Only order. The Add Only instruction will be ignored if specified for an IOC order. (iv) Virtu Principal Opt Out: Direct and Indirect Subscribers may request to have their orders not interact with Virtu principal orders. This instruction will only prevent interaction against orders entered by VAL under the MPID's NITE, VIRT and VALX. Principal orders entered by VAL or the Affiliates, as defined in Part II, Item 2a, using other MPIDs will not be subject to this opt out. See Part II, Item 3a for more detail. This order instruction can only be specified at the session level, and cannot be specified on an order by order basis via a FIX tag. (v) POSIT Liquidity Profiles and Limits on Interaction: This instruction specifies the types of counterparties that an order may interact with based on the counterparty's Liquidity Profile. POSIT uses quantitative metrics to create one or more Liquidity Profiles for each POSIT Subscriber. The metrics include execution performance relative to the market over different time horizons for all fills in POSIT. POSIT makes discretionary decisions in assigning a Liquidity Profile to a new or previously uncategorized Subscriber. POSIT will inform Subscribers about their own profile information upon request. See Part III, Item 13a for more detail on POSIT Liquidity Profiles. (vi) Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. This order instruction can only be specified at the session level, and cannot be specified on an order by order basis via a FIX tag. An order that contains a value in a utilized FIX field other than a value recognized by VAL (as described in its FIX specifications) will be rejected. An order containing a value in a non- utilized FIX field will be accepted, but that instruction will not be processed. Current Matcher Continuous Crossing Session POSIT accepts Peg orders and Immediate or Cancel ("IOC") orders. Peg orders may execute against contra-side Peg orders or against IOC orders. IOC orders may only execute against contra-side Peg orders. These order types may be entered with other instructions, as described below, that will be used by the matching algorithm to determine whether and how they will interact with other orders. (1) Peg Orders: Peg orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Peg orders can be designated with the following execution instruction: (i) Market: A Market instruction designates that a buy order can be executed up to the national best offer and a sell order can be executed down to the national best bid. (ii) Mid-Point: A Mid-Point instruction designates that an order can be executed up to the mid-point between the national best bid and national best offer ("NBBO"). (iii) Primary: A Primary instruction designates that the order can only be executed at the national best bid in the case of a buy order and the national best offer in the case of a sell order. (iv.) Limit Price: A Limit Price instruction specifies a price above which a buy order and below which a sell order that the order will not be eligible for execution. (2) IOC Orders: IOC orders will either execute if an eligible contra side order exists against which the order can be executed or if not the order is canceled. Subscribers may enter IOC orders with Market, Mid-Point and Limit Price instructions. Subscribers can include Minimum Execution Quantity ("MEQ") instructions on their orders via FIX, which specifies the minimum number of shares that must be available for a contra side order to be eligible for execution. Subscribers can also request to apply the following instructions on their orders at the session level: (i) Locked Market: Direct and Indirect Subscribers may request a Locked Market instruction, which specifies that an order is not eligible for execution during locked markets. IOC orders entered with a Locked Market instruction will be rejected if the NBBO is locked. Peg orders will be accepted but ineligible for execution until the NBBO unlocks. (ii) Virtu Principal Opt-Out: Direct and Indirect Subscribers may request to have their orders not interact with Virtu principal. This instruction will only prevent interaction against orders entered by VAL under the MPID's NITE, VIRT and VALX. Principal orders entered by VAL or the Affiliates using other MPIDs will not be subject to this opt out. See Part 2, Item 3a for more detail. (iii) POSIT Liquidity Profiles and Limits on Interaction: This instruction specifies the types of counterparties that an order may interact with based on the counterparty's Liquidity Profile. POSIT uses quantitative metrics to create one or more Liquidity Profiles for each POSIT Subscriber. The metrics include execution performance relative to the market over different time horizons for all fills in POSIT. POSIT makes discretionary decisions in assigning a Liquidity Profile to a new or previously uncategorized Subscriber. POSIT will inform Subscribers about their own profile information upon request. See Part III, Item 13a for more detail on POSIT Liquidity Profiles. (iv) MEQ Instruction Non-Aggregation: Direct and Indirect Subscribers may request that multiple orders are not aggregated to meet a MEQ instruction. By default, POSIT will aggregate orders to meet a Subscriber's MEQ instruction. (v) Cancel Residual if Below MEQ Instruction: Direct and Indirect Subscribers may request that a residual quantity be canceled back to the Subscriber if the residual quantity is less than the Subscriber's MEQ instruction. By default, POSIT will not cancel back an order if the residual is less than the MEQ instruction. (vi) Default Peg Instructions: Direct and Indirect Subscribers may request that their IOC and/or Day orders have a Default Peg instruction. An order that contains a value in a utilized FIX field other than a value recognized by VAL (as described in its FIX specifications) will be rejected. An order containing a value in a non- utilized FIX field will be accepted, but that instruction will not be processed. For resting Peg orders, priority in POSIT is based on the price instruction, i.e. market, mid, or primary. Resting Peg orders that can be executed at the same price receive a pro rata share allocation. However, POSIT will always attempt to execute at the midpoint of the NBBO, prior to executing at the NBB or NBO. Resting Peg orders with market instructions on the same side of the market will execute at the midpoint in a pro rata share allocation along with resting Peg orders with midpoint instructions also on the same side of the market. Peg orders with primary instructions, cannot execute at the midpoint, and would not participate and receive shares in a pro rata allocation when there are resting Peg orders with market and or midpoint price instructions on the same side. For IOC orders and Peg orders that remove liquidity, these orders are processed one at a time in time sequence. The following examples illustrate the matching process, assuming there are no instructions that would prevent an execution such as MEQ or a Limit Price that would be an order ineligible based upon the current NBBO. Example 1: Market bid/offer: $10.00 x $10.10 In POSIT, Order 1 is a Midpoint Peg order to buy 1,000 shares and Order 2 is a Market Peg order to buy 1,000 shares. An in-bound Peg order or IOC order with market or midpoint instructions to sell 1,000 shares is entered into POSIT. An execution of 1000 shares will occur at midpoint, with Order 1 receiving 500 shares, and Order 2 receiving 500 shares. Example 2: Market bid/offer: $10.00 x $10.10 In POSIT, Order 1 is a Midpoint Peg order to buy 1,000 shares and Order 2 is a Primary Peg order to buy 1,000 shares. An in-bound Peg order or IOC order with market or midpoint instructions to sell 1,000 shares is entered into POSIT. An execution of 1000 shares will occur at midpoint of the NBBO, with Order 1 receiving 1000 shares and Order 2 receiving no shares. Alert Crossing Session The Alert Crossing Session supports all of the order types and instructions described in the Continuous Crossing Session section in Part III, Item 7(a), with the exception that the Alert Crossing Session does not accept IOC orders. Additionally, the below order type instructions are only available in the Alert Crossing Session. (i) Conditional Indicator: Peg orders entered into the Alert Crossing Session are by default designated as Conditional Orders. Conditional Orders are not firm and must respond affirmatively to an Invitation to Firm-Up from the Alert Crossing Session by transmitting a Firm-Up Response Order to be eligible to be executed against contra-side orders. (ii) Firm-Up Response Order: These orders are entered in response to invitations from the Alert Crossing Session. (iii) Auto-Ex: Human Participants, as described in Part III, Item 9(a), can designate a Conditional Order as Auto-Ex. If the Auto-Ex instruction is enabled for a Conditional Order, the Human Participant will not receive a pop up window requesting to Firm-Up, as described in Part III, Item 9(a), but instead the Conditional Order from the Human Participant will automatically Firm-Up against a contra side order. See Part III, Item 9a for more detail on the Alert Crossing Session.

