UBS ATS

amendment_reason

This Updating Amendment provides additional information in Part III, Item 11 with regards to execution timestamps. This change does not affect any functionality or access for the Broker Dealer Operator or any Subscribers.

amendment_reason

Part II, Items 1, 2, 6, and Part III, Items 3, and 13 were revised with respect to disclosures relating to the order flows or subset of order flows eligible for grading (specifically related to orders received from clients of the UBS Retail Market Maker). These changes impact Class A Direct and Indirect Subscribers. Part III, Items 10 and 11 were revised with respect to disclosures related to executing in a locked or crossed market. These changes impact all classes of Subscribers including the Broker Dealer Operator. Part III, Item 13 was revised with respect to disclosures relating to: (1) the definition of Source Categories; (2) the order flows or subset of order flows eligible for grading; and (3) the grading process used to determine the Source Category assigned to an order flow or subset of order flow. These changes impact all classes of Subscribers including the Broker Dealer Operator. Part III, Item 14 was revised with respect the disclosures related to the No Locked crossing restriction due to the revision in Part III, Item 11 indicated above. These changes impact all classes of Subscribers including the Broker Dealer Operator. Part III, Item 23 has been revised with respect to adding NYSE National to the list of wireless market data feeds used by the UBS ATS. This change impacts all classes of Subscribers including the Broker Dealer Operator.

amendment_reason

Part I, Item 7 has been updated to correct the names of the primary and secondary data centers. These changes do not affect any functionality or access for the Broker Dealer Operator or any Subscribers.

amendment_reason

Part II, Item 6a was revised with respect to disclosures related to the Platform Licensing team having access to ATS Subscriber information. This change affects the Broker Dealer Operator and all Subscribers.

amendment_reason

This Updating Amendment removes firms from Part II, Item 4 (Agreements with Trading Centers). These changes do not affect any functionality or access for the Broker Dealer Operator or any Subscribers.

amendment_reason

Part II, Item 2 has been updated to add additional affiliates that have executed orders in UBS ATS Part II, Item 4 has been updated to reflect changes to the list of legal entities with bilateral Subscriber Agreements. Part II, Item 6 has been updated to reflect changes to the list of internal teams with access to Subscriber information. Part III, Item 11 has been updated to remove the language regarding the migration of the UBS ATS matching engines as that project is now completed. UBS Form BD Schedule A has been updated to reflect a change in individual roles and responsibilities. These changes do not affect any functionality or access for the Broker Dealer Operator or any Subscribers.

amendment_reason

This Material Amendment is intended to disclose two changes: (1) A change to the definition of a Class A Indirect Subscriber in Part II, Item 5a; and (2) A revision to the list of internal teams with access to Subscriber information to include Electronic Trading Sales (ETS) in Part II, Item 6a. The change to Part II, Item 5a affects access to the UBS ATS for Class A Indirect Subscribers that are clients of an affiliate of the Broker-Dealer Operator. These changes do not affect any other access for the Broker-Dealer Operator or any other Subscriber. These changes do not affect any functionality.

amendment_reason

UBS Form BD Schedule A has been updated to reflect a change in individual roles and responsibilities. This change does not affect any functionality or access for the Broker Dealer Operator or any Subscribers.

amendment_reason

This Updating Amendment is intended to disclose additional information about the new functionality in the UBS ATS called Adaptive Cross. This functionality affects all classes of Subscribers, including the Broker Dealer Operator Adaptive Cross introduces a new priority logic into the ATS for eligible Subscriber Flow when an Adaptive Cross Score exceeds a predetermined threshold. More specifically, priority in the ATS will be determined first by an order's effective price, then by factoring in applicable Adaptive Cross Priority, and then by the time of receipt by the UBS ATS. If Adaptive Cross Priority is not assigned to a specific Subscriber Flow or, more generally, the Adaptive Cross functionality is not in use, execution priority will be determined first by effective price and then by the time of receipt by the UBS ATS. Adaptive Cross is designed to cross similar order flows when possible, and it does not require Subscribers to change behavior or transmit additional information. For further details, please refer to the changes to Part II, Item 7; Part III, Item 3; Part III, Item 7; Part III, Item 8; Part III, Item 9; and Part III, Item 11 of this Form ATS-N.

