Stifel X

amendment_reason

The changes in this amendment relate to (A) Part II, Items 5 and 7; (B) Part III Items 1 and 2(b); and (C) Part III, Items 5(c), 13, and 15. The changes to these sections relate to additional means by which certain institutions can direct that their orders route directly to STFX if the institution meets certain criteria. These additional means are not available to retail participants. In addition, the amendments discuss how these changes impact confidentiality and order displays. These changes apply only to institutional participants.

amendment_reason

These changes apply to all subscribers and broker-dealer operators and relate to Part I Item 8, Part II, Items 2(a) 5(a), 6(a), 6(b), and 7; and Part III, Items 2(b), 5(c), 7(a), 10(a), 10(c), 11(a), 11(c), 13, and 15(b). The changes are updating amendments to reflect changes to STFL's officers and directors, certain affiliate name changes and activities, the removal of an affiliate, and an update with conforming changes reflect that Stifel only maintains one smart order router platform as the sole point of entry to the ATS.

amendment_reason

These changes apply to all subscribers and broker-dealer operators and relate to Part II, Item 5(a) and Part III, Items 1 and 5(c). These amendments correct the description of certain Subscribers that were previously described as Participants, including to reflect that certain non-affiliated broker-dealers are Subscribers.

amendment_reason

The changes in this amendment apply to certain subscribers, but do not apply to the broker-dealer operator. The changes apply to Part II Items 5(a) and 5(c), and Part III Items 1, 2(b), 5(c), and 13, and relate to unaffiliated broker-dealers being able to direct their retail order flow to STFX.

amendment_reason

These changes relate to Part III Item 2(b) and apply to certain subscribers, but do not apply to the broker-dealer operator. The changes are to reflect a new assets under management threshold to meet the requirements of an Institutional Participant (e.g., banks, insurance companies, mutual fund companies, registered investment advisors, pension funds, hedge funds, and other money managers) that may request a customized STFL SOR routing configuration.

amendment_reason

This is a correcting amendment to the material amendment filed on January 8, 2024 (Accession No. 0000950123-24-000052). The changes in this amendment apply to certain subscribers, but do not apply to the broker-dealer operator. The changes apply to Part II Item 5(a) and are being made to conform certain language to be consistent with the language in Part III Item 5(c). Specifically, the changes relate to the routing of orders by certain Directed Participants.

ats_name

Stifel X

operator_crd

000000793

operator_name

STIFEL, NICOLAUS & COMPANY, INCORPORATED

order_types

All orders within the STFX limit order book are subject to price then time priority. Upon receipt of a valid order from the STFL SOR, STFX applies an "Assigned Limit Price". The Assigned Limit Price of an order is the highest price for a buy order (lowest for a sell order) at which the order may be executed at or within the National Best Bid and Offer ("NBBO") after applying the constraints submitted to STFX by the Participant and/or the SOR (i.e., limit price or pegged order type). Assigned Limit Prices will be updated as necessary with each change in the NBBO. STFX will not apply an Assigned Limit Price worse than the Limit Price received on the order from the SOR - a Limit Price may be set by the Participant or by a STFL Algorithm and/or the SOR. STFL Algorithms and the SOR may independently submit a limit price and/or peg, time in force, and MinQty condition to STFX based on their design in achieving specific execution benchmarks and satisfying Participant order handling instructions. In any instance, a STFL Algorithm and/or SOR the submitted limit price or condition will not violate the Participant submitted limit price or condition. STFX does not have any order types that allow for routing to other Trading Centers, or that are designed not remove liquidity (e.g., post-only orders). All order types are the same across all access points to the ATS. The following order price types are available on STFX. 1. Limit Orders - Limit Orders, which are determined by the Participant or by a STFL algorithm and/or the SOR are posted to the STFX order book with an Assigned Limit Price equal to the received order's Limit Price with the following exceptions: Orders received with Limit Prices outside the NBBO (i.e., at prices higher than the NBBO for buy orders and lower than the NBBO for sell orders) are given an Assigned Limit Price at the NBBO. For example, if the NBBO is $10.00 x $11.00, a buy order with a limit price of $12.00 will have an Assigned Limit Price of $11.00. Pursuant to Rule 612 under Regulation NMS, orders with a price not within the minimum quotation increment will be rejected. For orders in stocks priced at or above $1.00, the minimum increment is $0.01. For orders in stocks priced below $1.00, the minimum increment is $0.0001. STFX will abide by these pricing requirements. No order will be executed at a price worse than the order's Limit Price. If a Participant or a STFL algorithm/the SOR amends the Limit Price of an order submitted to STFX, the ATS will update the Assigned Limit Price as necessary. 2. Market Orders - Market Orders are posted to the STFX order book with an Assigned Limit Price equal to the far price of the NBBO. For example, if the NBBO is $10.00 x $11.00, a buy market order will have an Assigned Limit Price of $11.00, while a sell market order will have an Assigned Limit Price of $10.00. Participant and/or STFL algorithm/SOR-initiated Limit Price changes will result in a new time stamp and the resetting of time priority. The following order conditions are available on STFX. 1. Pegged Orders - Pegged Orders are posted to the STFX order book, subject to regulatory considerations, with an Assigned Limit Price determined by the prevailing NBBO and any Participant and/or STFL algorithm/SOR submitted limit price. STFX continuously reevaluates and updates the Assigned Limit Price for Pegged Orders for changes in the NBBO. Changes in the Assigned Limit Price due to a pegged order condition do not affect time priority. The three peg conditions are (i) Midpoint Peg - order is pegged as close as possible to the midpoint of the current NBBO; (ii) Market Peg - order is pegged to the far side of the market NBBO; (iii) Primary Peg - the order is pegged to the near side of NBBO. For example, if a stock is trading with an NBBO of $10.00 x $11.00, a Midpoint Peg buy order with no limit would have an Assigned Limit Price of $10.50. A Midpoint Peg buy order with a Participant submitted limit of $10.00 would have an Assigned Limit Price of $10.00. A Primary Peg buy order with no Participant submitted limit would have an Assigned Limit Price of $10.00. A Market Peg buy order with no Participant submitted limit would have an Assigned Limit Price of $11.00. For securities priced under $1.00, if the Assigned Limit Price of an order is the midpoint of the NBBO, STFX will conservatively round the price from five decimal places to four decimal places - i.e., the price of a buy order will be rounded down, and the price of a sell order will be rounded up. Other regulatory considerations are market-wide circuit breakers, and Limit Up / Limit Down / Regulation SHO conditions. Pegged orders are executable subject to price-time priority when a contra-order satisfies the pegged order's Assigned Limit Price and applicable MinQty constraints. Participant or STFL algorithm/SOR-initiated amendments to a Peg Condition result in the resetting of time priority. STFX-initiated changes to the Assigned Limit Price due to changes in the NBBO do not result in a new time stamp or change in the time priority. The execution price for Peg Orders in general is discussed in detail in Part III, Item 11c under Price Improvement. 2. Day or IOC Orders - Day orders remain in the STFX order book until cancelled, the full quantity is executed, or the market closes. A Participant may modify, replace, or cancel day orders. Immediate-or-Cancel ("IOC") Orders will match immediately with eligible resting providing orders after which STFX will cancel back the balance. IOC orders may not be modified, replaced or cancelled. Participants can change a Day order to an IOC order. At such time, STFX will update the Assigned Limit Price of the order as necessary, along with its Time Priority, then execute or cancel the unexecuted balance of the order. 3. Minimum Execution Quantity - Participants and/or a STFL algorithm/SOR may submit an order with a Minimum Execution Quantity (MinQty) Condition. STFX does not aggregate contra-side orders to meet the MinQty. The MinQty specified on an order can only be filled by a single contra-side order. All contra-side orders matched with an order with a specified MinQty condition must satisfy that MinQty. STFX cancels an order if the order's remaining quantity is less than the MinQty. Participant and/or STFL algorithm/SOR-initiated amendments to a Peg Condition, Minimum Execution Quantity, or Time in Force (day/IOC), will result in a new time stamp and the resetting of time priority. Limit Orders may be combined with any Peg Condition, MinQty Condition, or Time in Force as instructed by the Participant and/or the STFL algorithm/SOR. At the discretion of the Participant and/or the STFL Algorithm/SOR, all orders, except for IOC orders, can be modified or cancelled. Participant defined Price Limits and/or order conditions cannot be violated by an algorithm or the SOR. STFX may reject or cancel an order that does not pass validation; for example, if the order message contains: an invalid or missing handling instruction, a missing parameter (e.g., order side), a MinQty that is greater than the order quantity, or an invalid symbol. Alternatively, orders may be cancelled upon STFX support personnel initiating a system-wide or symbol-specific "block" due to STFL or NASDAQ technical or operational issues (i.e., loss of FIX connectivity or primary and backup hardware failure). During a "block," STFX will immediately cancel all open orders in affected stocks on the order book and prohibit further order entry, order cancellation, and order replacement. In addition, STFX will prevent crossing in stocks with an NBBO that is locked or crossed. At the end of the regular session, STFX will cancel all open orders

