Piper Sandler ATS

amendment_reason

This updating amendment applies to the EDGAR accession number 0000724683-22-000038 filing. This updating amendment is being done to update the following areas of our Form ATS-N: 1. Part I: Item 8 - Modifying Exhibit 1, Schedule A, Direct Owners of the ATS. Specifically, the retirement of Francis Fairman from the Board of Directors of Piper Sandler & Co. (the Board), and the addition to the Board of Jeremy Gerber, both effective December 1, 2023. This change only affects the broker dealer operator.

amendment_reason

This updating amendment applies to the EDGAR accession number 0000724683-22-000010 filing. This updating amendment is being done to update employee trading holding periods for ETFs and Index securities, as well as clarifying other disclosures. Changes include: 1. Modifying Part II Item 1a for readability. This change only affects the broker dealer operator. 2. Modifying Part II 5a. This change only affects the broker dealer operator. Changes: a. Remove the word algorithms 3. Modifying Part II 6a. This change only affects the broker dealer operator. Changes: a. Add a clarifying statement to drive investment decisions 4. Modifying Part II Item 7a. This change only affects the broker dealer operator. Changes: a. Update the employee trading holding period for ETFs

amendment_reason

This correcting amendment applies to the EDGAR accession number 0000724683-21-000036 filing. This correcting amendment is being done to correct the following areas of our Form ATS: 1. Modifying Part II Item 6a. This changes only affect the broker dealer operator. Change: a. Stating that employees of the No-Touch trading group that are responsible for monitoring and assisting No-Touch client order flow can see No-Touch client order flow that was sent to the ATS via the No-Touch Trading Desk. 2. Modifying Part III Item 5a and 5c to: a. Update timestamp granularity for the time utilized to timestamp events. This change only affects the broker dealer operator. 3. Modifying Part III Item 7a by: a. Clarifying that supervisory and Select ATS support personnel are able to see response messages to the ATS. This change only affects the broker dealer operator. 4. Modifying Part III Items 7a and 11c to: a. Clarify that orders are processed in the order that they arrive and are accepted in the XE ATS by clarifying that even though the timestamp may be identical, the order that is accepted first will have time priority over an order with the same timestamp that was accepted after it. These changes affect the broker dealer operator and all subscribers. 5. Modifying Part III Item 11c to: a. Add timestamp granularity for event timestamps. This change affects the broker dealer operator.

amendment_reason

This updating amendment applies to the EDGAR accession number 0000724683-23-000039 filing. This updating amendment is being done to update the following areas of our Form ATS-N: 1. Part I: Item 8 - Modifying Exhibit 1, Schedule A, Direct Owners of the ATS. Specifically, the retirement of Timothy Carter from the Board of Directors of Piper Sandler & Co. (the Board), and the addition to the Board of Katherine Klune, both effective January 1, 2024. This change only affects the broker dealer operator.

amendment_reason

This updating amendment applies to the EDGAR accession number 0000724683-22-000014 filing. This updating amendment is being done to update our data feed disclosure language and manner of order entry language. There has been no change in the operation of the ATS and no change to our data feed provider. Updates include: 1. Modifying Part II Item 6b to add the name of our market data vendor, ACTIV Financial. This change affects all subscribers and the broker dealer operator. 2. Modifying Part III Item 5c. These changes affect all subscribers and the broker dealer operator. a. Clarify that certain orders on the NT desk received via FIX as described in Item Part III Item 5a are considered as received by the broker dealer operator (Piper) and immediately routed to XE automatically. 3. Modifying Part III Item 23a regarding data feeds and processing. These updates affect all subscribers and the broker dealer operator. a. Add the identification of our market data feed provider. b. Call out the fact that market data is processed real time.

amendment_reason

This material amendment applies to the EDGAR accession number 0000724683-22-000017 filing. This material amendment is being done to discontinue the Limit Order Match Book, as well as to allow di minimis employee trading orders to occur if the orders will have no market impact to any subscriber order received by the ATS. Changes: 1. Modifying the Form ATS filing to remove the Limit Order book and all references to activity done surrounding the Limit Order book such as conditional and firm orders and Limit Order Broadcasts in the following areas. These changes affect all subscribers and the broker dealer operator. a. Part II Items i. 1a ii. 6b b. Part III Items: i. 4a ii. 5a, 5c iii. 7a iv. 8a, 8c, 8e v. 10a, 10c vi. 11a, 11c vii. 17a viii. 20a ix. 23a 2. Modifying Part II Item 7a to allow for employee trading orders that are considered di minimis. These changes affect all subscribers and the broker dealer operator. 3. Modifying Part III Item 9a and 9b to NO as regards IOIs, actionable IOIs, or conditional orders and removing the ensuing discussion in Part III Item 9a. These changes affect all subscribers and the broker dealer operator. 4. Modifying Part III Item 15b to NO as regards display and removing the ensuing discussion. These changes affect all subscribers and the broker dealer operator. 5. Modifying Part III Item 16a to NO as regards routing and updating 16b to NO and removing the ensuing discussion. These changes affect all subscribers and the broker dealer operator.

amendment_reason

This updating amendment applies to the EDGAR accession number 0000724683-22-000027 filing. This updating amendment is being done to update the following areas of our Form ATS: 1. Schedule A Direct Owners in the attachments section. The change reflects a legal name change of the Chief Compliance Officer. This change only affects the broker dealer operator.

amendment_reason

This correcting amendment applies to the EDGAR accession number 0000724683-19-000030 filing. The amendment updates the name of the broker dealer operator from Piper Jaffray & Co. to Piper Sandler & Co. No other CRD/SEC registration identifiers were affected by the change. The name change is reflected in 5 locations within this document: Part I.2., Part II Items 1 a. (two instances), 6 a, and Item 7 a. Part 1 item 8 Schedule A and Part 1 item 9 Schedule B are also updated to reflect the name change and update the current ownership. These name changes only affect the broker dealer operator Piper Sandler & Co. In addition, the filing corrects a change to order priority for the On-Close Match Book in Part III, Item 11 c where an order now loses its priority in the event of a modification for order size. The order priority change was due to a program change made 10/9/2020, and the ATS Filing should have been updated to reflect the change. The order priority amendment applies to all Subscribers and the Broker-Dealer Operator. A review of activity within the ATS shows no order modifications occurred in the ATS after the programming change was made, therefore no orders were affected.

amendment_reason

This correcting amendment applies to the EDGAR accession number 0000724683-23-000037 filing. This correcting amendment is being done to update the following areas of our Form ATS-N: 1. Part I: Item 7 - Modifying the primary address, and adding a secondary address, of the ATS Matching Engine XE. This change affects the broker dealer operator and all subscribers. 2. Part II: Item 6b - Adding data center vendors Equinix LLC and Flexential LLC to our service provider discussion. This change affects the broker dealer operator and all subscribers. 3. Part II: Item 7a: a. Modifying language surrounding the location of the matching engine servers in relation to the trading desk of the broker dealer operator. This change only affects the broker dealer operator. b. Adding a description of what access data service provider personnel have to the matching engine servers. This change only affects the broker dealer operator.

ats_name

XE

operator_crd

000000665

operator_name

PIPER SANDLER & CO.

operator_name

PIPER JAFFRAY & CO.