amendment_reason

This material amendment is intended to disclose new functionality in the UBS ATS called Adaptive Cross. This functionality affects all classes of Subscribers, including the Broker Dealer Operator. Adaptive Cross introduces a new priority logic into the ATS for eligible Subscriber Flow when an Adaptive Cross Score exceeds a predetermined threshold. More specifically, priority in the ATS will be determined first by an order's effective price, then by factoring in applicable Adaptive Cross Priority, and then by the time of receipt by the UBS ATS. If Adaptive Cross Priority is not assigned to a specific Subscriber Flow or, more generally, the Adaptive Cross functionality is not in use, execution priority will be determined first by effective price and then by the time of receipt by the UBS ATS. Adaptive Cross is designed to cross similar order flows when possible, and it does not require Subscribers to change behavior or transmit additional information. For further details, please refer to the changes to Part II, Item 7; Part III, Item 3; Part III, Item 7; Part III, Item 8; Part III, Item 9; and Part III, Item 11 of this Form ATS-N.

amendment_reason

This Updating Amendment includes a revised Schedule A which should have been submitted as part of the Updating Amendment accepted on July 20, 2022 but was inadvertently omitted. This change does not affect any functionality or access for the Broker Dealer Operator or any Subscribers.

amendment_reason

Language was added to Part II, Item 5 and Part III, Item 5 to include a means of entry (a UBS developed FIX 4.2 client connectivity proxy) only for Class A Indirect Subscribers. Language was also added to Part III, Item 14 to include a crossing restriction that may be received by the UBS ATS on behalf of only Class A Indirect Subscribers and only when the UBS SOR determines the crossing restriction. Language also added to distinguish between which crossing restrictions can be determined by Subscribers and which can only be determined by the UBS SOR. Language to cross reference "Restricting Crossing Against a Specific Source Category" in Part III, Item 14a was added to Part II, Items 1b, 2b, 5b, 6d and Part III, Items 13a and 14b.

amendment_reason

This Updating Amendment is intended to clarify items in Part II, Item 7b and Part III, Item 19. The change to Part II, Item 7b clarifies the method in which any Subscriber type may request that their UBS ATS transactions be excluded from the advertisement of aggregated and anonymous execution information. The change to Part III, Item 19 clarifies the manner in which the UBS ATS (UBSA) will pass through regulatory fees, such as CAT related fees assessed to UBSA as the 'CAT Executing Broker". These updates do not affect any functionality or access for or by any Subscriber.

amendment_reason

This Material Amendment is intended to disclose that the UBS ATS is migrating its primary matching engines to the Equinix facility located at 755 Secaucus Road (NY4) in Secaucus, New Jersey. At the same time, the UBS ATS will utilize the Equinix facility located at 800 Secaucus Road (NY5) in Secaucus, New Jersey as its in-region backup location. This Material Amendment provides additional information in Part III, Item 11 with regards to the migration and specifies where additional information concerning the migration schedule can be found. This change does not affect any functionality or access for the Broker Dealer Operator or any Subscriber.

amendment_reason

Part III, Item 13 was revised with respect to disclosures relating to: (1) the definition of Source Categories; (2) the order flows or subset of order flows eligible for grading; and (3) the grading process used to determine the Source Category assigned to an order flow or subset of order flow. These changes impact all classes of Subscribers including the Broker Dealer Operator.

amendment_reason

This Updating Amendment includes a revised Schedule A of the UBS Form BD. These changes do not affect any functionality or access for the Broker Dealer Operator or any Subscribers.

amendment_reason

This Updating Amendment revises Part III, Item 13(a). This change relates to a typo in Part III, Item 13(a) to add the number "4" where it was missing in the definition of Source Category 3. This change does not affect any functionality or access for the Broker Dealer Operator or any Subscribers.