order_types

All orders within the STFX limit order book are subject to price then time priority. Upon receipt of a valid order from a STFL SOR, STFX applies an "Assigned Limit Price". The Assigned Limit Price of an order is the highest price for a buy order (lowest for a sell order) at which the order may be executed at or within the National Best Bid and Offer ("NBBO") after applying the constraints submitted to STFX by the Participant and/or SOR (i.e., limit price or pegged order type). Assigned Limit Prices will be updated as necessary with each change in the NBBO. STFX will not apply an Assigned Limit Price worse than the Limit Price received on the order from the SOR - a Limit Price may be set by the Participant or by a STFL Algorithm and/or SOR. STFL Algorithms and SORs may independently submit a limit price and/or peg, time in force, and MinQty condition to STFX based on their design in achieving specific execution benchmarks and satisfying Participant order handling instructions. In any instance, a STFL Algorithm and/or SOR submitted limit price or condition will not violate the Participant submitted limit price or condition. STFX does not have any order types that allow for routing to other Trading Centers, or that are designed not remove liquidity (e.g., post-only orders). All order types are the same across all access points to the ATS. The following order price types are available on STFX. 1. Limit Orders - Limit Orders, which are determined by the Participant or by a STFL algorithm and/or SOR are posted to the STFX order book with an Assigned Limit Price equal to the received order's Limit Price with the following exceptions: Orders received with Limit Prices outside the NBBO (i.e., at prices higher than the NBBO for buy orders and lower than the NBBO for sell orders) are given an Assigned Limit Price at the NBBO. For example, if the NBBO is $10.00 x $11.00, a buy order with a limit price of $12.00 will have an Assigned Limit Price of $11.00. Pursuant to Rule 612 under Regulation NMS, orders with a price not within the minimum quotation increment will be rejected. For orders in stocks priced at or above $1.00, the minimum increment is $0.01. For orders in stocks priced below $1.00, the minimum increment is $0.0001. STFX will abide by these pricing requirements. No order will be executed at a price worse than the order's Limit Price. If a Participant or a STFL algorithm/SOR amends the Limit Price of an order submitted to STFX, the ATS will update the Assigned Limit Price as necessary. 2. Market Orders - Market Orders are posted to the STFX order book with an Assigned Limit Price equal to the far price of the NBBO. For example, if the NBBO is $10.00 x $11.00, a buy market order will have an Assigned Limit Price of $11.00, while a sell market order will have an Assigned Limit Price of $10.00. Participant and/or STFL algorithm/SOR-initiated Limit Price changes will result in a new time stamp and the resetting of time priority. The following order conditions are available on STFX. 1. Pegged Orders - Pegged Orders are posted to the STFX order book, subject to regulatory considerations, with an Assigned Limit Price determined by the prevailing NBBO and any Participant and/or STFL algorithm/SOR submitted limit price. STFX continuously reevaluates and updates the Assigned Limit Price for Pegged Orders for changes in the NBBO. Changes in the Assigned Limit Price due to a pegged order condition do not affect time priority. The three peg conditions are (i) Midpoint Peg - order is pegged as close as possible to the midpoint of the current NBBO; (ii) Market Peg - order is pegged to the far side of the market NBBO; (iii) Primary Peg - the order is pegged to the near side of NBBO. For example, if a stock is trading with an NBBO of $10.00 x $11.00, a Midpoint Peg buy order with no limit would have an Assigned Limit Price of $10.50. A Midpoint Peg buy order with a Participant submitted limit of $10.00 would have an Assigned Limit Price of $10.00. A Primary Peg buy order with no Participant submitted limit would have an Assigned Limit Price of $10.00. A Market Peg buy order with no Participant submitted limit would have an Assigned Limit Price of $11.00. For securities priced under $1.00, if the Assigned Limit Price of an order is the midpoint of the NBBO, STFX will conservatively round the price from five decimal places to four decimal places - i.e., the price of a buy order will be rounded down, and the price of a sell order will be rounded up. Other regulatory considerations are market-wide circuit breakers, and Limit Up / Limit Down / Regulation SHO conditions. Pegged orders are executable subject to price-time priority when a contra-order satisfies the pegged order's Assigned Limit Price and applicable MinQty constraints. Participant or STFL algorithm/SOR-initiated amendments to a Peg Condition result in the resetting of time priority. STFX-initiated changes to the Assigned Limit Price due to changes in the NBBO do not result in a new time stamp or change in the time priority. The execution price for Peg Orders in general is discussed in detail in Part III, Item 11c under Price Improvement. 2. Day or IOC Orders - Day orders remain in the STFX order book until cancelled, the full quantity is executed, or the market closes. A Participant may modify, replace, or cancel day orders. Immediate-or-Cancel ("IOC") Orders will match immediately with eligible resting providing orders after which STFX will cancel back the balance. IOC orders may not be modified, replaced or cancelled. Participants can change a Day order to an IOC order. At such time, STFX will update the Assigned Limit Price of the order as necessary, along with its Time Priority, then execute or cancel the unexecuted balance of the order. 3. Minimum Execution Quantity - Participants and/or a STFL algorithm/SOR may submit an order with a Minimum Execution Quantity (MinQty) Condition. STFX does not aggregate contra-side orders to meet the MinQty. The MinQty specified on an order can only be filled by a single contra-side order. All contra-side orders matched with an order with a specified MinQty condition must satisfy that MinQty. STFX cancels an order if the order's remaining quantity is less than the MinQty. Participant and/or STFL algorithm/SOR-initiated amendments to a Peg Condition, Minimum Execution Quantity, or Time in Force (day/IOC), will result in a new time stamp and the resetting of time priority. Limit Orders may be combined with any Peg Condition, MinQty Condition, or Time in Force as instructed by the Participant and/or the STFL algorithm/SOR. At the discretion of the Participant and/or the STFL Algorithm/SOR, all orders, except for IOC orders, can be modified or cancelled. Participant defined Price Limits and/or order conditions cannot be violated by an algorithm or SOR. STFX may reject or cancel an order that does not pass validation; for example, if the order message contains: an invalid or missing handling instruction, a missing parameter (e.g., order side), a MinQty that is greater than the order quantity, or an invalid symbol. Alternatively, orders may be cancelled upon STFX support personnel initiating a system-wide or symbol-specific "block" due to STFL or NASDAQ technical or operational issues (i.e., loss of FIX connectivity or primary and backup hardware failure). During a "block," STFX will immediately cancel all open orders in affected stocks on the order book and prohibit further order entry, order cancellation, and order replacement. In addition, STFX will prevent crossing in stocks with an NBBO that is locked or crossed. At the end of the regular session, STFX will cancel all open orders