order_types

The XE ATS operates two books: the On-Close Match book and the Limit Order book. All order types, modifiers, and displayed information (in the case of the Limit Order book) for both order books are available on the same terms to all Subscribers, including traders on Pipers Cash Trading Desk with the limited exception that responses to Limit Order Broadcasts can only come through the Cash Trading Desk. Response orders to a Limit Order Broadcast are not visible to other Subscribers, including the sales and trading personnel responsible for that Subscribers account. However, sales and trading personnel responsible for the Subscribers account that submitted the Limit Order Broadcast response order (but not other Subscribers) are able to see any excess order interest resulting from a Limit Order Broadcast response order, as explained further below. This includes supervisory personnel on the trading desk handling the order and Select ATS support personnel. Orders submitted to XE that do not reflect a permissible order type or modifier (e.g., failing to specify a quantity) are rejected. Regarding time priority for the ATS, no two orders can ever be accepted simultaneously. Orders will be accepted as they arrive into the ATS and will be sequenced according to when they were accepted. Time priority will always go to the first order accepted by the ATS after all order validity checks are completed. Therefore, if two orders have the same timestamp, the order that was accepted first by the ATS will have priority when determining time priority. ON-CLOSE MATCH BOOK The On-Close Match book only accepts market orders with a time in force of either DAY or Immediate or Cancel (IOC), as selected by Subscribers. Limit orders are not accepted to the On-Close Match book. All orders submitted to the On-Close Match will be executed, if at all, at the closing price disseminated by the primary listing exchange for each NMS stock. Execution occurs upon the dissemination of the closing price, unless there is a trading halt in the stock at that time in which case no executions occur in the halted stock and all orders, including matched orders, are canceled back to Subscribers. Orders marked IOC will be canceled if they do not match with another order immediately upon submission. Orders marked DAY will rest in the On-Close Match book until they are matched or will be canceled if unmatched at the 3:55 p.m. ET cut-off time described in Part III, Item 4(a). Orders marked DAY that are submitted during the final five minutes of the trading day (i.e., 3:55 p.m. ET on normal trading days) will rest on the book until they are matched or will be canceled if unmatched at the time of the print of the closing price. If there is a partial match of an IOC order, only the unmatched portion will be canceled back. If there is a partial match of a DAY order, the unmatched portion will rest in the book until it is matched or canceled if unmatched at the time of the closing print in the stock (or canceled by the Subscriber). Execution priority in the On-Close Match book is determined based on the time they are received by XE with earlier arriving orders executed first in time. Subscribers can elect to apply a minimum quantity (MinQty) designation applicable to the initial fill of all of their orders sent to the On-Close Match book. Subscribers can specify or modify a MinQty designation by contacting Piper, and the MinQty function is available to Subscribers through both the Cash Trading Desk and the No-Touch (Electronic) Trading Desk. The specified MinQty will apply to all orders and cannot be selected on an order by order basis. A MinQty designation applies only to the initial match of an order sent to the On-Close Match book. Any remaining order interest, in the case of a partial fill, is not subject to the MinQty designation. There are no minimum order size requirements for the On-Close Match book, and the MinQty can be set for any amount of shares, including odd-lot and mixed lot quantities. Orders with a MinQty designation are filled first by orders that meet the MinQty designation. As a result, resting orders that satisfy an incoming contra-side orders MinQty designation gain priority over orders that do not satisfy the MinQty designation. For example, assume there are three resting DAY orders to sell XYZ all at the same price and arriving in the following time sequence: Order A for 100 shares, Order B for 100 shares, and Order C for 300 shares. A Subscriber submits a buy order marketable against these resting orders for 500 shares with a MinQty of 200 shares. The buy order would match first against Order C for its full quantity, and would then match with Order A and Order B to fill the remaining shares. If Order C were for 500 shares, the buy order would match entirely against Order C, and Orders A and B would not match notwithstanding their time priority over Order C. Orders submitted to the On-Close Match book can be modified or canceled at any time up until the closing print of the security. However, once an order is matched with a contra-side order, the order cannot be canceled or modified, other than in the case of a partial fill, in which case any remaining, unexecuted order interest can still be canceled or modified. Orders and modifications to orders in the On-Close Match book are timestamped upon entry. A modification to the size of an order will result in a new timestamp for the order and therefore a reset of the orders execution priority. Orders submitted to the On-Close Match book are not displayed or otherwise made known to other Subscribers or any non-Subscribers. However, when a Subscriber receives a match in the On-Close Match book, the ATS notifies the Subscriber that its order has been matched or partially matched as appropriate. The notification sent to Subscribers with respect to matched orders (or the matched portion of an order in the case of a partial fill) provide an indicative fill for the order at the NBBO midpoint at the time of the match. This indicative fill is not an execution confirmation; the actual fill will occur at the closing price on the primary listing market at which time an execution report is sent to the Subscriber and the indicative fill is canceled. LIMIT ORDER BOOK The Limit Order book accepts conditional and firm limit orders. Market orders are not accepted in the Limit Order book. Upon the receipt of a limit order to the Limit Order book, the order will first seek to match against any resting order interest in the book. If there is no match immediately upon entry, and the order is for 500 shares or more, the order is eligible to be broadcast to other Subscribers to solicit matching order interest (a Limit Order Broadcast). Subscribers must opt-in to having their orders disseminated through a Limit Order Broadcast and must be configured for such service by requesting it through Piper. All Subscribers are eligible to subscribe to Limit Order Broadcasts and configuration is performed with employees in the Technology Department. However, Subscribers must use the services of the Cash Trading Desk to be able to send orders in response to Limit Order Broadcasts. Once a Subscriber is configured to have its orders trigger Limit Order Broadcasts, all eligible orders will trigger a Limit Order Broadcast; selection of whether an order triggers a Limit Order Broadcast is not done on an order-by-order basis. If a Subscriber has opted into having its orders trigger Limit Order Broadcasts, each order must be for 500 shares or more, or will be rejected by the System. Subscribers that are not configured to have their orders trigger Limit Order Broadcasts can submit orders of any size. Subscribers can change their Limit Order Broadcast preference by contacting Piper. Subscribers must also opt-in to receive Limit Order Broadcasts resulting from other Subscribers orders. Orders submitted in responses to Limit Order Broadcasts can be for any size. There is no minimum quantity functionality with respect to the Limit Order book. XE will disseminate a Limit Order Broadcast to all Subscribers that have elected to receive Limit Order Broadcasts that details the price (either the initiating orders limit price or pegged price as described below), size, side (buy/sell), and symbol of eligible orders through Subscribers respective execution management systems. Subscribers that have opted into having their orders disseminated through a Limit Order Broadcast must populate an additional field when entering orders to indicate whether the Limit Order Broadcast should be pegged to the primary quote (i.e., the national best bid (NBB) for buy orders or national best offer (NBO) for sell orders) or the midpoint of the national best bid and offer (NBBO) for purposes of the displayed price of their order in the Limit Order Broadcast. If a Subscriber does not designate a peg preference, the Limit Order Broadcast will provide a default peg to the NBBO midpoint. Limit Order Broadcast displayed peg preferences are set on an order by order basis. The displayed price of a Limit Order Broadcast will be the initiating orders limit price unless or until the limit price is more aggressive than the primary quotation and/or midpoint of the NBBO, in which case the displayed price will be the pegged price, as selected by the Subscriber (i.e., either the primary quote or the NBBO midpoint). Limit Order Broadcasts pegged to the NBBO midpoint for display purposes are rounded down to the nearest whole penny increment for buy orders and up to the nearest whole penny increment for sell orders. Limit Order Broadcasts will not display order interest in sub-penny increments, including where the price of the security is less than $1.00. XE does not otherwise rank, display, or accept orders in sub-penny increments for NMS stocks trading above $1.00 per share. For example, assume the NBBO for stock XYZ is $10.00 x $10.05, and a Subscriber that has opted into having eligible orders disseminated through a Limit Order Broadcast submits an order to buy 500 shares of XYZ at a price of $10.02 pegged to the primary quote for Limit Order Broadcast display purposes. The Limit Order Broadcast would display the price at $10.00. If the NBBO moved to $10.03 x $10.05, the Limit Order Broadcast would reprice the buy order to display the orders limit price of $10.02. Assume instead that the buy order was priced at $10.03 and the Subscriber selected that the Limit Order Broadcast be pegged to the NBBO midpoint for display purposes while the NBBO is $10.00 x $10.05. The Limit Order Broadcast would display the price at $10.02, which is the NBBO midpoint rounded down (in the case of a buy order) to the nearest whole penny increment. If the NBBO were to move to $10.04 x $10.08, the Limit Order Broadcast would display a price of $10.03 (the originating orders limit price). If the NBBO were to move down to $9.95 x $10.00, the Limit Order Broadcast would display a price of $9.97, the NBBO midpoint rounded down to the nearest whole penny increment. The Limit Order Broadcast will remain visible to Subscribers that have elected to receive Limit Order Broadcasts until the order is executed or canceled. Orders submitted to the Limit Order book can have a time-in-force of either DAY or IOC. IOC orders do not cause XE to disseminate a Limit Order Broadcast detailing the terms of the order, and such orders will instead seek an immediate execution against any resting orders or cancel back to the Subscriber if there is no immediate match. DAY orders for 500 shares or more will cause XE to disseminate a Limit Order Broadcast (provided the Subscriber has opted into Limit Order Broadcasts with respect to its orders) and the order will remain in the Limit Order book until the order is executed, canceled by the Subscriber, or, if unexecuted at the end of the trading day, will be canceled by XE. If a DAY order that triggered a Limit Order Broadcast is partially filled such that its quantity falls below 500 shares, both the order and the Limit Order Broadcast will be canceled. Subscribers that have not been configured to have their orders trigger a Limit Order Broadcast can submit orders of any size (including for less than 500 shares) and such orders (with a time-in-force of DAY) will rest non-displayed until executed, canceled by the Subscriber, or until the end of the trading day. Execution priority for orders in the Limit Order book is based on price and then time. Price is determined by the limit price the Subscriber selects and time is based on the timestamp assigned to an order upon arriving at the ATS. Priority among equally priced orders is based on the time of order entry. Orders and modifications to orders are timestamped upon entry. Modifications to a resting orders price will affect its priority. Modifications to a resting orders size will result in a new time stamp for purposes of execution priority. In the case of a partial fill, any remaining order interest will preserve the time priority of the original order for execution priority purposes. Orders cannot be routed out of the Limit Order book. However, the ATS will route intermarket sweep orders (ISOs) as necessary in compliance with Rule 611 of regulation NMS, provided the Subscriber has opted into having XE route ISOs to facilitate executions on XE, as described in greater detail in Part III, Item 16. Matches within the Limit Order Book are automatically executed without human intervention or negotiation and are reported with the MPID PJCX. Please see Part III, Item 11(c) for further detail regarding the prices at which matched orders in the Limit Order book will execute. All orders submitted to the Limit Order book can interact with multiple matching contra-side orders. Any DAY order, or excess order interest of a DAY order in the case of a partial fill immediately upon arrival, can trigger a new Limit Order Broadcast if eligible (i.e., it is for a quantity greater than 500 shares and the Subscriber has opted-into Limit Order Broadcasts). However, responses to a Limit Order Broadcast cannot trigger a Limit Order Broadcast. All responses to a Limit Order Broadcast come through the Cash Trading Desk and are treated as a not-held order. Because orders sent in response to Limit Order Broadcasts (Limit Order Broadcast Responses) do not result in dissemination of a Limit Order Broadcast, Subscribers do not need to set a pegged order display preference. Any excess order interest a Limit Order Broadcast Response can rest in the ATS (provided the Limit Order Broadcast Response has a time in force of DAY) as a not-held order and is visible to the sales and trading personnel of the Cash Trading Desk responsible for that Subscribers account. For example, assume Order 1 is submitted to buy 500 shares of XYZ at $10.00 with a time-in-force of DAY, and Order 2 is submitted a moment later to also buy 500 shares of XYZ at $10.00 with a time-in-force of DAY when the NBBO for XYZ is $10.00 x $10.05 and where there is no resting sell interest in the Limit Order book for XYZ. Assuming the Subscribers submitting Order 1 and 2 have opted into Limit Order Broadcasts, XE would disseminate a Limit Order Broadcast with respect to both Order 1 and Order 2. Assume further that a Subscriber submits in response to the Limit Order Broadcast for Order 1 a DAY sell order for 1500 shares of XYZ priced at $10.00 (Order 3). XE would execute Order 3 against Order 1 for 500 shares and then execute against Order 2 for 500 shares with both executions occurring at $10.00. The remaining 500 shares of sell order interest from Order 3 would not cause the ATS to broadcast a new Limit Order Broadcast to Subscribers to sell 500 shares of XYZ. However, the 500 shares of excess sell order interest from Order 3 would rest in XE and be treated as a not-held order of the Cash Trading Desk. This excess order interest would be eligible to execute against any subsequent buy orders in XYZ submitted to XE for as long as the order rests there. If Order 3 had been marked IOC rather than DAY, the 500 shares of unexecuted sell order interest would be canceled back. In the event there is resting order interest with priority over an order that initiated a Limit Order Broadcast, such interest will execute first. For instance, in the example above, if there were a resting buy order for 200 shares of XYZ at $10.00 in the Limit Order book with time priority over Orders 1 and 2, Order 3 would execute first against this resting order before executing against Orders 1 and 2. In other words, an order sent in response to a Limit Order Broadcast will still consider any marketable resting order interest when executing. Conditional orders can only be sent by a Subscriber that: (i) has been configured to be able to submit conditional orders by contacting Piper; and (ii) uses a trading algorithm as the means of access, either through the No-Touch (Electronic) Trading Desk or through the Cash Trading Desk. Conditional orders are generally treated the same as non-conditional orders in the ATS except that any potential execution will be suspended pending satisfaction of the terms of the conditional order. For example, assume a Subscriber is looking to buy 500 shares of XYZ at a given price in the market and the Subscriber uses a trading algorithm that sends a 500 share order in XYZ to multiple trading venues being unsure where it will receive an execution. Provided the trading algorithm has been configured to route to XE as a possible routing destination, the algorithm can submit a conditional order to XE, which would only execute against a matching order pending the cancellation of the orders sent to the other venues. If the Subscribers conditional order matches on XE, the execution would be suspended while XE sends a message to Pipers algorithmic trading engine to inform the algorithm of a match on XE. The algorithm would then seek to cancel the orders in XYZ placed on other trading centers. If the algorithm successfully cancels the orders on other trading centers, the algorithm will send a firm order to effect the transaction on XE that replaces the conditional order. If the trading algorithm is not able to successfully cancel the orders in XYZ on the other venues (e.g., because an execution occurs on one of the other venues), the algorithm will submit as a firm order the decremented quantity (in the case of a partial fill on an away venue) to replace the conditional order or cancel (in the case of a complete fill on an away venue) the matched order on XE as appropriate. There is no human intervention involved in this process of cancelling the orders on other venues and replacing the conditional order with a firm order to facilitate the execution on XE. If the trading algorithm is unable to confirm the terms of the conditional order (e.g., cancellation of the orders on other venues) within one second after there is a match on XE, the match of the conditional order on XE will be broken resulting in a cancellation of the conditional order in XE and the Limit Order Message. If the terms of the conditional order are satisfied (e.g., the trading algorithm successfully cancels the orders on other markets), the conditional order will trade on XE based on the market conditions at the time of execution rather than at the time of the initial match. Conditional orders have the same execution priority as non-conditional orders and are discussed in greater detail in Part III, Items 9(a) and (b).