order_types

For both the Main and Conditional Sessions, MatchIt accepts Peg orders and Immediate or Cancel ("IOC") orders. Peg orders may cross with contra-side Peg orders or with IOC orders. IOC orders may only cross with contra-side Peg orders. These order types may be entered with other instructions that will be used by the matching algorithm to determine whether and how they will interact with other orders. Priority in the MatchIt Main Session for all order types is price, then time. If a Subscriber modifies the terms of a previously transmitted order, the order will receive a new order time stamp for matching purposes (i.e. the order will lose queue spot). The only exception is a reduction in order quantity which, absent any other changes to the terms of the order, will not update the order time stamp for matching purposes. Priority in the MatchIt Conditional Session for all order types is price, then size, then time. If the algorithm modifies the terms of a previously transmitted order, the order will receive a new order time stamp for matching purposes (i.e., the order will lose queue spot). The only exception is a reduction in order quantity which, absent any other changes to the terms of the order, will not update the order time stamp for matching purposes. The following instructions are available for orders entered in both the Main Session and the Conditional Session. The instructions placed on orders will affect whether an order is eligible to be executed against contra-side orders. (1) Peg Orders: Peg orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Peg orders can be designated with the following execution instruction: (i) Market: A Market instruction designates that the order can pay the full spread. For example, a buy order can be executed up to the national best offer and a sell order can be executed down to the national best bid. (ii) Mid-Point: A Mid-Point instruction designates that an order can pay up to the mid-point between the national best bid and national best offer ("NBBO"). (iii) Primary: A Primary instruction designates that the order can only be executed at the national best bid in the case of a buy order and the national best offer in the case of a sell order. (iv.) Limit Price: A Limit Price instruction specifies a price above which a buy order and below which a sell order that the order will not be eligible for execution. (2) IOC Orders: IOC orders will either execute if an eligible contra side order exists against which the order can be executed or if not the order is canceled. IOC orders can also include a Market, Mid-Point, Primary, or Limit Price instruction. Other available Instructions and Designations for the Main and Conditional Sessions: The following instructions may be applied to the above order types unless otherwise indicated. These instructions may be implemented by transmitting specified values on the order or by requesting configurations that will apply particular instructions after receipt of the order: (i) Minimum Execution Quantity ("MEQ"): An MEQ instruction specifies the minimum number of shares that must be available for a contra side order to be eligible for execution. (ii) Locked Market: A Locked Market instruction specifies that an order is not eligible for execution during locked markets. IOC orders entered with a Locked Market instruction will be rejected if the NBBO is locked. Peg orders will be accepted but ineligible for execution until the NBBO unlocks. (iii) Peg Order Add-Only Liquidity Instruction ("Add Only"): An Add-Only instruction specifies that the order is only eligible for execution when it adds liquidity to MatchIt upon entry. Peg orders that would remove liquidity from MatchIt will be accepted by MatchIt and remain open but ineligible for execution until such a time as the order adds liquidity to MatchIt. Contra-side Peg orders on the book at the time a Peg order with an Add Only instruction is entered will not interact with the Peg Add Only order. (iv) Soft Dollar Instruction: A Soft Dollar instruction will only allow riskless principal or agency crossing. To the extent that an order with a Soft Dollar instruction interacts with an order submitted by VCMM, MatchIt will pass information on the execution message so that the market maker's systems transact with its underlying client according to FINRA's definition of "riskless principal," i.e., at the same price, as the execution received in MatchIt. (v) Virtu Principal Opt Out: VAL and VAL Affiliates may submit instructions on orders that prevent interactions with Virtu principal orders. This instruction is not available to Direct Subscribers. This instruction will not prevent interactions with agency, riskless principal capacity orders, or other principal orders related to the facilitation of client order flow. This order instruction will also not prevent interaction with principal orders submitted by VAL traders who utilize VET algorithms. (vi) MatchIt Subscriber Profiles and Limits on Interaction: This instruction specifies the types of counterparties that an order may interact with based on the counterparty's Liquidity Profile. MatchIt uses quantitative metrics to create one or more Liquidity Profiles for each MatchIt Subscriber. The metrics include execution performance relative to the market over different time horizons when removing liquidity from MatchIt. MatchIt makes discretionary decisions in assigning a Liquidity Profile to a new or previously uncategorized Subscribers. MatchIt will inform Subscribers about their own profile information upon request. (vii) Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. See Attachment for Part III, 7a for details on available instructions and designations for the Conditional Session only.

order_types

For the Main Session, MatchIt accepts Peg orders, Day orders and Immediate or Cancel (IOC) orders. Peg and Day orders may cross with contra-side Peg orders, contra-side Day orders or with IOC orders. IOC orders may only cross with contra-side Peg orders or contra-side Day orders. These order types may be entered with other instructions that will be used by the matching algorithm to determine whether and how they will interact with other orders. For the Conditional Session, MatchIt accepts Peg orders and IOC orders. Peg orders may cross with contra-side Peg orders or with IOC orders. IOC orders may only cross with contra-side Peg orders. These order types may be entered with other instructions that will be used by the matching algorithm to determine whether and how they will interact with other orders. Priority in the MatchIt Main Session for all order types is price, then time. If a Subscriber modifies the terms of a previously transmitted order, the order will receive a new order time stamp for matching purposes (i.e. the order will lose queue spot). The only exception is a reduction in order quantity which, absent any other changes to the terms of the order, will not update the order time stamp for matching purposes. Priority in the MatchIt Conditional Session for all order types is price, then size, then time. If the algorithm modifies the terms of a previously transmitted order, the order will receive a new order time stamp for matching purposes (i.e., the order will lose queue spot). The only exception is a reduction in order quantity which, absent any other changes to the terms of the order, will not update the order time stamp for matching purposes. The following instructions are available for orders entered in both the Main Session and the Conditional Session. The instructions placed on orders will affect whether an order is eligible to be executed against contra-side orders. (1) Peg Orders: Peg orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Peg orders can be designated with the following execution instruction: (i) Market: A Market instruction designates that the order can pay the full spread. For example, a buy order can be executed up to the national best offer and a sell order can be executed down to the national best bid. (ii) Mid-Point: A Mid-Point instruction designates that an order can pay up to the mid-point between the national best bid and national best offer ("NBBO"). (iii) Primary: A Primary instruction designates that the order can only be executed at the national best bid in the case of a buy order and the national best offer in the case of a sell order. A Limit Price instruction can be specified for Peg orders in conjunction with the above referenced execution instruction. (2) Day Orders: Day orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Day orders can also include a Market, Mid-Point, Primary or Limit Price instruction. (3) IOC Orders: IOC orders will either execute if an eligible contra side order exists against which the order can be executed or if not the order is canceled. IOC orders can also include a Market, Mid-Point, Primary, or Limit Price instruction. IOC orders will default to Primary Peg if a peg instruction is not specified. Other available Instructions and Designations for the Main and Conditional Sessions: The following instructions may be applied to the above order types unless otherwise indicated. These instructions may be implemented by transmitting specified values on the order or by requesting configurations that will apply particular instructions after receipt of the order: (i) Minimum Execution Quantity (MEQ): An MEQ instruction specifies the minimum number of shares that must be available for a contra side order to be eligible for execution. (ii) Locked Market: A Locked Market instruction specifies that an order is not eligible for execution during locked markets. IOC orders entered with a Locked Market instruction will be rejected if the NBBO is locked. Peg orders will be accepted but ineligible for execution until the NBBO unlocks. (iii) Peg Order Add-Only Liquidity Instruction ("Add Only"): An Add-Only instruction specifies that the order is only eligible for execution when it adds liquidity to MatchIt upon entry. Peg orders that would remove liquidity from MatchIt will be accepted by MatchIt and remain open but ineligible for execution until such a time as the order adds liquidity to MatchIt. Contra-side Peg orders on the book at the time a Peg order with an Add Only instruction is entered will not interact with the Peg Add Only order. (iv) Soft Dollar Instruction: A Soft Dollar instruction will only allow riskless principal or agency crossing. To the extent that an order with a Soft Dollar instruction interacts with an order submitted by VCMM, MatchIt will pass information on the execution message so that the market maker's systems transact with its underlying client according to FINRA's definition of "riskless principal," i.e., at the same price, as the execution received in MatchIt. (v) Virtu Principal Opt Out: VAL and VAL Affiliates may submit instructions on orders that prevent interactions with Virtu principal orders, as described in Part II, item 3(a). This instruction is not available to Direct Subscribers. (vi) MatchIt Subscriber Profiles and Limits on Interaction: This instruction specifies the types of counterparties that an order may interact with based on the counterparty's Liquidity Profile. MatchIt uses quantitative metrics to create one or more Liquidity Profiles for each MatchIt Subscriber. The metrics include execution performance relative to the market over different time horizons when removing liquidity from MatchIt. MatchIt makes discretionary decisions in assigning a Liquidity Profile to a new or previously uncategorized Subscribers. MatchIt will inform Subscribers about their own profile information upon request. (vii) Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. See Attachment for Part III, 7a for details on available instructions and designations for the Conditional Session only.