pricing_methodology

STFX uses the services of NASDAQ OCEAN to manage the consumption of market data and derive the NBBO for use in pricing, prioritizing and executing orders. STFX can only execute orders at or within the NBBO. NASDAQ OCEAN utilizes the NASDAQ UltraFeed as its primary source of direct exchange data for all but the IEX, NYSE National, and CHX. The fully redundant feed from the securities information processor ("SIP") is utilized for the IEX, NYSE National, and CHX, as well as for redundancy purposes with all other exchanges. The SIP is also utilized for Limit Up / Limit Down and regulatory halt conditions. NASDAQ OCEAN systematically monitors direct feeds provided by UltraFeed and the SIP for latency. Should latency in the direct feeds exceed a threshold determined by NASDAQ OCEAN, crossing in affected symbols is automatically placed into a paused state until the issue is resolved or automatic failover to the SIP occurs. If failover occurs, STFX will utilize the SIP NBBO to resume and price transactions.

counterparty_selection

Orders can be designated to interact or not interact with certain orders based on (i) the Participant's assigned Segmentation Category and its use by the Segmentation Restrictions order parameter, or (ii) the self-match prevention order parameter. The specific process by which Segmentation Categories/Restrictions are assigned and implemented are discussed in Part III, Item 13a. At the request of the Participant, the self-match prevention parameter is configured within the ATS by STFX support personnel. This parameter allows Participants to prohibit their own orders from crossing with each other. Requests to enable self-match prevention must be received in writing and will become effective at the start of the following regular trading session.

financial_condition_summary

N/A- There are no fees or charges for use of STFX.

conflict_description

Yes, the list of STFL affiliates that can enter orders or direct the entry of orders and trading interest into STFX are listed below. AFFILIATE NAME: Stifel Independent Advisors, LLC TYPE OF ENTITY: SEC Registered Investment Adviser/Broker-Dealer CAPACITY: Agency MPID: CSAI AFFILIATE NAME: 1919 Investment Counsel, LLC TYPE OF ENTITY: SEC Registered Investment Adviser CAPACITY: Agency MPID: N/A AFFILIATE NAME: EquityCompass Investment Management, LLC TYPE OF ENTITY: SEC Registered Investment Adviser CAPACITY: Agency MPID: N/A AFFILIATE NAME: Keefe, Bruyette & Woods, Inc. TYPE OF ENTITY: U.S. Registered Broker-Dealer CAPACITY: Agency MPID: KBWI AFFILIATE NAME: : Stifel Europe Bank AG TYPE OF ENTITY: Non-U.S. Broker-Dealer (German Broker-Dealer Equivalent) CAPACITY: Agency MPID: MNFB AFFILIATE NAME: Stifel Nicolaus Europe Limited TYPE OF ENTITY: Non-U.S. Investment manager CAPACITY: Agency MPID: N/A AFFILIATE NAME: Stifel Nicolaus Canada Inc. TYPE OF ENTITY: Institutional Broker (Canadian Broker-Dealer equivalent) CAPACITY: Agency MPID: SFCN AFFILIATE NAME: Washington Crossing Advisors LLC TYPE OF ENTITY: SEC Registered Investment Adviser CAPACITY: Agency MPID: N/A

conflict_description

Yes, the list of STFL affiliates that can enter orders or direct the entry of orders and trading interest into STFX are listed below. AFFILIATE NAME: Century Securities Associates, Inc. TYPE OF ENTITY: SEC Registered Investment Adviser/Broker-Dealer CAPACITY: Agency MPID: CSAI AFFILIATE NAME: 1919 Investment Counsel, LLC TYPE OF ENTITY: SEC Registered Investment Adviser CAPACITY: Agency MPID: N/A AFFILIATE NAME: EquityCompass Investment Management, LLC TYPE OF ENTITY: SEC Registered Investment Adviser CAPACITY: Agency MPID: N/A AFFILIATE NAME: FSI Capital Holdings TYPE OF ENTITY: State Investment Adviser CAPACITY: Agency MPID: N/A AFFILIATE NAME: Keefe, Bruyette & Woods, Inc. TYPE OF ENTITY: U.S. Registered Broker-Dealer CAPACITY: Agency MPID: KBWI AFFILIATE NAME: Main First TYPE OF ENTITY: Non-U.S. Broker-Dealer (German Broker-Dealer Equivalent) CAPACITY: Agency MPID: MNFB AFFILIATE NAME: Stifel Nicolaus Europe Limited TYPE OF ENTITY: Non-U.S. Investment manager CAPACITY: Agency MPID: N/A AFFILIATE NAME: Stifel Nicolaus Canada Inc. TYPE OF ENTITY: Institutional Broker (Canadian Broker-Dealer equivalent) CAPACITY: Agency MPID: SFCN AFFILIATE NAME: Washington Crossing Advisors LLC TYPE OF ENTITY: SEC Registered Investment Adviser CAPACITY: Agency MPID: N/A

