Bruce ATS

amendment_reason

Part III, Item 4. and Item 10, are amended to reflect the ATS logic for orders queuing before 8:00:00 P.M. ET is in time priority. While orders submitted starting at 8:00:00 P.M. ET match on a price/time priority basis. Item 10. is amended to reflect that Immediate-or-Cancel ("IOC") Orders received prior to the 8:00:00 PM are rejected. Part III, Item 6, is amended to reflect that the ATS offers cross-connects. The changes apply to all Subscribers and the Broker-Dealer Operator.

amendment_reason

Material Amendment, Part III, Item 10. is amended to reflect that the Bruce ATS no longer disseminates passive orders outside of the 20% reference price bands. Part II Item 5. and Part III Item 15. are revised to reflect that Level 1 and Level 2 feeds no longer display passive quotes that are outside the 20% reference price bands. The changes apply to all Subscribers and the Broker-Dealer Operator.

amendment_reason

This is a material amendment in order to change the time at which Bruce ATS begins accepting orders from 7:30:00 PM ET to 7:50:00 PM ET. This change is applicable to all Subscribers and the Broker-Dealer Operator. The changes in this amendment are related to Part III, Items 4, 10 and 15.

amendment_reason

Part II, Item 10. was corrected to reflect that the ATS does not reject all orders outside of the 20% price bands. It accepts passively priced orders; however, the passive orders cannot interact with orders on the book and do not execute. Passive and aggressive price language was added to state what types of orders are rejected and accepted. Additionally, we are adding information on when a price can be changed before the Trading Session and if the reference price changes for a security before the start of the Trading Session so will the refence price band for that security. Part III, Item 23. was corrected to state that only executions within the 20% reference price are permitted. The Bruce ATS revised Part II Item 5. and Part III Item 15. to correctly describe that the Top of the Book and Depth of Book feeds, (Level 1 & Level 2 feeds) include displayed passive quotes outside of the 20% price bands that are not executable. The Bruce ATS also re-added the August 5th Material Amendment changes as they were inadvertently dropped from the last submission (December 5, 2025). Re-added Part III, Items 7 and 10 to add the Immediate or Cancel ("IOC') order type and add additional clarifying information of the behavior of Day and IOC orders in the ATS. These changes apply to the Subscribers of the ATS. Part II, Item 7 was revised to add the Chair role for the BDO's management, who will have access to CTI. The changes apply to all Subscribers and the Broker-Dealer Operator.

amendment_reason

This is a correcting amendment, changes in this amendment are related to Part III, Items 15 and Item 19. For Item 15, the change is clarifying who disseminates the market data. For Item 19 the change is correcting the percentage to reflect the correct basis points for transactions in stocks priced below $1.00 that remove liquidity; the change is 0.3%, from 0.003%, previously displayed incorrectly. These changes are applicable to all Subscribers and the Broker-Dealer Operator.

amendment_reason

This is an Updating Amendment, changes in this amendment are related to FORM BD updates. The changes include an update to the new CCO, Katarzyna Inglot, replacing CCO Andrew Tourney. A new Chair role, adding George Ruhana; and an update to the FINOP person replacing Kati Synder, to Ralph D'auge. These changes are applicable to all Subscribers and the Broker-Dealer Operator.

amendment_reason

The Bruce ATS revised Part III, Items 7 and 10 to add the Immediate or Cancel ("IOC") order type and add additional clarifying information of the behavior of Day and IOC orders in the ATS. These changes apply to the Subscribers of the ATS. Part II, Item 7 was revised to add the Chair role for the BDO's management, who will have access to CTI. This change applies to the Broker-Dealer Operator.

amendment_reason

Part II. Item 5(a) and Part II. Item 6(b) are revised to reflect a new service vendor Egnyte, for Bruce ATS, that is available to Subscribers and non-subscribers for Secure File Transfer Protocol (SFTP) file data sharing, including access to data containing confidential trading information which must be approved by the ATS Supervisor (or approved Series 24 delegate) and CCO. The change applies to the Broker-Dealer Operator and all Subscribers.

amendment_reason

Correcting Amendment, Part III, Item 19. is amended to reflect a change in the rebate up to $.002 for transactions in stocks priced greater than or equal to $1.00 that add liquidity. Also, Bruce ATS at its discretion may offer additional discounted rates for market data. Additionally, revised language to add that non-subscriber participants are eligible for market data discounts. The changes apply to all Subscribers and the Broker-Dealer Operator.

ats_name

Bruce Markets LLC

operator_crd

000300209

operator_name

BRUCE MARKETS LLC

order_types

ORDER TYPES, ORDER HANDLING, PRIORITY AND TIME-IN-FORCE Bruce ATS only accepts firm limit orders with Time-in-Force of "Day" or Immediate-or-Cancel ("IOC"). For the purposes of Bruce ATS, "Day and IOC" order refers to the full trading session of 8:00:00 P.M. ET to 4:00:00 A.M. ET the following day (the "Trading Session"). All orders and messages are handled via single thread processing. Bruce ATS automatically cancels all resting orders that have not been executed by 4:00:00 A.M. Except for trading in stocks priced below $1.00, Bruce ATS does not accept orders with sub-penny values in the price field. Bruce ATS does not route away. Bruce ATS Order Book ranks orders by price / time based and are matched by price / time as well. Time priority is determined by the order receipt time. Trades are not priced or relate to NBBO, which is not available during the operation hours of Bruce ATS. Order types cannot be modified since Bruce ATS only accepts limit orders. Day Orders: For Day orders, the order will remain in the Bruce ATS until it is cancelled, the full quantity is executed, or the trading session closes. If a partial match of a Day Order occurs, the remainder of the Day Order will stay open in the ATS until it is matched, cancelled or expires. Immediate-or-Cancel ("IOC") Orders: IOC orders are accepted starting at 8:00:00 PM ET; any IOC order(s) entered prior to the start of the Trading Session will be rejected. IOC orders will match immediately with eligible resting contra-side orders and Bruce ATS will cancel back the remaining balance. IOC orders may not be modified, replaced, cancelled or routed by the Subscriber. Subscribers can cancel unexecuted Day orders at their discretion during the Trading Session. Subscribers can cancel unexecuted orders at their discretion during the Trading Session. Modifications to decrease an order's size through a cancel/replace instruction will maintain the original time priority of an order. Modifications that increase an order's size will result in a new time priority. Additionally, modifications to an order's price results in a new time priority. Bruce ATS will process cancel requests immediately upon receipt, but executions may occur before the cancel request is fully processed Order types may be rejected for several reasons, including but not limited to, a violation of Bruce ATS's FIX specification or Subscribers' pre-trade credit and risk limits as set by the BDO (discussed in Part III, Item 2).

order_types

ORDER TYPES, ORDER HANDLING, PRIORITY AND TIME-IN-FORCE Bruce ATS only accepts firm limit orders with Time-in-Force of "Day" or Immediate-or-Cancel ("IOC"). For the purposes of Bruce ATS, "Day and IOC" orders refers to the full trading session of 8:00:00 P.M. ET to 4:00:00 A.M. ET the following day (the "Trading Session"). All orders and messages are handled via single thread processing. Bruce ATS automatically cancels all resting orders that have not been executed by 4:00:00 A.M. Except for trading in stocks priced below $1.00, Bruce ATS does not accept orders with sub-penny values in the price field. Bruce ATS does not route away. Bruce ATS Order Book ranks orders by price / time based and are matched by price / time as well. Time priority is determined by the order receipt time. Trades are not priced or relate to NBBO, which is not available during the operation hours of Bruce ATS. Order types cannot be modified since Bruce ATS only accepts limit orders. Day Orders: For Day orders, the order will remain in the Bruce ATS until it is cancelled, the full quantity is executed, or the trading session closes. If a partial match of a Day Order occurs, the remainder of the Day Order will stay open in the ATS until it is matched, cancelled or expires. Immediate-or-Cancel ("IOC") Orders: IOC orders will match immediately with eligible resting contra-side orders and Bruce ATS will cancel back the remaining balance. IOC orders may not be modified, replaced, cancelled or routed by the Subscriber. Subscribers can cancel unexecuted orders at their discretion during the Trading Session. Modifications to decrease an order's size through a cancel/replace instruction will maintain the original time priority of an order. Modifications that increase an order's size will result in a new time priority. Additionally, modifications to an order's price results in a new time priority. Bruce ATS will process cancel requests immediately upon receipt, but executions may occur before the cancel request is fully processed Order types may be rejected for several reasons, including but not limited to, a violation of Bruce ATS's FIX specification or Subscribers' pre-trade credit and risk limits as set by the BDO (discussed in Part III, Item 2).