order_types

Continuous Crossing Session POSIT accepts Peg orders, Day orders and Immediate or Cancel ("IOC") orders. Peg and Day orders may execute against contra-side Peg orders, contra-side Day orders or against IOC orders. IOC orders may only cross against contra-side Peg orders or contra-side Day orders. These order types may be entered with other instructions that will be used by the matching algorithm to determine whether and how they will interact with other orders. Priority in the POSIT Continuous Crossing Session for all order types is price, then size, then time. For orders without a peg instruction, the limit price submitted is used to determine the price portion of the queue priority. For orders with a peg instruction, the less aggressive price between the current peg price and limit price submitted is used to determine the price portion of the queue priority. If the algorithm modifies the terms of a previously transmitted order, the order will receive a new order time stamp for matching purposes (i.e. the order will lose queue spot). The only exception is a reduction in order quantity which, absent any other changes to the terms of the order, will not update the order time stamp for matching purposes. The following instructions are available for orders entered in the POSIT Continuous Crossing Session. The instructions placed on orders will affect whether an order is eligible to be executed against contra-side orders. (1) Peg Orders: Peg orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Peg orders can be designated with the following execution instruction: (i) Market: A Market instruction designates that a buy order can be executed up to the national best offer and a sell order can be executed down to the national best bid. (ii) Mid-Point: A Mid-Point instruction designates that an order can be executed up to the mid-point between the national best bid and national best offer ("NBBO"). (iii) Primary: A Primary instruction designates that the order can only be executed at the national best bid in the case of a buy order and the national best offer in the case of a sell order. A Limit Price instruction can be specified for Peg orders in conjunction with the above referenced execution instruction. (2) Day Orders: Day orders remain open until executed, canceled by the Subscriber or until the end of the daily matching session. Day orders can also include a Market, Mid-Point, Primary Peg or Limit Price instruction. (3) IOC Orders: IOC orders will either execute if an eligible contra side order exists against which the order can be executed or if not the order is canceled. Subscribers may enter IOC orders with Market, Mid-Point, Primary Peg or Limit Price instructions. Other available Instructions and Designations for the Continuous Crossing Session: The following instructions may be applied to the above order types unless otherwise indicated. These instructions may be implemented by either transmitting a specified value over a FIX tag on an order by order basis, or requesting a session level configuration that will apply the requested instruction across all orders sent to the session specified by the Direct Subscriber, unless otherwise indicated: (i) Minimum Execution Quantity (MEQ): An MEQ instruction specifies the minimum number of shares that must be available for a contra side order to be eligible for execution. POSIT does not aggregate multiple contra side orders to satisfy a MEQ instruction on a single order. POSIT will cancel back an order to the Direct Subscriber if the residual quantity of an order falls below the MEQ instruction. (ii) Locked Market: A Locked Market instruction specifies that an order is not eligible for execution during locked markets. IOC orders entered with a Locked Market instruction will be accepted if the NBBO is locked, but will receive a 'Nothing Done' message. Peg orders will be accepted but ineligible for execution until the NBBO unlocks. (iii) Peg Order Add-Only Liquidity Instruction ("Add Only"): An Add-Only instruction specifies that the order is only eligible for execution when it adds liquidity to POSIT upon entry. Peg orders that would remove liquidity from POSIT will be accepted by POSIT and remain open but ineligible for execution until such a time as the order adds liquidity to POSIT. Contra-side Peg orders on the book at the time a Peg order with an Add Only instruction is entered will not interact with the Peg Add Only order. The Add Only instruction will be ignored if specified for an IOC order. (iv) Virtu Principal Opt Out: Direct and Indirect Subscribers may request to have their orders not interact with Virtu principal orders. This instruction will only prevent interaction against orders entered by VAL under the MPID's NITE, VIRT and VALX. Principal orders entered by VAL or the Affiliates, as defined in Part II, Item 2a, using other MPIDs will not be subject to this opt out. See Part II, Item 3a for more detail. This order instruction can only be specified at the session level, and cannot be specified on an order by order basis via a FIX tag. (v) POSIT Liquidity Profiles and Limits on Interaction: This instruction specifies the types of counterparties that an order may interact with based on the counterparty's Liquidity Profile. POSIT uses quantitative metrics to create one or more Liquidity Profiles for each POSIT Subscriber. The metrics include execution performance relative to the market over different time horizons for all fills in POSIT. POSIT makes discretionary decisions in assigning a Liquidity Profile to a new or previously uncategorized Subscriber. POSIT will inform Subscribers about their own profile information upon request. See Part III, Item 13a for more detail on POSIT Liquidity Profiles. (vi) Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. This order instruction can only be specified at the session level, and cannot be specified on an order by order basis via a FIX tag. An order that contains a value in a utilized FIX field other than a value recognized by VAL (as described in its FIX specifications) will be rejected. An order containing a value in a non- utilized FIX field will be accepted, but that instruction will not be processed. Alert Crossing Session The Alert Crossing Session supports all of the order types and instructions described in the Continuous Crossing Session section in Part III, Item 7(a). Additionally, the below order type instructions are only available in the Alert Crossing Session. (i) Conditional Indicator: Peg orders entered into the Alert Crossing Session are by default designated as Conditional Orders. Conditional Orders are not firm and must respond affirmatively to an Invitation to Firm-Up from the Alert Crossing Session by transmitting a Firm-Up Response Order to be eligible to be executed against contra-side orders. (ii) Firm-Up Response Order: These orders are entered in response to invitations from the Alert Crossing Session. (iii) Auto-Ex: Human Participants, as described in Part III, Item 9(a), can designate a Conditional Order as Auto-Ex. If the Auto-Ex instruction is enabled for a Conditional Order, the Human Participant will not receive a pop up window requesting to Firm-Up, as described in Part III, Item 9(a), but instead the Conditional Order from the Human Participant will automatically Firm-Up against a contra side order. See Part III, Item 9a for more detail on the Alert Crossing Session.

means_of_entry

VAL, VAL Affiliates, and Direct Subscribers can enter orders directly to the MatchIt Main Session through an API in in the NY4 Datacenter. See, Part II, Item 5. All orders must be submitted electronically via FIX. VAL provides a MatchIt FIX Specification document for the MatchIt Main Session describing the transmission formats for order messages. MatchIt supports FIX versions up to V4.2. MatchIt only accepts orders that satisfy clearly defined parameters which include: Orders must satisfy certain security parameters - for example, orders must be transmitted from a known IP address that has been permissioned by MatchIt. Orders must adhere to the parameters provided in the FIX specification document. VAL and VAL Affiliates access the Conditional Session through the same API. VAL provides Direct Subscribers with a FIX specification document that contains message formats for the main session. VAL utilizes a FIX specification document that contains message formats for both the main session and the conditional session.

means_of_entry

VAL, VAL Affiliates, and Direct Subscribers can enter orders directly to the MatchIt Main Session through an API in either the NY4 or NY5 Datacenter. See, Part II, Item 5. All orders must be submitted electronically via FIX. VAL provides a MatchIt FIX Specification document for the MatchIt Main Session describing the transmission formats for order messages. MatchIt supports FIX versions up to V4.2. MatchIt only accepts orders that satisfy clearly defined parameters which include: Orders must satisfy certain security parameters - for example, orders must be transmitted from a known IP address that has been permissioned by MatchIt. Orders must adhere to the parameters provided in the FIX specification document. VAL and VAL Affiliates access the Conditional Session through the same API. VAL provides Direct Subscribers with a FIX specification document that contains message formats for the main session. VAL utilizes a FIX specification document that contains message formats for both the main session and the conditional session.

pricing_methodology

POSIT employs a proprietary market data system that uses direct market data feeds from exchanges to determine the NBBO. POSIT utilizes this proprietary system to price, prioritize, and match orders in the POSIT Continuous, POSIT Alert, and POSIT Agency Close Crossing Sessions, in compliance with regulations, including Reg NMS and Reg SHO. SIP data is used as a backup feed, and is used in place of a direct feed from a particular exchange if that exchange is experiencing a technical issue. Switching to the SIP data feed is done via an automated process that compares direct feed data to SIP data. Additionally, Core Operations have the ability to switch to the SIP data feed on a discretionary basis. Switching back to direct feed data from the SIP data feed is done purely on a discretionary basis, and is performed by the Core Operations team once this team has confirmed that direct feed data in question is correct. The SIP data feed is also used for regulatory items, including limit up/limit down bands, trading halts, and Reg SHO designations. With respect to trades executed as a result of an Agency Close Crossing Session match, the closing price for each security will be the closing price disseminated to POSIT from the primary exchange data feed.

pricing_methodology

MatchIt employs a proprietary market data system that combines direct market data feeds from exchanges and SIP data to determine the NBBO. MatchIt utilizes this proprietary system to price, prioritize, and match orders in both the Main and Conditional Sessions, in compliance with regulations, including Reg NMS and Reg SHO. SIP data is used as a backup feed, and is used in place of a direct feed from a particular market center if that market center is experiencing a technical issue. Switching to the SIP data feed is done via an automated process that compares direct feed data to SIP data. Additionally, Core Operations have the ability to switch to the SIP data feed on a discretionary basis. Switching back to direct feed data from the SIP data feed is done purely on a discretionary basis, and is performed by the Core Operations team once this team has confirmed that direct feed data in question is correct. The SIP data feed is also used for regulatory items, including limit up/limit down bands, trading halts, and Reg SHO designations.

pricing_methodology

MatchIt employs a proprietary market data system that uses direct market data feeds from exchanges to determine the NBBO. MatchIt utilizes this proprietary system to price, prioritize, and match orders in both the Main and Conditional Sessions, in compliance with regulations, including Reg NMS and Reg SHO. SIP data is used as a backup feed, and is used in place of a direct feed from a particular exchange if that exchange is experiencing a technical issue. Switching to the SIP data feed is done via an automated process that compares direct feed data to SIP data. Additionally, Core Operations have the ability to switch to the SIP data feed on a discretionary basis. Switching back to direct feed data from the SIP data feed is done purely on a discretionary basis, and is performed by the Core Operations team once this team has confirmed that direct feed data in question is correct. The SIP data feed is also used for regulatory items, including limit up/limit down bands, trading halts, and Reg SHO designations.

pricing_methodology

POSIT employs a proprietary market data system that uses direct market data feeds from exchanges to determine the NBBO. POSIT utilizes this proprietary system to price, prioritize, and match orders in the POSIT Continuous and POSIT Alert Crossing Sessions, in compliance with regulations, including Reg NMS and Reg SHO. SIP data is used as a backup feed, and is used in place of a direct feed from a particular exchange if that exchange is experiencing a technical issue. Switching to the SIP data feed is done via an automated process that compares direct feed data to SIP data. Additionally, Core Operations have the ability to switch to the SIP data feed on a discretionary basis. Switching back to direct feed data from the SIP data feed is done purely on a discretionary basis, and is performed by the Core Operations team once this team has confirmed that direct feed data in question is correct. The SIP data feed is also used for regulatory items, including limit up/limit down bands, trading halts, and Reg SHO designations.

pricing_methodology

MatchIt employs a proprietary market data system that uses a combination of direct market data feeds from exchanges and market data disseminated by the Securities Information Processors (SIP) to determine the NBBO. Specifically, MatchIt uses direct market data for all exchanges other than LTSE, for which the SIP is used as LTSE does not offer direct market data feeds. MatchIt utilizes this proprietary system to price, prioritize, and match orders in both the Main and Conditional Sessions, in compliance with regulations, including Reg NMS and Reg SHO. SIP data is used as a backup feed, and is used in place of a direct feed from a particular exchange if that exchange is experiencing a technical issue. Switching to the SIP data feed is done via an automated process that compares direct feed data to SIP data. Additionally, Core Operations have the ability to switch to the SIP data feed on a discretionary basis. Switching back to direct feed data from the SIP data feed is done purely on a discretionary basis, and is performed by the Core Operations team once this team has confirmed that direct feed data in question is correct. The SIP data feed is also used for regulatory items, including limit up/limit down bands, trading halts, and Reg SHO designations.