compliance_officer

STFL SAFEGUARDS REGARDING CONFIDENTIAL TRADING INFORMATION STFL has established and maintains written supervisory policies and procedures to protect confidential trading information related to all STFL products and services, including STFX. For purposes of this response, confidential information consists of Participants' identities, orders, transactions, strategies, and activities. All STFL personnel are subject to annual training regarding privacy and confidential information. Per firm policy, authorized STFL personnel have access to confidential information specific to STFX and/or its configuration as needed to fulfill their roles and responsibilities related to the operation and support of STFX. Authorized STFL personnel are strictly prohibited from using such information in an unauthorized manner and from discussing the details of any orders or executed trades occurring in STFX with persons who do not need such information to carry out their designated duties. The STFX matching engine is hosted and operated by NASDAQ. In turn, the ATS matching engine and limit order book reside on hardware that is physically separate from STFL locations, systems, and personnel. Participant confidential information pertaining to STFX is accessible by authorized STFL personnel via the PETD algorithm and SOR environment and related databases/data repositories, the STFL compliance data repository, the NASDAQ OceanView GUI, the NASDAQ SMARTS surveillance system, and the NASDAQ cloud-based data warehouse. Access is granted to one or more of these environments, systems, data repositories, or data warehouses by the Head of Equity Trading and their designee, or the Chief Institutional Equity Compliance Officer and their designee. Only the designated compliance officer can grant access to compliance surveillance systems and data repositories. Access to all systems containing confidential information is controlled by password and entitlements and/or two-factor authentication. STFL personnel with access to real-time Participant confidential information are physically separated from general sales and trading staff on STFL's trading floor. Specific policies and procedures are applied as follows: 1. Detect and prevent insider trading (including information barriers and Fire Walls): STFL's Written Standard Procedures prohibit PETD staff from disclosing the identity of Participants and such persons' orders or executions other than to authorized Compliance, Supervision, Trading Management, Platform Technical Support, and Back Office personnel. As part of these controls, login credentials that are granted by the Head of Equity Trading or his/her designee control access to STFL's order management systems and execution data. These login credentials and their use is tracked. STFL Personnel are permitted to view information specific to their roles and/or the clients under their coverage. This information may include the algorithm or SOR used and the venue of execution. STFL order management systems do not contain any data relating to the specific operation of STFX. Access to systems containing confidential STFX specific information such as resting orders or Participant identities is restricted by a combination of login credentials, electronic tokens, two-factor authentication, and IP whitelisting. The Head of Equity Trading or his/her designee are the only entities who can grant and revoke access to STFX operational systems. 2. Restrict trading in personal accounts of certain STFL personnel and transactions in employee and employee-related accounts: All personnel supporting the operation of STFX are subject to STFL's personal trading policy and supervision. This policy requires STFL employees to maintain personal trading accounts at STFL and obtain prior written approval for all transactions in NMS stocks via STFL's EQUBE System and its Control Room. Approval is based on the STFL restricted list and the employee's response to questions regarding their access to material, nonpublic information, their potential role as a market maker in the requested security, their knowledge of client orders in the requested security, and their acknowledgement of the firm's holding period restriction (i.e., 30 days with an exception for unrealized losses in excess of certain thresholds). 3. Prohibit certain activity that would disseminate confidential information, such as (i) limit the ability to reproduce or distribute "internal use only" or "broker/dealer only" items externally and (ii) prohibit the misuse of information obtained in a fiduciary capacity, or the sharing of information with any other unauthorized persons (e.g., spouses, relatives, household members, etc.). As it relates to STFX, this type of "internal use only" information includes daily STFX surveillance and end-of-day activity reports that NASDAQ makes available to authorized STFL personnel by electronic drop-copy to secure storage. Files are then archived on STFL's compliance data repository system. 4. Review electronic communications: All electronic communications by STFX support staff are subject to random and periodic review. 5. Govern employee-related and proprietary trading: Employee and principal (i.e., STFL acting as principal) transactions are not routed to STFX for execution, to mitigate the possibility of conflicts of interests. Internal and external auditors periodically review for compliance with firm policies and procedures governing all operational aspects of STFL PETD products, including STFX. STFL internal audit prepares, maintains, and distributes audit fieldwork for these products including STFX and reports to Supervision and Management. Access to NASDAQ Systems The following are NASDAQ-hosted systems accessible by STFL authorized personnel based on their specific roles and responsibilities in the operation and support of STFX. Access is granted by written request to NASDAQ by STFL's Head of Equity Trading or his/her designee. Access by STFL personnel is reviewed monthly by NASDAQ and provided to STFL for review. a. Configuration API - STFL personnel control and configure STFX through the Configuration API system. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading Desk authorize Configuration API system access based on the requesting employee's designated role and responsibilities. By way of example, crossing rules and order type parameters are changed by file submission to the Configuration API with access controlled by electronic tokens and access keys. b. OceanView GUI - The OceanView GUI is a secure web application that allows personnel responsible for the support and supervision of the ATS to view summary and detailed order, transaction, configuration, and reporting information. Specifically, it allows role-designated STFL personnel on the PETD, in compliance, and in IT to administer the operational aspects of STFX, including such things as connectivity, risk settings, symbol maintenance, and trade review/cancelation. Access to the OceanView GUI is controlled by integration to the NetIQ 2FA system that requires two-factor authentication. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading Desk authorize OceanView GUI system access based on the requesting employee's designated role and responsibilities. Authorized personnel with access to the OceanView GUI are separated from non-ATS and non-Algorithmic sales and trading personnel by a physical information barrier. To the extent that any authorized STFL personnel (i.e., the manager of the PETD) is also involved in the execution of transactions in NMS stock for a client or the firm, such personnel will do so from the other side of the information barrier, on a system without access to the OceanView GUI. c. JIRA Incident Management ("JIRA") - JIRA is a software system for STFL developers and NASDAQ technical support personnel to track technical issues pertaining to STFX. Access to JIRA is controlled by integration to the NetIQ 2FA system that uses two-factor authentication. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading desk authorize access by STFL personnel to the STFX instance of the JIRA system based on the requesting employee's designated role and responsibilities. d. Short-Term Data Warehouse and Long-Term Storage (AWS Environment) - STFL developers access historical data from NASDAQ's AWS Environment to facilitate ATS specific transaction analysis, regulatory reporting, and summary management reporting. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading desk authorize access to the AWS environment based on the requesting employee's designated role and responsibilities. e. NASDAQ SMARTS - SMARTS is a compliance software system provided by NASDAQ to STFL compliance and supervision personnel to facilitate in the surveillance of all activity in STFX. STFL's Head of Equity Trading or STFL's Equities Chief Compliance Officer authorize SMARTS access to compliance personnel based on their designated role and responsibilities. OCEAN Personnel Certain OCEAN and NASDAQ employees have access to Participant confidential trading information. Such employees include OCEAN and NASDAQ staff from Compliance, Operations, Technology Development (including trading and surrounding systems), Product Management, and Business Management. The confidential trading information consists of information regarding individual orders and executions, Participant codes, and order volume summaries in STFX. OCEAN's policies and procedures employ a three-pronged approach to permit access to STFX. First, an employee must complete compliance training specific to the OCEAN business unit. Second, an OCEAN employee must request, and OCEAN Compliance must approve, access to each specific system based on the employee's designated role and responsibilities. Third, once approved, the OCEAN employee must complete OCEAN's annual Compliance training. OCEAN employees that have access to confidential trading information are subject to OCEAN's "Information Barriers and Conflict Management Policies and Procedures." All OCEAN employees are subject to NASDAQ's Global Trading Policy ("GTP"), which outlines all requirements and restrictions related to personal trading activity including holding periods, annual attestations, IPO restrictions and a prohibited list. OCEAN employees are required to disclose personal investment and brokerage accounts, positions, and transactions. NASDAQ's Global Ethics Team monitors personal trade activities against the GTP. OCEAN also conducts electronic communications reviews to identify policy violations including noncompliance with the above referenced policies and procedures. STFL has the right to audit OCEAN's operation of STFX, including OCEAN's access to and use of Participant confidential trading information either through audits conducted by STFL's own audit team or by third-party auditors. Such audits may be conducted on-site or off-site. OCEAN also is obligated to notify STFL of any actual or suspected unauthorized access to confidential information, which includes Participant confidential trading information, in a timely manner.

