IBKR ATS

amendment_reason

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

amendment_reason

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

amendment_reason

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

amendment_reason

Part III Items 7, 9 and 11 are being amended to change the priority of resting Brokerage Customers' orders from (i) price, (ii) size and (iii) time priority to (x) price; (y) time; and (z) size priority and make related clarifying changes. For clarity, priority of Liquidity Providers' orders is not being changed. There are no other changes in this amendment. The changes herein impact Brokerage Customers. While the changes herein are not applicable to IBKR as ATS operator, IBKR routes non-directed customer orders to the IBKR ATS, and the changes herein impact the manner in which such orders will interact with directed orders of Brokerage Customers within the ATS.

amendment_reason

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

amendment_reason

Part I Item 6 is being amended to identify IBKR's website URL. Additionally, Part IV is being amended to identify a new contact person. There are no other changes in this amendment.

amendment_reason

This Updating Amendment to a Material Amendment filed on Nov. 30, 2023 (Acc-no: 0000902664-23-005747), includes (i) amendments to Part II Items 1 and 6 and Part III Items 2, 3, 5, 7, 9, 11, 13 and 15 to introduce Execution Customers (a subset of Brokerage Customers) as a category of subscriber and (ii) amendments to Part II Items 6 and 7 and Part III Items 3, 5, 7, 9, 11, 13, 14 and 15 to introduce Conditional Orders and Firm-Up Orders. Only Execution Customers may submit Conditional Orders and Firm-Up Orders to the ATS. While the above changes are only directly applicable to those subscribers that meet the definition of Execution Customer, the changes impact all subscribers' use of the ATS. Other than the changes in Part II Item 7, the changes are not applicable to IBKR as ATS operator.

amendment_reason

Part III Item 19 is being amended to reflect a change in the rebate paid to brokerage customers of IBKR where their non-directed liquidity-removing orders execute in the ATS against another IBKR brokerage customer's liquidity-adding order. There are no other changes in this amendment. The changes are not applicable to IBKR as ATS operator.

amendment_reason

Part III Item 9 is being amended such that, where an Execution Customer submits a Conditional Order pegged to the midpoint of the NBBO or a Conditional Order with a PegBest instruction, the Firm-Up Period will be 100 milliseconds. The Firm-Up period for all other Conditional Orders will remain 20 milliseconds. This change is directly applicable to Execution Customers and otherwise impacts all subscribers to the ATS. This change is not applicable to IBKR as ATS operator.

amendment_reason

Part III Item 19 is being amended to reflect that Brokerage Customers of IBKR are no longer paid a rebate where their non-directed liquidity-removing orders execute in the ATS against another IBKR Brokerage Customer's liquidity-adding order and to reflect that, as result of this change, IBKR no longer charges Brokerage Customers a venue fee or pays Brokerage Customers a venue rebate for fills in the ATS except in connection with the specific instances noted in Part III Item 19(c). There are no other changes in this amendment. The changes are not applicable to IBKR as ATS operator.

amendment_reason

Part III Item 7 is being amended to permit Brokerage Customers to submit directed midpoint pegged orders. Part III Item 7 is separately being amended to note that directed orders submitted to the ATS by Brokerage Customer that are marketable against resting contraside interest will not be rejected and instead will rest in the ATS. Part III Item 7 is also being amended to (i) permit Liquidity Providers and Brokerage Customers, when entering directed orders, to submit market pegged orders with dollar offset instructions and (ii) to note that the ATS will treat marketable directed orders submitted to the ATS by Brokerage Customers or Liquidity Providers as market pegged orders with a -$0.01 offset. There are no other changes in this amendment. The changes are not applicable to IBKR as ATS operator.

amendment_reason

Part III Item 22 is being amended as IBKR does not enter into QSR arrangements. Accordingly, for trades with broker-dealer subscribers that do not clear through IBKR, IBKR will submit the trade to NSCC for clearance and settlement through another agreed-to NSCC process. There are no other changes in this amendment. The changes in Part III Item 22 are applicable to broker-dealer subscribers and IBKR as ATS operator.

amendment_reason

Part III Items 9 and 15 are being amended such that Invites sent to Execution Customers asking them to "firm-up" their Conditional Orders will identify the size of the contraside interest that generated the Invite, capped at the size of the Execution Customer's Conditional Order. There are no other changes in this amendment. The changes herein are applicable to all Brokerage Customers, including, for clarity, Execution Customers. The changes herein are not applicable to IBKR as ATS operator.

amendment_reason

Part II Item 6 and Part III Items 2, 3, 5, 7, 9, 11, 13 and 15 are being amended to introduce Execution Customers (a subset of Brokerage Customers) as a category of subscriber. Part II Item 6 and Part III Items 3, 5, 7, 9, 11, 14 and 15 are being amended to introduce Conditional Orders and Firm-Up Orders. Only Execution Customers may submit Conditional Orders and Firm-Up Orders to the ATS. While the above changes are only directly applicable to those subscribers that meet the definition of Execution Customer, the changes impact all subscribers' use of the ATS. The changes are not applicable to IBKR as ATS operator.

amendment_reason

Previously, all orders submitted to the ATS via IBKR's SOR utilized the "IBKR" MPID. Part II Item 1 (Part II-1) is being amended to allow certain Brokerage Customers to submit directed orders to the ATS, via the SOR, under their own MPIDs. The only impact of this change is to the audit trails for such orders. Part III-5 is being amended to note that Liquidity Providers (LPs) can connect via cross connects within Equinix CH4. This change only applies to LPs. Part II-1 & 2 and Part III-5 & 13 are being amended to note that LPs do not have access to additional order instructions relative to other subscribers. Part II-6 is being amended to remove a reference to OATS. Part II-2 is being amended to reflect Timber Hill's current name. Exhibit 2 is amended to reflect T. Peterffy's existing interest in IBG Holdings. There are no other changes in this amendment. Except as noted above, the changes do not impact subscribers' use of the ATS or IBKR as ATS operator.

amendment_reason

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

amendment_reason

Part III Items 7 and 11 are being amended to introduce Midpoint Offset functionality. Midpoint Offset functionality is only available to Liquidity Providers and to Brokerage Customers when submitting directed orders. There are no other changes in this amendment. The changes are not applicable to IBKR as ATS operator.

amendment_reason

Part III Items 7 and 11 are being amended to introduce the "PegBest" order type, which is only available to Brokerage Customers. Generally, PegBest orders are pegged to the better of (i) the NBB (for buys) or the NBO (for sells) and (ii) the best-priced same-side order resting in the ATS, and include a +$0.01 offset. PegBest orders may include instructions to "compete" with contending PegBest orders. Part III Item 7 is also being amended to note that midpoint-pegged orders must include an ultimate limit price. Part III Item 7 is also being amended to remove minimum quantity instruction functionality. Such functionality was only available for use by Liquidity Providers. Part III Items 9 and 11 are separately being amended to provide that the IBKR SOR will preference IOIs generated by Brokerage Customers' orders relative to IOIs generated by Liquidity Providers. There are no other changes in this amendment. The changes are not applicable to IBKR as ATS operator.

amendment_reason

This Updating Amendment to a Material Amendment filed on March 24, 2022, includes amendments to Part III Items 7, 9 and 11 that change the priority of resting Brokerage Customers' orders from (i) price, (ii) size and (iii) time priority to (x) price; (y) time; and (z) size priority and make related clarifying changes. For clarity, priority of Liquidity Providers' orders is not being changed. There are no other changes in this amendment. The changes herein impact Brokerage Customers. While the changes herein are not applicable to IBKR as ATS operator, IBKR routes non-directed customer orders to the IBKR ATS, and the changes herein impact the manner in which such orders will interact with directed orders of Brokerage Customers within the ATS.

amendment_reason

Part III Item 7 is being amended to note that midpoint-pegged orders must include an ultimate limit price. There are no other changes in this amendment. The changes are not applicable to IBKR as ATS operator.

amendment_reason

Part II Item 2 is being amended to remove Interactive Brokers Central Europe from the list of IBKR affiliates who are permitted to enter or direct the entry of orders into the ATS. There are no other changes in this amendment. This change applies to IBKR as ATS operator and to all subscribers.

amendment_reason

Part III Item 7 is being amended to reflect that directed orders submitted to the ATS by Brokerage Customers may include a minimum quantity instruction. Part III Items 7 and 11 are also being amended to reflect that the ATS will no longer offer percentage offset instructions. Such functionality was only available to Liquidity Providers. Part III Items 9, 11 and 15 are also being amended to provide that the ATS may disseminate to the IBKR SOR information regarding the smallest minimum quantity instruction (which may be zero) among resting Brokerage Customer orders priced at or inside the NBBO. There are no other changes in this amendment. The changes relating to the ATS' dissemination of information to the IBKR SOR concerning customer minimum quantity instructions are applicable to IBKR as ATS operator; all other changes are not applicable to IBKR as ATS operator.

amendment_reason

Part III Items 7 and 11 are being amended to allow subscribers to express Competing Tick Offset instructions on PegBest orders as an offset from the midpoint of the prevailing NBBO, specified in the form of Midpoint Offsets, and to describe such order instructions' manner of operation. Only Brokerage Customers, as defined herein, may utilize PegBest orders (including PegBest orders using Competing Tick Offset instructions expressed in terms of a Midpoint Offset). Except for directed orders submitted to the ATS by Brokerage Customers, as a matter of policy IBKR does not utilize PegBest orders.

amendment_reason

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

amendment_reason

Part III Item 19 is amended to describe certain fees that are charged to subscribers to offset CAT fees assessed to IBKR as CAT Executing Broker. This change applies to IBKR as ATS operator and to all classes of subscribers.

amendment_reason

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

amendment_reason

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

amendment_reason

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

amendment_reason

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

amendment_reason

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

amendment_reason

Part II Item 2 is being amended to identify additional IBKR affiliates who are permitted to enter or direct the entry of orders into the ATS. There are no other changes in this amendment. The changes herein apply to IBKR as ATS operator and all subscribers.

amendment_reason

Part III Item 11 is being amended to further describe the random weighted selection process used in determining priority among Conditional Orders on price parity. There are no other changes in this amendment. The changes herein are applicable to all Brokerage Customers, including, for clarity, Execution Customers. The changes herein are not applicable to IBKR as ATS operator.

amendment_reason

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

amendment_reason

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

amendment_reason

Part II Item 1 and Part III Item 2 are being amended to clarify that the term "Brokerage Customer" includes any customer or broker-dealer client of IBKR accessing the ATS via IBKR's smart order router ("SOR"), including broker-dealers and other entities that submit directed orders to the ATS through IBKR's SOR and make no other use of IBKR's services. The term also includes firms that may separately act as "Liquidity Providers" when such firms access the ATS via the IBKR SOR rather than via direct FIX connection. The changes in Part II Item 1 and Part III Item 2 clarify subscriber categorizations and do not reflect a substantive change in the ATS' manner of operation or related procedures.

amendment_reason

Part II Item 5 is being amended to identify the IBKR Desktop, a new IBKR OMS available to Brokerage Customers through which Brokerage Customers may access the IBKR ATS. This change is applicable to all Brokerage Customers. This change is not directly applicable to Liquidity Providers. While the IBKR Desktop represents a Trading Product offered by IBKR, this change is not otherwise applicable to IBKR as ATS operator.

ats_name

INTERACTIVE BROKERS LLC

ats_name

IBKR ATS

operator_crd

000036418

operator_name

INTERACTIVE BROKERS LLC

order_types

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

order_types

Order Types The ATS accepts limit and pegged orders. The ATS does not accept market orders. Pegged orders may include the following reference prices: (i) primary (i.e., NBB for buy orders, NBO for sell orders); (ii) market (i.e., NBO for buy orders, NBB for sell orders); and (iii) midpoint of the NBBO. Pegged orders may include an ultimate limit price. Primary pegged orders may include a percentage offset instruction equal to either 0% or 50% of the NBBO spread and primary pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged primary plus $0.01). At no time will a peg instruction violate an order's ultimate limit price. Pegged orders are ranked based on their pegged price and not on any ultimate limit price associated with the order. Only Liquidity Providers may utilize the following order instructions: (i) midpoint pegging instructions; (ii) market pegging instructions; (iii) percentage offsets (i.e., 0% or 50% of the NBBO spread); and (iv) minimum quantity instructions (for the sake of clarity, both Liquidity Providers and Brokerage Customers may utilize pegged-primary order instructions). Orders submitted by Liquidity Providers may include a minimum quantity instruction. A minimum quantity instruction specifies the minimum execution size a subscriber will accept and does not allow for the aggregation of contra-side orders (i.e., the minimum quantity instruction must be satisfied by a single contra-side order). Subscribers who are not Liquidity Providers may not include minimum quantity instructions with their orders. Directed orders submitted to the ATS by a Brokerage Customer or Liquidity Provider will never remove liquidity from the ATS. Where at the time of order receipt by the ATS a directed-order submitted by a Brokerage Customer would interact with another directed-order submitted by a Brokerage Customer, the ATS will reject the order. For clarity, the ATS will not reject a directed order submitted by a Liquidity Provider due to the existence of resting contra-side interest in the ATS with an overlapping limit price. Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day", (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Non-directed orders routed to the ATS by the IBKR SOR (i.e., where the subscriber has not directed the order to the ATS) are submitted as either IOC orders or as GTT orders with a 1-second GTT instruction. Directed orders submitted to the ATS, whether by a Liquidity Provider or other subscriber, may include a TIF instruction of day, IOC or GTT. Orders submitted with TIF instructions of longer than day (e.g., GTD or GTT with an expiration time of post after trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading day. Priority Orders resting in the ATS are ranked based on the following factors in the following order: (i) price; (ii) size; and (iii) time. Pegged orders are ranked based on their pegged price and not on any ultimate limit price associated with the order. Where an order is pegged to the midpoint of the NBBO (including orders pegged to the primary with a 50% percentage offset instruction), the ATS will rank the order and any related IOI at the order's effective limit price (i.e., the pegged price), even where the effective limit price is not in a $0.01 increment (e.g., where the NBBO is $20.00 by $20.05, a buy order pegged to the midpoint of the NBBO will have a ranking price of $20.025 and, accordingly, will have priority over buy orders with limit prices of $20.02). For purposes of establishing time priority the ATS treats pegged orders as received at the time of original order receipt, rather than as received at each subsequent price change. Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber or the SOR, as applicable.