order_types

The XE ATS operates one book: the On-Close Match book. All order types and modifiers are available on the same terms to all Subscribers, including traders on Pipers Cash Trading Desk. Orders submitted to XE that do not reflect a permissible order type or modifier (e.g., failing to specify a quantity) are rejected. Regarding time priority for the ATS, no two orders can ever be accepted simultaneously. Orders will be accepted as they arrive into the ATS and will be sequenced according to when they were accepted. Time priority will always go to the first order accepted by the ATS after all order validity checks are completed. Therefore, if two orders have the same timestamp, the order that was accepted first by the ATS will have priority when determining time priority. ON-CLOSE MATCH BOOK The On-Close Match book only accepts market orders with a time in force of either DAY or Immediate or Cancel (IOC), as selected by Subscribers. Limit orders are not accepted to the On-Close Match book. All orders submitted to the On-Close Match will be executed, if at all, at the closing price disseminated by the primary listing exchange for each NMS stock. Execution occurs upon the dissemination of the closing price, unless there is a trading halt in the stock at that time in which case no executions occur in the halted stock and all orders, including matched orders, are canceled back to Subscribers. Orders marked IOC will be canceled if they do not match with another order immediately upon submission. Orders marked DAY will rest in the On-Close Match book until they are matched or will be canceled if unmatched at the 3:55 p.m. ET cut-off time described in Part III, Item 4(a). Orders marked DAY that are submitted during the final five minutes of the trading day (i.e., 3:55 p.m. ET on normal trading days) will rest on the book until they are matched or will be canceled if unmatched at the time of the print of the closing price. If there is a partial match of an IOC order, only the unmatched portion will be canceled back. If there is a partial match of a DAY order, the unmatched portion will rest in the book until it is matched or canceled if unmatched at the time of the closing print in the stock (or canceled by the Subscriber). Execution priority in the On-Close Match book is determined based on the time they are received by XE with earlier arriving orders executed first in time. Subscribers can elect to apply a minimum quantity (MinQty) designation applicable to the initial fill of all of their orders sent to the On-Close Match book. Subscribers can specify or modify a MinQty designation by contacting Piper, and the MinQty function is available to Subscribers through both the Cash Trading Desk and the No-Touch (Electronic) Trading Desk. The specified MinQty will apply to all orders and cannot be selected on an order by order basis. A MinQty designation applies only to the initial match of an order sent to the On-Close Match book. Any remaining order interest, in the case of a partial fill, is not subject to the MinQty designation. There are no minimum order size requirements for the On-Close Match book, and the MinQty can be set for any amount of shares, including odd-lot and mixed lot quantities. Orders with a MinQty designation are filled first by orders that meet the MinQty designation. As a result, resting orders that satisfy an incoming contra-side orders MinQty designation gain priority over orders that do not satisfy the MinQty designation. For example, assume there are three resting DAY orders to sell XYZ all at the same price and arriving in the following time sequence: Order A for 100 shares, Order B for 100 shares, and Order C for 300 shares. A Subscriber submits a buy order marketable against these resting orders for 500 shares with a MinQty of 200 shares. The buy order would match first against Order C for its full quantity, and would then match with Order A and Order B to fill the remaining shares. If Order C were for 500 shares, the buy order would match entirely against Order C, and Orders A and B would not match notwithstanding their time priority over Order C. Orders submitted to the On-Close Match book can be modified or canceled at any time up until the closing print of the security. However, once an order is matched with a contra-side order, the order cannot be canceled or modified, other than in the case of a partial fill, in which case any remaining, unexecuted order interest can still be canceled or modified. Orders and modifications to orders in the On-Close Match book are timestamped upon entry. A modification to the size of an order will result in a new timestamp for the order and therefore a reset of the orders execution priority. Orders submitted to the On-Close Match book are not displayed or otherwise made known to other Subscribers or any non-Subscribers. However, when a Subscriber receives a match in the On-Close Match book, the ATS notifies the Subscriber that its order has been matched or partially matched as appropriate. The notification sent to Subscribers with respect to matched orders (or the matched portion of an order in the case of a partial fill) provide an indicative fill for the order at the NBBO midpoint at the time of the match. This indicative fill is not an execution confirmation; the actual fill will occur at the closing price on the primary listing market at which time an execution report is sent to the Subscriber and the indicative fill is canceled.