order_types

ORDER TYPES, ORDER HANDLING, PRIORITY AND TIME-IN-FORCE Bruce ATS only accepts firm limit orders with Time-in-Force of "Day" or Immediate-or-Cancel ("IOC"). For the purposes of Bruce ATS, "Day and IOC" order refers to the full trading session of 8:00:00 P.M. ET to 4:00:00 A.M. ET the following day (the "Trading Session"). All orders and messages are handled via single thread processing. Bruce ATS automatically cancels all resting orders that have not been executed by 4:00:00 A.M. Except for trading in stocks priced below $1.00, Bruce ATS does not accept orders with sub-penny values in the price field. Bruce ATS does not route away. Bruce ATS Order Book ranks orders by price / time based and are matched by price / time as well. Time priority is determined by the order receipt time. Trades are not priced or relate to NBBO, which is not available during the operation hours of Bruce ATS. Order types cannot be modified since Bruce ATS only accepts limit orders. Day Orders: For Day orders, the order will remain in the Bruce ATS until it is cancelled, the full quantity is executed, or the trading session closes. If a partial match of a Day Order occurs, the remainder of the Day Order will stay open in the ATS until it is matched, cancelled or expires. Immediate-or-Cancel ("IOC") Orders: IOC orders will match immediately with eligible resting contra-side orders and Bruce ATS will cancel back the remaining balance. IOC orders may not be modified, replaced, cancelled or routed by the Subscriber. Subscribers can cancel unexecuted Day orders at their discretion during the Trading Session. Subscribers can cancel unexecuted orders at their discretion during the Trading Session. Modifications to decrease an order's size through a cancel/replace instruction will maintain the original time priority of an order. Modifications that increase an order's size will result in a new time priority. Additionally, modifications to an order's price results in a new time priority. Bruce ATS will process cancel requests immediately upon receipt, but executions may occur before the cancel request is fully processed Order types may be rejected for several reasons, including but not limited to, a violation of Bruce ATS's FIX specification or Subscribers' pre-trade credit and risk limits as set by the BDO (discussed in Part III, Item 2).

order_types

ORDER TYPES, ORDER HANDLING, PRIORITY AND TIME-IN-FORCE Bruce ATS only accepts firm limit orders and with Time-in-Force of "Day." For the purposes of Bruce ATS, "Day" order refers to the full trading session of 8:00:00 P.M. ET to 4:00:00 A.M. ET the following day (the "Trading Session"). All orders and messages are handled via single thread processing. Bruce ATS automatically cancels all resting orders that have not been executed by 4:00:00 A.M. Except for trading in stocks priced below $1.00, Bruce ATS does not accept orders with sub-penny values in the price field. Bruce ATS does not route away. Bruce ATS Order Book ranks orders by price / time based and are matched by price / time as well. Time priority is determined by the order receipt time. Trades are not priced or relate to NBBO, which is not available during the operation hours of Bruce ATS. Order types cannot be modified since Bruce ATS only accepts limit orders. Subscribers can cancel unexecuted orders at their discretion during the Trading Session. Modifications to decrease an order's size through a cancel/replace instruction will maintain the original time priority of an order. Modifications that increase an order's size will result in a new time priority. Additionally, modifications to an order's price results in a new time priority. Bruce ATS will process cancel requests immediately upon receipt, but executions may occur before the cancel request is fully processed Order types may be rejected for several reasons, including but not limited to, a violation of Bruce ATS's FIX specification or Subscribers' pre-trade credit and risk limits as set by the BDO (discussed in Part III, Item 2).

means_of_entry

Bruce ATS requires all orders to be entered via Financial Information eXchange ("FIX") protocol. Bruce ATS supports FIX 4.2. This applies to and is the same for all Subscribers, including Apex Clearing. Bruce ATS does not accept orders via telephone, email, instant message, or other form of communication.

pricing_methodology

Bruce ATS does not operate during regular or extended trading hours of the national securities exchanges, and there is no NBBO available for hours in which Bruce ATS operates. Bruce ATS obtains last print data from the Nasdaq SIP feed as of or near 7:30 P.M. ET that serves as the primary reference price for each NMS Stock that trades on Bruce ATS for that Trading Session. That reference price is the last sale price for each security printed on a national securities exchange or the closing price of the security on a national securities exchange if the former is not available. As discussed in Part III, Item 11 above, Bruce ATS only permits orders priced within 20% of the reference price.

pricing_methodology

Bruce ATS does not operate during regular or extended trading hours of the national securities exchanges, and there is no NBBO available for hours in which Bruce ATS operates. Bruce ATS obtains last print data from the Nasdaq SIP feed as of or near 7:30 P.M. ET that serves as the primary reference price for each NMS Stock that trades on Bruce ATS for that Trading Session. That reference price is the last sale price for each security printed on a national securities exchange or the closing price of the security on a national securities exchange if the former is not available. As discussed in Part III, Item 10 above, Bruce ATS only permits executions priced within 20% of the reference price.

counterparty_selection

Bruce ATS enforces self-trade prevention by default. Self-trade prevention prevents Subscriber orders from crossing with other orders from the same Subscriber. Subscribers can elect to opt out of self-trade prevention on Bruce ATS for all the Subscriber's orders, or a subset(s) of the Subscriber's orders. For example, a Subscriber can choose to have the ATS not enforce self-trade prevention only on orders from a particular business unit of the Subscriber (e.g., do not enforce for the agency trading desk; enforce for the proprietary trading desk) or only on orders from a specific customer(s) of the Subscriber. Subscribers can instruct the BDO to not enforce default self-trade prevention on Bruce ATS in either of two ways: i. By contacting the BDO's Subscriber support team during onboarding or at any time thereafter and requesting that Bruce ATS not enforce self-trade prevention for all or a subset of orders. This request is implemented by the BDO support team in the trading system. ii. By sending a FIX tag and value as specified in the Bruce ATS FIX specification in order to opt out of default self-trade prevention on an order-by-order basis. A cross between a buy and sell order from the same Subscriber will only occur if the Subscriber has requested that the ATS not enforce self-trade prevention on both the buy and sell order. No other counter-party selection or restrictions are available.

order_segmentation

false

financial_condition_summary

Transaction Fees The BDO assesses a negotiated per-executed-share fee to Subscribers for shares traded in Bruce ATS that remove liquidity (taking). For transactions in stocks priced greater than or equal to $1.00 that remove liquidity, there is a charge of $0.00 up to $0.0020. For transactions in stocks priced below $1.00 that remove liquidity, the BDO assesses a negotiated fee of $0.00 up to 0.003% (30 basis points) of the total notional dollar volume. Fees may be reduced for Subscribers at the BDO's discretion based on factors, including being an early adopter to Bruce ATS, the historical trading volume on Bruce ATS, and expected future trading volume on Bruce ATS. The BDO passes through certain regulatory fees, including Consolidated Audit Trail (CAT) fees and SEC's Section 31 fees and FINRA's Trading Activity Fee ("TAF") for subscribers who are not FINRA members. As the CAT Executing Broker for all trades on Bruce ATS, the BDO reports a cross trade as the buyer and seller for trade reporting purposes (i.e., "Alternative #1" method under FINRA guidance). Bruce ATS incurs charges on both sides of the cross, and the BDO passes the allocated regulatory fees back to the Subscribers on both sides of the transaction. As previously referenced, the applicable fees are a pass through of the fees charged to the BDO, with no markup applied to Subscribers. Market Data Fees The BDO's parent company, Bruce Markets Holdings LLC ("Bruce Holdings"), distributes Bruce ATS Market Data Feeds to Bruce ATS Market Data Subscribers either directly or via third-party distributors. Bruce Holdings charges recipients for Bruce ATS Market Data Feeds, assessed monthly. The monthly fees for Bruce ATS Market Data for Subscriber and non-subscriber participants are as follows: Level 1 and Level 2 non-display license (for internal use only): $5,000 for both Level 1 display license: $7,500 to $20,000 Level 2 display license: $10,000 to $22,000 Last sale price only: $5,000 to $7,500 The monthly fees for Bruce ATS Market Data for market data vendors and information portals are as follows: Level 1 and Level 2 non-display license (for internal use only): $5,000 for both Level 1 display license: $5,000 to $20,000 Level 2 display license: $10,000 to $22,000 Last sale price only: $5,000 to $7,500 A display license permits market data to be displayed on a screen or terminal, while a non-display license permits data to be used by systems or devices, but not displayed to end-users. Bruce Holdings determines pricing for Bruce ATS Market Data within the ranges above based on several factors, including client type (i.e., Bruce ATS Subscriber, non-Bruce ATS Subscriber, or media company), data usage (e.g., displayed or non-displayed), distribution (internal or external), data content (Level 1 or Level 2), and the historical and/or forecasted participation statistics of trading on ATS, number of terminals on which the data is displayed, open/public distribution or access restricted (e.g., distribution behind a paywall / login).