order_types

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

order_types

Order Types The ATS accepts limit and pegged orders. The ATS does not accept market orders. Pegged orders may include the following reference prices: (i) primary (i.e., NBB for buy orders, NBO for sell orders); (ii) market (i.e., NBO for buy orders, NBB for sell orders); and (iii) midpoint of the NBBO. The ATS also accepts "PegBest" orders, which, as further discussed below, are pegged to the Combined NBBO (defined below) with +$0.01 offset. Only PegBest orders may be pegged to the Combined NBBO. Pegged orders may include an ultimate limit price. PegBest orders and orders pegged to the midpoint of the NBBO must include an ultimate limit price. Primary pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged primary plus $0.01). Market pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged market minus $0.01). Orders pegged to the midpoint of the NBBO may include dollar offset instructions ("Midpoint Offsets"), further discussed below. When used herein, a "positive" (+) offset refers to a more aggressive price, while a "negative" (-) offset refers to a less aggressive price. For instance, where the NBBO is $20.00 x $20.05, a primary pegged buy order with a positive (+) $0.01 offset will have an effective limit price of $20.01, while a primary pegged sell order with a positive (+) $0.01 offset will have an effective limit price of $20.04). Pegged orders are ranked based on their effective limit price. At no time will a peg instruction, including any offset instruction, violate an order's ultimate limit price. Midpoint Offset instructions must include two values, one value that will be applied when the NBBO spread is an even value (e.g., where the NBBO is $20.00 x $20.10) (the "Even Spread Offset") and a second value that will be applied when the NBBO spread is an odd value (e.g., where the NBBO is $20.00 x $20.05) (the "Odd Spread Offset"). Even Spread Offsets must be expressed in full penny increments. Odd Spread Offsets must be expressed in a half penny increment, not a whole penny increment (that is, $0.005, $0.015, $0.025, etc.). Midpoint Offset instructions may be expressed as positive or negative offsets. An order's Even and Odd Spread Offset instructions must be sequential (that is, an order with an Even Spread Offset of +$0.01 must include Odd Spread Offset instructions of either +$0.005 or +$0.015; no other Odd Spread Offset instructions will be accepted). Midpoint Offset instructions will not cause an order's effective limit price to be marketable relative to the prevailing NBBO. Where a Midpoint Offset instruction would cause an order to be marketable relative to the prevailing NBBO (e.g., for buy orders, equal to or greater than the NBO), the ATS will treat the order's effective limit price as one penny below the NBO (for buy orders) or one penny above the NBB (for sell orders). The ATS will disregard any positive Midpoint Offset instruction when the NBBO is one penny wide. The above adjustments operate on a dynamic basis. For instance, assume a buy order pegged to the midpoint is submitted with an Even Spread Offset instruction of +$0.01 and an Odd Spread Offset instruction of +$0.015. If, upon order receipt, the prevailing NBBO is $20.00 x $20.10, the order's effective limit price would be $20.06 (that is, $20.05, the midpoint of the NBBO, plus a $0.01 Even Spread Offset). If, prior to the order being executed or cancelled, the NBBO updates to $20.00 x $20.03, the order's effective limit price would then be $20.02. If the NBBO further narrows to $20.00 x $20.01, the order's effective limit price would then be $20.005 (that is, the ATS will disregard the order's Midpoint Offset instruction). If the NBBO subsequently widens to $20.00 x $20.05, the order's effective limit price would then be $20.04 (that is, $20.025 plus the $0.015 Odd Spread Offset). As noted above, "PegBest orders" are orders that are pegged to the Combined NBBO with a +$0.01 offset. The "Combined NBBO" is the more aggressive (higher for buys, lower for sells) of (i) the prevailing NBB (for buy orders) or NBO (for sell orders) and (ii) the highest price (for buy orders) or lowest price (for sell orders) at which aggregate same-side interest, including better-price interest, equals or exceeds the PegBest order's Minimum Compete Size instruction (as defined below). For instance, where the prevailing NBBO is $20.00 x $20.09, and there is a resting non-PegBest buy order for 100-shares in the ATS with a limit price of $20.01, a buy PegBest order with a Minimum Compete Size instruction of 100-shares will have an effective limit price of $20.02 (Combined NBBO of $20.01 + $0.01 offset). Where the prevailing NBBO is $20.00 x $20.09, and the competing non-PegBest buy orders resting in the ATS are (i) an order for 50-shares with a limit price of $20.03, (ii) an order for 75-shares with a limit price of $20.02 and (iii) an order for 100-shares with a limit price of $20.01, a buy PegBest order with a Minimum Compete Size instruction of 100-shares will have an effective limit price of $20.03 (that is, the Combined NBBO would equal $20.02 as $20.02 is the highest price at which aggregate same-side interest, including better-price interest, equals or exceeds the PegBest order's Minimum Compete Size instruction, and the PegBest order's effective limit price would therefore equal $20.02 + $0.01 offset). The effective price of a PegBest order will never exceed the midpoint of the prevailing NBBO. For instance, where the prevailing NBBO is $20.00 x $20.09, and there is a resting 100-share non-PegBest buy order in the ATS with a limit price of $20.06, a buy PegBest order with a Minimum Compete Size instruction of 100 shares would be treated as pegged to the midpoint of the NBBO (effective limit price of $20.045). PegBest orders must include a "Minimum Compete Size" instruction, expressed as a share quantity. The ATS appends a default Minimum Compete Size of 100 shares, although subscribers may select Minimum Compete Sizes that are smaller or larger than the default quantity (including a Minimum Compete Size of zero (0) shares). Minimum Compete Size instructions, which are used in determining the Combined NBBO for any given order, designate the minimum competing order size required before the PegBest order will attempt to better the price. As noted above, in determining whether an order's Minimum Compete Size instruction has been met the ATS will effectively walk down the order book (including, for clarity, both resting Brokerage Customer orders and resting Liquidity Provider orders), aggregating competing interest at each price level. Accordingly, where a PegBest buy order has a Minimum Compete Size instruction of 200-shares, the NBBO is $20.00 x $20.09 and the best-priced non-PegBest competing orders resting in the ATS are (i) a 100-share order with a limit price of $20.05, (ii) a 75-share order with a limit price of $20.04, (iii) a 100-share order with a limit price of $20.02 and (iv) a 100-share order with a limit price of $20.00, the PegBest order's Minimum Compete Size instruction would be satisfied at $20.02 (its Combined NBBO) and its effective limit price would be $20.03 (Combined NBBO + $0.01). PegBest orders must also include a "Competing Tick Offset" instruction. By default, PegBest orders include a Competing Tick Offset instruction of +$0.02. Competing Tick Offset instructions are activated where there are competing PegBest orders in the ATS, and designate the amount by which a PegBest order's effective limit may exceed its Combined NBBO. A PegBest order will compete against another PegBest order even where the competing PegBest order doesn't satisfy its Minimum Compete Size instruction. Except as noted below, Competing Tick Offset instructions will not allow a PegBest order's effective limit price to exceed the midpoint of the prevailing NBBO. Subscribers may designate their orders as free to "compete" to the midpoint of the NBBO, regardless of the amount by which the midpoint of the prevailing NBBO exceeds the Combined NBBO (e.g., providing for "unconstrained" Competing Tick Offset instructions). Alternatively, subscribers may express Competing Tick Offset instructions as an offset from the midpoint of the prevailing NBBO, specified in the form of Midpoint Offsets as discussed above. Subscribers may otherwise express Competing Tick Offset instructions in penny increments, whereby the instruction identifies the amount by which the order's effective limit price may exceed its Combined NBBO when competing with another PegBest order. Competing Tick Offset instructions must be for +$0.01 or higher when expressed as an offset from the Combined NBBO. Competing Tick Offset instructions expressed as an offset from the midpoint of the prevailing NBBO may be expressed as negative or positive (or zero) Midpoint Offsets. For clarity, subscribers may not include both Midpoint Offset restrictions and Competing Tick Offset instructions expressed in penny increments on the same order. Notwithstanding any order's Competing Tick Offset instruction, the effective limit price of a PegBest order will never exceed the order's ultimate limit price. For PegBest orders with Competing Tick Offset instructions expressed in penny increments, the order's effective limit price will never exceed the midpoint of the prevailing NBBO. For PegBest orders with Competing Tick Offset instructions expressed as a Midpoint Offset, the order's effective limit price may exceed the midpoint of the prevailing NBBO (in the event of a positive Midpoint Offset), subject to the terms of such Midpoint Offset instruction and any ultimate limit price associated with the order. Assume that the prevailing NBBO is $20.00 x $20.15, and the Combined NBBO for each of PegBest Orders A and B (defined below) is $20.01. Further assume a PegBest buy order ("PegBest Order A") has been submitted to the ATS with a Competing Tick Offset of $0.02 and there are no competing PegBest buy orders in the ATS. PegBest Order A will have an effective limit price of $20.02 (one tick above its Combined NBBO) and its Competing Tick Offset will not be activated. Assume a competing PegBest buy order is subsequently submitted ("PegBest Order B"), with a Competing Tick Offset instruction of $0.04. PegBest Order A's effective limit price would increase to $20.03 (Combined NBBO + $0.02), while PegBest Order B's effective limit price would be $20.04 (Combined NBBO + $0.03). For clarity, PegBest Order B's effective limit price would not be $20.05 (Combined NBBO + $0.04) as Competing Tick Offset instructions are only activated to the extent necessary to contend with a competing PegBest order. Assume instead that the prevailing NBBO is $20.00 x $20.15, and the Combined NBBO for PegBest Order A is $20.01 and the Combined NBBO for PegBest Order B is $20.04. Assume that PegBest Order A again has a Competing Tick Offset of $0.02 and that PegBest Order B again has a Competing Tick Offset instruction of $0.04. PegBest Order A's effective limit price would still be $20.03 (its Combined NBBO + $0.02), while PegBest Order B's effective limit price would be $20.05 (its Combined NBBO of $20.04 plus a + $0.01 offset; its Competing Tick Offset would effectively not be triggered). Assume again that the prevailing NBBO is $20.00 x $20.15, the Combined NBBO for PegBest Order A is $20.01 and the Combined NBBO for PegBest Order B is $20.04. Assume that PegBest Order A now has a Competing Tick Offset expressed as Midpoint Offsets of $-.0005 (Odd Spread Offset) and $-.01 (Even Spread Offset), while PegBest Order B again has a Competing Tick Offset instruction of $0.04. Here, PegBest Order A's effective limit price would be $20.07 (midpoint of the NBBO ($20.075) minus $.0005 (Odd Spread Offset)), while PegBest Order B's effective limit price would be $20.075 (that is, PegBest Order B would be treated as pegged to the midpoint of the NBBO as its Combined NBBO of $20.04 plus a + $0.04 offset would exceed the midpoint of the NBBO). Directed orders submitted to the ATS by Brokerage Customers may include minimum quantity instructions. A minimum quantity instruction specifies the minimum execution size a subscriber will accept and does not allow for the aggregation of contra-side orders (i.e., the minimum quantity instruction must be satisfied by a single contra-side order). When an order that includes a minimum quantity instruction receives an execution it will continues to rest in the ATS until its leaves quantity falls below its minimum quantity instruction, at which points the ATS will cancel back the order. Liquidity Providers may not include minimum quantity instructions with their orders. Only Brokerage Customers (including Liquidity Providers in their capacities as Brokerage Customers) may (i) submit PegBest orders and (ii) utilize minimum quantity instructions. All other order instructions are available to both Liquidity Providers and Brokerage Customers. However, except for directed orders submitted to the ATS by Brokerage Customers, as a matter of policy IBKR does not rest non-marketable orders in the ATS, utilize peg instructions or utilize minimum quantity instructions. Directed orders submitted to the ATS by a Brokerage Customer or Liquidity Provider will never remove liquidity from the ATS. Where, upon receipt, a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider is marketable against trading interest on the ATS, the ATS will accept the order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Where a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider would be marketable relative to the NBBO (including, for clarity, any market pegged order and, where applicable, midpoint and primary pegged orders with positive dollar offset instructions), the ATS will treat the order as a market pegged order with a -$0.01 offset (that is, an effective limit price of $0.01 below the NBO for buy orders or $0.01 above the NBB for sell orders). Notwithstanding the foregoing, where an order contains Midpoint Offset instructions and the NBBO is one penny wide, the ATS will disregard the Midpoint Offset instructions and treat the order as pegged to the midpoint of the NBBO (with no offset). Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day", (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Non-directed orders routed to the ATS by the IBKR SOR (i.e., where the subscriber has not directed the order to the ATS) are submitted as either IOC orders or as GTT orders with a 1-second GTT instruction. Directed orders submitted to the ATS, whether by a Liquidity Provider or other subscriber, may include a TIF instruction of day, IOC or GTT. Orders submitted with TIF instructions of longer than day (e.g., GTD or GTT with an expiration time of post after trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading day. Priority The ATS ranks resting Liquidity Provider orders based on the following factors in the following order: (i) price; (ii) size; and (iii) time. The ATS ranks resting Brokerage Customer orders based on the following factors in the following order: (x) price; (y) time; and (z) size. Where a resting Brokerage Customer order is on price parity with a resting Liquidity Provider order, the SOR will always attempt to interact with the Brokerage Customer order (please see Part III Items 9 and 11 for a further discussion of the IBKR SOR's manner of routing non-directed Brokerage Customer orders to the ATS). Pegged orders are ranked based on their effective limit price and not on any ultimate limit price associated with the order. Where an order is pegged to the midpoint of the NBBO, the ATS will rank the order and any related IOI at the order's effective limit price (i.e., the pegged price), even where the effective limit price is not in a $0.01 increment (e.g., where the NBBO is $20.00 by $20.05, a buy order pegged to the midpoint of the NBBO will have a ranking price of $20.025 and, accordingly, will have priority over buy orders with limit prices of $20.02). For clarity, orders pegged to the midpoint of the NBBO that include Midpoint Offset instructions are ranked at their effective limit prices (which, except where the order's Midpoint Offset instructions are disregarded, are always priced in full-penny increments). For purposes of establishing time priority the ATS treats pegged orders, other than PegBest orders, as received at the time of original order receipt, rather than as received at each subsequent price change. For purposes of establishing time priority, the ATS treats PegBest orders as being resubmitted at the time of any increase in the PegBest order's offset relative to the Combined NBBO (e.g., where a PegBest order's offset increases from +$0.01 to +$0.02 due to the introduction of a competing PegBest order). Reductions in a PegBest order's offset (e.g., where a PegBest order's offset to the Combined NBBO is reduced from +$0.02 to +$0.01) do not impact time of receipt for priority purposes. For clarity, changes in the Combined NBBO or midpoint of the NBBO, without more, do not impact a PegBest order's time of receipt for time priority purposes. Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber or the SOR, as applicable.