counterparty_selection

Virtu Principal Opt Out: VAL and VAL Affiliates may submit instructions on orders that prevent interactions with Virtu principal orders. This instruction is not available to Direct Subscribers. This instruction will not prevent interactions with agency, riskless principal capacity orders, or other principal orders related to the facilitation of client order flow. VET provides clients with access to algorithms that allow clients to access liquidity. See Part II, Item 1 for a description of VET. VAL's trading desks also use these algorithms and transmit principal orders in connection with their facilitation of client orders for VAL's own account. These principal orders are not subject to the Virtu Principal Opt Out instruction. See Part III, Item 7 which lists order instructions including this instruction. MatchIt Liquidity Profile Interaction: All Direct Subscribers have the option to block interaction against specific Liquidity Profiles, as described in Part III, Item 13. VAL programs its algorithms to use blocking when analysis suggests it may improve execution outcomes. VAL implements the logic of the algorithms such that decisions are made on specific child orders in specific circumstances. Indirect Subscribers cannot make decisions to block based on Liquidity Profiles. MatchIt will prevent liquidity removing orders from matching with liquidity adding orders from counterparties falling into the specified liquidity profiles when Subscribers place the blocking instruction on their liquidity adding orders. Subscribers can send instructions designating which Liquidity Profiles to interact with on an order by order basis via FIX tag. These Profiles are only created for the Main Session and only effect counterparty interaction in the Main Session. See Part III, Item 7 which lists order instructions including this instruction. Self-Match Prevention: Direct Subscribers may provide instructions that will prevent order from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. Other Order Attributes: Direct Subscribers can place other attributes on orders that could limit an order's ability to interact with certain contra side interest. These additional attributes include: Minimum Execution Quantity, Do Not Execute In A Locked Market, and Add Only.

counterparty_selection

POSIT: Contra Participant Specific Blocking: Subscribers can request to block interaction with specific Subscribers within POSIT. Upon request, execution performance reports can be provided to Subscribers on their order flow, grouped by contra Subscriber, time in force, and peg instruction. Metrics included in the execution performance reports can include, but is not limited to, shares executed, average trade size, and stock price movement after the time of fill (mark outs). Contra Subscribers are anonymized in the execution performance reports. Upon receiving this information, a Subscriber can request which anonymized contra Subscribers to block interaction against, either in totality, or can specify specific contra Subscriber blocking by time in force and/or peg instructions. Once a Subscriber specifies a contra Subscriber block, that block will remain in effect until the Subscriber requests for that block to be removed. Subscribers can request Contra Participant Specific Blocking through their salesperson, who enter a ticket to make the request. Thereafter, an entry is made in a configuration file which takes effect in most cases on the next business day, but could take effect either the same day or greater than the next business day, depending upon the time of day the request is submitted. Liquidity Guard: Liquidity Guard is an automated means where VAL prevents certain IOC and Peg orders from interacting with resting Peg orders. Stocks that are subject to the interaction restrictions of Liquidity Guard are those that have a historical bid offer spread that is greater than or equal to $0.03 per share or a trailing 21-day average daily volume that is less than or equal to 3 million shares. Liquidity Guard uses inputs including a stock's trailing intraday bid offer spread, historical bid offer spread, and volatility, to compute price bands where executions can take place on a security basis. If a potential match of an incoming IOC or Peg order against a resting Peg order would occur at a price outside of the computed price bands for a particular stock, then the IOC or Peg order would be blocked from interacting against the resting Peg order. All Subscribers are subject to Liquidity Guard, but a Subscriber may elect to opt out of having their Peg orders subject to Liquidity Guard. Subscribers can request to opt out of Liquidity Guard through their sales person, who enter a ticket to make the request. Thereafter, an entry is made in a configuration file which takes effect in most cases on the next business day, but could take effect either the same day or greater than the next business day, depending upon the time of day the request is submitted. Subscribers are not provided with any information on when Liquidity Guard effected the interaction of their orders. Liquidity Guard is not employed in Alert. Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. Subscribers can request Self-Match Prevention through their salesperson, who enter a ticket to make the request. Thereafter, an entry is made in a configuration file which takes effect in most cases on the next business day, but could take effect either the same day or greater than the next business day, depending upon the time of day the request is submitted. Further, Subscribers are able to block interaction against certain Virtu MPIDs. See the response to Part II, Item 3b for further detail. Alert: Participant Type Blocking: Electronic Participants can request to block interaction against Human Participants via a FIX tag, on an individual order basis. Human Participants can request to block interaction against Electronic Participants. This blocking instruction is supported at the session level. Participant and Symbol Specific Blocking: Alert Sales and Coverage personnel can block certain participants in whole or at a symbol level. Alert Sales and Coverage personnel apply participant blocks in whole, or at a symbol level, on an intraday basis if a participant is having a technical issue. For example, if an Alert participant was duping messages repeatedly then the Alert Sales and Coverage personnel could introduce a temporary block until the issue was resolved. Alert Sales and Coverage personnel can lift this block once the participant verifies the technical issue has been resolved. Symbol level blocks are also applied on an automated basis between an Electronic Participant and a Human Participant if within a three-minute span, for a given symbol, five consecutive invitations to Firm Up between the two participants result in no trades, a two minute block will be applied between the two participants in the given symbol. After the two- minute blocking period, the block between the two participants will automatically be lifted in the given symbol. The three-minute time span begins at the time of when the first invitation is sent. Symbol level blocks do not carry over into the next trading day. Please see Part III, Item 9(a) for more detail on the POSIT Alert Conditional Order process. Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership.

counterparty_selection

POSIT: Virtu Principal Opt Out: Direct and Indirect Subscribers may request to have their orders not interact with Virtu principal orders. See Part III, Item 7a which lists order instructions including this instruction. POSIT Liquidity Profile Interaction: All Direct Subscribers have the option to block either the Move Towards or Move Away segments for a single order, as described in Part III, Item 13. Direct Subscribers cannot block both the Move Towards and Move Away segments for a single order. Direct Subscribers cannot block the Neutral segment. VAL programs its algorithms to use blocking when analysis suggests it may improve execution outcomes. VAL implements the logic of the algorithms such that decisions are made on specific child orders in specific circumstances. Indirect Subscribers cannot make decisions to block based on Liquidity Profiles. Direct subscribers can send instructions designating which Liquidity Profiles to interact with on an order by order basis via a FIX tag, or set a default at the session level. These Profiles are only created for the Continuous Crossing Session and only effect counterparty interaction in the Continuous Crossing Session. See Part III, Item 7a, which lists order instructions including this instruction. Self-Match Prevention: Direct Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership, as described in Part III, Item 7a. Subscribers can request Self-Match Prevention through their salesperson, who enter a ticket to make the request. Thereafter, an entry is made in a configuration file which takes effect in most cases on the next business day, but could take effect either the same day or greater than the next business day, depending upon the time of day the request is submitted. Further, Subscribers are able to block interaction against certain Virtu MPIDs. See Part II, Item 3a for further detail. Other Order Attributes: Direct Subscribers can place other attributes on orders that could limit an order's ability to interact with certain contra side interest. These additional attributes include: Minimum Execution Quantity, Do Not Execute In A Locked Market, and Add Only. See Part III, Item 7a for more detail. Alert: Participant Type Blocking: Electronic Participants can request to block interaction against Human Participants via a FIX tag, on an individual order basis. Human Participants can request to block interaction against Electronic Participants. This blocking instruction is supported at the session level. Participant and Symbol Specific Blocking: Alert Sales and Coverage personnel can block certain participants in whole or at a symbol level. Alert Sales and Coverage personnel apply participant blocks in whole, or at a symbol level, on an intraday basis if a participant is having a technical issue. For example, if an Alert participant was duping messages repeatedly then the Alert Sales and Coverage personnel could introduce a temporary block until the issue was resolved. Alert Sales and Coverage personnel can lift this block once the participant verifies the technical issue has been resolved. Symbol level blocks are also applied on an automated basis between an Electronic Participant and a Human Participant, as well as between two Electronic Participants. If within a two-minute span, for a given symbol, three consecutive invitations to Firm Up between the two participants result in no trades, a one minute block will be applied between the two participants in the given symbol. After the one-minute blocking period, the block between the two participants will automatically be lifted in the given symbol. The three-minute time span begins at the time of when the first invitation is sent. Symbol level blocks do not carry over into the next trading day. Please see Part III, Item 9(a) for more detail on the POSIT Alert Conditional Order process. Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership.

counterparty_selection

Virtu Principal Opt Out: VAL and VAL Affiliates may submit instructions on orders that prevent interactions with Virtu principal orders. This instruction is not available to Direct Subscribers. See Part III, Item 7 which lists order instructions including this instruction. MatchIt Liquidity Profile Interaction: All Direct Subscribers have the option to block interaction against specific Liquidity Profiles, as described in Part III, Item 13. VAL programs its algorithms to use blocking when analysis suggests it may improve execution outcomes. VAL implements the logic of the algorithms such that decisions are made on specific child orders in specific circumstances. Indirect Subscribers cannot make decisions to block based on Liquidity Profiles. MatchIt will prevent liquidity removing orders from matching with liquidity adding orders from counterparties falling into the specified liquidity profiles when Subscribers place the blocking instruction on their liquidity adding orders. Subscribers can send instructions designating which Liquidity Profiles to interact with on an order by order basis via FIX tag. These Profiles are only created for the Main Session and only effect counterparty interaction in the Main Session. See Part III, Item 7 which lists order instructions including this instruction. Self-Match Prevention: Direct and Indirect Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. Other Order Attributes: Direct Subscribers can place other attributes on orders that could limit an order's ability to interact with certain contra side interest. These additional attributes include: Minimum Execution Quantity, Do Not Execute In A Locked Market, and Add Only.