order_types

The XE ATS operates two books: the On-Close Match book and the Limit Order book. All order types, modifiers, and displayed information (in the case of the Limit Order book) for both order books are available on the same terms to all Subscribers, including traders on Pipers Cash Trading Desk with the limited exception that responses to Limit Order Broadcasts can only come through the Cash Trading Desk. Response orders to a Limit Order Broadcast are not visible to other Subscribers, including the sales and trading personnel responsible for that Subscribers account. However, sales and trading personnel responsible for the Subscribers account that submitted the Limit Order Broadcast response order (but not other Subscribers) are able to see any excess order interest resulting from a Limit Order Broadcast response order, as explained further below. Orders submitted to XE that do not reflect a permissible order type or modifier (e.g., failing to specify a quantity) are rejected. ON-CLOSE MATCH BOOK The On-Close Match book only accepts market orders with a time in force of either DAY or Immediate or Cancel (IOC), as selected by Subscribers. Limit orders are not accepted to the On-Close Match book. All orders submitted to the On-Close Match will be executed, if at all, at the closing price disseminated by the primary listing exchange for each NMS stock. Execution occurs upon the dissemination of the closing price, unless there is a trading halt in the stock at that time in which case no executions occur in the halted stock and all orders, including matched orders, are canceled back to Subscribers. Orders marked IOC will be canceled if they do not match with another order immediately upon submission. Orders marked DAY will rest in the On-Close Match book until they are matched or will be canceled if unmatched at the 3:55 p.m. ET cut-off time described in Part III, Item 4(a). Orders marked DAY that are submitted during the final five minutes of the trading day (i.e., 3:55 p.m. ET on normal trading days) will rest on the book until they are matched or will be canceled if unmatched at the time of the print of the closing price. If there is a partial match of an IOC order, only the unmatched portion will be canceled back. If there is a partial match of a DAY order, the unmatched portion will rest in the book until it is matched or canceled if unmatched at the time of the closing print in the stock (or canceled by the Subscriber). Execution priority in the On-Close Match book is determined based on the time they are received by XE with earlier arriving orders executed first in time. Subscribers can elect to apply a minimum quantity (MinQty) designation applicable to the initial fill of all of their orders sent to the On-Close Match book. Subscribers can specify or modify a MinQty designation by contacting Piper, and the MinQty function is available to Subscribers through both the Cash Trading Desk and the No-Touch (Electronic) Trading Desk. The specified MinQty will apply to all orders and cannot be selected on an order by order basis. A MinQty designation applies only to the initial match of an order sent to the On-Close Match book. Any remaining order interest, in the case of a partial fill, is not subject to the MinQty designation. There are no minimum order size requirements for the On-Close Match book, and the MinQty can be set for any amount of shares, including odd-lot and mixed lot quantities. Orders with a MinQty designation are filled first by orders that meet the MinQty designation. As a result, resting orders that satisfy an incoming contra-side orders MinQty designation gain priority over orders that do not satisfy the MinQty designation. For example, assume there are three resting DAY orders to sell XYZ all at the same price and arriving in the following time sequence: Order A for 100 shares, Order B for 100 shares, and Order C for 300 shares. A Subscriber submits a buy order marketable against these resting orders for 500 shares with a MinQty of 200 shares. The buy order would match first against Order C for its full quantity, and would then match with Order A and Order B to fill the remaining shares. If Order C were for 500 shares, the buy order would match entirely against Order C, and Orders A and B would not match notwithstanding their time priority over Order C. Orders submitted to the On-Close Match book can be modified or canceled at any time up until the closing print of the security. However, once an order is matched with a contra-side order, the order cannot be canceled or modified, other than in the case of a partial fill, in which case any remaining, unexecuted order interest can still be canceled or modified. Orders and modifications to orders in the On-Close Match book are timestamped upon entry. A modification to the size of an order will result in a new timestamp for the order and therefore a reset of the orders execution priority. Orders submitted to the On-Close Match book are not displayed or otherwise made known to other Subscribers or any non-Subscribers. However, when a Subscriber receives a match in the On-Close Match book, the ATS notifies the Subscriber that its order has been matched or partially matched as appropriate. The notification sent to Subscribers with respect to matched orders (or the matched portion of an order in the case of a partial fill) provide an indicative fill for the order at the NBBO midpoint at the time of the match. This indicative fill is not an execution confirmation; the actual fill will occur at the closing price on the primary listing market at which time an execution report is sent to the Subscriber and the indicative fill is canceled. LIMIT ORDER BOOK The Limit Order book accepts conditional and firm limit orders. Market orders are not accepted in the Limit Order book. Upon the receipt of a limit order to the Limit Order book, the order will first seek to match against any resting order interest in the book. If there is no match immediately upon entry, and the order is for 500 shares or more, the order is eligible to be broadcast to other Subscribers to solicit matching order interest (a Limit Order Broadcast). Subscribers must opt-in to having their orders disseminated through a Limit Order Broadcast and must be configured for such service by requesting it through Piper. All Subscribers are eligible to subscribe to Limit Order Broadcasts and configuration is performed with employees in the Technology Department. However, Subscribers must use the services of the Cash Trading Desk to be able to send orders in response to Limit Order Broadcasts. Once a Subscriber is configured to have its orders trigger Limit Order Broadcasts, all eligible orders will trigger a Limit Order Broadcast; selection of whether an order triggers a Limit Order Broadcast is not done on an order-by-order basis. If a Subscriber has opted into having its orders trigger Limit Order Broadcasts, each order must be for 500 shares or more, or will be rejected by the System. Subscribers that are not configured to have their orders trigger Limit Order Broadcasts can submit orders of any size. Subscribers can change their Limit Order Broadcast preference by contacting Piper. Subscribers must also opt-in to receive Limit Order Broadcasts resulting from other Subscribers orders. Orders submitted in responses to Limit Order Broadcasts can be for any size. There is no minimum quantity functionality with respect to the Limit Order book. XE will disseminate a Limit Order Broadcast to all Subscribers that have elected to receive Limit Order Broadcasts that details the price (either the initiating orders limit price or pegged price as described below), size, side (buy/sell), and symbol of eligible orders through Subscribers respective execution management systems. Subscribers that have opted into having their orders disseminated through a Limit Order Broadcast must populate an additional field when entering orders to indicate whether the Limit Order Broadcast should be pegged to the primary quote (i.e., the national best bid (NBB) for buy orders or national best offer (NBO) for sell orders) or the midpoint of the national best bid and offer (NBBO) for purposes of the displayed price of their order in the Limit Order Broadcast. If a Subscriber does not designate a peg preference, the Limit Order Broadcast will provide a default peg to the NBBO midpoint. Limit Order Broadcast displayed peg preferences are set on an order by order basis. The displayed price of a Limit Order Broadcast will be the initiating orders limit price unless or until the limit price is more aggressive than the primary quotation and/or midpoint of the NBBO, in which case the displayed price will be the pegged price, as selected by the Subscriber (i.e., either the primary quote or the NBBO midpoint). Limit Order Broadcasts pegged to the NBBO midpoint for display purposes are rounded down to the nearest whole penny increment for buy orders and up to the nearest whole penny increment for sell orders. Limit Order Broadcasts will not display order interest in sub-penny increments, including where the price of the security is less than $1.00. XE does not otherwise rank, display, or accept orders in sub-penny increments for NMS stocks trading above $1.00 per share. For example, assume the NBBO for stock XYZ is $10.00 x $10.05, and a Subscriber that has opted into having eligible orders disseminated through a Limit Order Broadcast submits an order to buy 500 shares of XYZ at a price of $10.02 pegged to the primary quote for Limit Order Broadcast display purposes. The Limit Order Broadcast would display the price at $10.00. If the NBBO moved to $10.03 x $10.05, the Limit Order Broadcast would reprice the buy order to display the orders limit price of $10.02. Assume instead that the buy order was priced at $10.03 and the Subscriber selected that the Limit Order Broadcast be pegged to the NBBO midpoint for display purposes while the NBBO is $10.00 x $10.05. The Limit Order Broadcast would display the price at $10.02, which is the NBBO midpoint rounded down (in the case of a buy order) to the nearest whole penny increment. If the NBBO were to move to $10.04 x $10.08, the Limit Order Broadcast would display a price of $10.03 (the originating orders limit price). If the NBBO were to move down to $9.95 x $10.00, the Limit Order Broadcast would display a price of $9.97, the NBBO midpoint rounded down to the nearest whole penny increment. The Limit Order Broadcast will remain visible to Subscribers that have elected to receive Limit Order Broadcasts until the order is executed or canceled. Orders submitted to the Limit Order book can have a time-in-force of either DAY or IOC. IOC orders do not cause XE to disseminate a Limit Order Broadcast detailing the terms of the order, and such orders will instead seek an immediate execution against any resting orders or cancel back to the Subscriber if there is no immediate match. DAY orders for 500 shares or more will cause XE to disseminate a Limit Order Broadcast (provided the Subscriber has opted into Limit Order Broadcasts with respect to its orders) and the order will remain in the Limit Order book until the order is executed, canceled by the Subscriber, or, if unexecuted at the end of the trading day, will be canceled by XE. If a DAY order that triggered a Limit Order Broadcast is partially filled such that its quantity falls below 500 shares, both the order and the Limit Order Broadcast will be canceled. Subscribers that have not been configured to have their orders trigger a Limit Order Broadcast can submit orders of any size (including for less than 500 shares) and such orders (with a time-in-force of DAY) will rest non-displayed until executed, canceled by the Subscriber, or until the end of the trading day. Execution priority for orders in the Limit Order book is based on price and then time. Price is determined by the limit price the Subscriber selects and time is based on the timestamp assigned to an order upon arriving at the ATS. Priority among equally priced orders is based on the time of order entry. Orders and modifications to orders are timestamped upon entry. Modifications to a resting orders price will affect its priority. Modifications to a resting orders size will result in a new time stamp for purposes of execution priority. In the case of a partial fill, any remaining order interest will preserve the time priority of the original order for execution priority purposes. Orders cannot be routed out of the Limit Order book. However, the ATS will route intermarket sweep orders (ISOs) as necessary in compliance with Rule 611 of regulation NMS, provided the Subscriber has opted into having XE route ISOs to facilitate executions on XE, as described in greater detail in Part III, Item 16. Matches within the Limit Order Book are automatically executed without human intervention or negotiation and are reported with the MPID PJCX. Please see Part III, Item 11(c) for further detail regarding the prices at which matched orders in the Limit Order book will execute. All orders submitted to the Limit Order book can interact with multiple matching contra-side orders. Any DAY order, or excess order interest of a DAY order in the case of a partial fill immediately upon arrival, can trigger a new Limit Order Broadcast if eligible (i.e., it is for a quantity greater than 500 shares and the Subscriber has opted-into Limit Order Broadcasts). However, responses to a Limit Order Broadcast cannot trigger a Limit Order Broadcast. All responses to a Limit Order Broadcast come through the Cash Trading Desk and are treated as a not-held order. Because orders sent in response to Limit Order Broadcasts (Limit Order Broadcast Responses) do not result in dissemination of a Limit Order Broadcast, Subscribers do not need to set a pegged order display preference. Any excess order interest a Limit Order Broadcast Response can rest in the ATS (provided the Limit Order Broadcast Response has a time in force of DAY) as a not-held order and is visible to the sales and trading personnel of the Cash Trading Desk responsible for that Subscribers account. For example, assume Order 1 is submitted to buy 500 shares of XYZ at $10.00 with a time-in-force of DAY, and Order 2 is submitted a moment later to also buy 500 shares of XYZ at $10.00 with a time-in-force of DAY when the NBBO for XYZ is $10.00 x $10.05 and where there is no resting sell interest in the Limit Order book for XYZ. Assuming the Subscribers submitting Order 1 and 2 have opted into Limit Order Broadcasts, XE would disseminate a Limit Order Broadcast with respect to both Order 1 and Order 2. Assume further that a Subscriber submits in response to the Limit Order Broadcast for Order 1 a DAY sell order for 1500 shares of XYZ priced at $10.00 (Order 3). XE would execute Order 3 against Order 1 for 500 shares and then execute against Order 2 for 500 shares with both executions occurring at $10.00. The remaining 500 shares of sell order interest from Order 3 would not cause the ATS to broadcast a new Limit Order Broadcast to Subscribers to sell 500 shares of XYZ. However, the 500 shares of excess sell order interest from Order 3 would rest in XE and be treated as a not-held order of the Cash Trading Desk. This excess order interest would be eligible to execute against any subsequent buy orders in XYZ submitted to XE for as long as the order rests there. If Order 3 had been marked IOC rather than DAY, the 500 shares of unexecuted sell order interest would be canceled back. In the event there is resting order interest with priority over an order that initiated a Limit Order Broadcast, such interest will execute first. For instance, in the example above, if there were a resting buy order for 200 shares of XYZ at $10.00 in the Limit Order book with time priority over Orders 1 and 2, Order 3 would execute first against this resting order before executing against Orders 1 and 2. In other words, an order sent in response to a Limit Order Broadcast will still consider any marketable resting order interest when executing. Conditional orders can only be sent by a Subscriber that: (i) has been configured to be able to submit conditional orders by contacting Piper; and (ii) uses a trading algorithm as the means of access, either through the No-Touch (Electronic) Trading Desk or through the Cash Trading Desk. Conditional orders are generally treated the same as non-conditional orders in the ATS except that any potential execution will be suspended pending satisfaction of the terms of the conditional order. For example, assume a Subscriber is looking to buy 500 shares of XYZ at a given price in the market and the Subscriber uses a trading algorithm that sends a 500 share order in XYZ to multiple trading venues being unsure where it will receive an execution. Provided the trading algorithm has been configured to route to XE as a possible routing destination, the algorithm can submit a conditional order to XE, which would only execute against a matching order pending the cancellation of the orders sent to the other venues. If the Subscribers conditional order matches on XE, the execution would be suspended while XE sends a message to Pipers algorithmic trading engine to inform the algorithm of a match on XE. The algorithm would then seek to cancel the orders in XYZ placed on other trading centers. If the algorithm successfully cancels the orders on other trading centers, the algorithm will send a firm order to effect the transaction on XE that replaces the conditional order. If the trading algorithm is not able to successfully cancel the orders in XYZ on the other venues (e.g., because an execution occurs on one of the other venues), the algorithm will submit as a firm order the decremented quantity (in the case of a partial fill on an away venue) to replace the conditional order or cancel (in the case of a complete fill on an away venue) the matched order on XE as appropriate. There is no human intervention involved in this process of cancelling the orders on other venues and replacing the conditional order with a firm order to facilitate the execution on XE. If the trading algorithm is unable to confirm the terms of the conditional order (e.g., cancellation of the orders on other venues) within one second after there is a match on XE, the match of the conditional order on XE will be broken resulting in a cancellation of the conditional order in XE and the Limit Order Message. If the terms of the conditional order are satisfied (e.g., the trading algorithm successfully cancels the orders on other markets), the conditional order will trade on XE based on the market conditions at the time of execution rather than at the time of the initial match. Conditional orders have the same execution priority as non-conditional orders and are discussed in greater detail in Part III, Items 9(a) and (b).