order_types

Order Types The ATS accepts firm orders (including "Firm-Up Orders," as defined below) and Conditional Orders (as defined below) (collectively, "Trading Interest"). Except as noted under the time-in-force heading, all order types and instructions discussed below (e.g., pricing conditions, permitted reference prices etc.) are available to Conditional Orders and firm orders (including Firm-Up Orders). The ATS accepts limit and pegged orders. The ATS does not accept market orders. Pegged orders may include the following reference prices: (i) primary (i.e., NBB for buy orders, NBO for sell orders); (ii) market (i.e., NBO for buy orders, NBB for sell orders); and (iii) midpoint of the NBBO. The ATS also accepts "PegBest" orders, which, as further discussed below, are pegged to the Combined NBBO (defined below) with +$0.01 offset. Only PegBest orders may be pegged to the Combined NBBO. Pegged orders may include an ultimate limit price. PegBest orders and orders pegged to the midpoint of the NBBO must include an ultimate limit price. Primary pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged primary plus $0.01). Market pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged market minus $0.01). Orders pegged to the midpoint of the NBBO may include dollar offset instructions ("Midpoint Offsets"), further discussed below. When used herein, a "positive" (+) offset refers to a more aggressive price, while a "negative" (-) offset refers to a less aggressive price. For instance, where the NBBO is $20.00 x $20.05, a primary pegged buy order with a positive (+) $0.01 offset will have an effective limit price of $20.01, while a primary pegged sell order with a positive (+) $0.01 offset will have an effective limit price of $20.04). Pegged orders are ranked based on their effective limit price. At no time will a peg instruction, including any offset instruction, violate an order's ultimate limit price. Midpoint Offset instructions must include two values, one value that will be applied when the NBBO spread is an even value (e.g., where the NBBO is $20.00 x $20.10) (the "Even Spread Offset") and a second value that will be applied when the NBBO spread is an odd value (e.g., where the NBBO is $20.00 x $20.05) (the "Odd Spread Offset"). Even Spread Offsets must be expressed in full penny increments. Odd Spread Offsets must be expressed in a half penny increment, not a whole penny increment (that is, $0.005, $0.015, $0.025, etc.). Midpoint Offset instructions may be expressed as positive or negative offsets. An order's Even and Odd Spread Offset instructions must be sequential (that is, an order with an Even Spread Offset of +$0.01 must include Odd Spread Offset instructions of either +$0.005 or +$0.015; no other Odd Spread Offset instructions will be accepted). Midpoint Offset instructions will not cause an order's effective limit price to be marketable relative to the prevailing NBBO. Where a Midpoint Offset instruction would cause an order to be marketable relative to the prevailing NBBO (e.g., for buy orders, equal to or greater than the NBO), the ATS will treat the order's effective limit price as one penny below the NBO (for buy orders) or one penny above the NBB (for sell orders). The ATS will disregard any positive Midpoint Offset instruction when the NBBO is one penny wide. The above adjustments operate on a dynamic basis. For instance, assume a buy order pegged to the midpoint is submitted with an Even Spread Offset instruction of +$0.01 and an Odd Spread Offset instruction of +$0.015. If, upon order receipt, the prevailing NBBO is $20.00 x $20.10, the order's effective limit price would be $20.06 (that is, $20.05, the midpoint of the NBBO, plus a $0.01 Even Spread Offset). If, prior to the order being executed or cancelled, the NBBO updates to $20.00 x $20.03, the order's effective limit price would then be $20.02. If the NBBO further narrows to $20.00 x $20.01, the order's effective limit price would then be $20.005 (that is, the ATS will disregard the order's Midpoint Offset instruction). If the NBBO subsequently widens to $20.00 x $20.05, the order's effective limit price would then be $20.04 (that is, $20.025 plus the $0.015 Odd Spread Offset). As noted above, "PegBest orders" are orders that are pegged to the Combined NBBO with a +$0.01 offset. The "Combined NBBO" is the more aggressive (higher for buys, lower for sells) of (i) the prevailing NBB (for buy orders) or NBO (for sell orders) and (ii) the highest price (for buy orders) or lowest price (for sell orders) at which aggregate same-side interest, including better-price interest, equals or exceeds the PegBest order's Minimum Compete Size instruction (as defined below). For instance, where the prevailing NBBO is $20.00 x $20.09, and there is a resting non-PegBest buy order for 100-shares in the ATS with a limit price of $20.01, a buy PegBest order with a Minimum Compete Size instruction of 100-shares will have an effective limit price of $20.02 (Combined NBBO of $20.01 + $0.01 offset). Where the prevailing NBBO is $20.00 x $20.09, and the competing non-PegBest buy orders resting in the ATS are (i) an order for 50-shares with a limit price of $20.03, (ii) an order for 75-shares with a limit price of $20.02 and (iii) an order for 100-shares with a limit price of $20.01, a buy PegBest order with a Minimum Compete Size instruction of 100-shares will have an effective limit price of $20.03 (that is, the Combined NBBO would equal $20.02 as $20.02 is the highest price at which aggregate same-side interest, including better-price interest, equals or exceeds the PegBest order's Minimum Compete Size instruction, and the PegBest order's effective limit price would therefore equal $20.02 + $0.01 offset). The effective price of a PegBest order will never exceed the midpoint of the prevailing NBBO. For instance, where the prevailing NBBO is $20.00 x $20.09, and there is a resting 100-share non-PegBest buy order in the ATS with a limit price of $20.06, a buy PegBest order with a Minimum Compete Size instruction of 100 shares would be treated as pegged to the midpoint of the NBBO (effective limit price of $20.045). PegBest orders must include a "Minimum Compete Size" instruction, expressed as a share quantity. The ATS appends a default Minimum Compete Size of 100 shares, although subscribers may select Minimum Compete Sizes that are smaller or larger than the default quantity (including a Minimum Compete Size of zero (0) shares). Minimum Compete Size instructions, which are used in determining the Combined NBBO for any given order, designate the minimum competing order size required before the PegBest order will attempt to better the price. As noted above, in determining whether an order's Minimum Compete Size instruction has been met the ATS will effectively walk down the order book (including, for clarity, both resting Brokerage Customer orders and resting Liquidity Provider orders), aggregating competing interest at each price level. Accordingly, where a PegBest buy order has a Minimum Compete Size instruction of 200-shares, the NBBO is $20.00 x $20.09 and the best-priced non-PegBest competing orders resting in the ATS are (i) a 100-share order with a limit price of $20.05, (ii) a 75-share order with a limit price of $20.04, (iii) a 100-share order with a limit price of $20.02 and (iv) a 100-share order with a limit price of $20.00, the PegBest order's Minimum Compete Size instruction would be satisfied at $20.02 (its Combined NBBO) and its effective limit price would be $20.03 (Combined NBBO + $0.01). PegBest orders must also include a "Competing Tick Offset" instruction. By default, PegBest orders include a Competing Tick Offset instruction of +$0.02. Competing Tick Offset instructions are activated where there are competing PegBest orders in the ATS, and designate the amount by which a PegBest order's effective limit may exceed its Combined NBBO. A PegBest order will compete against another PegBest order even where the competing PegBest order doesn't satisfy its Minimum Compete Size instruction. Except as noted below, Competing Tick Offset instructions will not allow a PegBest order's effective limit price to exceed the midpoint of the prevailing NBBO. Subscribers may designate their orders as free to "compete" to the midpoint of the NBBO, regardless of the amount by which the midpoint of the prevailing NBBO exceeds the Combined NBBO (e.g., providing for "unconstrained" Competing Tick Offset instructions). Alternatively, subscribers may express Competing Tick Offset instructions as an offset from the midpoint of the prevailing NBBO, specified in the form of Midpoint Offsets as discussed above. Subscribers may otherwise express Competing Tick Offset instructions in penny increments, whereby the instruction identifies the amount by which the order's effective limit price may exceed its Combined NBBO when competing with another PegBest order. Competing Tick Offset instructions must be for +$0.01 or higher when expressed as an offset from the Combined NBBO. Competing Tick Offset instructions expressed as an offset from the midpoint of the prevailing NBBO may be expressed as negative or positive (or zero) Midpoint Offsets. For clarity, subscribers may not include both Midpoint Offset restrictions and Competing Tick Offset instructions expressed in penny increments on the same order. Notwithstanding any order's Competing Tick Offset instruction, the effective limit price of a PegBest order will never exceed the order's ultimate limit price. For PegBest orders with Competing Tick Offset instructions expressed in penny increments, the order's effective limit price will never exceed the midpoint of the prevailing NBBO. For PegBest orders with Competing Tick Offset instructions expressed as a Midpoint Offset, the order's effective limit price may exceed the midpoint of the prevailing NBBO (in the event of a positive Midpoint Offset), subject to the terms of such Midpoint Offset instruction and any ultimate limit price associated with the order. Assume that the prevailing NBBO is $20.00 x $20.15, and the Combined NBBO for each of PegBest Orders A and B (defined below) is $20.01. Further assume a PegBest buy order ("PegBest Order A") has been submitted to the ATS with a Competing Tick Offset of $0.02 and there are no competing PegBest buy orders in the ATS. PegBest Order A will have an effective limit price of $20.02 (one tick above its Combined NBBO) and its Competing Tick Offset will not be activated. Assume a competing PegBest buy order is subsequently submitted ("PegBest Order B"), with a Competing Tick Offset instruction of $0.04. PegBest Order A's effective limit price would increase to $20.03 (Combined NBBO + $0.02), while PegBest Order B's effective limit price would be $20.04 (Combined NBBO + $0.03). For clarity, PegBest Order B's effective limit price would not be $20.05 (Combined NBBO + $0.04) as Competing Tick Offset instructions are only activated to the extent necessary to contend with a competing PegBest order. Assume instead that the prevailing NBBO is $20.00 x $20.15, and the Combined NBBO for PegBest Order A is $20.01 and the Combined NBBO for PegBest Order B is $20.04. Assume that PegBest Order A again has a Competing Tick Offset of $0.02 and that PegBest Order B again has a Competing Tick Offset instruction of $0.04. PegBest Order A's effective limit price would still be $20.03 (its Combined NBBO + $0.02), while PegBest Order B's effective limit price would be $20.05 (its Combined NBBO of $20.04 plus a + $0.01 offset; its Competing Tick Offset would effectively not be triggered). Assume again that the prevailing NBBO is $20.00 x $20.15, the Combined NBBO for PegBest Order A is $20.01 and the Combined NBBO for PegBest Order B is $20.04. Assume that PegBest Order A now has a Competing Tick Offset expressed as Midpoint Offsets of $-.0005 (Odd Spread Offset) and $-.01 (Even Spread Offset), while PegBest Order B again has a Competing Tick Offset instruction of $0.04. Here, PegBest Order A's effective limit price would be $20.07 (midpoint of the NBBO ($20.075) minus $.0005 (Odd Spread Offset)), while PegBest Order B's effective limit price would be $20.075 (that is, PegBest Order B would be treated as pegged to the midpoint of the NBBO as its Combined NBBO of $20.04 plus a + $0.04 offset would exceed the midpoint of the NBBO). Directed orders submitted to the ATS by Brokerage Customers may include minimum quantity instructions. A minimum quantity instruction specifies the minimum execution size a subscriber will accept and does not allow for the aggregation of contra-side orders (i.e., the minimum quantity instruction must be satisfied by a single contra-side order). When an order that includes a minimum quantity instruction receives an execution it will continues to rest in the ATS until its leaves quantity falls below its minimum quantity instruction, at which points the ATS will cancel back the order. Liquidity Providers may not include minimum quantity instructions with their orders. Only Brokerage Customers (including Execution Customers and, separately, Liquidity Providers in their capacities as Brokerage Customers) may (i) submit PegBest orders and (ii) utilize minimum quantity instructions. Only Execution Customers may submit Conditional Orders and Firm-Up Orders, and only when accessing the SOR via FIX connection. All other order instructions are available to both Liquidity Providers and Brokerage Customers. However, except for directed orders submitted to the ATS by Brokerage Customers, as a matter of policy IBKR does not rest non-marketable orders in the ATS, utilize peg instructions or utilize minimum quantity instructions. Directed orders submitted to the ATS by a Brokerage Customer or Liquidity Provider will never be deeemed to remove liquidity from the ATS. Where, upon receipt, a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider is marketable against directed orders resting on the ATS, the ATS will accept the order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Where, however, a directed order submitted to the ATS by a Brokerage Customer is marketable against a resting non-directed order (i.e., a non-directed order waiting for a subscriber to submit a Firm-Up Order in response to an Invite), the orders, subject to their terms, may interact with one another. In such instances, the non-directed order will be deemed to remove liquidity from the ATS (notwithstanding that it was received by the ATS first). Where a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider would be marketable relative to the NBBO (including, for clarity, any market pegged order and, where applicable, midpoint and primary pegged orders with positive dollar offset instructions), the ATS will treat the order as a market pegged order with a -$0.01 offset (that is, an effective limit price of $0.01 below the NBO for buy orders or $0.01 above the NBB for sell orders). Notwithstanding the foregoing, where an order contains Midpoint Offset instructions and the NBBO is one penny wide, the ATS will disregard the Midpoint Offset instructions and treat the order as pegged to the midpoint of the NBBO (with no offset). Conditional Orders & Firm-Up Orders The ATS accepts Conditional Orders and Firm-Up Orders. Please see Part III Item 9 for additional information. Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day", (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Non-directed orders routed to the ATS by the IBKR SOR (i.e., where the subscriber has not directed the order to the ATS) are submitted as either IOC orders or as GTT orders and, in all instances, with an effective TIF of 1-second or less. Directed orders submitted to the ATS, whether by a Liquidity Provider or other subscriber, may include a TIF instruction of day, IOC or GTT; provided, however, that Conditional Orders must be designated as day or GTT and Firm-Up Orders have a mandatory TIF of IOC, irrespective of the TIF specified in the order. Orders submitted with TIF instructions of longer than day (e.g., GTD or GTT with an expiration time of post after trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading day. Priority See Part III Item 11c for a discussion of priority. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber or the SOR, as applicable.