counterparty_selection

Virtu Principal Opt Out: VAL and VAL Affiliates may submit instructions on orders that prevent interactions with Virtu principal orders. This instruction is not available to Direct Subscribers. See Part III, Item 7 which lists order instructions including this instruction. MatchIt Liquidity Profile Interaction: All Direct Subscribers have the option to block interaction against specific Liquidity Profiles, as described in Part III, Item 13. VAL programs its algorithms to use blocking when analysis suggests it may improve execution outcomes. VAL implements the logic of the algorithms such that decisions are made on specific child orders in specific circumstances. Indirect Subscribers cannot make decisions to block based on Liquidity Profiles. MatchIt will prevent liquidity removing orders from matching with liquidity adding orders from counterparties falling into the specified liquidity profiles when Subscribers place the blocking instruction on their liquidity adding orders. Subscribers can send instructions designating which Liquidity Profiles to interact with on an order by order basis via FIX tag. These Profiles are only created for the Main Session and only effect counterparty interaction in the Main Session. See Part III, Item 7 which lists order instructions including this instruction. Self-Match Prevention: Direct Subscribers may provide instructions that will prevent order from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. Other Order Attributes: Direct Subscribers can place other attributes on orders that could limit an order's ability to interact with certain contra side interest. These additional attributes include: Minimum Execution Quantity, Do Not Execute In A Locked Market, and Add Only.

counterparty_selection

POSIT: Contra Participant Specific Blocking: Subscribers can request to block interaction with specific Subscribers within POSIT. Upon request, execution performance reports can be provided to Subscribers on their order flow, grouped by contra Subscriber, time in force, and peg instruction. Metrics included in the execution performance reports can include, but is not limited to, shares executed, average trade size, and stock price movement after the time of fill (mark outs). Contra Subscribers are anonymized in the execution performance reports. Upon receiving this information, a Subscriber can request which anonymized contra Subscribers to block interaction against, either in totality, or can specify specific contra Subscriber blocking by time in force and/or peg instructions. Once a Subscriber specifies a contra Subscriber block, that block will remain in effect until the Subscriber requests for that block to be removed. Subscribers can request Contra Participant Specific Blocking through their salesperson, who enter a ticket to make the request. Thereafter, an entry is made in a configuration file which takes effect in most cases on the next business day, but could take effect either the same day or greater than the next business day, depending upon the time of day the request is submitted. Liquidity Guard: Liquidity Guard is an automated means where VAL prevents certain IOC and Peg orders from interacting with resting Peg orders. Stocks that are subject to the interaction restrictions of Liquidity Guard are those that have a historical bid offer spread that is greater than or equal to $0.03 per share or a trailing 21-day average daily volume that is less than or equal to 3 million shares. Liquidity Guard uses inputs including a stock's trailing intraday bid offer spread, historical bid offer spread, and volatility, to compute price bands where executions can take place on a security basis. If a potential match of an incoming IOC or Peg order against a resting Peg order would occur at a price outside of the computed price bands for a particular stock, then the IOC or Peg order would be blocked from interacting against the resting Peg order. All Subscribers are subject to Liquidity Guard, but a Subscriber may elect to opt out of having their Peg orders subject to Liquidity Guard. Subscribers can request to opt out of Liquidity Guard through their sales person, who enter a ticket to make the request. Thereafter, an entry is made in a configuration file which takes effect in most cases on the next business day, but could take effect either the same day or greater than the next business day, depending upon the time of day the request is submitted. Subscribers are not provided with any information on when Liquidity Guard effected the interaction of their orders. Liquidity Guard is not employed in Alert. Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. Subscribers can request Self-Match Prevention through their salesperson, who enter a ticket to make the request. Thereafter, an entry is made in a configuration file which takes effect in most cases on the next business day, but could take effect either the same day or greater than the next business day, depending upon the time of day the request is submitted. Further, Subscribers are able to block interaction against certain Virtu MPIDs. See the response to Part II, Item 3b for further detail. Alert: Participant Type Blocking: Electronic Participants can request to block interaction against Human Participants via a FIX tag, on an individual order basis. Human Participants can request to block interaction against Electronic Participants. This blocking instruction is supported at the session level. Participant and Symbol Specific Blocking: Alert Sales and Coverage personnel can block certain participants in whole or at a symbol level. Alert Sales and Coverage personnel apply participant blocks in whole, or at a symbol level, on an intraday basis if a participant is having a technical issue. For example, if an Alert participant was duping messages repeatedly then the Alert Sales and Coverage personnel could introduce a temporary block until the issue was resolved. Alert Sales and Coverage personnel can lift this block once the participant verifies the technical issue has been resolved. Symbol level blocks are also applied on an automated basis between an Electronic Participant and a Human Participant if within a two-minute span, for a given symbol, three consecutive invitations to Firm Up between the two participants result in no trades, a one minute block will be applied between the two participants in the given symbol. After the two- minute blocking period, the block between the two participants will automatically be lifted in the given symbol. The three-minute time span begins at the time of when the first invitation is sent. Symbol level blocks do not carry over into the next trading day. Please see Part III, Item 9(a) for more detail on the POSIT Alert Conditional Order process. Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership.

counterparty_selection

POSIT: Contra Participant Specific Blocking: Subscribers can request to block interaction with specific Subscribers within POSIT. Upon request, execution performance reports can be provided to Subscribers on their order flow, grouped by contra Subscriber, time in force, and peg instruction. Metrics included in the execution performance reports can include, but is not limited to, shares executed, average trade size, and stock price movement after the time of fill (mark outs). Contra Subscribers are anonymized in the execution performance reports. Upon receiving this information, a Subscriber can request which anonymized contra Subscribers to block interaction against, either in totality, or can specify specific contra Subscriber blocking by time in force and/or peg instructions. Once a Subscriber specifies a contra Subscriber block, that block will remain in effect until the Subscriber requests for that block to be removed. Subscribers can request Contra Participant Specific Blocking through their salesperson, who enter a ticket to make the request. Thereafter, an entry is made in a configuration file which takes effect in most cases on the next business day, but could take effect either the same day or greater than the next business day, depending upon the time of day the request is submitted. Liquidity Guard: Liquidity Guard is an automated means where VAL prevents certain IOC and Peg orders from interacting with resting Peg orders. Stocks that are subject to the interaction restrictions of Liquidity Guard are those that have a historical bid offer spread that is greater than or equal to $0.03 per share or a trailing 21-day average daily volume that is less than or equal to 3 million shares. Liquidity Guard uses inputs including a stock's trailing intraday bid offer spread, historical bid offer spread, and volatility, to compute price bands where executions can take place on a security basis. If a potential match of an incoming IOC or Peg order against a resting Peg order would occur at a price outside of the computed price bands for a particular stock, then the IOC or Peg order would be blocked from interacting against the resting Peg order. All Subscribers are subject to Liquidity Guard, but a Subscriber may elect to opt out of having their Peg orders subject to Liquidity Guard. Subscribers can request to opt out of Liquidity Guard through their sales person, who enter a ticket to make the request. Thereafter, an entry is made in a configuration file which takes effect in most cases on the next business day, but could take effect either the same day or greater than the next business day, depending upon the time of day the request is submitted. Subscribers are not provided with any information on when Liquidity Guard effected the interaction of their orders. Liquidity Guard is not employed in Alert. Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership. Subscribers can request Self-Match Prevention through their salesperson, who enter a ticket to make the request. Thereafter, an entry is made in a configuration file which takes effect in most cases on the next business day, but could take effect either the same day or greater than the next business day, depending upon the time of day the request is submitted. Further, Subscribers are able to block interaction against certain Virtu MPIDs. See the response to Part II, Item 3b for further detail. Alert: Participant Type Blocking: Electronic Participants can request to block interaction against Human Participants via a FIX tag, on an individual order basis. Human Participants can request to block interaction against Electronic Participants. This blocking instruction is supported at the session level. Participant and Symbol Specific Blocking: Alert Sales and Coverage personnel can block certain participants in whole or at a symbol level. Alert Sales and Coverage personnel apply participant blocks in whole, or at a symbol level, on an intraday basis if a participant is having a technical issue. For example, if an Alert participant was duping messages repeatedly then the Alert Sales and Coverage personnel could introduce a temporary block until the issue was resolved. Alert Sales and Coverage personnel can lift this block once the participant verifies the technical issue has been resolved. Symbol level blocks are also applied on an automated basis between an Electronic Participant and a Human Participant, as well as between two Electronic Participants. If within a two-minute span, for a given symbol, three consecutive invitations to Firm Up between the two participants result in no trades, a one minute block will be applied between the two participants in the given symbol. After the one- minute blocking period, the block between the two participants will automatically be lifted in the given symbol. The three-minute time span begins at the time of when the first invitation is sent. Symbol level blocks do not carry over into the next trading day. Please see Part III, Item 9(a) for more detail on the POSIT Alert Conditional Order process. Self-Match Prevention: Subscribers may provide instructions that will prevent orders from crossing if the resulting cross may result in a transaction with no change in beneficial ownership.

financial_condition_summary

MatchIt does not charge any subscription or connectivity fees. Direct Subscribers pay fees between $.0001 and $.0010 per share. VAL and VAL Affiliates are not assessed a fee for MatchIt trades. Indirect Subscribers pay bundled fees, See Section III, Item 19(b). VAL will consider a number of factors in determining the fee an individual Subscriber will be assessed, including, but not limited to, the client's overall relationship with VAL, the type of trading flow, the amount of trading flow, and the markets that will be traded.

financial_condition_summary

Some Subscribers do not have a dedicated rate for executions in POSIT, but, instead, have a default rate across VAL's products where that default rate can apply to executions in POSIT. The commissions charged to execute in POSIT can vary based on the means of access. Direct Subscribers not using other products are charged a rate per executed share ranging from $0.0005 to $0.0065. Orders originating from Subscribers accessing POSIT through Alert, VAL's algorithms, smart order router, trading desks, and/or Alert are charged a rate per executed share based on the fees associated with the particular products used by the Subscriber, irrespective of whether the orders are executed in POSIT or another venue.