means_of_entry

Subscribers can access XE directly via a FIX connection or through the use of an algorithmic trading strategy offered by Piper that is configured to submit orders to XE as a possible routing destination. Orders submitted using a trading algorithm are also sent to XE via a FIX connection. All orders submitted to XE will pass through the Firms order entry gateway where orders are timestamped to the millisecond and risk controls (e.g., credit limit checks) are applied. Subscribers entering orders directly via FIX connection must be configured at the hosting site at a specific IP address and port of access. Connectivity must be established through a private, professional network provider. All orders and other messages submitted via direct-FIX connection must be compatible with FIX specifications 4.2.

means_of_entry

Subscribers can access XE directly via a FIX connection or through the use of an algorithmic trading strategy offered by Piper that is configured to submit orders to XE as a possible routing destination. Orders submitted using a trading algorithm are also sent to XE via a FIX connection. All orders submitted to XE will pass through the Firms order entry gateway where orders are timestamped to the second and risk controls (e.g., credit limit checks) are applied. Response orders to Limit Order Broadcasts (as described in Part III, Item 7(a)) are also sent via FIX connection and cannot be sent through a trading algorithm. Subscribers entering orders directly via FIX connection must be configured at the hosting site at a specific IP address and port of access. Connectivity must be established through a private, professional network provider. All orders and other messages submitted via direct-FIX connection must compatible with FIX specifications 4.2.

means_of_entry

Subscribers can access XE directly via a FIX connection or through the use of an algorithmic trading strategy offered by Piper that is configured to submit orders to XE as a possible routing destination. Orders submitted using a trading algorithm are also sent to XE via a FIX connection. All orders submitted to XE will pass through the Firms order entry gateway where orders are timestamped to the millisecond and risk controls (e.g., credit limit checks) are applied. Response orders to Limit Order Broadcasts (as described in Part III, Item 7(a)) are also sent via FIX connection and cannot be sent through a trading algorithm. Subscribers entering orders directly via FIX connection must be configured at the hosting site at a specific IP address and port of access. Connectivity must be established through a private, professional network provider. All orders and other messages submitted via direct-FIX connection must compatible with FIX specifications 4.2.

pricing_methodology

Piper, the Broker-Dealer Operator, maintains feeds from the SIP and direct feeds from the national exchanges via market data provider ACTIV Financial. The feeds are received and processed real time with no delays or aggregation. XE uses SIP data to capture the closing print at the primary exchange where the stock is traded for purposes of facilitating executions in the On-Close Match book.

pricing_methodology

Piper, the Broker-Dealer Operator, maintains proprietary feeds from the SIP and direct feeds from the national exchanges. XE uses SIP data to capture the closing print at the primary exchange where the stock is traded for purposes of facilitating executions in the On-Close Match book. With respect to the Limit Order book, when XE receives an order that is eligible for broadcast through a Limit Order Broadcast (i.e., an order that is for 500 shares or more, marked DAY, and where the Subscriber has opted-in for Limit Order Broadcasts), the Limit Order Broadcasts displayed price is pegged to either the primary quote (i.e., the national best bid (NBB) for buy orders and national best offer (NBO) for sell orders) or the midpoint of the NBBO for display purposes, subject to the initiating orders limit price (as described in Part III, Item 7(a)). XE disseminates the Limit Order Broadcast to Subscribers via their respective execution management systems (EMS) and/or Bloomberg terminal by instructing the Limit Order Broadcast to display its price pegged to the NBB or NBO or midpoint as appropriate. Certain Subscribers EMSs support functionality to peg orders to the NBB or NBO or midpoint (pegged order functionality), while others may not. Subscribers choose which EMSs they wish to use and can use more than one type. EMSs that support pegged order functionality may use the SIP or exchange proprietary feeds to update Limit Order Broadcast prices as changes to the NBBO occur. For EMSs that do not support pegged order functionality, XE uses SIP data to determine the NBB or NBO or midpoint to communicate the displayed price of orders through a Limit Order Broadcast. As the NBB or NBO changes, XE will communicate updates to the displayed price of Limit Order Broadcasts (subject to the limit price of the order that initiated the Limit Order Broadcast) based on SIP data. Limit Order Broadcast pricing updates sent by XE do not affect execution priority. XE uses direct exchange feeds from exchanges to ensure that matched orders in the Limit Order book will not trade through protected quotations. In such circumstances, XE will send ISOs using the direct exchange data feeds as necessary to sweep the full displayed size of any better priced quotations and subsequently allow orders matched on XE to trade.

pricing_methodology

Piper, the Broker-Dealer Operator, maintains feeds from the SIP and direct feeds from the national exchanges via market data provider ACTIV Financial. The feeds are received and processed real time with no delays or aggregation. XE uses SIP data to capture the closing print at the primary exchange where the stock is traded for purposes of facilitating executions in the On-Close Match book. With respect to the Limit Order book, when XE receives an order that is eligible for broadcast through a Limit Order Broadcast (i.e., an order that is for 500 shares or more, marked DAY, and where the Subscriber has opted-in for Limit Order Broadcasts), the Limit Order Broadcasts displayed price is pegged to either the primary quote (i.e., the national best bid (NBB) for buy orders and national best offer (NBO) for sell orders) or the midpoint of the NBBO for display purposes, subject to the initiating orders limit price (as described in Part III, Item 7(a)). XE disseminates the Limit Order Broadcast to Subscribers via their respective execution management systems (EMS) and/or Bloomberg terminal by instructing the Limit Order Broadcast to display its price pegged to the NBB or NBO or midpoint as appropriate. Certain Subscribers EMSs support functionality to peg orders to the NBB or NBO or midpoint (pegged order functionality), while others may not. Subscribers choose which EMSs they wish to use and can use more than one type. EMSs that support pegged order functionality may use the SIP or exchange proprietary feeds to update Limit Order Broadcast prices as changes to the NBBO occur. For EMSs that do not support pegged order functionality, XE uses SIP data to determine the NBB or NBO or midpoint to communicate the displayed price of orders through a Limit Order Broadcast. As the NBB or NBO changes, XE will communicate updates to the displayed price of Limit Order Broadcasts (subject to the limit price of the order that initiated the Limit Order Broadcast) based on SIP data. Limit Order Broadcast pricing updates sent by XE do not affect execution priority. XE uses direct exchange feeds from exchanges to ensure that matched orders in the Limit Order book will not trade through protected quotations. In such circumstances, XE will send ISOs using the direct exchange data feeds as necessary to sweep the full displayed size of any better priced quotations and subsequently allow orders matched on XE to trade.

counterparty_selection

The XE ATS does not tier, segment, rank, or otherwise categorize Subscribers. Subscribers cannot select or deselect any counterparty except themselves to prevent self-crossing. Subscribers can use Piper self-trade prevention functionality to avoid trading against themselves or related business units or accounts by contacting Piper and specifying the desired self-trade prevention configurations. Once certain self-trade prevention configurations are established, a Subscriber can change these configurations by contacting Piper.