order_types

Order Types The ATS accepts limit and pegged orders. The ATS does not accept market orders. Pegged orders may include the following reference prices: (i) primary (i.e., NBB for buy orders, NBO for sell orders); (ii) market (i.e., NBO for buy orders, NBB for sell orders); and (iii) midpoint of the NBBO. The ATS also accepts "PegBest" orders, which, as further discussed below, are pegged to the Combined NBBO (defined below) with +$0.01 offset. Only PegBest orders may be pegged to the Combined NBBO. Pegged orders may include an ultimate limit price. PegBest orders and orders pegged to the midpoint of the NBBO must include an ultimate limit price. Primary pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged primary plus $0.01). Market pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged market minus $0.01). Orders pegged to the midpoint of the NBBO may include dollar offset instructions ("Midpoint Offsets"), further discussed below. When used herein, a "positive" (+) offset refers to a more aggressive price, while a "negative" (-) offset refers to a less aggressive price. For instance, where the NBBO is $20.00 x $20.05, a primary pegged buy order with a positive (+) $0.01 offset will have an effective limit price of $20.01, while a primary pegged sell order with a positive (+) $0.01 offset will have an effective limit price of $20.04). Pegged orders are ranked based on their effective limit price. At no time will a peg instruction, including any offset instruction, violate an order's ultimate limit price. Midpoint Offset instructions must include two values, one value that will be applied when the NBBO spread is an even value (e.g., where the NBBO is $20.00 x $20.10) (the "Even Spread Offset") and a second value that will be applied when the NBBO spread is an odd value (e.g., where the NBBO is $20.00 x $20.05) (the "Odd Spread Offset"). Even Spread Offsets must be expressed in full penny increments. Odd Spread Offsets must be expressed in a half penny increment, not a whole penny increment (that is, $0.005, $0.015, $0.025, etc.). Midpoint Offset instructions may be expressed as positive or negative offsets. An order's Even and Odd Spread Offset instructions must be sequential (that is, an order with an Even Spread Offset of +$0.01 must include Odd Spread Offset instructions of either +$0.005 or +$0.015; no other Odd Spread Offset instructions will be accepted). Midpoint Offset instructions will not cause an order's effective limit price to be marketable relative to the prevailing NBBO. Where a Midpoint Offset instruction would cause an order to be marketable relative to the prevailing NBBO (e.g., for buy orders, equal to or greater than the NBO), the ATS will treat the order's effective limit price as one penny below the NBO (for buy orders) or one penny above the NBB (for sell orders). The ATS will disregard any positive Midpoint Offset instruction when the NBBO is one penny wide. The above adjustments operate on a dynamic basis. For instance, assume a buy order pegged to the midpoint is submitted with an Even Spread Offset instruction of +$0.01 and an Odd Spread Offset instruction of +$0.015. If, upon order receipt, the prevailing NBBO is $20.00 x $20.10, the order's effective limit price would be $20.06 (that is, $20.05, the midpoint of the NBBO, plus a $0.01 Even Spread Offset). If, prior to the order being executed or cancelled, the NBBO updates to $20.00 x $20.03, the order's effective limit price would then be $20.02. If the NBBO further narrows to $20.00 x $20.01, the order's effective limit price would then be $20.005 (that is, the ATS will disregard the order's Midpoint Offset instruction). If the NBBO subsequently widens to $20.00 x $20.05, the order's effective limit price would then be $20.04 (that is, $20.025 plus the $0.015 Odd Spread Offset). As noted above, "PegBest orders" are orders that are pegged to the Combined NBBO with a +$0.01 offset. The "Combined NBBO" is the more aggressive (higher for buys, lower for sells) of (i) the prevailing NBB (for buy orders) or NBO (for sell orders) and (ii) the highest price (for buy orders) or lowest price (for sell orders) at which aggregate same-side interest, including better-price interest, equals or exceeds the PegBest order's Minimum Compete Size instruction (as defined below). For instance, where the prevailing NBBO is $20.00 x $20.09, and there is a resting non-PegBest buy order for 100-shares in the ATS with a limit price of $20.01, a buy PegBest order with a Minimum Compete Size instruction of 100-shares will have an effective limit price of $20.02 (Combined NBBO of $20.01 + $0.01 offset). Where the prevailing NBBO is $20.00 x $20.09, and the competing non-PegBest buy orders resting in the ATS are (i) an order for 50-shares with a limit price of $20.03, (ii) an order for 75-shares with a limit price of $20.02 and (iii) an order for 100-shares with a limit price of $20.01, a buy PegBest order with a Minimum Compete Size instruction of 100-shares will have an effective limit price of $20.03 (that is, the Combined NBBO would equal $20.02 as $20.02 is the highest price at which aggregate same-side interest, including better-price interest, equals or exceeds the PegBest order's Minimum Compete Size instruction, and the PegBest order's effective limit price would therefore equal $20.02 + $0.01 offset). The effective price of a PegBest order will never exceed the midpoint of the prevailing NBBO. For instance, where the prevailing NBBO is $20.00 x $20.09, and there is a resting 100-share non-PegBest buy order in the ATS with a limit price of $20.06, a buy PegBest order with a Minimum Compete Size instruction of 100 shares would be treated as pegged to the midpoint of the NBBO (effective limit price of $20.045). PegBest orders must include a "Minimum Compete Size" instruction, expressed as a share quantity. The ATS appends a default Minimum Compete Size of 100 shares, although subscribers may select Minimum Compete Sizes that are smaller or larger than the default quantity (including a Minimum Compete Size of zero (0) shares). Minimum Compete Size instructions, which are used in determining the Combined NBBO for any given order, designate the minimum competing order size required before the PegBest order will attempt to better the price. As noted above, in determining whether an order's Minimum Compete Size instruction has been met the ATS will effectively walk down the order book (including, for clarity, both resting Brokerage Customer orders and resting Liquidity Provider orders), aggregating competing interest at each price level. Accordingly, where a PegBest buy order has a Minimum Compete Size instruction of 200-shares, the NBBO is $20.00 x $20.09 and the best-priced non-PegBest competing orders resting in the ATS are (i) a 100-share order with a limit price of $20.05, (ii) a 75-share order with a limit price of $20.04, (iii) a 100-share order with a limit price of $20.02 and (iv) a 100-share order with a limit price of $20.00, the PegBest order's Minimum Compete Size instruction would be satisfied at $20.02 (its Combined NBBO) and its effective limit price would be $20.03 (Combined NBBO + $0.01). PegBest orders must also include a "Competing Tick Offset" instruction. By default, PegBest orders include a Competing Tick Offset instruction of +$0.02. Competing Tick Offset instructions are activated where there are competing PegBest orders in the ATS, and designate the amount by which a PegBest order's effective limit may exceed its Combined NBBO. A PegBest order will compete against another PegBest order even where the competing PegBest order doesn't satisfy its Minimum Compete Size instruction. Except as noted below, Competing Tick Offset instructions will not allow a PegBest order's effective limit price to exceed the midpoint of the prevailing NBBO. Subscribers may designate their orders as free to "compete" to the midpoint of the NBBO, regardless of the amount by which the midpoint of the prevailing NBBO exceeds the Combined NBBO (e.g., providing for "unconstrained" Competing Tick Offset instructions). Alternatively, subscribers may express Competing Tick Offset instructions as an offset from the midpoint of the prevailing NBBO, specified in the form of Midpoint Offsets as discussed above. Subscribers may otherwise express Competing Tick Offset instructions in penny increments, whereby the instruction identifies the amount by which the order's effective limit price may exceed its Combined NBBO when competing with another PegBest order. Competing Tick Offset instructions must be for +$0.01 or higher when expressed as an offset from the Combined NBBO. Competing Tick Offset instructions expressed as an offset from the midpoint of the prevailing NBBO may be expressed as negative or positive (or zero) Midpoint Offsets. For clarity, subscribers may not include both Midpoint Offset restrictions and Competing Tick Offset instructions expressed in penny increments on the same order. Notwithstanding any order's Competing Tick Offset instruction, the effective limit price of a PegBest order will never exceed the order's ultimate limit price. For PegBest orders with Competing Tick Offset instructions expressed in penny increments, the order's effective limit price will never exceed the midpoint of the prevailing NBBO. For PegBest orders with Competing Tick Offset instructions expressed as a Midpoint Offset, the order's effective limit price may exceed the midpoint of the prevailing NBBO (in the event of a positive Midpoint Offset), subject to the terms of such Midpoint Offset instruction and any ultimate limit price associated with the order. Assume that the prevailing NBBO is $20.00 x $20.15, and the Combined NBBO for each of PegBest Orders A and B (defined below) is $20.01. Further assume a PegBest buy order ("PegBest Order A") has been submitted to the ATS with a Competing Tick Offset of $0.02 and there are no competing PegBest buy orders in the ATS. PegBest Order A will have an effective limit price of $20.02 (one tick above its Combined NBBO) and its Competing Tick Offset will not be activated. Assume a competing PegBest buy order is subsequently submitted ("PegBest Order B"), with a Competing Tick Offset instruction of $0.04. PegBest Order A's effective limit price would increase to $20.03 (Combined NBBO + $0.02), while PegBest Order B's effective limit price would be $20.04 (Combined NBBO + $0.03). For clarity, PegBest Order B's effective limit price would not be $20.05 (Combined NBBO + $0.04) as Competing Tick Offset instructions are only activated to the extent necessary to contend with a competing PegBest order. Assume instead that the prevailing NBBO is $20.00 x $20.15, and the Combined NBBO for PegBest Order A is $20.01 and the Combined NBBO for PegBest Order B is $20.04. Assume that PegBest Order A again has a Competing Tick Offset of $0.02 and that PegBest Order B again has a Competing Tick Offset instruction of $0.04. PegBest Order A's effective limit price would still be $20.03 (its Combined NBBO + $0.02), while PegBest Order B's effective limit price would be $20.05 (its Combined NBBO of $20.04 plus a + $0.01 offset; its Competing Tick Offset would effectively not be triggered). Assume again that the prevailing NBBO is $20.00 x $20.15, the Combined NBBO for PegBest Order A is $20.01 and the Combined NBBO for PegBest Order B is $20.04. Assume that PegBest Order A now has a Competing Tick Offset expressed as Midpoint Offsets of $-.0005 (Odd Spread Offset) and $-.01 (Even Spread Offset), while PegBest Order B again has a Competing Tick Offset instruction of $0.04. Here, PegBest Order A's effective limit price would be $20.07 (midpoint of the NBBO ($20.075) minus $.0005 (Odd Spread Offset)), while PegBest Order B's effective limit price would be $20.075 (that is, PegBest Order B would be treated as pegged to the midpoint of the NBBO as its Combined NBBO of $20.04 plus a + $0.04 offset would exceed the midpoint of the NBBO). Directed orders submitted to the ATS by Brokerage Customers may include minimum quantity instructions. A minimum quantity instruction specifies the minimum execution size a subscriber will accept and does not allow for the aggregation of contra-side orders (i.e., the minimum quantity instruction must be satisfied by a single contra-side order). When an order that includes a minimum quantity instruction receives an execution it will continues to rest in the ATS until its leaves quantity falls below its minimum quantity instruction, at which points the ATS will cancel back the order. Liquidity Providers may not include minimum quantity instructions with their orders. Only Brokerage Customers (including Liquidity Providers in their capacities as Brokerage Customers) may (i) submit PegBest orders and (ii) utilize minimum quantity instructions. All other order instructions are available to both Liquidity Providers and Brokerage Customers. However, except for directed orders submitted to the ATS by Brokerage Customers, as a matter of policy IBKR does not rest non-marketable orders in the ATS, utilize peg instructions or utilize minimum quantity instructions. Directed orders submitted to the ATS by a Brokerage Customer or Liquidity Provider will never remove liquidity from the ATS. Where, upon receipt, a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider is marketable against trading interest on the ATS, the ATS will accept the order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Where a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider would be marketable relative to the NBBO (including, for clarity, any market pegged order and, where applicable, midpoint and primary pegged orders with positive dollar offset instructions), the ATS will treat the order as a market pegged order with a -$0.01 offset (that is, an effective limit price of $0.01 below the NBO for buy orders or $0.01 above the NBB for sell orders). Notwithstanding the foregoing, where an order contains Midpoint Offset instructions and the NBBO is one penny wide, the ATS will disregard the Midpoint Offset instructions and treat the order as pegged to the midpoint of the NBBO (with no offset). Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day", (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Non-directed orders routed to the ATS by the IBKR SOR (i.e., where the subscriber has not directed the order to the ATS) are submitted as either IOC orders or as GTT orders with a 1-second GTT instruction. Directed orders submitted to the ATS, whether by a Liquidity Provider or other subscriber, may include a TIF instruction of day, IOC or GTT. Orders submitted with TIF instructions of longer than day (e.g., GTD or GTT with an expiration time of post after trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading day. Priority Orders resting in the ATS are ranked based on the following factors in the following order: (i) price; (ii) size; and (iii) time. Pegged orders are ranked based on their effective limit price and not on any ultimate limit price associated with the order. Where an order is pegged to the midpoint of the NBBO, the ATS will rank the order and any related IOI at the order's effective limit price (i.e., the pegged price), even where the effective limit price is not in a $0.01 increment (e.g., where the NBBO is $20.00 by $20.05, a buy order pegged to the midpoint of the NBBO will have a ranking price of $20.025 and, accordingly, will have priority over buy orders with limit prices of $20.02). For clarity, orders pegged to the midpoint of the NBBO that include Midpoint Offset instructions are ranked at their effective limit prices (which, except where the order's Midpoint Offset instructions are disregarded, are always priced in full-penny increments). For purposes of establishing time priority the ATS treats pegged orders, other than PegBest orders, as received at the time of original order receipt, rather than as received at each subsequent price change. For purposes of establishing time priority, the ATS treats PegBest orders as being resubmitted at the time of any increase in the PegBest order's offset relative to the Combined NBBO (e.g., where a PegBest order's offset increases from +$0.01 to +$0.02 due to the introduction of a competing PegBest order). Reductions in a PegBest order's offset (e.g., where a PegBest order's offset to the Combined NBBO is reduced from +$0.02 to +$0.01) do not impact time of receipt for priority purposes. For clarity, changes in the Combined NBBO or midpoint of the NBBO, without more, do not impact a PegBest order's time of receipt for time priority purposes. Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber or the SOR, as applicable.

order_types

Order Types The ATS accepts limit and pegged orders. The ATS does not accept market orders. Pegged orders may include the following reference prices: (i) primary (i.e., NBB for buy orders, NBO for sell orders); (ii) market (i.e., NBO for buy orders, NBB for sell orders); and (iii) midpoint of the NBBO. Pegged orders may include an ultimate limit price. Primary pegged orders may include a percentage offset instruction equal to either 0% or 50% of the NBBO spread or dollar offset instructions expressed in penny increments (e.g., pegged primary plus $0.01). Market pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged market minus $0.01). Orders pegged to the midpoint of the NBBO may include dollar offset instructions ("Midpoint Offsets"), further discussed below. When used herein, a "positive" (+) offset refers to a more aggressive price, while a "negative" (-) offset refers to a less aggressive price. For instance, where the NBBO is $20.00 x $20.05, a primary pegged buy order with a positive (+) $0.01 offset will have an effective limit price of $20.01, while a primary pegged sell order with a positive (+) $0.01 offset will have an effective limit price of $20.04). Pegged orders are ranked based on their effective limit price. At no time will a peg instruction, including any offset instruction, violate an order's ultimate limit price. Midpoint Offset instructions must include two values, one value that will be applied when the NBBO spread is an even value (e.g., where the NBBO is $20.00 x $20.10) (the "Even Spread Offset") and a second value that will be applied when the NBBO spread is an odd value (e.g., where the NBBO is $20.00 x $20.05) (the "Odd Spread Offset"). Even Spread Offsets must be expressed in full penny increments. Odd Spread Offsets must be expressed in a half penny increment, not a whole penny increment (that is, $0.005, $0.015, $0.025, etc.). Midpoint Offset instructions may be expressed as positive or negative offsets. An order's Even and Odd Spread Offset instructions must be sequential (that is, an order with an Even Spread Offset of +$0.01 must include Odd Spread Offset instructions of either +$0.005 or +$0.015; no other Odd Spread Offset instructions will be accepted). Midpoint Offset instructions will not cause an order's effective limit price to be marketable relative to the prevailing NBBO. Where a Midpoint Offset instruction would cause an order to be marketable relative to the prevailing NBBO (e.g., for buy orders, equal to or greater than the NBO), the ATS will treat the order's effective limit price as one penny below the NBO (for buy orders) or one penny above the NBB (for sell orders). The ATS will disregard any positive Midpoint Offset instruction when the NBBO is one penny wide. The above adjustments operate on a dynamic basis. For instance, assume a buy order pegged to the midpoint is submitted with an Even Spread Offset instruction of +$0.01 and an Odd Spread Offset instruction of +$0.015. If, upon order receipt, the prevailing NBBO is $20.00 x $20.10, the order's effective limit price would be $20.06 (that is, $20.05, the midpoint of the NBBO, plus a $0.01 Even Spread Offset). If, prior to the order being executed or cancelled, the NBBO updates to $20.00 x $20.03, the order's effective limit price would then be $20.02. If the NBBO further narrows to $20.00 x $20.01, the order's effective limit price would then be $20.005 (that is, the ATS will disregard the order's Midpoint Offset instruction). If the NBBO subsequently widens to $20.00 x $20.05, the order's effective limit price would then be $20.04 (that is, $20.025 plus the $0.015 Odd Spread Offset). Only Liquidity Providers may utilize the following order instructions: (i) percentage offsets (i.e., 0% or 50% of the NBBO spread) and (ii) minimum quantity instructions. All other order instructions are available to both Liquidity Providers and Brokerage Customers. However, except for directed orders submitted to the ATS by Brokerage Customers, as a matter of policy IBKR does not rest non-marketable orders in the ATS and does not utilize peg instructions. Orders submitted by Liquidity Providers may include a minimum quantity instruction. A minimum quantity instruction specifies the minimum execution size a subscriber will accept and does not allow for the aggregation of contra-side orders (i.e., the minimum quantity instruction must be satisfied by a single contra-side order). Subscribers who are not Liquidity Providers may not include minimum quantity instructions with their orders. Directed orders submitted to the ATS by a Brokerage Customer or Liquidity Provider will never remove liquidity from the ATS. Where, upon receipt, a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider is marketable against trading interest on the ATS, the ATS will accept the order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Where a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider would be marketable relative to the NBBO (including, for clarity, any market pegged order and, where applicable, midpoint and primary pegged orders with positive dollar offset instructions), the ATS will treat the order as a market pegged order with a -$0.01 offset (that is, an effective limit price of $0.01 below the NBO for buy orders or $0.01 above the NBB for sell orders). Notwithstanding the foregoing, where an order contains Midpoint Offset instructions and the NBBO is one penny wide, the ATS will disregard the Midpoint Offset instructions and treat the order as pegged to the midpoint of the NBBO (with no offset). Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day", (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Non-directed orders routed to the ATS by the IBKR SOR (i.e., where the subscriber has not directed the order to the ATS) are submitted as either IOC orders or as GTT orders with a 1-second GTT instruction. Directed orders submitted to the ATS, whether by a Liquidity Provider or other subscriber, may include a TIF instruction of day, IOC or GTT. Orders submitted with TIF instructions of longer than day (e.g., GTD or GTT with an expiration time of post after trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading day. Priority Orders resting in the ATS are ranked based on the following factors in the following order: (i) price; (ii) size; and (iii) time. Pegged orders are ranked based on their effective limit price and not on any ultimate limit price associated with the order. Where an order is pegged to the midpoint of the NBBO (including orders pegged to the primary with a 50% percentage offset instruction), the ATS will rank the order and any related IOI at the order's effective limit price (i.e., the pegged price), even where the effective limit price is not in a $0.01 increment (e.g., where the NBBO is $20.00 by $20.05, a buy order pegged to the midpoint of the NBBO will have a ranking price of $20.025 and, accordingly, will have priority over buy orders with limit prices of $20.02). For clarity, orders pegged to the midpoint of the NBBO that include Midpoint Offset instructions are ranked at their effective limit prices (which, except where the order's Midpoint Offset instructions are disregarded, are always priced in full-penny increments). For purposes of establishing time priority the ATS treats pegged orders as received at the time of original order receipt, rather than as received at each subsequent price change. Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber or the SOR, as applicable.