financial_condition_summary

Transaction Fees The BDO assesses a negotiated per-executed-share fee to Subscribers for shares traded in Bruce ATS that remove liquidity (taking). For transactions in stocks priced greater than or equal to $1.00 that remove liquidity, there is a charge of $0.00 up to $0.0020. For transactions in stocks priced below $1.00 that remove liquidity, the BDO assesses a negotiated fee of $0.00 up to 0.3% (30 basis points) of the total notional dollar volume. Fees may be reduced for Subscribers at the BDO's discretion based on factors, including being an early adopter to Bruce ATS, the historical trading volume on Bruce ATS, and expected future trading volume on Bruce ATS. The BDO passes through certain regulatory fees, including Consolidated Audit Trail (CAT) fees and SEC's Section 31 fees and FINRA's Trading Activity Fee ("TAF") for subscribers who are not FINRA members. As the CAT Executing Broker for all trades on Bruce ATS, the BDO reports a cross trade as the buyer and seller for trade reporting purposes (i.e., "Alternative #1" method under FINRA guidance). Bruce ATS incurs charges on both sides of the cross, and the BDO passes the allocated regulatory fees back to the Subscribers on both sides of the transaction. As previously referenced, the applicable fees are a pass through of the fees charged to the BDO, with no markup applied to Subscribers. Market Data Fees The BDO's parent company, Bruce Markets Holdings LLC ("Bruce Holdings"), distributes Bruce ATS Market Data Feeds to Bruce ATS Market Data Subscribers either directly or via third-party distributors. Bruce Holdings charges recipients for Bruce ATS Market Data Feeds, assessed monthly. The monthly fees for Bruce ATS Market Data for Subscriber and non-subscriber participants are as follows: Level 1 and Level 2 non-display license (for internal use only): $5,000 for both Level 1 display license: $7,500 to $20,000 Level 2 display license: $10,000 to $22,000 Last sale price only: $5,000 to $7,500 The monthly fees for Bruce ATS Market Data for market data vendors and information portals are as follows: Level 1 and Level 2 non-display license (for internal use only): $5,000 for both Level 1 display license: $5,000 to $20,000 Level 2 display license: $10,000 to $22,000 Last sale price only: $5,000 to $7,500 A display license permits market data to be displayed on a screen or terminal, while a non-display license permits data to be used by systems or devices, but not displayed to end-users. Bruce Holdings determines pricing for Bruce ATS Market Data within the ranges above based on several factors, including client type (i.e., Bruce ATS Subscriber, non-Bruce ATS Subscriber, or media company), data usage (e.g., displayed or non-displayed), distribution (internal or external), data content (Level 1 or Level 2), and the historical and/or forecasted participation statistics of trading on ATS, number of terminals on which the data is displayed, open/public distribution or access restricted (e.g., distribution behind a paywall / login).

financial_condition_summary

Transaction Fees The BDO assesses a negotiated per-executed-share fee to Subscribers for shares traded in Bruce ATS that remove liquidity (taking). For transactions in stocks priced greater than or equal to $1.00 that remove liquidity, there is a charge of $0.00 up to $0.0020. For transactions in stocks priced below $1.00 that remove liquidity, the BDO assesses a negotiated fee of $0.00 up to 0.3% (30 basis points) of the total notional dollar volume. Fees may be reduced for Subscribers at the BDO's discretion based on factors, including being an early adopter to Bruce ATS, the historical trading volume on Bruce ATS, and expected future trading volume on Bruce ATS. The BDO passes through certain regulatory fees, including Consolidated Audit Trail (CAT) fees and SEC's Section 31 fees and FINRA's Trading Activity Fee ("TAF") for subscribers who are not FINRA members. As the CAT Executing Broker for all trades on Bruce ATS, the BDO reports a cross trade as the buyer and seller for trade reporting purposes (i.e., "Alternative #1" method under FINRA guidance). Bruce ATS incurs charges on both sides of the cross, and the BDO passes the allocated regulatory fees back to the Subscribers on both sides of the transaction. As previously referenced, the applicable fees are a pass through of the fees charged to the BDO, with no markup applied to Subscribers. Market Data Fees The BDO's parent company, Bruce Markets Holdings LLC ("Bruce Holdings"), distributes Bruce ATS Market Data Feeds to Bruce ATS Market Data Subscribers either directly or via third-party distributors. Bruce Holdings charges recipients for Bruce ATS Market Data Feeds, assessed monthly. The monthly fees for Bruce ATS Market Data for Subscriber and non-subscriber participants are as follows: Level 1 and Level 2 non-display license (for internal use only): $5,000 for both Level 1 display license: $7,500 to $20,000 Level 2 display license: $10,000 to $22,000 Last sale price only: $5,000 to $7,500 The monthly fees for Bruce ATS Market Data for market data vendors and information portals are as follows: Level 1 and Level 2 non-display license (for internal use only): $5,000 for both Level 1 display license: $5,000 to $20,000 Level 2 display license: $10,000 to $22,000 Last sale price only: $5,000 to $7,500 A display license permits market data to be displayed on a screen or terminal, while a non-display license permits data to be used by systems or devices, but not displayed to end-users. Bruce Holdings determines pricing for Bruce ATS Market Data within the ranges above and may at its discretion offer additional discounted rates based on several factors, including client type (i.e., Bruce ATS Subscriber, non-Bruce ATS Subscriber, or media company), data usage (e.g., displayed or non-displayed), distribution (internal or external), data content (Level 1 or Level 2), and the historical and/or forecasted participation statistics of trading on ATS, number of terminals on which the data is displayed, open/public distribution or access restricted (e.g., distribution behind a paywall / login).

conflict_description

Bruce Markets LLC ("BDO") is the Broker-Dealer operator of the NMS Stock ATS and is referred to as the "BDO" throughout this Form. The MPID for the BDO is "BOSS." The NMS Stock ATS is known as Bruce ATS and referred to as such throughout this Form. Apex Clearing Corporation ("Apex Clearing") is a registered broker-dealer and correspondent clearing firm (CRD 13071, SEC 8-23522), regulated by the U.S. Securities and Exchange Commission ("SEC"), the Financial Institution Regulatory Authority ("FINRA"), and various national securities exchanges of which it is a member. Apex Clearing is a Bruce ATS Subscriber and permitted to enter orders to Bruce ATS in an agency or principal capacity under the MPIDs "APCC" and "PFCM." PEAK6 Capital Management LLC ("CapMan") is a registered broker-dealer (CRD 43773, SEC 8-50422), regulated by SEC, FINRA, and various national securities exchanges of which it is a member. CapMan is a Bruce ATS Subscriber and permitted to enter orders to Bruce ATS in a Principal capacity under the MPIDs "PKCM" and "PXAX." The BDO, Apex Clearing, and CapMan are all under common majority ultimate beneficial ownership and thereby recognized as Affiliates.