compliance_officer

STFL SAFEGUARDS REGARDING CONFIDENTIAL TRADING INFORMATION STFL has established and maintains written supervisory policies and procedures to protect confidential trading information related to all STFL products and services, including STFX. For purposes of this response, confidential information consists of Participants' identities, orders, transactions, strategies, and activities. All STFL personnel are subject to annual training regarding privacy and confidential information. Per firm policy, authorized STFL personnel have access to confidential information specific to STFX and/or its configuration as needed to fulfill their roles and responsibilities related to the operation and support of STFX. Authorized STFL personnel are strictly prohibited from using such information in an unauthorized manner and from discussing the details of any orders or executed trades occurring in STFX with persons who do not need such information to carry out their designated duties. Additionally, neither of the two SOR platforms that directly access STFX take into account means of entry or the type of participant (i.e., Retail Participant, Institutional Participant, or Directed Participant) when sending subsequent orders to or canceling orders from STFX. The applicable STFL SOR platform, however, does not share such order information specifically pertaining to exclusive routes to STFX with any other Stifel trading system, desk, or any third party, other than with personnel who require access to address operational, technological, legal, or compliance issues that may arise with STFX or the STFL SOR. The same client onboarding information is requested from both Participants and Directed Participants. Participants also cannot opt out of the STFL SOR having knowledge of orders bound for STFX. This information is inherent in the operation of STFX. The STFL SOR does not generate indications of interest based on STFX information. The STFX matching engine is hosted and operated by NASDAQ. In turn, the ATS matching engine and limit order book reside on hardware that is physically separate from STFL locations, systems, and personnel. Participant confidential information pertaining to STFX is accessible by authorized STFL personnel via the PETD algorithm and SOR environment and related databases/data repositories, the STFL compliance data repository, the NASDAQ OceanView GUI, the NASDAQ SMARTS surveillance system, and the NASDAQ cloud-based data warehouse. Access is granted to one or more of these environments, systems, data repositories, or data warehouses by the Head of Equity Trading and their designee, or the Chief Institutional Equity Compliance Officer and their designee. Only the designated compliance officer can grant access to compliance surveillance systems and data repositories. Access to all systems containing confidential information is controlled by password and entitlements and/or two-factor authentication. STFL personnel with access to real-time Participant confidential information are physically separated from general sales and trading staff on STFL's trading floor. Specific policies and procedures are applied as follows: 1. Detect and prevent insider trading (including information barriers and Fire Walls): STFL's Written Standard Procedures prohibit PETD staff from disclosing the identity of Participants and such persons' orders or executions other than to authorized Compliance, Supervision, Trading Management, Platform Technical Support, and Back Office personnel. As part of these controls, login credentials that are granted by the Head of Equity Trading or his/her designee control access to STFL's order management systems and execution data. These login credentials and their use is tracked. STFL Personnel are permitted to view information specific to their roles and/or the clients under their coverage. This information may include the algorithm or SOR used and the venue of execution. STFL order management systems do not contain any data relating to the specific operation of STFX. Access to systems containing confidential STFX specific information such as resting orders or Participant identities is restricted by a combination of login credentials, electronic tokens, two-factor authentication, and IP whitelisting. The SORs do not take into account means of entry or the type of participant (i.e., Retail Participant, Institutional Participants, or Directed Participant) when sending subsequent orders to or canceling orders from STFX. The Head of Equity Trading or his/her designee are the only entities who can grant and revoke access to STFX operational systems. 2. Restrict trading in personal accounts of certain STFL personnel and transactions in employee and employee-related accounts: All personnel supporting the operation of STFX are subject to STFL's personal trading policy and supervision. This policy requires STFL employees to maintain personal trading accounts at STFL and obtain prior written approval for all transactions in NMS stocks via STFL's EQUBE System and its Control Room. Approval is based on the STFL restricted list and the employee's response to questions regarding their access to material, nonpublic information, their potential role as a market maker in the requested security, their knowledge of client orders in the requested security, and their acknowledgement of the firm's holding period restriction (i.e., 30 days with an exception for unrealized losses in excess of certain thresholds). 3. Prohibit certain activity that would disseminate confidential information, such as (i) limit the ability to reproduce or distribute "internal use only" or "broker/dealer only" items externally and (ii) prohibit the misuse of information obtained in a fiduciary capacity, or the sharing of information with any other unauthorized persons (e.g., spouses, relatives, household members, etc.). As it relates to STFX, this type of "internal use only" information includes daily STFX surveillance and end-of-day activity reports that NASDAQ makes available to authorized STFL personnel by electronic drop-copy to secure storage. Files are then archived on STFL's compliance data repository system. 4. Review electronic communications: All electronic communications by STFX support staff are subject to random and periodic review. 5. Govern employee-related and proprietary trading: Employee and principal (i.e., STFL acting as principal) transactions are not routed to STFX for execution, to mitigate the possibility of conflicts of interests. Internal and external auditors periodically review for compliance with firm policies and procedures governing all operational aspects of STFL PETD products, including STFX. STFL internal audit prepares, maintains, and distributes audit fieldwork for these products including STFX and reports to Supervision and Management. Access to NASDAQ Systems The following are NASDAQ-hosted systems accessible by STFL authorized personnel based on their specific roles and responsibilities in the operation and support of STFX. Access is granted by written request to NASDAQ by STFL's Head of Equity Trading or his/her designee. Access by STFL personnel is reviewed monthly by NASDAQ and provided to STFL for review. a. Configuration API - STFL personnel control and configure STFX through the Configuration API system. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading Desk authorize Configuration API system access based on the requesting employee's designated role and responsibilities. By way of example, crossing rules and order type parameters are changed by file submission to the Configuration API with access controlled by electronic tokens and access keys. b. OceanView GUI - The OceanView GUI is a secure web application that allows personnel responsible for the support and supervision of the ATS to view summary and detailed order, transaction, configuration, and reporting information. Specifically, it allows role-designated STFL personnel on the PETD, in compliance, and in IT to administer the operational aspects of STFX, including such things as connectivity, risk settings, symbol maintenance, and trade review/cancelation. Access to the OceanView GUI is controlled by integration to the NetIQ 2FA system that requires two-factor authentication. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading Desk authorize OceanView GUI system access based on the requesting employee's designated role and responsibilities. Authorized personnel with access to the OceanView GUI are separated from non-ATS and non-Algorithmic sales and trading personnel by a physical information barrier. To the extent that any authorized STFL personnel (i.e., the manager of the PETD) is also involved in the execution of transactions in NMS stock for a client or the firm, such personnel will do so from the other side of the information barrier, on a system without access to the OceanView GUI. c. JIRA Incident Management ("JIRA") - JIRA is a software system for STFL developers and NASDAQ technical support personnel to track technical issues pertaining to STFX. Access to JIRA is controlled by integration to the NetIQ 2FA system that uses two-factor authentication. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading desk authorize access by STFL personnel to the STFX instance of the JIRA system based on the requesting employee's designated role and responsibilities. d. Short-Term Data Warehouse and Long-Term Storage (AWS Environment) - STFL developers access historical data from NASDAQ's AWS Environment to facilitate ATS specific transaction analysis, regulatory reporting, and summary management reporting. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading desk authorize access to the AWS environment based on the requesting employee's designated role and responsibilities. e. NASDAQ SMARTS - SMARTS is a compliance software system provided by NASDAQ to STFL compliance and supervision personnel to facilitate in the surveillance of all activity in STFX. STFL's Head of Equity Trading or STFL's Equities Chief Compliance Officer authorize SMARTS access to compliance personnel based on their designated role and responsibilities. OCEAN Personnel Certain OCEAN and NASDAQ employees have access to Participant confidential trading information. Such employees include OCEAN and NASDAQ staff from Compliance, Operations, Technology Development (including trading and surrounding systems), Product Management, and Business Management. The confidential trading information consists of information regarding individual orders and executions, Participant codes, and order volume summaries in STFX. OCEAN's policies and procedures employ a three-pronged approach to permit access to STFX. First, an employee must complete compliance training specific to the OCEAN business unit. Second, an OCEAN employee must request, and OCEAN Compliance must approve, access to each specific system based on the employee's designated role and responsibilities. Third, once approved, the OCEAN employee must complete OCEAN's annual Compliance training. OCEAN employees that have access to confidential trading information are subject to OCEAN's "Information Barriers and Conflict Management Policies and Procedures." All OCEAN employees are subject to NASDAQ's Global Trading Policy ("GTP"), which outlines all requirements and restrictions related to personal trading activity including holding periods, annual attestations, IPO restrictions and a prohibited list. OCEAN employees are required to disclose personal investment and brokerage accounts, positions, and transactions. NASDAQ's Global Ethics Team monitors personal trade activities against the GTP. OCEAN also conducts electronic communications reviews to identify policy violations including noncompliance with the above referenced policies and procedures. STFL has the right to audit OCEAN's operation of STFX, including OCEAN's access to and use of Participant confidential trading information either through audits conducted by STFL's own audit team or by third-party auditors. Such audits may be conducted on-site or off-site. OCEAN also is obligated to notify STFL of any actual or suspected unauthorized access to confidential information, which includes Participant confidential trading information, in a timely manner.