order_types

Order Types The ATS accepts limit and pegged orders. The ATS does not accept market orders. Pegged orders may include the following reference prices: (i) primary (i.e., NBB for buy orders, NBO for sell orders); (ii) market (i.e., NBO for buy orders, NBB for sell orders); and (iii) midpoint of the NBBO. Pegged orders may include an ultimate limit price, although orders pegged to the midpoint of the NBBO must include an ultimate limit price. Primary pegged orders may include a percentage offset instruction equal to either 0% or 50% of the NBBO spread or dollar offset instructions expressed in penny increments (e.g., pegged primary plus $0.01). Market pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged market minus $0.01). Orders pegged to the midpoint of the NBBO may include dollar offset instructions ("Midpoint Offsets"), further discussed below. When used herein, a "positive" (+) offset refers to a more aggressive price, while a "negative" (-) offset refers to a less aggressive price. For instance, where the NBBO is $20.00 x $20.05, a primary pegged buy order with a positive (+) $0.01 offset will have an effective limit price of $20.01, while a primary pegged sell order with a positive (+) $0.01 offset will have an effective limit price of $20.04). Pegged orders are ranked based on their effective limit price. At no time will a peg instruction, including any offset instruction, violate an order's ultimate limit price. Midpoint Offset instructions must include two values, one value that will be applied when the NBBO spread is an even value (e.g., where the NBBO is $20.00 x $20.10) (the "Even Spread Offset") and a second value that will be applied when the NBBO spread is an odd value (e.g., where the NBBO is $20.00 x $20.05) (the "Odd Spread Offset"). Even Spread Offsets must be expressed in full penny increments. Odd Spread Offsets must be expressed in a half penny increment, not a whole penny increment (that is, $0.005, $0.015, $0.025, etc.). Midpoint Offset instructions may be expressed as positive or negative offsets. An order's Even and Odd Spread Offset instructions must be sequential (that is, an order with an Even Spread Offset of +$0.01 must include Odd Spread Offset instructions of either +$0.005 or +$0.015; no other Odd Spread Offset instructions will be accepted). Midpoint Offset instructions will not cause an order's effective limit price to be marketable relative to the prevailing NBBO. Where a Midpoint Offset instruction would cause an order to be marketable relative to the prevailing NBBO (e.g., for buy orders, equal to or greater than the NBO), the ATS will treat the order's effective limit price as one penny below the NBO (for buy orders) or one penny above the NBB (for sell orders). The ATS will disregard any positive Midpoint Offset instruction when the NBBO is one penny wide. The above adjustments operate on a dynamic basis. For instance, assume a buy order pegged to the midpoint is submitted with an Even Spread Offset instruction of +$0.01 and an Odd Spread Offset instruction of +$0.015. If, upon order receipt, the prevailing NBBO is $20.00 x $20.10, the order's effective limit price would be $20.06 (that is, $20.05, the midpoint of the NBBO, plus a $0.01 Even Spread Offset). If, prior to the order being executed or cancelled, the NBBO updates to $20.00 x $20.03, the order's effective limit price would then be $20.02. If the NBBO further narrows to $20.00 x $20.01, the order's effective limit price would then be $20.005 (that is, the ATS will disregard the order's Midpoint Offset instruction). If the NBBO subsequently widens to $20.00 x $20.05, the order's effective limit price would then be $20.04 (that is, $20.025 plus the $0.015 Odd Spread Offset). Only Liquidity Providers may utilize the following order instructions: (i) percentage offsets (i.e., 0% or 50% of the NBBO spread) and (ii) minimum quantity instructions. All other order instructions are available to both Liquidity Providers and Brokerage Customers. However, except for directed orders submitted to the ATS by Brokerage Customers, as a matter of policy IBKR does not rest non-marketable orders in the ATS and does not utilize peg instructions. Orders submitted by Liquidity Providers may include a minimum quantity instruction. A minimum quantity instruction specifies the minimum execution size a subscriber will accept and does not allow for the aggregation of contra-side orders (i.e., the minimum quantity instruction must be satisfied by a single contra-side order). Subscribers who are not Liquidity Providers may not include minimum quantity instructions with their orders. Directed orders submitted to the ATS by a Brokerage Customer or Liquidity Provider will never remove liquidity from the ATS. Where, upon receipt, a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider is marketable against trading interest on the ATS, the ATS will accept the order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Where a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider would be marketable relative to the NBBO (including, for clarity, any market pegged order and, where applicable, midpoint and primary pegged orders with positive dollar offset instructions), the ATS will treat the order as a market pegged order with a -$0.01 offset (that is, an effective limit price of $0.01 below the NBO for buy orders or $0.01 above the NBB for sell orders). Notwithstanding the foregoing, where an order contains Midpoint Offset instructions and the NBBO is one penny wide, the ATS will disregard the Midpoint Offset instructions and treat the order as pegged to the midpoint of the NBBO (with no offset). Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day", (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Non-directed orders routed to the ATS by the IBKR SOR (i.e., where the subscriber has not directed the order to the ATS) are submitted as either IOC orders or as GTT orders with a 1-second GTT instruction. Directed orders submitted to the ATS, whether by a Liquidity Provider or other subscriber, may include a TIF instruction of day, IOC or GTT. Orders submitted with TIF instructions of longer than day (e.g., GTD or GTT with an expiration time of post after trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading day. Priority Orders resting in the ATS are ranked based on the following factors in the following order: (i) price; (ii) size; and (iii) time. Pegged orders are ranked based on their effective limit price and not on any ultimate limit price associated with the order. Where an order is pegged to the midpoint of the NBBO (including orders pegged to the primary with a 50% percentage offset instruction), the ATS will rank the order and any related IOI at the order's effective limit price (i.e., the pegged price), even where the effective limit price is not in a $0.01 increment (e.g., where the NBBO is $20.00 by $20.05, a buy order pegged to the midpoint of the NBBO will have a ranking price of $20.025 and, accordingly, will have priority over buy orders with limit prices of $20.02). For clarity, orders pegged to the midpoint of the NBBO that include Midpoint Offset instructions are ranked at their effective limit prices (which, except where the order's Midpoint Offset instructions are disregarded, are always priced in full-penny increments). For purposes of establishing time priority the ATS treats pegged orders as received at the time of original order receipt, rather than as received at each subsequent price change. Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber or the SOR, as applicable.

order_types

Order Types The ATS accepts limit and pegged orders. The ATS does not accept market orders. Pegged orders may include the following reference prices: (i) primary (i.e., NBB for buy orders, NBO for sell orders); (ii) market (i.e., NBO for buy orders, NBB for sell orders); and (iii) midpoint of the NBBO. Pegged orders may include an ultimate limit price. Primary pegged orders may include a percentage offset instruction equal to either 0% or 50% of the NBBO spread or dollar offset instructions expressed in penny increments (e.g., pegged primary plus $0.01). Market pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged market minus $0.01). Orders pegged to the midpoint of the NBBO may include dollar offset instructions ("Midpoint Offsets"), further discussed below. When used herein, a "positive" (+) offset refers to a more aggressive price, while a "negative" (-) offset refers to a less aggressive price. For instance, where the NBBO is $20.00 x $20.05, a primary pegged buy order with a positive (+) $0.01 offset will have an effective limit price of $20.01, while a primary pegged sell order with a positive (+) $0.01 offset will have an effective limit price of $20.04). Pegged orders are ranked based on their effective limit price. At no time will a peg instruction, including any offset instruction, violate an order's ultimate limit price. Midpoint Offset instructions must include two values, one value that will be applied when the NBBO spread is an even value (e.g., where the NBBO is $20.00 x $20.10) (the "Even Spread Offset") and a second value that will be applied when the NBBO spread is an odd value (e.g., where the NBBO is $20.00 x $20.05) (the "Odd Spread Offset"). Even Spread Offsets must be expressed in full penny increments. Odd Spread Offsets must be expressed in a half penny increment, not a whole penny increment (that is, $0.005, $0.015, $0.025, etc.). Midpoint Offset instructions may be expressed as positive or negative offsets. An order's Even and Odd Spread Offset instructions must be sequential (that is, an order with an Even Spread Offset of +$0.01 must include Odd Spread Offset instructions of either +$0.005 or +$0.015; no other Odd Spread Offset instructions will be accepted). Midpoint Offset instructions will not cause an order's effective limit price to be marketable relative to the prevailing NBBO. Where a Midpoint Offset instruction would cause an order to be marketable relative to the prevailing NBBO (e.g., for buy orders, equal to or greater than the NBO), the ATS will treat the order's effective limit price as one penny below the NBO (for buy orders) or one penny above the NBB (for sell orders). The ATS will disregard any positive Midpoint Offset instruction when the NBBO is one penny wide. The above adjustments operate on a dynamic basis. For instance, assume a buy order pegged to the midpoint is submitted with an Even Spread Offset instruction of +$0.01 and an Odd Spread Offset instruction of +$0.015. If, upon order receipt, the prevailing NBBO is $20.00 x $20.10, the order's effective limit price would be $20.06 (that is, $20.05, the midpoint of the NBBO, plus a $0.01 Even Spread Offset). If, prior to the order being executed or cancelled, the NBBO updates to $20.00 x $20.03, the order's effective limit price would then be $20.02. If the NBBO further narrows to $20.00 x $20.01, the order's effective limit price would then be $20.005 (that is, the ATS will disregard the order's Midpoint Offset instruction). If the NBBO subsequently widens to $20.00 x $20.05, the order's effective limit price would then be $20.04 (that is, $20.025 plus the $0.015 Odd Spread Offset). Only Liquidity Providers may utilize the following order instructions: (i) percentage offsets (i.e., 0% or 50% of the NBBO spread) and (ii) minimum quantity instructions. All other order instructions are available to both Liquidity Providers and Brokerage Customers. However, except for directed orders submitted to the ATS by Brokerage Customers, as a matter of policy IBKR does not rest non-marketable orders in the ATS and does not utilize peg instructions. Directed orders submitted to the ATS by a Brokerage Customer or Liquidity Provider will never remove liquidity from the ATS. Where, upon receipt, a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider is marketable against trading interest on the ATS, the ATS will accept the order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Where a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider would be marketable relative to the NBBO (including, for clarity, any market pegged order and, where applicable, midpoint and primary pegged orders with positive dollar offset instructions), the ATS will treat the order as a market pegged order with a -$0.01 offset (that is, an effective limit price of $0.01 below the NBO for buy orders or $0.01 above the NBB for sell orders). Notwithstanding the foregoing, where an order contains Midpoint Offset instructions and the NBBO is one penny wide, the ATS will disregard the Midpoint Offset instructions and treat the order as pegged to the midpoint of the NBBO (with no offset). Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day", (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Non-directed orders routed to the ATS by the IBKR SOR (i.e., where the subscriber has not directed the order to the ATS) are submitted as either IOC orders or as GTT orders with a 1-second GTT instruction. Directed orders submitted to the ATS, whether by a Liquidity Provider or other subscriber, may include a TIF instruction of day, IOC or GTT. Orders submitted with TIF instructions of longer than day (e.g., GTD or GTT with an expiration time of post after trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading day. Priority Orders resting in the ATS are ranked based on the following factors in the following order: (i) price; (ii) size; and (iii) time. Pegged orders are ranked based on their effective limit price and not on any ultimate limit price associated with the order. Where an order is pegged to the midpoint of the NBBO (including orders pegged to the primary with a 50% percentage offset instruction), the ATS will rank the order and any related IOI at the order's effective limit price (i.e., the pegged price), even where the effective limit price is not in a $0.01 increment (e.g., where the NBBO is $20.00 by $20.05, a buy order pegged to the midpoint of the NBBO will have a ranking price of $20.025 and, accordingly, will have priority over buy orders with limit prices of $20.02). For clarity, orders pegged to the midpoint of the NBBO that include Midpoint Offset instructions are ranked at their effective limit prices (which, except where the order's Midpoint Offset instructions are disregarded, are always priced in full-penny increments). For purposes of establishing time priority the ATS treats pegged orders as received at the time of original order receipt, rather than as received at each subsequent price change. Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber or the SOR, as applicable.