compliance_officer

Subscribers' Confidential Trading Information ("CTI") includes: - Subscriber order and execution information (i.e., symbol, side, size, quantity, price, type) (discussed in detail in Part III, Item 7(a)); - Subscriber-attributed execution detail; - Individual Subscriber order and execution statistics; - FIX messages sent to Bruce ATS from Subscribers; and - FIX messages sent from Bruce ATS to Subscribers The BDO does not consider post-execution information typically of the type made public under Bruce ATS's Market Data Feeds, reporting, or regulation (e.g., information that is reported to the consolidated tape pursuant to FINRA trade reporting requirements), or information of an aggregated nature (e.g., aggregated and anonymous execution statistics and the information disclosed as described in Part II, Item 7(b), below) to be classified as CTI. Furthermore, CTI originates from Bruce ATS, where orders are received and processed almost instantaneously by the BDO before being immediately made available to Nasdaq Data Business Inc. as market data. Nasdaq Data Business Inc. disseminates the order information via a multicast feed within milliseconds following the submission of an order. As a result, the window during which this data qualifies as "confidential" is so brief that the opportunity for CTI misuse is de minimus. As discussed in Part II, Item 5(a), Bruce ATS provides Subscribers with reports containing data that includes or is derived from CTI specific to the respective Subscriber. All such reports adhere to Bruce ATS's policies pertaining to the protection of CTI. Report content containing only aggregated or non-attributed data are not classified as CTI. Reports containing non-aggregated information that reflects an individual Subscriber's experience will be shared, confidentially, only with that Subscriber and any authorized parties of a Subscriber (e.g., a Subscriber's clearing firm or a Subscriber's customer). The BDO has established confidentiality and information security policies and procedures, including the protection of subscriber confidential trading information, which apply to all BDO personnel and Shared Employees with access to CTI until such information is published on the Bruce ATS Market Data Feeds. Subscriber CTI is encrypted and access-controlled with access only granted upon Compliance personnel approval based on a "rights of least privilege" methodology and on a "needs to know" basis in order to perform required job duties. Refer to Part III, Item 7(d) for additional information. Furthermore, personnel with CTI access must complete mandatory security awareness training. Third Party Access Protections: Certain Ocean employees have access to CTI, including information regarding individual orders and executions, names of Subscribers, and volume of orders in the ATS. Such employees include Ocean staff from compliance, operations, technology development (including trading and surrounding systems), product management, and business management. Ocean's policies and procedures (i) restrict which Ocean employees have access to CTI, and (ii) implement information barriers that prohibit employees with CTI from sharing such information in an unauthorized fashion, as well as (iii) impose personal trading limitations. Ocean's policies and procedures employ a three-pronged approach to permission access to the Bruce ATS. First, an Ocean employee must complete Compliance training specific to the Ocean business unit. Second, an Ocean employee must request, and Ocean Compliance must approve, access to each Bruce ATS system operated by Ocean based on the employee's designated role and responsibilities where such role and responsibilities require access to the Bruce ATS. No other Ocean employees have access to the Bruce ATS or Subscriber Confidential Information. Third, once approved, the Ocean employee must complete Ocean's annual compliance training. Furthermore, the BDO requires that Ocean obtain express approval from the BDO's Chief Compliance Officer or designee before granting access to CTI for any user and to perform quarterly reviews to confirm system access or entitlements remain accurate and terminate systems access or entitlements that are no longer necessary. Ocean employees who have access to CTI are subject to Ocean's "Information Barriers and Conflict Management Policies and Procedures." Pursuant to these procedures, Ocean employees are prohibited from sharing CTI with other employees (including at Nasdaq) who are not expressly authorized to receive such information. All Ocean employees are also subject to Nasdaq's Global Trading Policy ("GTP"), which outlines all requirements and restrictions related to personal trading activity, including holding periods, annual attestations, IPO restrictions, and a prohibited list. Ocean employees are required to disclose personal investment and brokerage accounts, positions, and transactions. Nasdaq's Global Ethics Team monitors personal trade activities against GTP. Ocean also conducts electronic communications reviews to identify policy violations, including non-compliance with the above-referenced policies and procedures. In addition to the foregoing, Ocean maintains written policies and procedures concerning unauthorized disclosures, which include escalation procedures for such incidents. In this regard, Ocean will promptly notify the BDO of any actual or suspected unauthorized disclosure of confidential information, which includes Subscriber CTI (so long as not prohibited by applicable laws, rules, or regulations). The BDO has the right to audit Ocean's operation of the ATS, including Ocean's access to and use of CTI, either through audits conducted by the BDO's own audit team or by third-party auditors. Such audits may be conducted onsite or offsite. In addition to Ocean personnel, Ocean has retained S3 to submit trade reports to the Consolidated Audit Trail ("CAT") on the BDO's behalf. Accordingly, certain S3 personnel have access to Bruce ATS and order and trade information, which are components of CTI. Only S3 personnel that are required to perform approved tasks (i.e., performing the trade reporting functions on the BDO's behalf via its relationship with Ocean) are authorized to access the relevant CTI (as described above). To ensure that only authorized personnel access the relevant CTI, and that authorized personnel only use such access to perform approved functions, S3 performs periodic access audits. An attestation setting forth the results of these audits are provided to the BDO. In addition to the results of these audits, S3 will notify the BDO of any actual or suspected unauthorized disclosure of CTI. Ocean also conducts electronic communications reviews monthly, or additionally as necessary, for potential policy violations, including non-compliance with the referenced policies and procedure and will promptly notify Bruce ATS senior management of any actual or suspected unauthorized disclosure of Subscriber CTI. Bruce ATS has the right to audit Ocean's operation of the ATS matching engine, including access to and use of Subscriber CTI, either through audits by Bruce ATS or a third-party auditor. As noted earlier in Part II, Item 7(a), the window during which Nasdaq Data Business Inc. has access to CTI of Bruce ATS is so brief that the opportunity for CTI misuse is de minimus. Nevertheless, Nasdaq Data Business Inc.'s receipt and usage of Bruce ATS data is subject to (i) contractual confidentiality provisions pursuant to our data distribution agreement, which includes restrictive covenants requiring that Nasdaq Data Business Inc. protect and use substantially equivalent steps it takes to protect its own proprietary information to prevent any disclosure of Bruce ATS data, including CTI, (other than to those individuals who must have access to perform its duties under the agreement, and each such person must also affirmatively agree to comply with such restrictions); and (ii) Nasdaq Data Business Inc. personnel are subject to Nasdaq's Global Trading Policy, which outlines all requirements and restrictions related to personal trading activity, including holding periods, annual attestations, IPO restrictions, and a prohibited list. Responsibilities For Users with CTI Access Users with access to CTI, including BDO personnel, Shared Employees and third-party service providers, must adhere to the following: 1. Protecting CTI from unauthorized and even inadvertent access; 2. Remaining familiar with and adhering to information barriers; 3. Having CTI access removed or reduced when no longer needed; 4. Reporting breaches of CTI or other issues of non-compliance or potential non-compliance with this policy to the CCO. Supervision Quarterly, the Chief Compliance Officer or qualified designee will review users with access to CTI to confirm system access or entitlements remain accurate and terminate systems access or entitlements that are no longer necessary. Avoiding Conflicts of Interest In order to prevent the misuse of CTI and other potential conflicts of interest, the BDO has implemented the following policies and procedures, which are applicable to BDO personnel and Shared Employees: 1. Any personnel, including personnel of parent or affiliated companies, who directly or indirectly trade for or have influence over the trading decisions of a Subscriber or other trading entity are strictly prohibited from accessing CTI. 2. Everyone with access to CTI is prohibited from accessing and using CTI for any reason other than providing support and supervision of the ATS. 3. BDO personnel and Shared Employees are required to obtain compliance approval prior to establishing brokerage accounts, and approved accounts are subject to ongoing monitoring by the compliance department of the BDO or an affiliated company. Annually, each employee must attest in writing that they have disclosed to all their brokerage accounts and that they understand and will abide by company personal trading policies, including the prohibition of trading on material, non-public information which can include CTI. 4. No one with access to real-time CTI may trade for their own account during Bruce ATS's Trading Session whether through the ATS or elsewhere, unless an exception is granted for nominally-sized trades (less than $1,000 notional) entered for bona fide testing and observation purposes. 5. The BDO provides training to new hires and on an ongoing basis (no less than annually) regarding safeguarding CTI, information barriers, personal trading policies, material non-public information, and information and cyber security.