financial_condition_summary

The XE ATS does not have any specific fees for access to or executions occurring on the ATS. Piper, the Broker-Dealer Operator, has commission agreements in place with each of its customers and any executions that occur on XE are subject to these schedules. The commission schedules are agnostic as to where a customers executions occur, whether on XE as a Subscriber or on another trading venue. Piper does not receive any other consideration outside of these what is set forth in each commission agreement. Commissions vary depending on the specific arrangement with each customer and services provided by Piper (e.g., a Subscriber that only uses the No-Touch (Electronic) Trading Desk may have a lower commission schedule than a Subscriber using both the No-Touch (Electronic) Trading Desk and the services of the Cash Trading Desk). Neither XE nor the Piper receive or offer payment for order flow. Subscribers are not tiered, ranked, segmented, or otherwise categorized on XE or by Piper.

compliance_officer

GENERALLY XE, the NMS Stock ATS, is separate from Piper Sandler & Co. (Piper), the Broker-Dealer Operators other trading systems and is individually password protected. Piper considers Subscribers live orders routed to XE to be confidential (Confidential ATS Information). Piper does not use Confidential ATS Information to inform its principal trading activities. XE is housed in a separate server from Pipers algorithmic trading engine. Both servers are located on a separate floor from Piper traders on the Cash Trading Desk. EMPLOYEES WITH ACCESS TO CONFIDENTIAL ATS INFORMATION Access to Confidential ATS Information is restricted to Select ATS Employees of Piper as described in Part II, Item 6(a). In order for employees to access Confidential ATS Information, an employee must fill out a request form and submit to the Employee Access area of the Technology Department. The request for access is then reviewed by the Compliance Director and Head of the Global Middle Office based on the employees need for access to XE and their purpose or function with respect to XE. Quarterly, the Employee Access area of the Technology Department performs an entitlement review and sends a list of all employees with access to the XE ATS to the Head of the Global Middle Office where the information is reviewed and employees are reapproved or removed based on their continued need to have access to the information (e.g., based on the employees current role and whether access is necessary to support the functions of XE) and functions with respect to XE. Select ATS Employees are prohibited from sharing Confidential ATS Information with employees and other persons not authorized to receive Confidential ATS Information. Pipers policies and procedures, consistent with FINRA rules, prohibit traders from front-running or trading ahead of Piper customers, including Subscribers to XE. SYSTEMS WITH ACCESS TO SUBSCRIBER CONFIDENTIAL TRADING INFORMATION Orders can be sent to XE indirectly via certain algorithmic trading strategies offered by Piper. The Piper systems that support these algorithms have access to orders sent to XE by the trading algorithm. Traders on the Cash Trading Desk can see orders that they have routed to XE through an algorithmic trading strategy in order to ensure the algorithm is operating appropriately. However, such traders are not able to see orders routed to XE by Subscribers via the No-Touch Trading Desk. Certain Piper employees (i.e., Select ATS Employees as described in Part II, Item 6(a)) that are responsible for monitoring and compliance functions and for maintaining and troubleshooting issues that arise with respect Subscribers FIX connections or trading algorithms that are configured to route orders to XE, are able to see Subscribers orders sent to XE through FIX connections or Pipers algorithm engine in carrying out these functions. PERSONAL TRADING POLICY All Select ATS Employees and any other personnel provided with access to Confidential ATS Information on an ad hoc basis are not permitted to trade for their own personal account in any side/symbol for which Piper is handling a customer order at that time or that is currently trading in the ATS. Similarly, even though they only have access to Confidential ATS Information with respect to orders they submitted to XE, all traders on the Cash Trading Desk are also subject to the same restrictions. All equity and option trades for the above mentioned employees are subject to the Firms pre-approval and subsequently, a 20 calendar day holding period (5 day holding period if the security is an ETF or index). When Select ATS Employees and traders on the Cash Trading Desk place a trade request through Pipers trade approval system, the system checks for live customer orders with Piper and that are in the NMS Stock ATS. These trade requests are denied if there are any live customer orders with the same side/symbol for either Piper or the ATS. If a trade request is approved, the order must be executed within 15 minutes of the time of approval. Piper monitors Select ATS Employees (as well as other Piper employees) to ensure trades were preapproved and that securities are held for the required holding periods. Piper also maintains a restricted list of securities in which no Piper employees is permitted to trade. WRITTEN OVERSIGHT PROCEDURES As noted above, Piper performs a quarterly review of all employees with access to Confidential ATS Information, and those that no longer have a need to access Confidential ATS Information based on their functions will have their access terminated. All requests for access to Confidential ATS Information are reviewed and approved by both the Global Middle Office and Compliance Department. Piper reviews its policies and procedures relating to XE, including its personal trading policy, at least once annually. With respect to the personal trading policy of employees with access to Confidential ATS Information and Piper traders, the Compliance Department monitors trading activity for any violation of the Firms employee trading policies and holding period requirements. Employees are required to attest to Pipers policies and procedures on an annual basis.

compliance_officer

Generally, XE, the NMS Stock ATS, is separate from Piper Sandler & Co. (Piper), the Broker-Dealer Operators other trading systems and is individually password protected. Piper considers Subscribers live orders routed to XE to be confidential (Confidential ATS Information). Piper does not use Confidential ATS Information to inform its principal trading activities. XE is housed in a separate server from Pipers algorithmic trading engine. Both servers are located on a separate floor from Piper traders on the Cash Trading Desk. EMPLOYEES WITH ACCESS TO CONFIDENTIAL ATS INFORMATION Access to Confidential ATS Information is restricted to Select ATS Employees of Piper as described in Part II, Item 6(a). In order for employees to access Confidential ATS Information, an employee must fill out a request form and submit to the Employee Access area of the Technology Department. The request for access is then reviewed by the Compliance Director and Head of the Global Middle Office based on the employees need for access to XE and their purpose or function with respect to XE. Quarterly, the Employee Access area of the Technology Department performs an entitlement review and sends a list of all employees with access to the XE ATS to the Head of the Global Middle Office where the information is reviewed and employees are reapproved or removed based on their continued need to have access to the information (e.g., based on the employees current role and whether access is necessary to support the functions of XE) and functions with respect to XE. Select ATS Employees are prohibited from sharing Confidential ATS Information with employees and other persons not authorized to receive Confidential ATS Information. Pipers policies and procedures, consistent with FINRA rules, prohibit traders from front-running or trading ahead of Piper customers, including Subscribers to XE. SYSTEMS WITH ACCESS TO SUBSCRIBER CONFIDENTIAL TRADING INFORMATION Orders can be sent to XE indirectly via certain algorithmic trading strategies offered by Piper. The Piper systems that support these algorithms have access to orders sent to XE by the trading algorithm. Traders on the Cash Trading Desk can see orders that they have routed to XE through an algorithmic trading strategy in order to ensure the algorithm is operating appropriately. However, such traders are not able to see orders routed to XE by Subscribers via the No-Touch Trading Desk. Certain Piper employees (i.e., Select ATS Employees as described in Part II, Item 6(a)) that are responsible for monitoring and compliance functions and for maintaining and troubleshooting issues that arise with respect Subscribers FIX connections or trading algorithms that are configured to route orders to XE, are able to see Subscribers orders sent to XE through FIX connections or Pipers algorithm engine in carrying out these functions. PERSONAL TRADING POLICY All Select ATS Employees and any other personnel provided with access to Confidential ATS Information on an ad hoc basis are not permitted to trade for their own personal account in any side/symbol for which Piper is handling a customer order at that time or that is currently trading in the ATS. Similarly, even though they only have access to Confidential ATS Information with respect to orders they submitted to XE, all traders on the Cash Trading Desk are also subject to the same restrictions. All equity and option trades for the above mentioned employees are subject to the Firms pre-approval and subsequently, a 20 calendar day holding period for equities (no holding period if the security is an ETF or index). When Select ATS Employees and traders on the Cash Trading Desk place a trade request through Pipers trade approval system, the system checks for live customer orders with Piper and that are in the NMS Stock ATS. These trade requests are denied if there are any live customer orders with the same side/symbol for either Piper or the ATS. If a trade request is approved, the order must be executed within 15 minutes of the time of approval. For di minimis orders that would not presume to have an effect on any client orders, as well as in situations where a client limit order is not considered marketable, Piper can make an exception to our employee trading policy and allow an employee order to occur. More specifically, the employee order must be less than or equal to 1000 shares or 1% of the adtv, whichever is lower, the subscribers orders in aggregate in the ATS on the same side of the market as the employee order must be less than 1% of the adtv, and neither the employee order nor the subscribers orders in the ATS in aggregate would be considered to have significant market impact. Piper monitors Select ATS Employees (as well as other Piper employees) to ensure trades were preapproved and that securities are held for the required holding periods. Piper also maintains a restricted list of securities in which no Piper employees is permitted to trade. WRITTEN OVERSIGHT PROCEDURES As noted above, Piper performs a quarterly review of all employees with access to Confidential ATS Information, and those that no longer have a need to access Confidential ATS Information based on their functions will have their access terminated. All requests for access to Confidential ATS Information are reviewed and approved by both the Global Middle Office and Compliance Department. Piper reviews its policies and procedures relating to XE, including its personal trading policy, at least once annually. With respect to the personal trading policy of employees with access to Confidential ATS Information and Piper traders, the Compliance Department monitors trading activity for any violation of the Firms employee trading policies and holding period requirements. Employees are required to attest to Pipers policies and procedures on an annual basis.