order_types

Order Types The ATS accepts limit and pegged orders. The ATS does not accept market orders. Pegged orders may include the following reference prices: (i) primary (i.e., NBB for buy orders, NBO for sell orders); (ii) market (i.e., NBO for buy orders, NBB for sell orders); and (iii) midpoint of the NBBO. Pegged orders may include an ultimate limit price. Primary pegged orders may include a percentage offset instruction equal to either 0% or 50% of the NBBO spread or dollar offset instructions expressed in penny increments (e.g., pegged primary plus $0.01). Market pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged market minus $0.01). When used herein, a "positive" (+) offset refers to a more aggressive price, while a "negative" (-) offset refers to a less aggressive price. For instance, where the NBBO is $20.00 x $20.05, a primary pegged buy order with a positive (+) $0.01 offset will have an effective limit price of $20.01, while a primary pegged sell order with a positive (+) $0.01 offset will have an effective limit price of $20.04). Pegged orders are ranked based on their effective limit price. At no time will a peg instruction, including any offset instruction, violate an order's ultimate limit price. Only Liquidity Providers may utilize the following order instructions: (i) percentage offsets (i.e., 0% or 50% of the NBBO spread) and (ii) minimum quantity instructions. All other order instructions are available to both Liquidity Providers and Brokerage Customers. However, except for directed orders submitted to the ATS by Brokerage Customers, as a matter of policy IBKR does not rest non-marketable orders in the ATS and does not utilize peg instructions. Orders submitted by Liquidity Providers may include a minimum quantity instruction. A minimum quantity instruction specifies the minimum execution size a subscriber will accept and does not allow for the aggregation of contra-side orders (i.e., the minimum quantity instruction must be satisfied by a single contra-side order). Subscribers who are not Liquidity Providers may not include minimum quantity instructions with their orders. Directed orders submitted to the ATS by a Brokerage Customer or Liquidity Provider will never remove liquidity from the ATS. Where, upon receipt, a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider is marketable against trading interest on the ATS, the ATS will accept the order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Where a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider would be marketable relative to the NBBO (including, for clarity, any market pegged order and, where applicable, primary pegged orders with positive dollar offset instructions), the ATS will treat the order as a market pegged order with a -$0.01 offset (that is, an effective limit price of $0.01 below the NBO for buy orders or $0.01 above the NBB for sell orders). Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day", (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Non-directed orders routed to the ATS by the IBKR SOR (i.e., where the subscriber has not directed the order to the ATS) are submitted as either IOC orders or as GTT orders with a 1-second GTT instruction. Directed orders submitted to the ATS, whether by a Liquidity Provider or other subscriber, may include a TIF instruction of day, IOC or GTT. Orders submitted with TIF instructions of longer than day (e.g., GTD or GTT with an expiration time of post after trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading day. Priority Orders resting in the ATS are ranked based on the following factors in the following order: (i) price; (ii) size; and (iii) time. Pegged orders are ranked based on their effective limit price and not on any ultimate limit price associated with the order. Where an order is pegged to the midpoint of the NBBO (including orders pegged to the primary with a 50% percentage offset instruction), the ATS will rank the order and any related IOI at the order's effective limit price (i.e., the pegged price), even where the effective limit price is not in a $0.01 increment (e.g., where the NBBO is $20.00 by $20.05, a buy order pegged to the midpoint of the NBBO will have a ranking price of $20.025 and, accordingly, will have priority over buy orders with limit prices of $20.02). For purposes of establishing time priority the ATS treats pegged orders as received at the time of original order receipt, rather than as received at each subsequent price change. Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber or the SOR, as applicable.

order_types

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

order_types

Order Types The ATS accepts limit and pegged orders. The ATS does not accept market orders. Pegged orders may include the following reference prices: (i) primary (i.e., NBB for buy orders, NBO for sell orders); (ii) market (i.e., NBO for buy orders, NBB for sell orders); and (iii) midpoint of the NBBO. The ATS also accepts "PegBest" orders, which, as further discussed below, are pegged to the Combined NBBO (defined below) with +$0.01 offset. Only PegBest orders may be pegged to the Combined NBBO. Pegged orders may include an ultimate limit price. PegBest orders and orders pegged to the midpoint of the NBBO must include an ultimate limit price. Primary pegged orders may include a percentage offset instruction equal to either 0% or 50% of the NBBO spread or dollar offset instructions expressed in penny increments (e.g., pegged primary plus $0.01). Market pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged market minus $0.01). Orders pegged to the midpoint of the NBBO may include dollar offset instructions ("Midpoint Offsets"), further discussed below. When used herein, a "positive" (+) offset refers to a more aggressive price, while a "negative" (-) offset refers to a less aggressive price. For instance, where the NBBO is $20.00 x $20.05, a primary pegged buy order with a positive (+) $0.01 offset will have an effective limit price of $20.01, while a primary pegged sell order with a positive (+) $0.01 offset will have an effective limit price of $20.04). Pegged orders are ranked based on their effective limit price. At no time will a peg instruction, including any offset instruction, violate an order's ultimate limit price. Midpoint Offset instructions must include two values, one value that will be applied when the NBBO spread is an even value (e.g., where the NBBO is $20.00 x $20.10) (the "Even Spread Offset") and a second value that will be applied when the NBBO spread is an odd value (e.g., where the NBBO is $20.00 x $20.05) (the "Odd Spread Offset"). Even Spread Offsets must be expressed in full penny increments. Odd Spread Offsets must be expressed in a half penny increment, not a whole penny increment (that is, $0.005, $0.015, $0.025, etc.). Midpoint Offset instructions may be expressed as positive or negative offsets. An order's Even and Odd Spread Offset instructions must be sequential (that is, an order with an Even Spread Offset of +$0.01 must include Odd Spread Offset instructions of either +$0.005 or +$0.015; no other Odd Spread Offset instructions will be accepted). Midpoint Offset instructions will not cause an order's effective limit price to be marketable relative to the prevailing NBBO. Where a Midpoint Offset instruction would cause an order to be marketable relative to the prevailing NBBO (e.g., for buy orders, equal to or greater than the NBO), the ATS will treat the order's effective limit price as one penny below the NBO (for buy orders) or one penny above the NBB (for sell orders). The ATS will disregard any positive Midpoint Offset instruction when the NBBO is one penny wide. The above adjustments operate on a dynamic basis. For instance, assume a buy order pegged to the midpoint is submitted with an Even Spread Offset instruction of +$0.01 and an Odd Spread Offset instruction of +$0.015. If, upon order receipt, the prevailing NBBO is $20.00 x $20.10, the order's effective limit price would be $20.06 (that is, $20.05, the midpoint of the NBBO, plus a $0.01 Even Spread Offset). If, prior to the order being executed or cancelled, the NBBO updates to $20.00 x $20.03, the order's effective limit price would then be $20.02. If the NBBO further narrows to $20.00 x $20.01, the order's effective limit price would then be $20.005 (that is, the ATS will disregard the order's Midpoint Offset instruction). If the NBBO subsequently widens to $20.00 x $20.05, the order's effective limit price would then be $20.04 (that is, $20.025 plus the $0.015 Odd Spread Offset). As noted above, "PegBest orders" are orders that are pegged to the Combined NBBO with a +$0.01 offset. The "Combined NBBO" is the more aggressive (higher for buys, lower for sells) of (i) the prevailing NBB (for buy orders) or NBO (for sell orders) and (ii) the highest price (for buy orders) or lowest price (for sell orders) at which aggregate same-side interest, including better-price interest, equals or exceeds the PegBest order's Minimum Compete Size instruction (as defined below). For instance, where the prevailing NBBO is $20.00 x $20.09, and there is a resting non-PegBest buy order for 100-shares in the ATS with a limit price of $20.01, a buy PegBest order with a Minimum Compete Size instruction of 100-shares will have an effective limit price of $20.02 (Combined NBBO of $20.01 + $0.01 offset). Where the prevailing NBBO is $20.00 x $20.09, and the competing non-PegBest buy orders resting in the ATS are (i) an order for 50-shares with a limit price of $20.03, (ii) an order for 75-shares with a limit price of $20.02 and (iii) an order for 100-shares with a limit price of $20.01, a buy PegBest order with a Minimum Compete Size instruction of 100-shares will have an effective limit price of $20.03 (that is, the Combined NBBO would equal $20.02 as $20.02 is the highest price at which aggregate same-side interest, including better-price interest, equals or exceeds the PegBest order's Minimum Compete Size instruction, and the PegBest order's effective limit price would therefore equal $20.02 + $0.01 offset). The effective price of a PegBest order will never exceed the midpoint of the prevailing NBBO. For instance, where the prevailing NBBO is $20.00 x $20.09, and there is a resting 100-share non-PegBest buy order in the ATS with a limit price of $20.06, a buy PegBest order with a Minimum Compete Size instruction of 100 shares would be treated as pegged to the midpoint of the NBBO (effective limit price of $20.045). PegBest orders must include a "Minimum Compete Size" instruction, expressed as a share quantity. The ATS appends a default Minimum Compete Size of 100 shares, although subscribers may select Minimum Compete Sizes that are smaller or larger than the default quantity (including a Minimum Compete Size of zero (0) shares). Minimum Compete Size instructions, which are used in determining the Combined NBBO for any given order, designate the minimum competing order size required before the PegBest order will attempt to better the price. As noted above, in determining whether an order's Minimum Compete Size instruction has been met the ATS will effectively walk down the order book (including, for clarity, both resting Brokerage Customer orders and resting Liquidity Provider orders), aggregating competing interest at each price level. Accordingly, where a PegBest buy order has a Minimum Compete Size instruction of 200-shares, the NBBO is $20.00 x $20.09 and the best-priced non-PegBest competing orders resting in the ATS are (i) a 100-share order with a limit price of $20.05, (ii) a 75-share order with a limit price of $20.04, (iii) a 100-share order with a limit price of $20.02 and (iv) a 100-share order with a limit price of $20.00, the PegBest order's Minimum Compete Size instruction would be satisfied at $20.02 (its Combined NBBO) and its effective limit price would be $20.03 (Combined NBBO + $0.01). PegBest orders must also include a "Competing Tick Offset" instruction. By default, PegBest orders include a Competing Tick Offset instruction of +$0.02. Competing Tick Offset instructions are activated where there are competing PegBest orders in the ATS, and designate the amount by which a PegBest order's effective limit may exceed its Combined NBBO. A PegBest order will compete against another PegBest order even where the competing PegBest order doesn't satisfy its Minimum Compete Size instruction. Competing Tick Offset instructions will not allow a PegBest order's effective limit price to exceed the midpoint of the prevailing NBBO. Subscribers may designate their orders as free to "compete" to the midpoint of the NBBO, regardless of the amount by which the midpoint of the prevailing NBBO exceeds the Combined NBBO (e.g., providing for "unconstrained" Competing Tick Offset instructions). Subscribers may otherwise express Competing Tick Offset instructions in penny increments, whereby the instruction identifies the amount by which the order's effective limit price may exceed its Combined NBBO when competing with another PegBest order. Competing Tick Offset instructions must be for +$0.01 or higher. Notwithstanding any order's Competing Tick Offset instruction, the effective limit price of a PegBest order will never exceed (i) the order's ultimate limit price or (ii) the midpoint of the prevailing NBBO. Assume that the prevailing NBBO is $20.00 x $20.15, and the Combined NBBO for each of PegBest Orders A and B (defined below) is $20.01. Further assume a PegBest buy order ("PegBest Order A") has been submitted to the ATS with a Competing Tick Offset of $0.02 and there are no competing PegBest buy orders in the ATS. PegBest Order A will have an effective limit price of $20.02 (one tick above its Combined NBBO) and its Competing Tick Offset will not be activated. Assume a competing PegBest buy order is subsequently submitted ("PegBest Order B"), with a Competing Tick Offset instruction of $0.04. PegBest Order A's effective limit price would increase to $20.03 (Combined NBBO + $0.02), while PegBest Order B's effective limit price would be $20.04 (Combined NBBO + $0.03). For clarity, PegBest Order B's would not be $20.05 (Combined NBBO + $0.04) as Competing Tick Offset instructions are only activated to the extent necessary to contend with a competing PegBest order. Assume instead that the prevailing NBBO is $20.00 x $20.15, and the Combined NBBO for PegBest Order A is $20.01 and the Combined NBBO for PegBest Order B is $20.04. Assume that PegBest Order A again has a Competing Tick Offset of $0.02 and that PegBest Order B again has a Competing Tick Offset instruction of $0.04. PegBest Order A's effective limit price would still be $20.03 (its Combined NBBO + $0.02), while PegBest Order B's effective limit price would be $20.05 (its Combined NBBO of $20.04 plus a + $0.01 offset; its Competing Tick Offset would effectively not be triggered). Only Liquidity Providers may utilize percentage offset instructions (i.e., 0% or 50% of the NBBO spread). Only Brokerage Customers (including Liquidity Providers in their capacities as Brokerage Customers) may submit PegBest orders. All other order instructions are available to both Liquidity Providers and Brokerage Customers. However, except for directed orders submitted to the ATS by Brokerage Customers, as a matter of policy IBKR does not rest non-marketable orders in the ATS and does not utilize peg instructions. Directed orders submitted to the ATS by a Brokerage Customer or Liquidity Provider will never remove liquidity from the ATS. Where, upon receipt, a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider is marketable against trading interest on the ATS, the ATS will accept the order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Where a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider would be marketable relative to the NBBO (including, for clarity, any market pegged order and, where applicable, midpoint and primary pegged orders with positive dollar offset instructions), the ATS will treat the order as a market pegged order with a -$0.01 offset (that is, an effective limit price of $0.01 below the NBO for buy orders or $0.01 above the NBB for sell orders). Notwithstanding the foregoing, where an order contains Midpoint Offset instructions and the NBBO is one penny wide, the ATS will disregard the Midpoint Offset instructions and treat the order as pegged to the midpoint of the NBBO (with no offset). Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day", (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Non-directed orders routed to the ATS by the IBKR SOR (i.e., where the subscriber has not directed the order to the ATS) are submitted as either IOC orders or as GTT orders with a 1-second GTT instruction. Directed orders submitted to the ATS, whether by a Liquidity Provider or other subscriber, may include a TIF instruction of day, IOC or GTT. Orders submitted with TIF instructions of longer than day (e.g., GTD or GTT with an expiration time of post after trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading day. Priority Orders resting in the ATS are ranked based on the following factors in the following order: (i) price; (ii) size; and (iii) time. Pegged orders are ranked based on their effective limit price and not on any ultimate limit price associated with the order. Where an order is pegged to the midpoint of the NBBO (including orders pegged to the primary with a 50% percentage offset instruction), the ATS will rank the order and any related IOI at the order's effective limit price (i.e., the pegged price), even where the effective limit price is not in a $0.01 increment (e.g., where the NBBO is $20.00 by $20.05, a buy order pegged to the midpoint of the NBBO will have a ranking price of $20.025 and, accordingly, will have priority over buy orders with limit prices of $20.02). For clarity, orders pegged to the midpoint of the NBBO that include Midpoint Offset instructions are ranked at their effective limit prices (which, except where the order's Midpoint Offset instructions are disregarded, are always priced in full-penny increments). For purposes of establishing time priority the ATS treats pegged orders, other than PegBest orders, as received at the time of original order receipt, rather than as received at each subsequent price change. For purposes of establishing time priority, the ATS treats PegBest orders as being resubmitted at the time of any increase in the PegBest order's offset relative to the Combined NBBO (e.g., where a PegBest order's offset increases from +$0.01 to +$0.02 due to the introduction of a competing PegBest order). Reductions in a PegBest order's offset (e.g., where a PegBest order's offset to the Combined NBBO is reduced from +$0.02 to +$0.01) do not impact time of receipt for priority purposes. For clarity, changes in the Combined NBBO, without more, do not impact a PegBest order's time of receipt for time priority purposes. Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber or the SOR, as applicable.