nms_equity

true

subscriber_types

Brokers

hours_of_operation

The Bruce ATS trading session is from Sunday evening through Friday morning from 8:00:00 P.M. ET to 4:00:00 A.M. ET. These hours constitute the "Trading Session" as used herein, and these are the regular hours of Bruce ATS; Bruce ATS does not operate outside of these hours or during the regular trading hours of the national securities exchanges. Bruce ATS is available for connectivity beginning at 7:00:00 P.M. ET and accepts orders beginning at 7:30:00 P.M. ET. Orders received between 7:30:00 P.M. ET and 8:00:00 P.M. ET are accepted in Bruce ATS's Order Book and queued based on price and time priority until the start of the Trading Session. At that time, the orders become eligible for execution. All orders received outside of the applicable operating hours are rejected. Open orders in the overnight Trading Session remaining at 4:00:00 A.M. ET expire at that time and do not carry over to the following overnight session. At 4:00:00 A.M. ET, Bruce ATS cancels all orders in Bruce ATS. Bruce ATS observes the holiday schedule followed by the national securities exchanges and does not operate on the day immediately preceding an exchange holiday. However, Bruce ATS does not adjust its hours of operation on days the exchanges are scheduled early close. For example, there is no overnight Trading Session on Christmas Eve (December 24th) since the TRF is not open on Christmas Day (December 25th). However, Bruce ATS may operate in its overnight Trading Session beginning on Christmas night (i.e., at 7:30 P.M. ET on December 25th) assuming the TRF is open and available for trade reporting the following day on December 26th.

hours_of_operation

The Bruce ATS trading session is from Sunday evening through Friday morning from 8:00:00 P.M. ET to 4:00:00 A.M. ET. These hours constitute the "Trading Session" as used herein, and these are the regular hours of Bruce ATS; Bruce ATS does not operate outside of these hours or during the regular trading hours of the national securities exchanges. Bruce ATS is available for connectivity beginning at 7:00:00 P.M. ET and accepts orders beginning at 7:50:00 P.M. ET. Orders received between 7:50:00 P.M. ET and 8:00:00 P.M. ET are accepted in Bruce ATS's Order Book and queued based on price and time priority until the start of the Trading Session. At that time, the orders become eligible for execution. All orders received outside of the applicable operating hours are rejected. Open orders in the overnight Trading Session remaining at 4:00:00 A.M. ET expire at that time and do not carry over to the following overnight session. At 4:00:00 A.M. ET, Bruce ATS cancels all orders in Bruce ATS. Bruce ATS observes the holiday schedule followed by the national securities exchanges and does not operate on the day immediately preceding an exchange holiday. However, Bruce ATS does not adjust its hours of operation on days the exchanges are scheduled early close. For example, there is no overnight Trading Session on Christmas Eve (December 24th) since the TRF is not open on Christmas Day (December 25th). However, Bruce ATS may operate in its overnight Trading Session beginning on Christmas night (i.e., at 7:50 P.M. ET on December 25th) assuming the TRF is open and available for trade reporting the following day on December 26th.

hours_of_operation

The Bruce ATS trading session is from Sunday evening through Friday morning from 8:00:00 P.M. ET to 4:00:00 A.M. ET. These hours constitute the "Trading Session" as used herein, and these are the regular hours of Bruce ATS; Bruce ATS does not operate outside of these hours or during the regular trading hours of the national securities exchanges. Bruce ATS is available for connectivity beginning at 7:00:00 P.M. ET and accepts orders beginning at 7:50:00 P.M. ET. Orders received between 7:50:00 P.M. ET and 8:00:00 P.M. ET are accepted in Bruce ATS's Order Book and queued in time priority until the start of the Trading Session and will match in time priority. After 8:00:00 P.M. ET orders submitted to the ATS match on a price/time priority basis. All orders received outside of the applicable operating hours are rejected. Open orders in the overnight Trading Session remaining at 4:00:00 A.M. ET expire at that time and do not carry over to the following overnight session. At 4:00:00 A.M. ET, Bruce ATS cancels all orders in Bruce ATS. Bruce ATS observes the holiday schedule followed by the national securities exchanges and does not operate on the day immediately preceding an exchange holiday. However, Bruce ATS does not adjust its hours of operation on days the exchanges are scheduled early close. For example, there is no overnight Trading Session on Christmas Eve (December 24th) since the TRF is not open on Christmas Day (December 25th). However, Bruce ATS may operate in its overnight Trading Session beginning on Christmas night (i.e., at 7:50 P.M. ET on December 25th) assuming the TRF is open and available for trade reporting the following day on December 26th.

display_best_quotes

Bruce ATS is a non-attributed display venue providing Bruce ATS Market Data Feeds containing market data during Bruce ATS's Trading Session to Subscribers and third parties that consume or redistribute market data. This includes top of book (i.e., "Level 1"), full depth of book (i.e., "Level 2"), or both, for all symbols traded on Bruce ATS during the Trading Session. Level 1 data includes the most aggressively priced aggregated bid and offer, and Level 2 includes information (described below) about an order is added, replaced, canceled, and/or executed. Both Level 1 and Level 2 include the last sale price for trades executed on Bruce ATS. When a Subscriber submits an order to Bruce ATS, the order will be displayed (including odd and mixed lot orders). Subscribers cannot opt out of order display. Orders are displayed until canceled, cancel/replaced, executed, or expired. Information on orders displayed includes: 1) Time, 2) Order ID, 3) Side Indicator, 4) Quantity, 5) Symbol, 6) Price. See Part III, Item 11(a) and Part II, Item 7 above for more information. Bruce ATS disseminates security eligibility information prior to accepting orders at 7:50:00 P.M. ET (the "Opening Message"), which indicates all securities eligible to trade during that session. Following the Opening Message until 8:00 P.M. ET, Bruce ATS only sends updates to the eligible security list, if any. From 8:00:00 P.M. to 4:00:00 A.M. ET, Bruce Holdings sends the Bruce ATS Market Data Feeds that include the order information described above as well as execution information indicating that an order previously displayed has been executed. The counterparties for executions are not displayed. Bruce ATS Market Data Subscribers include Bruce ATS broker-dealer subscribers that subscribe to Bruce ATS for the purpose of transacting in securities, as well as recipients that subscribe solely for access to the data. It is not a requirement for a Bruce ATS Market Data Subscriber to be a broker-dealer or Bruce ATS Subscriber. Each Bruce ATS Market Data Subscriber is subject to the same terms of use. Bruce ATS Market Data Subscribers must subscribe by entering into a market data agreement with Bruce Holdings. Bruce Holdings disseminates the Bruce ATS Market Data Feeds to Bruce ATS Market Data Subscribers in one of two ways: directly from Bruce Holdings to the Bruce ATS Market Data Subscriber, or indirectly via third-party distributors. Third-party distributors include vendors or service providers that redistribute market data. Bruce ATS Market Data Subscribers receiving market data via third-party distributors may experience additional latency compared to those receiving data directly from Bruce Holdings. Bruce Holdings offers Bruce ATS Market Data Subscribers the option to receive market data either directly from Bruce Holdings or indirectly via third-party distributors. For further information regarding market data dissemination, please see Part II, Item 5.