compliance_officer

GENERALLY XE, the NMS Stock ATS, is separate from Piper Sandler & Co. (Piper), the Broker-Dealer Operators other trading systems and is individually password protected. Piper considers Subscribers live orders routed to XE to be confidential (Confidential ATS Information). Piper does not use Confidential ATS Information to inform its principal trading activities. XE is housed in a separate server from Pipers algorithmic trading engine. Both servers are located on a separate floor from Piper traders on the Cash Trading Desk. EMPLOYEES WITH ACCESS TO CONFIDENTIAL ATS INFORMATION Access to Confidential ATS Information is restricted to Select ATS Employees of Piper as described in Part II, Item 6(a). In order for employees to access Confidential ATS Information, an employee must fill out a request form and submit to the Employee Access area of the Technology Department. The request for access is then reviewed by the Compliance Director and Head of the Global Middle Office based on the employees need for access to XE and their purpose or function with respect to XE. Quarterly, the Employee Access area of the Technology Department performs an entitlement review and sends a list of all employees with access to the XE ATS to the Head of the Global Middle Office where the information is reviewed and employees are reapproved or removed based on their continued need to have access to the information (e.g., based on the employees current role and whether access is necessary to support the functions of XE) and functions with respect to XE. Select ATS Employees are prohibited from sharing Confidential ATS Information with employees and other persons not authorized to receive Confidential ATS Information. Pipers policies and procedures, consistent with FINRA rules, prohibit traders from front-running or trading ahead of Piper customers, including Subscribers to XE. SYSTEMS WITH ACCESS TO SUBSCRIBER CONFIDENTIAL TRADING INFORMATION Orders can be sent to XE indirectly via certain algorithmic trading strategies offered by Piper. The Piper systems that support these algorithms have access to orders sent to XE by the trading algorithm. Traders on the Cash Trading Desk can see orders that they have routed to XE through an algorithmic trading strategy in order to ensure the algorithm is operating appropriately. However, such traders are not able to see orders routed to XE by Subscribers via the No-Touch Trading Desk. Certain Piper employees (i.e., Select ATS Employees as described in Part II, Item 6(a)) that are responsible for monitoring and compliance functions and for maintaining and troubleshooting issues that arise with respect Subscribers FIX connections or trading algorithms that are configured to route orders to XE, are able to see Subscribers orders sent to XE through FIX connections or Pipers algorithm engine in carrying out these functions. PERSONAL TRADING POLICY All Select ATS Employees and any other personnel provided with access to Confidential ATS Information on an ad hoc basis are not permitted to trade for their own personal account in any side/symbol for which Piper is handling a customer order at that time or that is currently trading in the ATS. Similarly, even though they only have access to Confidential ATS Information with respect to orders they submitted to XE, all traders on the Cash Trading Desk are also subject to the same restrictions. All equity and option trades for the above mentioned employees are subject to the Firms pre-approval and subsequently, a 20 calendar day holding period for equities (no holding period if the security is an ETF or index). When Select ATS Employees and traders on the Cash Trading Desk place a trade request through Pipers trade approval system, the system checks for live customer orders with Piper and that are in the NMS Stock ATS. These trade requests are denied if there are any live customer orders with the same side/symbol for either Piper or the ATS. If a trade request is approved, the order must be executed within 15 minutes of the time of approval. Piper monitors Select ATS Employees (as well as other Piper employees) to ensure trades were preapproved and that securities are held for the required holding periods. Piper also maintains a restricted list of securities in which no Piper employees is permitted to trade. WRITTEN OVERSIGHT PROCEDURES As noted above, Piper performs a quarterly review of all employees with access to Confidential ATS Information, and those that no longer have a need to access Confidential ATS Information based on their functions will have their access terminated. All requests for access to Confidential ATS Information are reviewed and approved by both the Global Middle Office and Compliance Department. Piper reviews its policies and procedures relating to XE, including its personal trading policy, at least once annually. With respect to the personal trading policy of employees with access to Confidential ATS Information and Piper traders, the Compliance Department monitors trading activity for any violation of the Firms employee trading policies and holding period requirements. Employees are required to attest to Pipers policies and procedures on an annual basis.

compliance_officer

Generally, XE, the NMS Stock ATS, is separate from Piper Sandler & Co. (Piper), the Broker-Dealer Operators other trading systems and is individually password protected. Piper considers Subscribers live orders routed to XE to be confidential (Confidential ATS Information). Piper does not use Confidential ATS Information to inform its principal trading activities. XE is housed in a separate server from Pipers algorithmic trading engine. Both servers are located aton a separate floor location from Piper traders on the Cash Trading Desk. Piper Traders reside in Greenwich, CT, and the servers are located as disclosed in Part I Item 7. EMPLOYEES WITH ACCESS TO CONFIDENTIAL ATS INFORMATION Access to Confidential ATS Information is restricted to Select ATS Employees of Piper as described in Part II, Item 6(a). In order for employees to access Confidential ATS Information, an employee must fill out a request form and submit to the Employee Access area of the Technology Department. The request for access is then reviewed by the Compliance Director and Head of the Global Middle Office based on the employees need for access to XE and their purpose or function with respect to XE. Quarterly, the Employee Access area of the Technology Department performs an entitlement review and sends a list of all employees with access to the XE ATS to the Head of the Global Middle Office where the information is reviewed and employees are reapproved or removed based on their continued need to have access to the information (e.g., based on the employees current role and whether access is necessary to support the functions of XE) and functions with respect to XE. Select ATS Employees are prohibited from sharing Confidential ATS Information with employees and other persons not authorized to receive Confidential ATS Information. Pipers policies and procedures, consistent with FINRA rules, prohibit traders from front-running or trading ahead of Piper customers, including Subscribers to XE. SYSTEMS WITH ACCESS TO SUBSCRIBER CONFIDENTIAL TRADING INFORMATION Orders can be sent to XE indirectly via certain algorithmic trading strategies offered by Piper. The Piper systems that support these algorithms have access to orders sent to XE by the trading algorithm. Traders on the Cash Trading Desk can see orders that they have routed to XE through an algorithmic trading strategy in order to ensure the algorithm is operating appropriately. However, such traders are not able to see orders routed to XE by Subscribers via the No-Touch Trading Desk. Certain Piper employees (i.e., Select ATS Employees as described in Part II, Item 6(a)) that are responsible for monitoring and compliance functions and for maintaining and troubleshooting issues that arise with respect Subscribers FIX connections or trading algorithms that are configured to route orders to XE, are able to see Subscribers orders sent to XE through FIX connections or Pipers algorithm engine in carrying out these functions. Data center personnel at Equinix LLC and Flexential LLC have limited physical access to the data center cage housing the servers, and only as the result of specific request of the broker dealer operator, and they have no access to subscriber confidential trading information. PERSONAL TRADING POLICY All Select ATS Employees and any other personnel provided with access to Confidential ATS Information on an ad hoc basis are not permitted to trade for their own personal account in any side/symbol for which Piper is handling a customer order at that time or that is currently trading in the ATS. Similarly, even though they only have access to Confidential ATS Information with respect to orders they submitted to XE, all traders on the Cash Trading Desk are also subject to the same restrictions. All equity and option trades for the above mentioned employees are subject to the Firms pre-approval and subsequently, a 20 calendar day holding period for equities (no holding period if the security is an ETF or index). When Select ATS Employees and traders on the Cash Trading Desk place a trade request through Pipers trade approval system, the system checks for live customer orders with Piper and that are in the NMS Stock ATS. These trade requests are denied if there are any live customer orders with the same side/symbol for either Piper or the ATS. If a trade request is approved, the order must be executed within 15 minutes of the time of approval. For di minimis orders that would not presume to have an effect on any client orders, as well as in situations where a client limit order is not considered marketable, Piper can make an exception to our employee trading policy and allow an employee order to occur. More specifically, the employee order must be less than or equal to 1000 shares or 1% of the adtv, whichever is lower, the subscribers orders in aggregate in the ATS on the same side of the market as the employee order must be less than 1% of the adtv, and neither the employee order nor the subscribers orders in the ATS in aggregate would be considered to have significant market impact. Piper monitors Select ATS Employees (as well as other Piper employees) to ensure trades were preapproved and that securities are held for the required holding periods. Piper also maintains a restricted list of securities in which no Piper employees is permitted to trade. WRITTEN OVERSIGHT PROCEDURES As noted above, Piper performs a quarterly review of all employees with access to Confidential ATS Information, and those that no longer have a need to access Confidential ATS Information based on their functions will have their access terminated. All requests for access to Confidential ATS Information are reviewed and approved by both the Global Middle Office and Compliance Department. Piper reviews its policies and procedures relating to XE, including its personal trading policy, at least once annually. With respect to the personal trading policy of employees with access to Confidential ATS Information and Piper traders, the Compliance Department monitors trading activity for any violation of the Firms employee trading policies and holding period requirements. Employees are required to attest to Pipers policies and procedures on an annual basis.