order_types

Order Types The ATS accepts limit and pegged orders. The ATS does not accept market orders. Pegged orders may include the following reference prices: (i) primary (i.e., NBB for buy orders, NBO for sell orders); (ii) market (i.e., NBO for buy orders, NBB for sell orders); and (iii) midpoint of the NBBO. The ATS also accepts "PegBest" orders, which, as further discussed below, are pegged to the Combined NBBO (defined below) with +$0.01 offset. Only PegBest orders may be pegged to the Combined NBBO. Pegged orders may include an ultimate limit price. PegBest orders and orders pegged to the midpoint of the NBBO must include an ultimate limit price. Primary pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged primary plus $0.01). Market pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged market minus $0.01). Orders pegged to the midpoint of the NBBO may include dollar offset instructions ("Midpoint Offsets"), further discussed below. When used herein, a "positive" (+) offset refers to a more aggressive price, while a "negative" (-) offset refers to a less aggressive price. For instance, where the NBBO is $20.00 x $20.05, a primary pegged buy order with a positive (+) $0.01 offset will have an effective limit price of $20.01, while a primary pegged sell order with a positive (+) $0.01 offset will have an effective limit price of $20.04). Pegged orders are ranked based on their effective limit price. At no time will a peg instruction, including any offset instruction, violate an order's ultimate limit price. Midpoint Offset instructions must include two values, one value that will be applied when the NBBO spread is an even value (e.g., where the NBBO is $20.00 x $20.10) (the "Even Spread Offset") and a second value that will be applied when the NBBO spread is an odd value (e.g., where the NBBO is $20.00 x $20.05) (the "Odd Spread Offset"). Even Spread Offsets must be expressed in full penny increments. Odd Spread Offsets must be expressed in a half penny increment, not a whole penny increment (that is, $0.005, $0.015, $0.025, etc.). Midpoint Offset instructions may be expressed as positive or negative offsets. An order's Even and Odd Spread Offset instructions must be sequential (that is, an order with an Even Spread Offset of +$0.01 must include Odd Spread Offset instructions of either +$0.005 or +$0.015; no other Odd Spread Offset instructions will be accepted). Midpoint Offset instructions will not cause an order's effective limit price to be marketable relative to the prevailing NBBO. Where a Midpoint Offset instruction would cause an order to be marketable relative to the prevailing NBBO (e.g., for buy orders, equal to or greater than the NBO), the ATS will treat the order's effective limit price as one penny below the NBO (for buy orders) or one penny above the NBB (for sell orders). The ATS will disregard any positive Midpoint Offset instruction when the NBBO is one penny wide. The above adjustments operate on a dynamic basis. For instance, assume a buy order pegged to the midpoint is submitted with an Even Spread Offset instruction of +$0.01 and an Odd Spread Offset instruction of +$0.015. If, upon order receipt, the prevailing NBBO is $20.00 x $20.10, the order's effective limit price would be $20.06 (that is, $20.05, the midpoint of the NBBO, plus a $0.01 Even Spread Offset). If, prior to the order being executed or cancelled, the NBBO updates to $20.00 x $20.03, the order's effective limit price would then be $20.02. If the NBBO further narrows to $20.00 x $20.01, the order's effective limit price would then be $20.005 (that is, the ATS will disregard the order's Midpoint Offset instruction). If the NBBO subsequently widens to $20.00 x $20.05, the order's effective limit price would then be $20.04 (that is, $20.025 plus the $0.015 Odd Spread Offset). As noted above, "PegBest orders" are orders that are pegged to the Combined NBBO with a +$0.01 offset. The "Combined NBBO" is the more aggressive (higher for buys, lower for sells) of (i) the prevailing NBB (for buy orders) or NBO (for sell orders) and (ii) the highest price (for buy orders) or lowest price (for sell orders) at which aggregate same-side interest, including better-price interest, equals or exceeds the PegBest order's Minimum Compete Size instruction (as defined below). For instance, where the prevailing NBBO is $20.00 x $20.09, and there is a resting non-PegBest buy order for 100-shares in the ATS with a limit price of $20.01, a buy PegBest order with a Minimum Compete Size instruction of 100-shares will have an effective limit price of $20.02 (Combined NBBO of $20.01 + $0.01 offset). Where the prevailing NBBO is $20.00 x $20.09, and the competing non-PegBest buy orders resting in the ATS are (i) an order for 50-shares with a limit price of $20.03, (ii) an order for 75-shares with a limit price of $20.02 and (iii) an order for 100-shares with a limit price of $20.01, a buy PegBest order with a Minimum Compete Size instruction of 100-shares will have an effective limit price of $20.03 (that is, the Combined NBBO would equal $20.02 as $20.02 is the highest price at which aggregate same-side interest, including better-price interest, equals or exceeds the PegBest order's Minimum Compete Size instruction, and the PegBest order's effective limit price would therefore equal $20.02 + $0.01 offset). The effective price of a PegBest order will never exceed the midpoint of the prevailing NBBO. For instance, where the prevailing NBBO is $20.00 x $20.09, and there is a resting 100-share non-PegBest buy order in the ATS with a limit price of $20.06, a buy PegBest order with a Minimum Compete Size instruction of 100 shares would be treated as pegged to the midpoint of the NBBO (effective limit price of $20.045). PegBest orders must include a "Minimum Compete Size" instruction, expressed as a share quantity. The ATS appends a default Minimum Compete Size of 100 shares, although subscribers may select Minimum Compete Sizes that are smaller or larger than the default quantity (including a Minimum Compete Size of zero (0) shares). Minimum Compete Size instructions, which are used in determining the Combined NBBO for any given order, designate the minimum competing order size required before the PegBest order will attempt to better the price. As noted above, in determining whether an order's Minimum Compete Size instruction has been met the ATS will effectively walk down the order book (including, for clarity, both resting Brokerage Customer orders and resting Liquidity Provider orders), aggregating competing interest at each price level. Accordingly, where a PegBest buy order has a Minimum Compete Size instruction of 200-shares, the NBBO is $20.00 x $20.09 and the best-priced non-PegBest competing orders resting in the ATS are (i) a 100-share order with a limit price of $20.05, (ii) a 75-share order with a limit price of $20.04, (iii) a 100-share order with a limit price of $20.02 and (iv) a 100-share order with a limit price of $20.00, the PegBest order's Minimum Compete Size instruction would be satisfied at $20.02 (its Combined NBBO) and its effective limit price would be $20.03 (Combined NBBO + $0.01). PegBest orders must also include a "Competing Tick Offset" instruction. By default, PegBest orders include a Competing Tick Offset instruction of +$0.02. Competing Tick Offset instructions are activated where there are competing PegBest orders in the ATS, and designate the amount by which a PegBest order's effective limit may exceed its Combined NBBO. A PegBest order will compete against another PegBest order even where the competing PegBest order doesn't satisfy its Minimum Compete Size instruction. Competing Tick Offset instructions will not allow a PegBest order's effective limit price to exceed the midpoint of the prevailing NBBO. Subscribers may designate their orders as free to "compete" to the midpoint of the NBBO, regardless of the amount by which the midpoint of the prevailing NBBO exceeds the Combined NBBO (e.g., providing for "unconstrained" Competing Tick Offset instructions). Subscribers may otherwise express Competing Tick Offset instructions in penny increments, whereby the instruction identifies the amount by which the order's effective limit price may exceed its Combined NBBO when competing with another PegBest order. Competing Tick Offset instructions must be for +$0.01 or higher. Notwithstanding any order's Competing Tick Offset instruction, the effective limit price of a PegBest order will never exceed (i) the order's ultimate limit price or (ii) the midpoint of the prevailing NBBO. Assume that the prevailing NBBO is $20.00 x $20.15, and the Combined NBBO for each of PegBest Orders A and B (defined below) is $20.01. Further assume a PegBest buy order ("PegBest Order A") has been submitted to the ATS with a Competing Tick Offset of $0.02 and there are no competing PegBest buy orders in the ATS. PegBest Order A will have an effective limit price of $20.02 (one tick above its Combined NBBO) and its Competing Tick Offset will not be activated. Assume a competing PegBest buy order is subsequently submitted ("PegBest Order B"), with a Competing Tick Offset instruction of $0.04. PegBest Order A's effective limit price would increase to $20.03 (Combined NBBO + $0.02), while PegBest Order B's effective limit price would be $20.04 (Combined NBBO + $0.03). For clarity, PegBest Order B's would not be $20.05 (Combined NBBO + $0.04) as Competing Tick Offset instructions are only activated to the extent necessary to contend with a competing PegBest order. Assume instead that the prevailing NBBO is $20.00 x $20.15, and the Combined NBBO for PegBest Order A is $20.01 and the Combined NBBO for PegBest Order B is $20.04. Assume that PegBest Order A again has a Competing Tick Offset of $0.02 and that PegBest Order B again has a Competing Tick Offset instruction of $0.04. PegBest Order A's effective limit price would still be $20.03 (its Combined NBBO + $0.02), while PegBest Order B's effective limit price would be $20.05 (its Combined NBBO of $20.04 plus a + $0.01 offset; its Competing Tick Offset would effectively not be triggered). Directed orders submitted to the ATS by Brokerage Customers may include minimum quantity instructions. A minimum quantity instruction specifies the minimum execution size a subscriber will accept and does not allow for the aggregation of contra-side orders (i.e., the minimum quantity instruction must be satisfied by a single contra-side order). When an order that includes a minimum quantity instruction receives an execution it will continues to rest in the ATS until its leaves quantity falls below its minimum quantity instruction, at which points the ATS will cancel back the order. Liquidity Providers may not include minimum quantity instructions with their orders. Only Brokerage Customers (including Liquidity Providers in their capacities as Brokerage Customers) may (i) submit PegBest orders and (ii) utilize minimum quantity instructions. All other order instructions are available to both Liquidity Providers and Brokerage Customers. However, except for directed orders submitted to the ATS by Brokerage Customers, as a matter of policy IBKR does not rest non-marketable orders in the ATS, utilize peg instructions or utilize minimum quantity instructions. Directed orders submitted to the ATS by a Brokerage Customer or Liquidity Provider will never remove liquidity from the ATS. Where, upon receipt, a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider is marketable against trading interest on the ATS, the ATS will accept the order for further processing as a post-only order (i.e., the order will not be crossed against the existing contra-side interest). Where a directed order submitted to the ATS by a Brokerage Customer or Liquidity Provider would be marketable relative to the NBBO (including, for clarity, any market pegged order and, where applicable, midpoint and primary pegged orders with positive dollar offset instructions), the ATS will treat the order as a market pegged order with a -$0.01 offset (that is, an effective limit price of $0.01 below the NBO for buy orders or $0.01 above the NBB for sell orders). Notwithstanding the foregoing, where an order contains Midpoint Offset instructions and the NBBO is one penny wide, the ATS will disregard the Midpoint Offset instructions and treat the order as pegged to the midpoint of the NBBO (with no offset). Time-in-Force The ATS accepts orders with the following time-in-force ("TIF") instructions: (i) "day", (ii) immediate or cancel ("IOC") and (iii) good-til-time ("GTT"). Non-directed orders routed to the ATS by the IBKR SOR (i.e., where the subscriber has not directed the order to the ATS) are submitted as either IOC orders or as GTT orders with a 1-second GTT instruction. Directed orders submitted to the ATS, whether by a Liquidity Provider or other subscriber, may include a TIF instruction of day, IOC or GTT. Orders submitted with TIF instructions of longer than day (e.g., GTD or GTT with an expiration time of post after trading hours) are treated as day orders by the ATS and cancelled back at the end of the trading day. Priority Orders resting in the ATS are ranked based on the following factors in the following order: (i) price; (ii) size; and (iii) time. Pegged orders are ranked based on their effective limit price and not on any ultimate limit price associated with the order. Where an order is pegged to the midpoint of the NBBO, the ATS will rank the order and any related IOI at the order's effective limit price (i.e., the pegged price), even where the effective limit price is not in a $0.01 increment (e.g., where the NBBO is $20.00 by $20.05, a buy order pegged to the midpoint of the NBBO will have a ranking price of $20.025 and, accordingly, will have priority over buy orders with limit prices of $20.02). For clarity, orders pegged to the midpoint of the NBBO that include Midpoint Offset instructions are ranked at their effective limit prices (which, except where the order's Midpoint Offset instructions are disregarded, are always priced in full-penny increments). For purposes of establishing time priority the ATS treats pegged orders, other than PegBest orders, as received at the time of original order receipt, rather than as received at each subsequent price change. For purposes of establishing time priority, the ATS treats PegBest orders as being resubmitted at the time of any increase in the PegBest order's offset relative to the Combined NBBO (e.g., where a PegBest order's offset increases from +$0.01 to +$0.02 due to the introduction of a competing PegBest order). Reductions in a PegBest order's offset (e.g., where a PegBest order's offset to the Combined NBBO is reduced from +$0.02 to +$0.01) do not impact time of receipt for priority purposes. For clarity, changes in the Combined NBBO, without more, do not impact a PegBest order's time of receipt for time priority purposes. Where a subscriber modifies the price or size instruction associated with an order (e.g., changing an order's limit price or increasing or decreasing the size of any order), the ATS treats the order as received at the time of modification. Order Routing The ATS does not route-out. All orders not executed in the ATS are cancelled back to the subscriber or the SOR, as applicable.

order_types

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

means_of_entry

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

means_of_entry

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

means_of_entry

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

pricing_methodology

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

pricing_methodology

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

pricing_methodology

IBKR's systems utilize direct market data feeds received from each national securities exchange to create a consolidated view of the national best bid and offer (the "NBBO"). By default, the NBBO, as determined based on these direct market data feeds, is used in determining eligible execution prices within the ATS (e.g., compliance with Regulation NMS and Regulation SHO) and to determine the effective limit price of pegged orders. Additionally, IBKR's systems contain a module (the "BestTickerSpeedComp" program) designed to evaluate the accuracy of the direct market data feeds utilized by IBKR relative to the SIP (e.g., to confirm that direct market data feeds provide the most current view of the NBBO). Where the BestTickerSpeedComp's logic determines that the SIP provides a more accurate view of current market prices relative to the direct data feeds, the ATS will use the NBBO as identified by the SIP in determining eligible execution prices within the ATS (for the avoidance of doubt, when the ATS switches to the SIP the ATS ceases using direct market data feeds completely).