display_best_quotes

Bruce ATS is a non-attributed display venue providing Bruce ATS Market Data Feeds containing market data during Bruce ATS's Trading Session to Subscribers and third parties that consume or redistribute market data. This includes information on Level 1 and Level 2 data that describes display and order acceptance in Part II, Item 5. When a Subscriber submits an order to Bruce ATS, the order will be displayed only if the order is within the 20% reference price band (including odd and mixed lot orders). Subscribers cannot opt out of order display. Orders are displayed until canceled, cancel/replaced, executed, or expired. Information on orders displayed includes: 1) Time, 2) Order ID, 3) Side Indicator, 4) Quantity, 5) Symbol, 6) Price. See Part III, Item 11(a) and Part II, Item 7 above for more information. Bruce ATS disseminates security eligibility information prior to accepting orders at 7:50:00 P.M. ET (the "Opening Message"), which indicates all securities eligible to trade during that session. Following the Opening Message until 8:00 P.M. ET, Bruce ATS only sends updates to the eligible security list, if any. From 8:00:00 P.M. to 4:00:00 A.M. ET, Bruce Holdings sends the Bruce ATS Market Data Feeds that include the order information described above as well as execution information indicating that an order previously displayed has been executed. The counterparties for executions are not displayed. Bruce ATS Market Data Subscribers include Bruce ATS broker-dealer subscribers that subscribe to Bruce ATS for the purpose of transacting in securities, as well as recipients that subscribe solely for access to the data. It is not a requirement for a Bruce ATS Market Data Subscriber to be a broker-dealer or Bruce ATS Subscriber. Each Bruce ATS Market Data Subscriber is subject to the same terms of use. Bruce ATS Market Data Subscribers must subscribe by entering into a market data agreement with Bruce Holdings. Bruce Holdings disseminates the Bruce ATS Market Data Feeds to Bruce ATS Market Data Subscribers in one of two ways: directly from Bruce Holdings to the Bruce ATS Market Data Subscriber, or indirectly via third-party distributors. Third-party distributors include vendors or service providers that redistribute market data. Bruce ATS Market Data Subscribers receiving market data via third-party distributors may experience additional latency compared to those receiving data directly from Bruce Holdings. Bruce Holdings offers Bruce ATS Market Data Subscribers the option to receive market data either directly from Bruce Holdings or indirectly via third-party distributors. For further information regarding market data dissemination, please see Part II, Item 5.

display_best_quotes

Bruce ATS is a non-attributed display venue providing Bruce ATS Market Data Feeds containing market data during Bruce ATS's Trading Session to Subscribers and third parties that consume or redistribute market data. This includes information on Level 1 and Level 2 data that describes display and order acceptance in Part II, Item 5. When a Subscriber submits an order to Bruce ATS, the order will be displayed (including odd and mixed lot orders). Subscribers cannot opt out of order display. Orders are displayed until canceled, cancel/replaced, executed, or expired. Information on orders displayed includes: 1) Time, 2) Order ID, 3) Side Indicator, 4) Quantity, 5) Symbol, 6) Price. See Part III, Item 11(a) and Part II, Item 7 above for more information. Bruce ATS disseminates security eligibility information prior to accepting orders at 7:50:00 P.M. ET (the "Opening Message"), which indicates all securities eligible to trade during that session. Following the Opening Message until 8:00 P.M. ET, Bruce ATS only sends updates to the eligible security list, if any. From 8:00:00 P.M. to 4:00:00 A.M. ET, Bruce Holdings sends the Bruce ATS Market Data Feeds that include the order information described above as well as execution information indicating that an order previously displayed has been executed. The counterparties for executions are not displayed. Bruce ATS Market Data Subscribers include Bruce ATS broker-dealer subscribers that subscribe to Bruce ATS for the purpose of transacting in securities, as well as recipients that subscribe solely for access to the data. It is not a requirement for a Bruce ATS Market Data Subscriber to be a broker-dealer or Bruce ATS Subscriber. Each Bruce ATS Market Data Subscriber is subject to the same terms of use. Bruce ATS Market Data Subscribers must subscribe by entering into a market data agreement with Bruce Holdings. Bruce Holdings disseminates the Bruce ATS Market Data Feeds to Bruce ATS Market Data Subscribers in one of two ways: directly from Bruce Holdings to the Bruce ATS Market Data Subscriber, or indirectly via third-party distributors. Third-party distributors include vendors or service providers that redistribute market data. Bruce ATS Market Data Subscribers receiving market data via third-party distributors may experience additional latency compared to those receiving data directly from Bruce Holdings. Bruce Holdings offers Bruce ATS Market Data Subscribers the option to receive market data either directly from Bruce Holdings or indirectly via third-party distributors. For further information regarding market data dissemination, please see Part II, Item 5.

display_best_quotes

Bruce ATS is a non-attributed display venue providing Bruce ATS Market Data Feeds containing market data during Bruce ATS's Trading Session to Subscribers and third parties that consume or redistribute market data. This includes top of book (i.e., "Level 1"), full depth of book (i.e., "Level 2"), or both, for all symbols traded on Bruce ATS during the Trading Session. Level 1 data includes the most aggressively priced aggregated bid and offer, and Level 2 includes information (described below) about an order is added, replaced, canceled, and/or executed. Both Level 1 and Level 2 include the last sale price for trades executed on Bruce ATS. When a Subscriber submits an order to Bruce ATS, the order will be displayed (including odd and mixed lot orders). Subscribers cannot opt out of order display. Orders are displayed until canceled, cancel/replaced, executed, or expired. Information on orders displayed includes: 1) Time, 2) Order ID, 3) Side Indicator, 4) Quantity, 5) Symbol, 6) Price. See Part III, Item 11(a) and Part II, Item 7 above for more information. The Bruce ATS Market Data Feeds disseminate security information prior to accepting orders at 7:30:00 P.M. ET (the "Opening Message"), which indicates all securities eligible to trade during that session. Following the Opening Message until 8:00 P.M. ET, the Bruce ATS Market Data Feeds only send updates to the eligible security list, if any. From 8:00:00 P.M. - 4:00:00 A.M. ET, Bruce Holdings sends the Bruce ATS Market Data Feeds that include the order information described above as well as execution information indicating that an order previously displayed has been executed. The counterparties for executions are not displayed. Bruce ATS Market Data Subscribers include Bruce ATS broker-dealer subscribers that subscribe to Bruce ATS for the purpose of transacting in securities, as well as recipients that subscribe solely for access to the data. It is not a requirement for a Bruce ATS Market Data Subscriber to be a broker-dealer or Bruce ATS Subscriber. Each Bruce ATS Market Data Subscriber is subject to the same terms of use. Bruce ATS Market Data Subscribers must subscribe by entering into a market data agreement with Bruce Holdings. Bruce Holdings disseminates the Bruce ATS Market Data Feeds to Bruce ATS Market Data Subscribers in one of two ways: directly from Bruce Holdings to the Bruce ATS Market Data Subscriber, or indirectly via third-party distributors. Third-party distributors include vendors or service providers that redistribute market data. Bruce ATS Market Data Subscribers receiving market data via third-party distributors may experience additional latency compared to those receiving data directly from Bruce Holdings. Bruce Holdings offers Bruce ATS Market Data Subscribers the option to receive market data either directly from Bruce Holdings or indirectly via third-party distributors. For further information regarding market data dissemination, please see Part II, Item 5.