financial_condition_summary

POSIT does not charge any subscription or connectivity fees. Historically, execution charges, if any, were individually negotiated with each Direct Subscriber. Currently, Direct Subscribers pay fees between $0 and $.05 per share. VAL and VAL Affiliates are not assessed a fee for POSIT trades. Indirect Subscribers pay bundled fees, See Section III, Item 19(b). VAL will consider a number of factors in determining the fee an individual Subscriber will be assessed, including, but not limited to, the client's overall relationship with VAL, the type of trading flow, the amount of trading flow, and the markets that will be traded.

financial_condition_summary

MatchIt does not charge any subscription or connectivity fees. Historically, execution charges, if any, were individually negotiated with each Direct Subscriber. Currently, Direct Subscribers pay fees between $.0005 and $.0025 per share with most Subscribers paying $.001 per share. Any new Subscribers will be charged $.001 per share. VAL and VAL Affiliates are not assessed a fee for MatchIt trades. Indirect Subscribers pay bundled fees, See Section III, Item 19(b). VAL will consider a number of factors in determining the fee an individual Subscriber will be assessed, including, but not limited to, the client's overall relationship with VAL, the type of trading flow, the amount of trading flow, and the markets that will be traded.

financial_condition_summary

MatchIt does not charge any subscription or connectivity fees. Direct Subscribers pay fees between $.0001 and $.0010 per share. VAL and VAL Affiliates are not assessed a fee for MatchIt trades. Indirect Subscribers pay bundled fees, See Section III, Item 19(b). VAL will consider a number of factors in determining the fee an individual Subscriber will be assessed, including, but not limited to, the client's overall relationship with VAL, the type of trading flow, the amount of trading flow, and the markets that will be traded. VAL is assessed certain Consolidated Audit Trail (CAT) regulatory fees relating to trading on MatchIt as an execution venue. In each transaction that does not include VAL mpids VIRT and VALX, VAL is identified on transaction reports as the CAT executing broker for the buyer and the selling MatchIt subscriber is reported as the CAT executing broker for the seller. FINRA assesses CAT fees on both VAL, on behalf of the buying MatchIt subscriber, and on the selling MatchIt subscriber. VAL passes through to the buying MatchIt subscriber these CAT-related fees that VAL is assessed on behalf of those buying MatchIt subscribers. For transactions that include VAL mpids VIRT or VALX and an external subscriber as the contra, the external subscriber's mpid is reported as the CAT executing broker regardless of the side of the external subscriber's trade. VAL does not pass through CAT-related fees if the MatchIt subscriber's CAT-related fees are less than $50 for a given month.

financial_condition_summary

Some Subscribers do not have a dedicated rate for executions in POSIT, but, instead, have a default rate across VAL's products where that default rate can apply to executions in POSIT. The commissions charged to execute in POSIT can vary based on the means of access. Direct Subscribers not using other products are charged a rate per executed share ranging from $0.0002 to $0.0065. Orders originating from Subscribers accessing POSIT through Alert, VAL's algorithms, smart order router, trading desks, and/or Alert are charged a rate per executed share based on the fees associated with the particular products used by the Subscriber, irrespective of whether the orders are executed in POSIT or another venue.

financial_condition_summary

MatchIt does not charge any subscription or connectivity fees. Direct Subscribers pay fees between $.0002 and $.0010 per share. VAL and VAL Affiliates are not assessed a fee for MatchIt trades. Indirect Subscribers pay bundled fees, See Section III, Item 19(b). VAL will consider a number of factors in determining the fee an individual Subscriber will be assessed, including, but not limited to, the client's overall relationship with VAL, the type of trading flow, the amount of trading flow, and the markets that will be traded.

financial_condition_summary

POSIT does not charge any subscription or connectivity fees. Historically, execution charges, if any, were individually negotiated with each Direct Subscriber. Currently, Direct Subscribers pay fees between $0 and $.0065 per share. VAL and VAL Affiliates are not assessed a fee for POSIT trades. Indirect Subscribers pay bundled fees, See Section III, Item 19(b). VAL will consider a number of factors in determining the fee an individual Subscriber will be assessed, including, but not limited to, the client's overall relationship with VAL, the type of trading flow, the amount of trading flow, and the markets that will be traded.

financial_condition_summary

POSIT does not charge any subscription or connectivity fees. Historically, execution charges, if any, were individually negotiated with each Direct Subscriber. Currently, Direct Subscribers pay fees between $.0002 and $.0065 per share. VAL and VAL Affiliates are not assessed a fee for POSIT trades. Indirect Subscribers pay bundled fees, See Section III, Item 19(b). VAL will consider a number of factors in determining the fee an individual Subscriber will be assessed, including, but not limited to, the client's overall relationship with VAL, the type of trading flow, the amount of trading flow, and the markets that will be traded.

financial_condition_summary

MatchIt does not charge any subscription or connectivity fees. Direct Subscribers pay fees between $.0005 and $.0010 per share. VAL and VAL Affiliates are not assessed a fee for MatchIt trades. Indirect Subscribers pay bundled fees, See Section III, Item 19(b). VAL will consider a number of factors in determining the fee an individual Subscriber will be assessed, including, but not limited to, the client's overall relationship with VAL, the type of trading flow, the amount of trading flow, and the markets that will be traded.

conflict_description

Virtu ITG LLC ("VIL") is a U.S. broker-dealer that provides execution services to clients and operates the POSIT ATS ("POSIT"). VIL can enter or direct the entry of orders as agent utilizing the MPID ITGI to either MatchIt crossing session. VIL does not trade for its own account in the ordinary course but may enter or direct the entry of orders as principal in connection with errors or accommodations. VAL and VIL enter or direct the entry of orders for other Affiliates, including Virtu AlterNet LLC, a U.S. broker-dealer that provides net trading and step out services to other broker-dealers utilizing the MPID ALTX, and on behalf of non-U.S. Affiliates in Canada, the EU region, and the Asia Pacific region. The Firm's non-U.S. Affiliates trade for their own accounts and provide services to clients globally. VAL and VIL enter or direct orders to the ATS for these Affiliates as agent or riskless principal using a VAL MPID in the case of VAL entering the order or a VIL MPID in the case of VIL entering the order.

conflict_description

"VAL's Canadian, EU and Asia Pacific Affiliates are broker-dealers that offer products and services similar to ""VET and have hi-touch desks, all of which can enter or direct the entry of orders to MatchIt through VAL'. VAL enters or directs orders to the ATS for these Affiliates as agent or riskless principal using the VAL MPIDs VALR, VALX or ITGI.

conflict_description

VAL's Canadian, EU and Asia Pacific Affiliates are broker-dealers that offer products and services similar to VET and have hi-touch desks, all of which can enter or direct the entry of orders to POSIT through VAL. VAL enters or directs orders to the ATS for these Affiliates as agent or riskless principal using the VAL MPIDs VALR, VALX or ITGI.

conflict_description

"VAL's Canadian, EU and Asia Pacific Affiliates are broker-dealers that offer products and services similar to ""VET and have hi-touch desks, all of which can enter or direct the entry of orders to MatchIt through VAL'. VAL enters or directs orders to the ATS for these Affiliates as agent or riskless principal using the VAL MPIDs VALR or VALX.

conflict_description

The following entities are U.S. Affiliates of the Firm that can enter or direct the entry of orders to either MatchIt crossing session: Virtu Financial Capital Markets LLC ("VFCM") is a U.S. broker-dealer that provides algorithms and routing services to VAL, which is VFCM's only client. VAL transmits orders to VFCM that originate from VCMM, the Institutional Desk, the ETF Desk and VET. VFCM enters or directs the entry of all orders received from VAL, irrespective of the capacity transmitted by VAL to VFCM, as agent to both MatchIt crossing sessions utilizing the MPID EWTT. Virtu ITG LLC ("VIL") is a U.S. broker-dealer that provides execution services to clients and operates the POSIT ATS ("POSIT"). VIL ordinarily enters or directs the entry of orders as agent utilizing the MPID ITGI. VIL does not trade for its own account in the ordinary course but may enter or direct the entry of orders as principal in connection with errors or accommodations. VAL, VFCM and VIL enter or direct the entry of orders for other Affiliates, including Virtu AlterNet LLC, a U.S. broker-dealer that provides net trading and step out services to other broker-dealers utilizing the MPID ALTX, and on behalf of non-U.S. Affiliates in Canada, the EU region, and the Asia Pacific region. The Firm's non-U.S. Affiliates trade for their own accounts and provide services to clients globally. VAL, VFCM and VIL enter or direct orders to the ATS for these Affiliates as agent or riskless principal using a VAL MPID in the case of VAL entering the order, a VFCM MPID in the case of VFCM entering the order or a VIL MPID in the case of VIL entering the order.

conflict_description

VAL's Canadian, EU and Asia Pacific Affiliates are broker-dealers that offer products and services similar to VET and have hi-touch desks, all of which can enter or direct the entry of orders to POSIT through VAL. VAL enters or directs orders to the ATS for these Affiliates as agent or riskless principal using the VAL MPIDs GFLO, VALR, VALX or ITGI.

conflict_description

VAL's Canadian, EU and Asia Pacific Affiliates are broker-dealers that offer products and services similar to VET and have hi-touch desks, all of which can enter or direct the entry of orders to POSIT through VAL. VAL enters or directs orders to the ATS for these Affiliates as agent or riskless principal using the VAL MPIDs VALR or VALX.