compliance_officer

STFL SAFEGUARDS REGARDING CONFIDENTIAL TRADING INFORMATION STFL has established and maintains written supervisory policies and procedures to protect confidential trading information related to all STFL products and services, including STFX. For purposes of this response, confidential information consists of Participants' identities, orders, transactions, strategies, and activities. All STFL personnel are subject to annual training regarding privacy and confidential information. Per firm policy, authorized STFL personnel have access to confidential information specific to STFX and/or its configuration as needed to fulfill their roles and responsibilities related to the operation and support of STFX. Authorized STFL personnel are strictly prohibited from using such information in an unauthorized manner and from discussing the details of any orders or executed trades occurring in STFX with persons who do not need such information to carry out their designated duties. Additionally, the SOR platform that directly accesses STFX does not take into account the means of entry or the type of participant (i.e., retail Participant, Institutional Participant, or Directed Participant) when sending subsequent orders to or canceling orders from STFX. The STFL SOR platform, however, does not share such order information specifically pertaining to exclusive routes to STFX with any other Stifel trading system, desk, or any third party, other than with personnel who require access to address operational, technological, legal, or compliance issues that may arise with STFX or the STFL SOR. The same client onboarding information is requested from both Participants and Directed Participants. Participants also cannot opt out of the STFL SOR having knowledge of orders bound for STFX. This information is inherent in the operation of STFX. The STFL SOR does not generate indications of interest based on STFX information. The STFX matching engine is hosted and operated by NASDAQ. In turn, the ATS matching engine and limit order book reside on hardware that is physically separate from STFL locations, systems, and personnel. Participant confidential information pertaining to STFX is accessible by authorized STFL personnel via the PETD algorithm and SOR environment and related databases/data repositories, the STFL compliance data repository, the NASDAQ OceanView GUI, the NASDAQ SMARTS surveillance system, and the NASDAQ cloud-based data warehouse. Access is granted to one or more of these environments, systems, data repositories, or data warehouses by the Head of Equity Trading and their designee, or the Chief Institutional Equity Compliance Officer and their designee. Only the designated compliance officer can grant access to compliance surveillance systems and data repositories. Access to all systems containing confidential information is controlled by password and entitlements and/or two-factor authentication. STFL personnel with access to real-time Participant confidential information are physically separated from general sales and trading staff on STFL's trading floor. Specific policies and procedures are applied as follows: 1. Detect and prevent insider trading (including information barriers and Fire Walls): STFL's Written Standard Procedures prohibit PETD staff from disclosing the identity of Participants and such persons' orders or executions other than to authorized Compliance, Supervision, Trading Management, Platform Technical Support, and Back Office personnel. As part of these controls, login credentials that are granted by the Head of Equity Trading or his/her designee control access to STFL's order management systems and execution data. These login credentials and their use is tracked. STFL Personnel are permitted to view information specific to their roles and/or the clients under their coverage. This information may include the algorithm or SOR used and the venue of execution. STFL order management systems do not contain any data relating to the specific operation of STFX. Access to systems containing confidential STFX specific information such as resting orders or Participant identities is restricted by a combination of login credentials, electronic tokens, two-factor authentication, and IP whitelisting. The SOR does not take into account means of entry or the type of participant (i.e., retail Participant, Institutional Participants, or Directed Participant) when sending subsequent orders to or canceling orders from STFX. The Head of Equity Trading or his/her designee are the only entities who can grant and revoke access to STFX operational systems. 2. Restrict trading in personal accounts of certain STFL personnel and transactions in employee and employee-related accounts: All personnel supporting the operation of STFX are subject to STFL's personal trading policy and supervision. This policy requires STFL employees to maintain personal trading accounts at STFL and obtain prior written approval for all transactions in NMS stocks via STFL's EQUBE System and its Control Room. Approval is based on the STFL restricted list and the employee's response to questions regarding their access to material, nonpublic information, their potential role as a market maker in the requested security, their knowledge of client orders in the requested security, and their acknowledgement of the firm's holding period restriction (i.e., 30 days with an exception for unrealized losses in excess of certain thresholds). 3. Prohibit certain activity that would disseminate confidential information, such as (i) limit the ability to reproduce or distribute "internal use only" or "broker/dealer only" items externally and (ii) prohibit the misuse of information obtained in a fiduciary capacity, or the sharing of information with any other unauthorized persons (e.g., spouses, relatives, household members, etc.). As it relates to STFX, this type of "internal use only" information includes daily STFX surveillance and end-of-day activity reports that NASDAQ makes available to authorized STFL personnel by electronic drop-copy to secure storage. Files are then archived on STFL's compliance data repository system. 4. Review electronic communications: All electronic communications by STFX support staff are subject to random and periodic review. 