display_best_quotes

Bruce ATS is a non-attributed display venue providing Bruce ATS Market Data Feeds containing market data during Bruce ATS's Trading Session to Subscribers and third parties that consume or redistribute market data. This includes top of book (i.e., "Level 1"), full depth of book (i.e., "Level 2"), or both, for all symbols traded on Bruce ATS during the Trading Session. Level 1 data includes the most aggressively priced aggregated bid and offer, and Level 2 includes information (described below) about an order is added, replaced, canceled, and/or executed. Both Level 1 and Level 2 include the last sale price for trades executed on Bruce ATS. When a Subscriber submits an order to Bruce ATS, the order will be displayed (including odd and mixed lot orders). Subscribers cannot opt out of order display. Orders are displayed until canceled, cancel/replaced, executed, or expired. Information on orders displayed includes: 1) Time, 2) Order ID, 3) Side Indicator, 4) Quantity, 5) Symbol, 6) Price. See Part III, Item 11(a) and Part II, Item 7 above for more information. The Bruce ATS Market Data Feeds disseminate security information prior to accepting orders at 7:50:00 P.M. ET (the "Opening Message"), which indicates all securities eligible to trade during that session. Following the Opening Message until 8:00 P.M. ET, the Bruce ATS Market Data Feeds only send updates to the eligible security list, if any. From 8:00:00 P.M. to 4:00:00 A.M. ET, Bruce Holdings sends the Bruce ATS Market Data Feeds that include the order information described above as well as execution information indicating that an order previously displayed has been executed. The counterparties for executions are not displayed. Bruce ATS Market Data Subscribers include Bruce ATS broker-dealer subscribers that subscribe to Bruce ATS for the purpose of transacting in securities, as well as recipients that subscribe solely for access to the data. It is not a requirement for a Bruce ATS Market Data Subscriber to be a broker-dealer or Bruce ATS Subscriber. Each Bruce ATS Market Data Subscriber is subject to the same terms of use. Bruce ATS Market Data Subscribers must subscribe by entering into a market data agreement with Bruce Holdings. Bruce Holdings disseminates the Bruce ATS Market Data Feeds to Bruce ATS Market Data Subscribers in one of two ways: directly from Bruce Holdings to the Bruce ATS Market Data Subscriber, or indirectly via third-party distributors. Third-party distributors include vendors or service providers that redistribute market data. Bruce ATS Market Data Subscribers receiving market data via third-party distributors may experience additional latency compared to those receiving data directly from Bruce Holdings. Bruce Holdings offers Bruce ATS Market Data Subscribers the option to receive market data either directly from Bruce Holdings or indirectly via third-party distributors. For further information regarding market data dissemination, please see Part II, Item 5.

display_trading_interest

false

execution_services

Bruce ATS is available for connectivity beginning at 7:00:00 P.M. ET and begins accepting orders at 7:50:00 P.M. ET on each day the ATS is open for business. Bruce ATS does not accept and will reject all orders sent by Subscribers to Bruce ATS prior to 7:50:00 P.M. ET. Orders received between 7:50:00 P.M. and 8:00:00 P.M. ET are held in the order book until the Trading Session begins at 8:00:00 P.M. ET and ranked by price/time. When the Trading Session opens at 8:00:00 P.M. ET, Bruce ATS begins matching orders based on the terms of the orders and price and time priority. Bruce ATS establishes a 20% reference price band for each NMS stock using the last print reported to the SIP at or prior to 7:30:00 P.M. ET during the post session (i.e. 4:00:00 P.M ET- 8:00:00pm ET). These reference prices are set before the opening of the Trading Session and do not change after the trading session begins. In order to maintain a fair and orderly market the BDO may in limited circumstances update the reference price to reflect market news, corporate actions, system errors where the reference price is missing or incorrect, and significant price movements subsequent to the prior regular day's session and prior to the beginning of the Trading Session. The 20% reference price bands are established once the reference price is set. If the reference price is updated (for reasons mentioned above), the band will also update for that security. If the reference price or band can't be established for a security before the Trading Session, the ATS will not trade in that security. The ATS will reject orders outside the 20% reference price bands but will accept passive orders under certain circumstances. Accepting passive orders means Bruce ATS accepts all buy orders with prices at or below the upper band, which include unexecutable passive buy orders with prices below the lower band. Bruce ATS accepts all sell orders with prices above the lower band, including unexecutable passive sell orders with prices above the upper band. These passive orders are accepted and prioritized by price and time, but the ATS does not disseminate passive orders outside of the 20% reference price bands. For passive orders to become executable, they need to be canceled and replaced in order to become marketable. Bruce ATS automatically rejects any order priced aggressively outside of the price band (i.e. sell orders with prices below the lower band will be rejected and buy orders with prices above the upper band will be rejected). At its discretion, the BDO may halt trading in one or more securities or all securities trading through Bruce ATS in order to manage risk as discussed further in Part III, Item 20. If trading in an NMS stock is halted by an exchange during the regular day session, that stock is not eligible for trading during the subsequent overnight session. Bruce ATS does not operate during regular and extended trading hours of the national securities exchanges, and trading halts are uncommon but possible during Bruce ATS's Trading Session. In the event an NMS stock is halted by an exchange during an overnight trading session, Bruce ATS cancels all orders for the affected NMS stock on the Bruce ATS's Order Book at the time of the trading halt and all new incoming orders are rejected. In the event that the halt is lifted, orders are accepted in the impacted security. If a halt is imposed, Bruce ATS will notify all Subscribers and automatically cancel all orders in the Order Book for the subject security. Once the halt is lifted, Bruce ATS will notify all Subscribers that the halt has been lifted and that the subject security is available for trading. Bruce ATS employs the same policies and procedures for order handling, pricing, priority, etc. as described in Part III, Item 7 once it re-opens and when a halt is lifted. Bruce ATS does not use any special order acceptance, handling or execution procedures at the open, during a re-open or following stoppage of trading during regular trading hours. At the open, during a re-open or following a stoppage, Bruce ATS accepts, handles, and executes orders and trading interests as described in Part III, Item 11(c).

execution_services

Bruce ATS is available for connectivity beginning at 7:00:00 P.M. ET and begins accepting orders at 7:50:00 P.M. ET on each day the ATS is open for business. Bruce ATS does not accept and will reject all orders sent by Subscribers to Bruce ATS prior to 7:50:00 P.M. ET. Orders received between 7:50:00 P.M. and 8:00:00 P.M. ET are held in the order book until the Trading Session begins at 8:00:00 P.M. ET and ranked by price/time. When the Trading Session opens at 8:00:00 P.M. ET, Bruce ATS begins matching orders based on the terms of the orders and price and time priority. Bruce ATS establishes a 20% reference price band for each NMS stock using the last print reported to the SIP at or prior to 7:30:00 P.M. ET during the post session (i.e. 4:00:00 P.M ET- 8:00:00pm ET). These reference prices are set before the opening of the Trading Session and do not change after the trading session begins. In order to maintain a fair and orderly market the BDO may in limited circumstances update the reference price to reflect market news, corporate actions, system errors where the reference price is missing or incorrect, and significant price movements subsequent to the prior regular day's session and prior to the beginning of the Trading Session. The 20% reference price bands are established once the reference price is set. If the reference price is updated (for reasons mentioned above), the band will also update for that security. If the reference price or band can't be established for a security before the Trading Session, the ATS will not trade in that security. The ATS will reject orders outside the 20% reference price bands but will accept passive orders under certain circumstances. Accepting passive orders means Bruce ATS accepts all buy orders with prices at or below the upper band, which include unexecutable passive buy orders with prices below the lower band. Bruce ATS accepts all sell orders with prices above the lower band, including unexecutable passive sell orders with prices above the upper band. These orders are accepted and prioritized by price and time. For passive orders to become executable, they need to be canceled and replaced in order to become marketable. Bruce ATS automatically rejects any order priced aggressively outside of the price band (i.e. sell orders with prices below the lower band will be rejected and buy orders with prices above the upper band will be rejected). At its discretion, the BDO may halt trading in one or more securities or all securities trading through Bruce ATS in order to manage risk as discussed further in Part III, Item 20. If trading in an NMS stock is halted by an exchange during the regular day session, that stock is not eligible for trading during the subsequent overnight session. Bruce ATS does not operate during regular and extended trading hours of the national securities exchanges, and trading halts are uncommon but possible during Bruce ATS's Trading Session. In the event an NMS stock is halted by an exchange during an overnight trading session, Bruce ATS cancels all orders for the affected NMS stock on the Bruce ATS's Order Book at the time of the trading halt and all new incoming orders are rejected. In the event that the halt is lifted, orders are accepted in the impacted security. If a halt is imposed, Bruce ATS will notify all Subscribers and automatically cancel all orders in the Order Book for the subject security. Once the halt is lifted, Bruce ATS will notify all Subscribers that the halt has been lifted and that the subject security is available for trading. Bruce ATS employs the same policies and procedures for order handling, pricing, priority, etc. as described in Part III, Item 7 once it re-opens and when a halt is lifted. Bruce ATS does not use any special order acceptance, handling or execution procedures at the open, during a re-open or following stoppage of trading during regular trading hours. At the open, during a re-open or following a stoppage, Bruce ATS accepts, handles, and executes orders and trading interests as described in Part III, Item 11(c).