counterparty_selection

Orders submitted by IBKR's affiliate, Covestor Ltd, are configured to interact only with trading interest of Liquidity Providers. Such counter-party permissioning functionality is not available to other subscribers. Orders submitted by a Liquidity Provider may not interact with other orders submitted by that Liquidity Provider. Orders submitted by a Liquidity Provider may not interact with orders submitted by other Liquidity Providers, nor may such orders interact with orders directed to the ATS by subscribers that are not acting as Liquidity Providers. Notwithstanding the foregoing, where a Liquidity Provider is separately a Brokerage Customer of IBKR, the ATS treats orders submitted to the ATS by the Liquidity Provider in its capacity as a Brokerage Customer in the same manner that the ATS treats orders received from other Brokerage Customers (including subject to the below counterparty restrictions); such orders may interact with orders submitted by the subscriber in its capacity as a Liquidity Provider. Directed orders submitted to the ATS by non-Liquidity Providers (including Liquidity Providers acting as Brokerage Customers) may not interact with orders submitted by Liquidity Providers (in their capacities as Liquidity Providers), nor may they interact with directed orders submitted by non-Liquidity Providers (including directed orders submitted by Liquidity Providers acting as Brokerage Customers). Non-directed orders submitted to the ATS by the IBKR SOR may, subject to the terms of the orders, interact with any other order in the ATS. The SOR may designate a non-directed order as ineligible to interact with Conditional Orders.

counterparty_selection

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

counterparty_selection

Orders submitted by IBKR's affiliate, Covestor Ltd, are configured to interact only with trading interest of Liquidity Providers. Such counter-party permissioning functionality is not available to other subscribers. Orders submitted by a Liquidity Provider may not interact with other orders submitted by that Liquidity Provider. Orders submitted by a Liquidity Provider may not interact with orders submitted by other Liquidity Providers, nor may such orders interact with orders directed to the ATS by subscribers that are not acting as Liquidity Providers. Notwithstanding the foregoing, where a Liquidity Provider is separately a Brokerage Customer of IBKR, the ATS treats orders submitted to the ATS by the Liquidity Provider in its capacity as a Brokerage Customer in the same manner that the ATS treats orders received from other Brokerage Customers (including subject to the below counterparty restrictions); such orders may interact with orders submitted by the subscriber in its capacity as a Liquidity Provider. Directed orders submitted to the ATS by non-Liquidity Providers (including Liquidity Providers acting as Brokerage Customers) may not interact with orders submitted by Liquidity Providers (in their capacities as Liquidity Providers), nor may they interact with directed orders submitted by non-Liquidity Providers (including directed orders submitted by Liquidity Providers acting as Brokerage Customers). Non-directed orders submitted to the ATS by the IBKR SOR may, subject to the terms of the orders, interact with any other order in the ATS.

counterparty_selection

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

financial_condition_summary

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

financial_condition_summary

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

financial_condition_summary

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

financial_condition_summary

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

financial_condition_summary

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

financial_condition_summary

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

financial_condition_summary

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

financial_condition_summary

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

conflict_description

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

conflict_description

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

conflict_description

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

conflict_description

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

conflict_description

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

conflict_description

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

conflict_description

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

conflict_description

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

compliance_officer

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

compliance_officer

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

compliance_officer

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

compliance_officer

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

hours_of_operation

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

hours_of_operation

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

hours_of_operation

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

hours_of_operation

The ATS accepts orders from 8:30 AM ET until 4:00 PM ET. The ATS may effect transactions from 9:30 AM ET until 4:00 PM ET. The ATS observes the New York Stock Exchange's holiday and early close schedule.

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Indications of Interest: The ATS, on a security-by-security basis, disseminates IOIs to the IBKR SOR identifying the symbol, size, side and ranking price of (i) the best-priced resting order of each Liquidity Provider, (ii) the best-priced resting firm order amongst all other subscribers (i.e., of all Brokerage Customers) and (iii) the best-priced resting Conditional Order amongst all Brokerage Customers. For Liquidity Providers, the IOI identifies the best-priced order based on its distance from the NBBO (e.g., NBB + $0.01). Accordingly, for Liquidity Providers, changes to the top-of-book relative to the NBB or NBO (as applicable), will generate a new IOI, as will increases in the size of an order at top of book; however, changes in an order's effective limit price due to changes in the NBBO will not, without more, generate a new IOI. For Brokerage Customers (as a group), IOIs identify the group's best-priced resting buy and sell orders (e.g., if the best-priced buy order has an effective limit price of $20.00, and the best-priced sell order has an effective limit price of $20.05, the relevant IOI will identify the best priced buy and sell order among Brokerage Customers as being $20.00 and $20.05, respectively, rather than such orders' respective distances from the NBBO). The IOIs may also include information regarding the smallest minimum quantity instruction (which may be zero) among resting Brokerage Customer orders priced at or inside the NBBO (including among Conditional Orders priced at or inside the NBBO), including information sufficient for the IBKR SOR to determine whether the order associated with such minimum quantity instruction has an effective limit price that equals or betters (x) the effective limit price of competing Liquidity Providers' orders and/or (y) the NBBO. Accordingly, any changes to the price or size of the top of book for resting Brokerage Customers orders (including resting Conditional Orders), including changes resulting from changes in the NBBO, or to the smallest minimum quantity instruction among resting Brokerage Customer orders priced at or inside the NBBO, including among resting Conditional Orders priced at or inside the NBBO, will generate a new IOI. The SOR utilizes the information contained in the above IOIs in determining whether to route orders to the ATS. All trading interest submitted to the ATS, other than orders directly submitted by Liquidity Providers via FIX connection, passes through the IBKR SOR. The ATS begins transmitting the above IOIs to the SOR at 9:30 ET; the ATS does not transmit the IOIs to any other person or functionality. The ATS does not otherwise transmit IOIs. The ATS does not receive IOIs. Invites: As noted above, Execution Customers may submit Conditional Orders to the ATS. Conditional Orders operate on a conditional basis and require that the submitter "firm-up" its trading interest prior to execution. Where a Conditional Order is the subject of a conditional match, the ATS will notify the subscriber that submitted the Conditional Order (such notification, the "Invite") and request that the subscriber "firm-up" by submitting a firm order ("Firm-Up Orders") in response. While an Invite effectively notes that eligible contraside interest has been submitted to the ATS, the Invite does not otherwise provide any information regarding the non-directed order that triggered the Invite. IBKR Systems (Generally): To the extent an IBKR customer submits an order or other Trading Interest through an IBKR service or functionality, including any order management system, algorithmic trading product or order router operated by IBKR, such service or functionality will have information relating to the order route and any resulting execution or cancellation and persons involved in the operation of these systems will have access to information about orders submitted to or passing through such systems. For instance, those systems through which conditional Orders and Firm-Up Orders are transmitted prior to reaching the SOR (and through which Invites are transmitted prior to reaching the relevant Execution Customer) will have access to informaiton about such Conditional Orders, Firm-Up Orders and Invites.

display_best_quotes

The ATS, on a security-by-security basis, disseminates IOIs to the IBKR SOR identifying the symbol, size, side and ranking price of (i) the best-priced resting order of each Liquidity Provider and (ii) the best-priced resting order amongst all other subscribers (i.e., of all Brokerage Customers). For Liquidity Providers, the IOI identifies the best-priced order based on its distance from the NBBO (e.g., NBB + $0.01). Accordingly, for Liquidity Providers, changes to the top-of-book relative to the NBB or NBO (as applicable), will generate a new IOI, as will increases in the size of an order at top of book; however, changes in an order's effective limit price due to changes in the NBBO will not, without more, generate a new IOI. For Brokerage Customers (as a group), IOIs identify the group's best-priced resting buy and sell orders (e.g., if the best-priced buy order has an effective limit price of $20.00, and the best-priced sell order has an effective limit price of $20.05, the relevant IOI will identify the best priced buy and sell order among Brokerage Customers as being $20.00 and $20.05, respectively, rather than such orders' respective distances from the NBBO). The IOIs may also include information regarding the smallest minimum quantity instruction (which may be zero) among resting Brokerage Customer orders priced at or inside the NBBO, including information sufficient for the IBKR SOR to determine whether the order associated with such minimum quantity instruction has an effective limit price that equals or betters (x) the effective limit price of competing Liquidity Providers' orders and/or (y) the NBBO. Accordingly, any changes to the price or size of the top of book for resting Brokerage Customers orders, including changes resulting from changes in the NBBO, or to the smallest minimum quantity instruction among resting Brokerage Customer orders priced at or inside the NBBO, will generate a new IOI. The SOR utilizes the information contained in the above IOIs in determining whether to route orders to the ATS. All trading interest submitted to the ATS, other than orders directly submitted by Liquidity Providers via FIX connection, passes through the IBKR SOR. The ATS begins transmitting the above IOIs to the SOR at 9:30 ET; the ATS does not transmit the IOIs to any other person or functionality. The ATS does not otherwise transmit IOIs. The ATS does not receive IOIs. To the extent an IBKR customer submits an order through an IBKR service or functionality, including any order management system, algorithmic trading product or order router operated by IBKR, such service or functionality will have information relating to the order route and any resulting execution or cancellation and persons involved in the operation of these systems will have access to information about orders submitted to or passing through such systems.

display_best_quotes

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

display_best_quotes

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

display_best_quotes

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

display_best_quotes

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

display_best_quotes

Indications of Interest: The ATS, on a security-by-security basis, disseminates IOIs to the IBKR SOR identifying the symbol, size, side and ranking price of (i) the best-priced resting order of each Liquidity Provider, (ii) the best-priced resting firm order amongst all other subscribers (i.e., of all Brokerage Customers) and (iii) the best-priced resting Conditional Order amongst all Brokerage Customers. For Liquidity Providers, the IOI identifies the best-priced order based on its distance from the NBBO (e.g., NBB + $0.01). Accordingly, for Liquidity Providers, changes to the top-of-book relative to the NBB or NBO (as applicable), will generate a new IOI, as will increases in the size of an order at top of book; however, changes in an order's effective limit price due to changes in the NBBO will not, without more, generate a new IOI. For Brokerage Customers (as a group), IOIs identify the group's best-priced resting buy and sell orders (e.g., if the best-priced buy order has an effective limit price of $20.00, and the best-priced sell order has an effective limit price of $20.05, the relevant IOI will identify the best priced buy and sell order among Brokerage Customers as being $20.00 and $20.05, respectively, rather than such orders' respective distances from the NBBO). The IOIs may also include information regarding the smallest minimum quantity instruction (which may be zero) among resting Brokerage Customer orders priced at or inside the NBBO (including among Conditional Orders priced at or inside the NBBO), including information sufficient for the IBKR SOR to determine whether the order associated with such minimum quantity instruction has an effective limit price that equals or betters (x) the effective limit price of competing Liquidity Providers' orders and/or (y) the NBBO. Accordingly, any changes to the price or size of the top of book for resting Brokerage Customers orders (including resting Conditional Orders), including changes resulting from changes in the NBBO, or to the smallest minimum quantity instruction among resting Brokerage Customer orders priced at or inside the NBBO, including among resting Conditional Orders priced at or inside the NBBO, will generate a new IOI. The SOR utilizes the information contained in the above IOIs in determining whether to route orders to the ATS. All trading interest submitted to the ATS, other than orders directly submitted by Liquidity Providers via FIX connection, passes through the IBKR SOR. The ATS begins transmitting the above IOIs to the SOR at 9:30 ET; the ATS does not transmit the IOIs to any other person or functionality. The ATS does not otherwise transmit IOIs. The ATS does not receive IOIs. Invites: As noted above, Execution Customers may submit Conditional Orders to the ATS. Conditional Orders operate on a conditional basis and require that the submitter "firm-up" its trading interest prior to execution. Where a Conditional Order is the subject of a conditional match, the ATS will notify the subscriber that submitted the Conditional Order (such notification, the "Invite") and request that the subscriber "firm-up" by submitting a firm order ("Firm-Up Orders") in response. An Invite effectively notes that eligible contraside interest has been submitted to the ATS. Invites also note the size of the eligible contraside interest that generated the Invite, capped at the size of the Execution Customer's Conditional Order. For instance, assume an Execution Customer had submitted a 500-share Conditional Order to the ATS. Where the ATS subsequently received eligible contraside interest in the form of a 100-share non-directed order that would execute against the Conditional Order if the Conditional Order were firm, the Invite to the Execution Customer would indicate that 100-shares of eligible contraside interest had been submitted to the ATS. Where, instead, the ATS received an eligible contraside order for 600-shares, the Invite to the Execution Customer would indicate that 500-shares of eligible contraside interest had been submitted to the ATS . While, as noted in Part III Item 9, Execution Customers may submit Firm-Up Orders that are larger (or smaller) than the corresponding Conditional Order, size information included in an Invite is capped at the size of the corresponding Conditional Order in order to, among other things, limit information leakage. Invites do not otherwise provide any information regarding the non-directed order that triggered the Invite. IBKR Systems (Generally): To the extent an IBKR customer submits an order or other Trading Interest through an IBKR service or functionality, including any order management system, algorithmic trading product or order router operated by IBKR, such service or functionality will have information relating to the order route and any resulting execution or cancellation and persons involved in the operation of these systems will have access to information about orders submitted to or passing through such systems. For instance, those systems through which conditional Orders and Firm-Up Orders are transmitted prior to reaching the SOR (and through which Invites are transmitted prior to reaching the relevant Execution Customer) will have access to informaiton about such Conditional Orders, Firm-Up Orders and Invites.

display_best_quotes

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

display_best_quotes

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

display_best_quotes

The ATS, on a security-by-security basis, disseminates IOIs to the IBKR SOR identifying the symbol, size, side and ranking price of (i) the best-priced resting order of each Liquidity Provider and (ii) the best-priced resting order amongst all other subscribers. For Liquidity Providers, the IOI identifies the best-priced order based on its distance from the NBBO (e.g., NBB + $0.01). Accordingly, for Liquidity Providers, changes to the top-of-book relative to the NBB or NBO (as applicable), will generate a new IOI, as will increases in the size of an order at top of book; however, changes in an order's effective limit price due to changes in the NBBO will not, without more, generate a new IOI. For non-Liquidity Providers (as a group), IOIs identify the group's best-priced resting buy and sell orders (e.g., if the best-priced buy order has an effective limit price of $20.00, and the best-priced sell order has an effective limit price of $20.05, the relevant IOI will identify the best priced buy and sell order among non-Liquidity Providers as being $20.00 and $20.05, respectively, rather than such orders' respective distances from the NBBO). Accordingly, any changes to the price or size of the top of book for resting non-Liquidity Provider orders, including changes resulting from changes in the NBBO, will generate a new IOI. The SOR utilizes the information contained in the above IOIs in determining whether to route orders to the ATS. All trading interest submitted to the ATS, other than orders directly submitted by Liquidity Providers via FIX connection, passes through the IBKR SOR. The ATS begins transmitting the above IOIs to the SOR at 9:30 ET; the ATS does not transmit the IOIs to any other person or functionality. The ATS does not otherwise transmit IOIs. The ATS does not receive IOIs. To the extent an IBKR customer submits an order through an IBKR service or functionality, including any order management system, algorithmic trading product or order router operated by IBKR, such service or functionality will have information relating to the order route and any resulting execution or cancellation and persons involved in the operation of these systems will have access to information about orders submitted to or passing through such systems.

execution_services

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

execution_services

The ATS does not perform any opening or reopening cross. The ATS begins matching orders at 9:30 ET.