5. Govern employee-related and proprietary trading: Employee and principal (i.e., STFL acting as principal) transactions are not routed to STFX for execution, to mitigate the possibility of conflicts of interests. Internal and external auditors periodically review for compliance with firm policies and procedures governing all operational aspects of STFL PETD products, including STFX. STFL internal audit prepares, maintains, and distributes audit fieldwork for these products including STFX and reports to Supervision and Management. Access to NASDAQ Systems The following are NASDAQ-hosted systems accessible by STFL authorized personnel based on their specific roles and responsibilities in the operation and support of STFX. Access is granted by written request to NASDAQ by STFL's Head of Equity Trading or his/her designee. Access by STFL personnel is reviewed monthly by NASDAQ and provided to STFL for review. a. Configuration API - STFL personnel control and configure STFX through the Configuration API system. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading Desk authorize Configuration API system access based on the requesting employee's designated role and responsibilities. By way of example, crossing rules and order type parameters are changed by file submission to the Configuration API with access controlled by electronic tokens and access keys. b. OceanView GUI - The OceanView GUI is a secure web application that allows personnel responsible for the support and supervision of the ATS to view summary and detailed order, transaction, configuration, and reporting information. Specifically, it allows role-designated STFL personnel on the PETD, in compliance, and in IT to administer the operational aspects of STFX, including such things as connectivity, risk settings, symbol maintenance, and trade review/cancelation. Access to the OceanView GUI is controlled by integration to the NetIQ 2FA system that requires two-factor authentication. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading Desk authorize OceanView GUI system access based on the requesting employee's designated role and responsibilities. Authorized personnel with access to the OceanView GUI are separated from non-ATS and non-Algorithmic sales and trading personnel by a physical information barrier. To the extent that any authorized STFL personnel (i.e., the manager of the PETD) is also involved in the execution of transactions in NMS stock for a client or the firm, such personnel will do so from the other side of the information barrier, on a system without access to the OceanView GUI. c. JIRA Incident Management ("JIRA") - JIRA is a software system for STFL developers and NASDAQ technical support personnel to track technical issues pertaining to STFX. Access to JIRA is controlled by integration to the NetIQ 2FA system that uses two-factor authentication. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading desk authorize access by STFL personnel to the STFX instance of the JIRA system based on the requesting employee's designated role and responsibilities. d. Short-Term Data Warehouse and Long-Term Storage (AWS Environment) - STFL developers access historical data from NASDAQ's AWS Environment to facilitate ATS specific transaction analysis, regulatory reporting, and summary management reporting. STFL's Head of Equity Trading or the manager of the Portfolio & Electronic Trading desk authorize access to the AWS environment based on the requesting employee's designated role and responsibilities. e. NASDAQ SMARTS - SMARTS is a compliance software system provided by NASDAQ to STFL compliance and supervision personnel to facilitate in the surveillance of all activity in STFX. STFL's Head of Equity Trading or STFL's Equities Chief Compliance Officer authorize SMARTS access to compliance personnel based on their designated role and responsibilities. OCEAN Personnel Certain OCEAN and NASDAQ employees have access to Participant confidential trading information. Such employees include OCEAN and NASDAQ staff from Compliance, Operations, Technology Development (including trading and surrounding systems), Product Management, and Business Management. The confidential trading information consists of information regarding individual orders and executions, Participant codes, and order volume summaries in STFX. OCEAN's policies and procedures employ a three-pronged approach to permit access to STFX. First, an employee must complete compliance training specific to the OCEAN business unit. Second, an OCEAN employee must request, and OCEAN Compliance must approve, access to each specific system based on the employee's designated role and responsibilities. Third, once approved, the OCEAN employee must complete OCEAN's annual Compliance training. OCEAN employees that have access to confidential trading information are subject to OCEAN's "Information Barriers and Conflict Management Policies and Procedures." All OCEAN employees are subject to NASDAQ's Global Trading Policy ("GTP"), which outlines all requirements and restrictions related to personal trading activity including holding periods, annual attestations, IPO restrictions and a prohibited list. OCEAN employees are required to disclose personal investment and brokerage accounts, positions, and transactions. NASDAQ's Global Ethics Team monitors personal trade activities against the GTP. OCEAN also conducts electronic communications reviews to identify policy violations including noncompliance with the above referenced policies and procedures. STFL has the right to audit OCEAN's operation of STFX, including OCEAN's access to and use of Participant confidential trading information either through audits conducted by STFL's own audit team or by third-party auditors. Such audits may be conducted on-site or off-site. OCEAN also is obligated to notify STFL of any actual or suspected unauthorized access to confidential information, which includes Participant confidential trading information, in a timely manner.

subscriber_types

Other

hours_of_operation

STFX operates during regular trading hours (9:30:00 AM ET to 4:00:00 PM ET) and also follows the New York Stock Exchange holiday and early close schedule. STFX accepts orders from 8:00:00 AM to 4:00:00 PM ET. Matching commences at 9:30:00 AM ET. STFX does not match orders outside of regular trading hours. All orders received between 8:00:00 AM ET and 9:30:00 AM ET are queued by the system until matching begins at 9:30:00 AM ET and are subject to price-time priority.