conflict_description

The following entities are U.S. Affiliates of the Firm that can enter or direct the entry of orders to either MatchIt crossing session: Virtu Financial BD LLC ("VFBD") is a U.S. broker-dealer that is a market maker in NMS equity securities. VFBD enters or directs the entry of orders as principal to both MatchIt crossing sessions utilizing the MPID VIRT. Virtu Financial Capital Markets LLC ("VFCM") is a U.S. broker-dealer that provides algorithms and routing services to VAL, which is VFCM's only client. VAL transmits orders to VFCM that originate from VCMM, the Institutional Desk, the ETF Desk and VET. VFCM enters or directs the entry of all orders received from VAL, irrespective of the capacity transmitted by VAL to VFCM, as agent to both MatchIt crossing sessions utilizing the MPID EWTT. Virtu ITG LLC ("VIL") is a U.S. broker-dealer that provides execution services to clients and operates the POSIT ATS ("POSIT"). VIL ordinarily enters or directs the entry of orders as agent utilizing the MPID ITGI. VIL does not trade for its own account in the ordinary course but may enter or direct the entry of orders as principal in connection with errors or accommodations. VAL, VFCM and VIL enter or direct the entry of orders for other Affiliates, including Virtu AlterNet LLC, a U.S. broker-dealer that provides net trading and step out services to other broker-dealers utilizing the MPID ALTX, and on behalf of non-U.S. Affiliates in Canada, the EU region, and the Asia Pacific region. The Firm's non-U.S. Affiliates trade for their own accounts and provide services to clients globally. VAL, VFCM and VIL enter or direct orders to the ATS for these Affiliates as agent or riskless principal using a VAL MPID in the case of VAL entering the order, a VFCM MPID in the case of VFCM entering the order or a VIL MPID in the case of VIL entering the order.

conflict_description

"VAL's Canadian, EU and Asia Pacific Affiliates are broker-dealers that offer products and services similar to ""VET and have hi-touch desks, all of which can enter or direct the entry of orders to MatchIt through VAL'. VAL enters or directs orders to the ATS for these Affiliates as agent or riskless principal using the VAL MPIDs GFLO, VALR, VALX or ITGI.

conflict_description

Virtu Canada Corporation, Virtu Europe Trading Limited, and Virtu ITG Hong Kong Limited are broker-dealers that offer products and services similar to VET and have hi-touch desks, all of which can enter or direct the entry of orders to MatchIt through VAL. VAL enters or directs orders to the ATS for these Affiliates as agent or riskless principal using the VAL MPIDs VALR or VALX.

compliance_officer

GENERAL BACKGROUND AND SCOPE OF CONFIDENTIAL INFORMATION. The Firm operates POSIT on a matching engine that runs on a standalone server in the NY5 Data Center. See Part I, Item 7; and Part III, Item 6(a). The POSIT matching engine communicates with shared systems to book trades, to report executed trades to the tape, to facilitate clearance and settlement, for financial reporting and billing, and to facilitate other post-trade processes. The Firm operates the Alert application on servers that are separate from the POSIT matching engine. These systems contain Confidential Information. See Part II, Item 6 for information on personnel that have access to Confidential Information. AGGREGATED ANONYMOUS DATA. Data which has been aggregated and which does not identify any Subscribers is not Confidential Information ("Aggregated Anonymous Data"). The Firm publishes firm-wide aggregated anonymous execution data to market wide trade advertisement systems after the transaction has been reported to the consolidated tape. The data does not include any client identities but does include symbol level executed volumes. The Firm includes POSIT Aggregated Anonymous Data in these reports at the end of day. The POSIT Aggregated Anonymous data is combined with the rest of the Firm's data when it is disseminated to these market-wide systems and is not separately identified or attributed to POSIT. While the Firm does not consider this data to be Confidential Information, it nonetheless permits Subscribers to opt out of having their data included in these reports. The Firm posts monthly statistics on its website and disseminates this data to Subscribers ("the Monthly POSIT and Alert Statistics"). The Monthly POSIT and Alert Statistics are available at https://www.virtu.com/about/transparency and provide aggregate and anonymous information about POSIT and Alert, including total volume; volume by sector; volume by market cap; fill size distribution; distribution of Alert block size, and distribution of executions at the bid, mid and offer. The Firm produces market commentary from time-to-time that discusses general market trends. The statistical data described in this paragraph can be used to produce market commentary. The Firm considers this data to be Aggregated Anonymous Data and not Confidential Information. The Firm does not permit Subscribers to opt out of having their data included in these reports. SALES DATA. Sales Data is aggregated information about the products and services the Firm's clients use and includes the client's name, the product or service they use, aggregate executed volume, and revenues ("Sales Data"). Sales Data includes aggregated ATS data as described in the preceding sentence. The Firm provides Sales Data to management personnel, Sales or Trading personnel, Relationship Management personnel and Alert Sales and Coverage personnel who are involved in handling relationships with the Firm's clients. Sales Data is provided for the purpose of allowing these personnel to keep abreast of the client's business activities to manage the client relationship and to cross sell the Firm's products and services to the client. The Firm does not consider Sales Data to be Confidential Information when distributed internally for the above described purposes. The Firm makes this information available in end of day reports and in sales systems (i.e., systems that support activities of Sales or Trading personnel, Relationship Management personnel and Alert Sales and Coverage personnel for the purposes described above) on T+1. The Firm prohibits personnel from disclosing Sales Data to third parties. The Firm does not permit Subscribers to opt out of having this data made available to personnel involved handling client relationships, as defined in Part II, Item 6(a). PERSONNEL WITH ACCESS TO CONFIDENTIAL INFORMATION. The Firm does not have any personnel whose sole responsibility is for the operations of POSIT. The shared personnel discussed in response to Part II, Item 6(a), have access to Confidential Information. SAFEGUARDS AND OVERSEEING CONFIDENTIAL INFORMATION. The Firm maintains written policies and procedures regarding use and protection of Confidential Information. Firm personnel are subject to its parent, Virtu Financial Inc.'s Code of Conduct and Employee Manual. Firm personnel are also subject to the Firm's Information Security Policy, Compliance Manual, and Written Supervisory Procedures. These policies prohibit the personnel listed in Part II, Item 6(a), from sharing Confidential Information with other personnel who are not in one of these permitted categories or with any other person. The exception is that Compliance and Legal personnel may provide information to regulators in response to regulatory requests or to third parties pursuant to subpoena. Personnel who violate the Firm's policies concerning Confidential Information are subject to discipline, including termination of their employment. The Firm performs email reviews and employs data loss software as a means of safeguarding Confidential Information. The Firm procedures require that personnel make requests for access to its systems through the Firm's access ticketing system and to receive approval from a supervisor prior to being granted access to any systems. The Firm's supervisory personnel grant access to systems on the premise that it is necessary to perform their duties and to carry out the purpose for which the information is provided to them. The supervisor responsible for POSIT and Alert approves requests for access to the POSIT matching engine and Alert application. The Firm only permits approved personnel in the categories described in Part II, Item 6(a), to have access to Confidential Information and only permits these personnel to access the systems and the Confidential Information contained therein using approved means of access and credentials. Supervisors do not grant access to Confidential Information. The Firm maintains a process that sends notifications to designated personnel to disable systems access for personnel who are no longer employed by the Firm. Supervisors are responsible for instructing the technology personnel to disable access when employees change roles. The Firm provides reports to the supervisors that show personnel with access to the POSIT matching engine and Alert application on a monthly basis. Supervisors review these reports to ensure that these personnel still require access to carry out responsibilities related to the ATS. PERSONAL TRADING RESTRICTIONS. The Firm maintains employee trading policies that require personnel to disclose their own personal accounts and the accounts of close family members, that prohibit personnel from trading based on any client Confidential Information, that require personnel to pre-clear transactions and attest at the time of trade entry that they are not trading on Confidential Information, and that prescribe holding periods for securities purchases. The Firm conducts reviews of employee trading to determine whether trades were pre-cleared and whether holding periods were observed.