execution_services

Bruce ATS is available for connectivity beginning at 7:00:00 P.M. ET and begins accepting orders at 7:50:00 P.M. ET on each day the ATS is open for business. Bruce ATS does not accept and will reject all orders sent by Subscribers to Bruce ATS prior to 7:50:00 P.M. ET. Orders received between 7:50:00 P.M. and 8:00:00 P.M. ET are held in the order book until the Trading Session begins at 8:00:00 P.M. ET and ranked by price / time. When the Trading Session opens at 8:00:00 P.M. ET, Bruce ATS begins matching orders based on the terms of the orders and price and time priority. Bruce ATS established a 20% reference price band for each NMS stock at the opening of each Trading Session. Specifically, Bruce ATS automatically cancels any order priced more than 20% above or below the last print at or prior to 7:30:00 P.M. ET on a national securities exchange during a post session, or the official closing price on a national securities exchange if former is not available. In limited circumstances, the BDO updates the reference price to reflect market news, corporate actions, and significant price movements subsequent to the prior regular day's session and prior to the beginning of the Trading Session. In its discretion, the BDO may halt trading in one or more security or all trading through Bruce ATS in order to manage risk as discussed further in Part III, Item 20. If trading in an NMS stock is halted by an exchange during the regular day session, that stock is not eligible for trading during the subsequent overnight session. Bruce ATS does not operate during regular and extended trading hours of the national securities exchanges, and trading halts are uncommon but possible during Bruce ATS's Trading Session. In the event an NMS stock is halted by an exchange during an overnight trading session, Bruce ATS cancels all orders for the affected NMS stock on the Bruce ATS's Order Book at the time of the trading halt and new orders are rejected. In the event that the halt is lifted, orders are accepted in the impacted security. If a halt is imposed, Bruce ATS will notify all Subscribers and automatically cancel all orders in the Order Book for the subject security. Once the halt is lifted, Bruce ATS will notify all Subscribers that the halt has been lifted and that the subject security is available for trading. Bruce ATS employs the same policies and procedures for order handling, pricing, priority, etc. as described in Part III, Item 7 once it re-opens and when a halt is lifted. Bruce ATS does not use any special order acceptance, handling or execution procedures at the open, during a re-open or following stoppage of trading during regular trading hours. At the open, during a re-open or following a stoppage, Bruce ATS accepts, handles, and executes orders and trading interests as described in Part III, Item 11(c).

execution_services

Bruce ATS is available for connectivity beginning at 7:00:00 P.M. ET and begins accepting orders at 7:50:00 P.M. ET on each day the ATS is open for business. Bruce ATS does not accept and will reject all orders sent by Subscribers to Bruce ATS prior to 7:50:00 P.M. ET. Orders, except for IOC orders (which are rejected during the queuing session), received 7:50:00 P.M. to 8:00:00 P.M. ET are held in the order book until the Trading Session begins at 8:00:00 P.M. ET are queued and match in time priority. When the Trading Session opens at 8:00:00 P.M. ET, all new orders submitted to Bruce ATS begin matching orders based on the terms of the orders and price and time priority. Bruce ATS establishes a 20% reference price band for each NMS stock using the last print reported to the SIP at or prior to 7:30:00 P.M. ET during the post session (i.e. 4:00:00 P.M ET- 8:00:00pm ET). These reference prices are set before the opening of the Trading Session and do not change after the trading session begins. In order to maintain a fair and orderly market the BDO may in limited circumstances update the reference price to reflect market news, corporate actions, system errors where the reference price is missing or incorrect, and significant price movements subsequent to the prior regular day's session and prior to the beginning of the Trading Session. The 20% reference price bands are established once the reference price is set. If the reference price is updated (for reasons mentioned above), the band will also update for that security. If the reference price or band can't be established for a security before the Trading Session, the ATS will not trade in that security. The ATS will reject orders outside the 20% reference price bands but will accept passive orders under certain circumstances. Accepting passive orders means Bruce ATS accepts all buy orders with prices at or below the upper band, which include unexecutable passive buy orders with prices below the lower band. Bruce ATS accepts all sell orders with prices above the lower band, including unexecutable passive sell orders with prices above the upper band. These passive orders are accepted and prioritized by price and time, but the ATS does not disseminate passive orders outside of the 20% reference price bands. For passive orders to become executable, they need to be canceled and replaced in order to become marketable. Bruce ATS automatically rejects any order priced aggressively outside of the price band (i.e. sell orders with prices below the lower band will be rejected and buy orders with prices above the upper band will be rejected). At its discretion, the BDO may halt trading in one or more securities or all securities trading through Bruce ATS in order to manage risk as discussed further in Part III, Item 20. If trading in an NMS stock is halted by an exchange during the regular day session, that stock is not eligible for trading during the subsequent overnight session. Bruce ATS does not operate during regular and extended trading hours of the national securities exchanges, and trading halts are uncommon but possible during Bruce ATS's Trading Session. In the event an NMS stock is halted by an exchange during an overnight trading session, Bruce ATS cancels all orders for the affected NMS stock on the Bruce ATS's Order Book at the time of the trading halt and all new incoming orders are rejected. In the event that the halt is lifted, orders are accepted in the impacted security. If a halt is imposed, Bruce ATS will notify all Subscribers and automatically cancel all orders in the Order Book for the subject security. Once the halt is lifted, Bruce ATS will notify all Subscribers that the halt has been lifted and that the subject security is available for trading. Bruce ATS employs the same policies and procedures for order handling, pricing, priority, etc. as described in Part III, Item 7 once it re-opens and when a halt is lifted. Bruce ATS does not use any special order acceptance, handling or execution procedures at the open, during a re-open or following stoppage of trading during regular trading hours. At the open, during a re-open or following a stoppage, Bruce ATS accepts, handles, and executes orders and trading interests as described in Part III, Item 11(c).

execution_services

Bruce ATS is available for connectivity beginning at 7:00:00 P.M. ET and begins accepting orders at 7:30:00 P.M. ET on each day the ATS is open for business. Bruce ATS does not accept and will reject all orders sent by Subscribers to Bruce ATS prior to 7:30:00 P.M. ET. Orders received between 7:30:00 P.M. and 8:00:00 P.M. ET are held in the order book until the Trading Session begins at 8:00:00 P.M. ET and ranked by price / time. When the Trading Session opens at 8:00:00 P.M. ET, Bruce ATS begins matching orders based on the terms of the orders and price and time priority. Bruce ATS established a 20% reference price band for each NMS stock at the opening of each Trading Session. Specifically, Bruce ATS automatically cancels any order priced more than 20% above or below the last print prior to 7:30:00 P.M. ET on a national securities exchange during a post session, or the official closing price on a national securities exchange if former is not available. In limited circumstances, the BDO updates the reference price to reflect market news, corporate actions, and significant price movements subsequent to the prior regular day's session and prior to the beginning of the Trading Session. In its discretion, the BDO may halt trading in one or more security or all trading through Bruce ATS in order to manage risk as discussed further in Part III, Item 20. If trading in an NMS stock is halted by an exchange during the regular day session, that stock is not eligible for trading during the subsequent overnight session. Bruce ATS does not operate during regular and extended trading hours of the national securities exchanges, and trading halts are uncommon but possible during Bruce ATS's Trading Session. In the event an NMS stock is halted by an exchange during an overnight trading session, Bruce ATS cancels all orders for the affected NMS stock on the Bruce ATS's Order Book at the time of the trading halt and new orders are rejected. In the event that the halt is lifted, orders are accepted in the impacted security. If a halt is imposed, Bruce ATS will notify all Subscribers and automatically cancel all orders in the Order Book for the subject security. Once the halt is lifted, Bruce ATS will notify all Subscribers that the halt has been lifted and that the subject security is available for trading. Bruce ATS employs the same policies and procedures for order handling, pricing, priority, etc. as described in Part III, Item 7 once it re-opens and when a halt is lifted. Bruce ATS does not use any special order acceptance, handling or execution procedures at the open, during a re-open or following stoppage of trading during regular trading hours. At the open, during a re-open or following a stoppage, Bruce ATS accepts, handles, and executes orders and trading interests as described in Part III, Item 11(c).