display_best_quotes

Order related information regarding orders routed to STFX is not provided to Participants (including Directed Participants) by STFX. Further, no real-time, client-specific information is provided by STFX to any STFL SOR for purposes other than notifying the routing SOR of an execution, rejection, or cancelation of a child order routed to STFX from that SOR. That said, eligible Direct Participants can route orders solely to STFX through a customized STFL SOR routing configuration that restricts the SOR to routing their orders only to STFX, thereby excluding all other execution venues (see Part II, Item 5). In these instances, STFL's SOR platform will necessarily have information about orders that are bound exclusively for STFX, and executions occurring at STFX. The applicable STFL SOR platform, however, does not share such order information specifically pertaining to exclusive routes to STFX with any other Stifel trading system, desk or any third party, other than with personnel who require access to address operational, technological, legal, or compliance issues that may arise with STFX or the STFL SOR. Participants cannot opt out of the STFL SOR having knowledge of orders bound for STFX. This information is inherent in the operation of the system. The STFL SOR does not generate indications of interest based on information from STFX. Please also see the information provided regarding disclosure of confidential trading information provided in Part II, Item 7.

display_best_quotes

Order related information regarding orders routed to STFX is not provided to Participants (including Directed Participants) by STFX. Further, no real-time, client-specific information is provided by STFX to the STFL SOR for purposes other than notifying the SOR of an execution, rejection, or cancelation of a child order routed to STFX from the SOR. That said, eligible Direct Participants can route orders solely to STFX through a customized STFL SOR routing configuration that restricts the SOR to routing their orders only to STFX, thereby excluding all other execution venues (see Part II, Item 5). In these instances, STFL's SOR platform will necessarily have information about orders that are bound exclusively for STFX, and executions occurring at STFX. The STFL SOR platform, however, does not share such order information specifically pertaining to exclusive routes to STFX with any other Stifel trading system, desk or any third party, other than with personnel who require access to address operational, technological, legal, or compliance issues that may arise with STFX or the STFL SOR. Participants cannot opt out of the STFL SOR having knowledge of orders bound for STFX. This information is inherent in the operation of the system. The STFL SOR does not generate indications of interest based on information from STFX. Please also see the information provided regarding disclosure of confidential trading information provided in Part II, Item 7.

execution_services

STFX accepts day orders (limit, market, pegged, MinQty) beginning at 8:00:00 AM ET. STFX does not allow Immediate or Cancel (IOC) orders prior to 9:30:00 AM ET. Orders received by the STFL SOR prior to 8:00:00 AM ET are queued by the SOR in order of time received and routed to STFX at 8:00:00 AM ET. All orders received by STFX between 8:00:00 AM ET and 9:30:00 AM ET are time-stamped and entered into the limit order book preserving any pre-existing time priority set by the order received time at the STFL SOR (See Part III Item 11a for more details on time priority). Excluding periods during regulatory trading halts (e.g., a halt due to volatility or news pending) or market-wide circuit breakers, STFX matches and executes crosses within the NBBO (with respect to Limit Up / Limit Down Bands) during regular market trading hours - 9:30:00 AM to 4:00:00 PM (or earlier for abbreviated trading sessions). STFX does not operate opening, re-opening, or closing auctions. STFX executes crosses based on price-time priority and the NBBO starting at 9:30:00 ET for all tradeable (not restricted) NMS stock symbols for which an NBBO can be determined by direct exchange feeds and/or the SIP feed. STFX does not require an opening trade on an NMS stock's primary exchange prior to executing a cross. STFX cancels all open orders at 4:00:00 PM ET and rejects all new orders received from 4:00:00 PM ET to 8:00:00 AM ET. At the conclusion of the regular trading session, STFX cancels all orders on the limit order book. STFX automatically initiates a "pause" in crossing when a message is received via direct exchange feed or the SIP from all U.S. equity exchanges that indicate a regulatory trading halt or circuit breaker condition has been triggered. During a "pause", STFX accepts new orders and cancels, but does not effect any crosses. STFX resumes crossing orders on the limit order book based on price-time priority (subject to Limit Up / Limit Down Bands) when a message received via direct exchange feed or the SIP indicates that trading has resumed on at least one exchange. Alternatively, STFX support personnel may "pause" or "block" crossing in one or many NMS stock symbols due to systemic issues (e.g., loss of FIX connectivity or primary and backup market data feeds). In the event of a STFL-initiated "block", STFX cancels all open orders and rejects all new orders. Once a STFL-initiated "block" is lifted, STFX accepts new orders and crossing resumes based on the new orders' price-time priority and the NBBO. STFX support personnel exercise discretion over whether to initiate a "pause" or "block" based on their assessment of the severity of the issue. For example, a temporary disruption in FIX connectivity would likely result in a "pause," while a sustained FIX connectivity outage would result in a "block" and in turn, the rejection and canceling of all orders in affected names.

execution_services

STFX accepts day orders (limit, market, pegged, MinQty) beginning at 8:00:00 AM ET. STFX does not allow Immediate or Cancel (IOC) orders prior to 9:30:00 AM ET. Orders received by a STFL SOR prior to 8:00:00 AM ET are queued by the SOR in order of time received and routed to STFX at 8:00:00 AM ET. All orders received by STFX between 8:00:00 AM ET and 9:30:00 AM ET are time-stamped and entered into the limit order book preserving any pre-existing time priority set by the order received time at the STFL SOR (See Part III Item 11a for more details on time priority). Excluding periods during regulatory trading halts (e.g., a halt due to volatility or news pending) or market-wide circuit breakers, STFX matches and executes crosses within the NBBO (with respect to Limit Up / Limit Down Bands) during regular market trading hours - 9:30:00 AM to 4:00:00 PM (or earlier for abbreviated trading sessions). STFX does not operate opening, re-opening, or closing auctions. STFX executes crosses based on price-time priority and the NBBO starting at 9:30:00 ET for all tradeable (not restricted) NMS stock symbols for which an NBBO can be determined by direct exchange feeds and/or the SIP feed. STFX does not require an opening trade on an NMS stock's primary exchange prior to executing a cross. STFX cancels all open orders at 4:00:00 PM ET and rejects all new orders received from 4:00:00 PM ET to 8:00:00 AM ET. At the conclusion of the regular trading session, STFX cancels all orders on the limit order book. STFX automatically initiates a "pause" in crossing when a message is received via direct exchange feed or the SIP from all U.S. equity exchanges that indicate a regulatory trading halt or circuit breaker condition has been triggered. During a "pause", STFX accepts new orders and cancels, but does not effect any crosses. STFX resumes crossing orders on the limit order book based on price-time priority (subject to Limit Up / Limit Down Bands) when a message received via direct exchange feed or the SIP indicates that trading has resumed on at least one exchange. Alternatively, STFX support personnel may "pause" or "block" crossing in one or many NMS stock symbols due to systemic issues (e.g., loss of FIX connectivity or primary and backup market data feeds). In the event of a STFL-initiated "block", STFX cancels all open orders and rejects all new orders. Once a STFL-initiated "block" is lifted, STFX accepts new orders and crossing resumes based on the new orders' price-time priority and the NBBO. STFX support personnel exercise discretion over whether to initiate a "pause" or "block" based on their assessment of the severity of the issue. For example, a temporary disruption in FIX connectivity would likely result in a "pause," while a sustained FIX connectivity outage would result in a "block" and in turn, the rejection and canceling of all orders in affected names.