compliance_officer

GENERAL BACKGROUND AND SCOPE OF CONFIDENTIAL INFORMATION. The Firm operates MatchIt on a matching engine that runs on a standalone server in the NY5 Data Center. See Part I, Item 7; and Part III, Item 6(a). The MatchIt matching engine communicates with shared systems to book trades, to report executed trades to the tape, to facilitate clearance and settlement, for financial reporting and billing, and to facilitate other post-trade processes. See Part II, Item 6 for information on personnel that have access to Confidential Information. AGGREGATED ANONYMOUS DATA. Data which has been aggregated and which does not identify any Subscribers is not Confidential Information ("Aggregated Anonymous Data"). The Firm publishes firm-wide aggregated anonymous execution data to market wide trade advertisement systems after the transaction has been reported to the consolidated tape. The data does not include any client identities but does include symbol level executed volumes. 'While the Firm does not consider this data to be Confidential Information, it does not include MatchIT Aggregated Anonymous data in these reports. The Firm posts monthly statistics on its website and disseminates this data to Subscribers ("the Monthly MatchIt Statistics"). The Monthly MatchIt Statistics are available at https://www.virtu.com/about/transparency and provide aggregate and anonymous information about MatchIt, including total volume; volume by sector; volume by market cap; fill size distribution; and distribution of executions at the bid, mid and offer. The Firm produces market commentary from time-to-time that discusses general market trends. The statistical data described in this paragraph can be used to produce market commentary. The Firm considers this data to be Aggregated Anonymous Data and not Confidential Information. The Firm does not permit Subscribers to opt out of having their data included in these reports. SALES DATA. Sales Data is aggregated information about the products and services the Firm's clients use and includes the client's name, the product or service they use, aggregate executed volume, and revenues ("Sales Data"). Sales Data includes aggregated ATS data as described in the preceding sentence. The Firm provides Sales Data to management personnel, Sales or Trading personnel and Relationship Management personnel who are involved in handling relationships with the Firm's clients. Sales Data is provided for the purpose of allowing these personnel to keep abreast of the client's business activities to manage the client relationship and to cross sell the Firm's products and services to the client. The Firm does not consider Sales Data to be Confidential Information when distributed internally for the above described purposes. The Firm makes this information available in end of day reports and in sales systems (i.e., systems that support activities of Sales or Trading personnel and Relationship Management personnel for the purposes described above) on T+1. The Firm prohibits personnel from disclosing Sales Data to third parties. The Firm does not permit Subscribers to opt out of having this data made available to personnel involved in handling client relationships, as defined in Part II, Item 6(a). PERSONNEL WITH ACCESS TO CONFIDENTIAL INFORMATION. The Firm does not have any personnel whose sole responsibility is for the operations of MatchIt. The shared personnel discussed in response to Part II, Item 6(a), have access to Confidential Information. SAFEGUARDS AND OVERSEEING CONFIDENTIAL INFORMATION. The Firm maintains written policies and procedures regarding use and protection of Confidential Information. Firm personnel are subject to its parent, Virtu Financial Inc.'s Code of Conduct and Employee Manual. Firm personnel are also subject to the Firm's Information Security Policy, Compliance Manual, and Written Supervisory Procedures. These policies prohibit the personnel listed in Part II, Item 6(a), from sharing Confidential Information with other personnel who are not in one of these permitted categories or with any other person. The exception is that Compliance and Legal personnel may provide information to regulators in response to regulatory requests or to third parties pursuant to subpoena. Personnel who violate the Firm's policies concerning Confidential Information are subject to discipline, including termination of their employment. The Firm performs email reviews and employs data loss software as a means of safeguarding Confidential Information. The Firm procedures require that personnel make requests for access to its systems through the Firm's access ticketing system and to receive approval from a supervisor prior to being granted access to any systems. The Firm's supervisory personnel grant access to systems on the premise that it is necessary to perform their duties and to carry out the purpose for which the information is provided to them. The supervisor responsible for MatchIt approves requests for access to the MatchIt matching engine. The Firm only permits approved personnel in the categories described in Part II, Item 6(a), to have access to Confidential Information and only permits these personnel to access the systems and the Confidential Information contained therein using approved means of access and credentials. Supervisors do not grant access to Confidential Information. The Firm maintains a process that sends notifications to designated personnel to disable systems access for personnel who are no longer employed by the Firm. Supervisors are responsible for instructing the technology personnel to disable access when employees change roles. The Firm provides reports to the supervisors that show personnel with access to the MatchIt matching engine on a monthly basis. Supervisors review these reports to ensure that these personnel still require access to carry out responsibilities related to the ATS. PERSONAL TRADING RESTRICTIONS. The Firm maintains employee trading policies that require personnel to disclose their own personal accounts and the accounts of close family members, that prohibit personnel from trading based on any client Confidential Information, that require personnel to pre-clear transactions and attest at the time of trade entry that they are not trading on Confidential Information, and that prescribe holding periods for securities purchases. The Firm conducts reviews of employee trading to determine whether trades were pre-cleared and whether holding periods were observed.

compliance_officer

GENERAL BACKGROUND AND SCOPE OF CONFIDENTIAL INFORMATION. The Firm operates MatchIt on a matching engine that runs on a standalone server in the NY5 Data Center. See Part I, Item 7; and Part III, Item 6(a). The MatchIt matching engine communicates with shared systems to book trades, to report executed trades to the tape, to facilitate clearance and settlement, for financial reporting and billing, and to facilitate other post-trade processes. See Part II, Item 6 for information on personnel that have access to Confidential Information. AGGREGATED ANONYMOUS DATA. Data which has been aggregated and which does not identify any Subscribers is not Confidential Information ("Aggregated Anonymous Data"). The Firm publishes firm-wide aggregated anonymous execution data to market wide trade advertisement systems after the transaction has been reported to the consolidated tape. The data does not include any client identities but does include symbol level executed volumes. The Firm includes MatchIt Aggregated Anonymous Data in these reports at the end of day. The MatchIt Aggregated Anonymous data is combined with the rest of the Firm's data when it is disseminated to these market-wide systems and is not separately identified or attributed to MatchIt. While the Firm does not consider this data to be Confidential Information, it nonetheless permits Subscribers to opt out of having their data included in these reports. The Firm posts monthly statistics on its website and disseminates this data to Subscribers ("the Monthly MatchIt Statistics"). The Monthly MatchIt Statistics are available at https://www.virtu.com/about/transparency and provide aggregate and anonymous information about MatchIt, including total volume; volume by sector; volume by market cap; fill size distribution; and distribution of executions at the bid, mid and offer. The Firm produces market commentary from time-to-time that discusses general market trends. The statistical data described in this paragraph can be used to produce market commentary. The Firm considers this data to be Aggregated Anonymous Data and not Confidential Information. The Firm does not permit Subscribers to opt out of having their data included in these reports. SALES DATA. Sales Data is aggregated information about the products and services the Firm's clients use and includes the client's name, the product or service they use, aggregate executed volume, and revenues ("Sales Data"). Sales Data includes aggregated ATS data as described in the preceding sentence. The Firm provides Sales Data to management personnel, Sales or Trading personnel and Relationship Management personnel who are involved in handling relationships with the Firm's clients. Sales Data is provided for the purpose of allowing these personnel to keep abreast of the client's business activities to manage the client relationship and to cross sell the Firm's products and services to the client. The Firm does not consider Sales Data to be Confidential Information when distributed internally for the above described purposes. The Firm makes this information available in end of day reports and in sales systems (i.e., systems that support activities of Sales or Trading personnel and Relationship Management personnel for the purposes described above) on T+1. The Firm prohibits personnel from disclosing Sales Data to third parties. The Firm does not permit Subscribers to opt out of having this data made available to personnel involved in handling client relationships, as defined in Part II, Item 6(a). PERSONNEL WITH ACCESS TO CONFIDENTIAL INFORMATION. The Firm does not have any personnel whose sole responsibility is for the operations of MatchIt. The shared personnel discussed in response to Part II, Item 6(a), have access to Confidential Information. SAFEGUARDS AND OVERSEEING CONFIDENTIAL INFORMATION. The Firm maintains written policies and procedures regarding use and protection of Confidential Information. Firm personnel are subject to its parent, Virtu Financial Inc.'s Code of Conduct and Employee Manual. Firm personnel are also subject to the Firm's Information Security Policy, Compliance Manual, and Written Supervisory Procedures. These policies prohibit the personnel listed in Part II, Item 6(a), from sharing Confidential Information with other personnel who are not in one of these permitted categories or with any other person. The exception is that Compliance and Legal personnel may provide information to regulators in response to regulatory requests or to third parties pursuant to subpoena. Personnel who violate the Firm's policies concerning Confidential Information are subject to discipline, including termination of their employment. The Firm performs email reviews and employs data loss software as a means of safeguarding Confidential Information. The Firm procedures require that personnel make requests for access to its systems through the Firm's access ticketing system and to receive approval from a supervisor prior to being granted access to any systems. The Firm's supervisory personnel grant access to systems on the premise that it is necessary to perform their duties and to carry out the purpose for which the information is provided to them. The supervisor responsible for MatchIt approves requests for access to the MatchIt matching engine. The Firm only permits approved personnel in the categories described in Part II, Item 6(a), to have access to Confidential Information and only permits these personnel to access the systems and the Confidential Information contained therein using approved means of access and credentials. Supervisors do not grant access to Confidential Information. The Firm maintains a process that sends notifications to designated personnel to disable systems access for personnel who are no longer employed by the Firm. Supervisors are responsible for instructing the technology personnel to disable access when employees change roles. The Firm provides reports to the supervisors that show personnel with access to the MatchIt matching engine on a monthly basis. Supervisors review these reports to ensure that these personnel still require access to carry out responsibilities related to the ATS. PERSONAL TRADING RESTRICTIONS. The Firm maintains employee trading policies that require personnel to disclose their own personal accounts and the accounts of close family members, that prohibit personnel from trading based on any client Confidential Information, that require personnel to pre-clear transactions and attest at the time of trade entry that they are not trading on Confidential Information, and that prescribe holding periods for securities purchases. The Firm conducts reviews of employee trading to determine whether trades were pre-cleared and whether holding periods were observed.

hours_of_operation

MatchIt accepts orders beginning at 7:00 a.m. EST. MatchIt executes orders from 9:30 a.m. to 4:00 p.m. EST, Monday through Friday, except for during partial trading days and during United States equity market holidays.

display_best_quotes

For MatchIt's Conditional Session, when there is a potential match of conditional placements, the MatchIt matching engine will send a Firm-Up invite message, which includes the side, symbol, and quantity of the contra-side placement. This information is only sent to the algorithms of VAL and its Affiliates, as Direct Subscribers are not eligible to send orders to the Conditional Session. The messages and the response are all automated and occur in milliseconds.

execution_services

MatchIt begins accepting all order types at 7:00 AM EST. MatchIt does not execute orders before the U.S. market's open, after the U.S. market's close, and during a trading halt. There are no limitations on the types of orders MatchIt will accept prior to the start of regular trading hours or during a trading halt; however, IOC orders will be cancelled back and Peg orders will remain on the MatchIt order book until trading begins. Unexecuted orders will be cancelled at the market's close time. MatchIt does not have an opening auction or have any specific procedures to reopen after a stoppage of trading in either the Main Session or the Conditional Session. Prior to the market's open, and during a trading halt, Peg orders will remain on the book and be prioritized by price, then time, for the Main Session, subject to the constraints placed on an order by a Subscriber. For the Conditional Session, orders will remain on the book and be prioritized by price, then size, then time, subject to the constraints placed on an order. After the market opens, MatchIt will execute orders to the extent there are contra-side matches.