compliance_officer

GENERALLY XE, the NMS Stock ATS, is separate from Piper Jaffray & Co. (Piper), the Broker-Dealer Operators other trading systems and is individually password protected. Piper considers Subscribers live orders routed to XE to be confidential (Confidential ATS Information). Piper does not use Confidential ATS Information to inform its principal trading activities. XE is housed in a separate server from Pipers algorithmic trading engine. Both servers are located on a separate floor from Piper traders on the Cash Trading Desk. EMPLOYEES WITH ACCESS TO CONFIDENTIAL ATS INFORMATION Access to Confidential ATS Information is restricted to Select ATS Employees of Piper as described in Part II, Item 6(a). In order for employees to access Confidential ATS Information, an employee must fill out a request form and submit to the Employee Access area of the Technology Department. The request for access is then reviewed by the Compliance Director and Head of the Global Middle Office based on the employees need for access to XE and their purpose or function with respect to XE. Quarterly, the Employee Access area of the Technology Department performs an entitlement review and sends a list of all employees with access to the XE ATS to the Head of the Global Middle Office where the information is reviewed and employees are reapproved or removed based on their continued need to have access to the information (e.g., based on the employees current role and whether access is necessary to support the functions of XE) and functions with respect to XE. Select ATS Employees are prohibited from sharing Confidential ATS Information with employees and other persons not authorized to receive Confidential ATS Information. Pipers policies and procedures, consistent with FINRA rules, prohibit traders from front-running or trading ahead of Piper customers, including Subscribers to XE. SYSTEMS WITH ACCESS TO SUBSCRIBER CONFIDENTIAL TRADING INFORMATION Orders can be sent to XE indirectly via certain algorithmic trading strategies offered by Piper. The Piper systems that support these algorithms have access to orders sent to XE by the trading algorithm. Traders on the Cash Trading Desk can see orders that they have routed to XE through an algorithmic trading strategy in order to ensure the algorithm is operating appropriately. However, such traders are not able to see orders routed to XE by Subscribers via the No-Touch Trading Desk. Certain Piper employees (i.e., Select ATS Employees as described in Part II, Item 6(a)) that are responsible for monitoring and compliance functions and for maintaining and troubleshooting issues that arise with respect Subscribers FIX connections or trading algorithms that are configured to route orders to XE, are able to see Subscribers orders sent to XE through FIX connections or Pipers algorithm engine in carrying out these functions. PERSONAL TRADING POLICY All Select ATS Employees and any other personnel provided with access to Confidential ATS Information on an ad hoc basis are not permitted to trade for their own personal account in any side/symbol for which Piper is handling a customer order at that time or that is currently trading in the ATS. Similarly, even though they only have access to Confidential ATS Information with respect to orders they submitted to XE, all traders on the Cash Trading Desk are also subject to the same restrictions. All equity and option trades for the above mentioned employees are subject to the Firms pre-approval and subsequently, a 20 calendar day holding period (5 day holding period if the security is an ETF or index). When Select ATS Employees and traders on the Cash Trading Desk place a trade request through Pipers trade approval system, the system checks for live customer orders with Piper and that are in the NMS Stock ATS. These trade requests are denied if there are any live customer orders with the same side/symbol for either Piper or the ATS. If a trade request is approved, the order must be executed within 15 minutes of the time of approval. Piper monitors Select ATS Employees (as well as other Piper employees) to ensure trades were preapproved and that securities are held for the required holding periods. Piper also maintains a restricted list of securities in which no Piper employees is permitted to trade. WRITTEN OVERSIGHT PROCEDURES As noted above, Piper performs a quarterly review of all employees with access to Confidential ATS Information, and those that no longer have a need to access Confidential ATS Information based on their functions will have their access terminated. All requests for access to Confidential ATS Information are reviewed and approved by both the Global Middle Office and Compliance Department. Piper reviews its policies and procedures relating to XE, including its personal trading policy, at least once annually. With respect to the personal trading policy of employees with access to Confidential ATS Information and Piper traders, the Compliance Department monitors trading activity for any violation of the Firms employee trading policies and holding period requirements. Employees are required to attest to Pipers policies and procedures on an annual basis.

hours_of_operation

XE operates on all U.S. trading days where the public exchanges are open. The ATS accepts orders from 7:00 AM ET to 4:00 PM ET. As described in greater detail below, XE operates two separate order books: (i) the On-Close Match book, which is specific to transactions at the market close; and (ii) the Limit Order book, which matches and executes limit orders throughout the trading day, but not before or after regular trading hours. The order books are separate, meaning that an order cannot rest simultaneously on each order book or be routed from one order book to another. During the pre-market session between 7:00 a.m. ET and the market open at 9:30 a.m. ET, orders submitted to both order books are held in queue. Orders are only eligible for matching and execution in the Limit Order book between 9:30 a.m. ET and 4:00 p.m. ET during regular trading days and 9:30 a.m. ET to 1:00 p.m. ET on designated early market closings. Orders in the On-Close Match book also begin matching between 9:30 a.m. ET and 4:00 p.m. and are eligible to execute upon the printing of the closing price on the primary listing market for each exchange and not prior to that time. There are two cutoff times for submitting orders to both order books in order to facilitate the market close. Orders received before 3:55 p.m. ET that have not matched (or executed in the case of the Limit Order book) are canceled back to Subscribers at 3:55 p.m. ET. Orders received after 3:55 p.m. ET will rest on the order books for matching and potential execution until 3:59:59 p.m. ET, at which time, any unmatched orders (or unexecuted orders in the case of the Limit Order book) are canceled back to Subscribers at 3:59:59 p.m. ET. These cutoff times are 12:55 p.m. ET and 12:59:59 p.m. ET respectively on designated early market closings. Please see Part III, Item 17(a) for additional detail.

hours_of_operation

XE operates on all U.S. trading days where the public exchanges are open. The ATS accepts orders from 7:00 AM ET to 4:00 PM ET. As described in greater detail below, XE operates an On-Close Match book, which is specific to transactions at the market close. During the pre-market session between 7:00 a.m. ET and the market open at 9:30 a.m. ET, orders submitted are held in queue. Orders in the On-Close Match book also begin matching between 9:30 a.m. ET and 4:00 p.m. and are eligible to execute upon the printing of the closing price on the primary listing market for each exchange and not prior to that time. There are two cutoff times for submitting orders to the On-Close Match book in order to facilitate the market close. Orders received before 3:55 p.m. ET that have not matched are canceled back to Subscribers at 3:55 p.m. ET. Orders received after 3:55 p.m. ET will rest on the order books for matching and potential execution until 3:59:59 p.m. ET, at which time, any unmatched orders are canceled back to Subscribers at 3:59:59 p.m. ET. These cutoff times are 12:55 p.m. ET and 12:59:59 p.m. ET respectively on designated early market closings. Please see Part III, Item 17(a) for additional detail.

display_best_quotes

No orders are displayed to other Subscribers or any other person (other than Select ATS Employees of the Broker-Dealer Operator as described in Part II, Item 6(a)) in the On-Close Match book. DAY orders submitted to the Limit Order book with a quantity of 500 shares or more are eligible to be broadcast to other Subscribers via a Limit Order Broadcast. A Subscriber must opt into having its eligible orders generate a Limit Order Broadcast and must also opt into receiving Limit Order Broadcasts generated from other Subscribers orders by contacting Piper. Orders submitted in response to a Limit Order Broadcast must come through the Cash Trading Desk, meaning that a Subscriber must use the services of the Cash Trading Desk to be able to submit orders in response to Limit Order Broadcasts. All Subscribers can gain access to the services of the Cash Trading Desk by contacting Piper. The symbol, side (buy/sell), size, and limit price of eligible orders (or pegged price as described in Part III, Item 7(a)) are disseminated through a Limit Order Broadcast to Subscribers that have elected to receive Limit Order Broadcasts via their respective execution management systems and/or Bloomberg terminals. Orders submitted by Subscribers in response to Limit Order Broadcasts (Limit Order Broadcast Responses) are never disseminated as a Limit Order Broadcast (e.g., in the case of excess order interest in an Limit Order Broadcast Response, such excess interest will not result in a new Limit Order Broadcast). Piper employees on the Cash Trading Desk that are responsible for a Subscribers account are not able to see Limit Order Broadcast Responses submitted by a Subscriber, but are able to see executions that may result from an Limit Order Broadcast Response and excess order interest subsequent to an execution if the response order is larger than the initiating order. Please see the response to Part II, Item 6(a) and 6(b) for a discussion of the access to ATS order information of employees of the Broker-Dealer Operator and certain service providers.

execution_services

XE is open during all U.S. market trading days. Hours of operation begin at 7:00 a.m. ET and end at the close of the U.S. markets at 4:00 p.m. ET during regular trading days and at 1:00 p.m. ET on scheduled early market closings. While orders will be accepted from 7:00 a.m. ET to 4:00 p.m. ET, the ATS will not match or execute before the stock the market open at 9:30 a.m. ET. The ATS operates two books: the On-Close Match book and the Limit Order book. Executions in the On-Close Match book are executed and reported immediately following the closing print of the primary exchange on which the security is traded using the MPID PJCX. In the event that the primary exchange is closed due to unforeseen events, the ATS will prevent matching and trading in the symbols effected in both the On-Close Match and Limit Order books. For halted stocks, orders in the Limit Order book are immediately canceled back to Subscribers. All orders submitted to the Limit Order book during a trading halt are rejected. Orders resting in the On-Close Match book prior to a halt will remain resting in XE throughout the halt, and will be eligible for matching in the event the halt is lifted. If, however, the trading halt is not lifted and is still in effect five minutes before the close (i.e., at 3:55 PM ET for most trading days), any unmatched orders in the On-Close Match book will be canceled back to Subscribers at that time, consistent with the cut-off times described in Part III, Item 4(a). Orders in the On-Close Match book that have matched prior to a trading halt will continue to rest in the book until the halt is lifted or until it is determined that the halt will not be lifted and the stock will not have an official closing print. If there is no closing print, all orders in the On-Close match book, including matched orders, will be canceled back to Subscribers and no executions will occur. Orders submitted to the On-Close match book during a trading halt will be accepted, but no matching will occur until the trading halt is lifted. The ATS will not declare Self Help, within the meaning of Regulation NMS.

execution_services

XE is open during all U.S. market trading days. Hours of operation begin at 7:00 a.m. ET and end at the close of the U.S. markets at 4:00 p.m. ET during regular trading days and at 1:00 p.m. ET on scheduled early market closings. While orders will be accepted from 7:00 a.m. ET to 4:00 p.m. ET, the ATS will not match or execute before the stock market open at 9:30 a.m. ET. Executions in the On-Close Match book are executed and reported immediately following the closing print of the primary exchange on which the security is traded using the MPID PJCX. In the event that the primary exchange is closed due to unforeseen events, the ATS will prevent matching and trading in the symbols effected in the On-Close Match book. Orders resting in the On-Close Match book prior to a halt will remain resting in XE throughout the halt, and will be eligible for matching in the event the halt is lifted. If, however, the trading halt is not lifted and is still in effect five minutes before the close (i.e., at 3:55 PM ET for most trading days), any unmatched orders in the On-Close Match book will be canceled back to Subscribers at that time, consistent with the cut-off times described in Part III, Item 4(a). Orders in the On-Close Match book that have matched prior to a trading halt will continue to rest in the book until the halt is lifted or until it is determined that the halt will not be lifted and the stock will not have an official closing print. If there is no closing print, all orders in the On-Close match book, including matched orders, will be canceled back to Subscribers and no executions will occur. Orders submitted to the On-Close match book during a trading halt will be accepted, but no matching will occur until the trading halt is lifted. The ATS will not declare Self Help, within the meaning of Regulation NMS.