amendment_reason

UBS Form BD Schedule A has been updated to reflect a change in individual roles and responsibilities. These changes do not affect any functionality or access for the Broker Dealer Operator or any Subscribers.

amendment_reason

This Updating Amendment revises Part II, Item 1, Part II, Item 2(a), Part III, Item 6(a), and Part III, Item 13(a). The changes relate to (1) updating Part II, Item 1 to change the name of High Touch Cash Trading to Voice (High Touch) Cash Trading; (2) updating Part II, Item 2(a) with the description of and applicable period that Affiliates have historically executed orders in the UBS ATS; (3) updating Part III, Item 6(a) to change the name of the Platform Licensing team to Platform Services, and (4) updating Part III, Item 13(a) to change the name of the ATS Execution Committee to ATS Execution Forum. These changes do not affect any functionality or access for the Broker Dealer Operator or any Subscribers.

amendment_reason

Part II, Item 2 has been updated to add additional affiliates that have executed orders in UBS ATS. This Updating Amendment includes a revised Schedule A of the UBS Form BD. These changes do not affect any functionality or access for the Broker Dealer Operator or any Subscribers.

amendment_reason

UBS Form BD Schedule A has been updated to reflect a change in individual roles and responsibilities. This does not affect the Broker Dealer Operator or any Subscribers.

amendment_reason

This Updating Amendment makes a change to Part III, Item 11 and is intended to clarify when the Adaptive Cross functionality may not be enabled. This update reflects a procedural change and affects all classes of Subscribers, including the Broker Dealer Operator.

ats_name

UBS ATS

operator_crd

000007654

operator_name

UBS SECURITIES LLC

order_types

The following order and CI types are offered by the UBS ATS: -- Pegged Orders and CIs - A pegged order may be pegged to the near, midpoint, or far side of the national best bid or offer (NBBO), and may be executed at any price at or within the NBBO. Pegged orders may optionally have a limit price. -- Limit Orders and CIs - An order to buy or sell a stated amount of a security at a specified price or better. A marketable limit order is a limit order to buy (sell) at or above (below) the lowest (highest) Protected Offer (Bid) for the security. -- Market Orders - An order to buy or sell a stated amount of a security that is to be executed at or better than the NBBO at the time the order reaches the UBS ATS. Market Orders are treated the same as market Pegged Orders. i. The priority of an order is determined first by its effective price, then by factoring in AdaptiveX Priority; and then by the time of receipt by the UBS ATS. Within the Adaptive Cross Priority, orders in larger Size Bins will have priority over orders in smaller Size Bins regardless of the contra Size Bin or AdaptiveX Priority status. For additional information on Adaptive Cross, please refer to Part III, Item 11 of this Form ATS-N. The priority of a Conditional Indication (CI) is determined by its effective price, then by its quantity, and then by its time of receipt by the UBS ATS. For priority purposes, the effective price of an order or CI is defined based on its type: -- For Pegged Orders and CIs: The effective price is considered to be the less aggressive of the limit price (if provided) and the pegged price (near, mid, or far). For midpeg orders, there is an additional option, 'PeggedMidpointMode', which is described below. -- For Limit Orders and CIs: The effective price is considered to be the limit price. In all cases, the effective price of an order or CI will not be allowed to exceed the far price (i.e., for buy orders or CIs, the NBO, and for sell orders or CIs, the NBB). Limit orders or CIs with limit prices that exceed the far price (i.e., marketable limit order or CI) will be treated as though they are at equivalent prices (i.e., the far price) for priority purposes. An order will be matched with the highest priority order(s) that would not violate any crossing restrictions. So, for example, the highest priority buy order may cross against the second-highest priority sell order if there is a crossing restriction on the highest priority buy order or the highest priority sell order that prevents crossing between those two orders. All modifications of orders and CIs processed by UBS will cause an order or CI to lose its original time priority. The time priority of a modified order or CI will correspond to the time when the modified order or CI is received by the UBS ATS. In all cases, the timestamp used by the UBS ATS is measured in microseconds. When two orders are matched in the UBS ATS, they will be matched at the earlier received order's effective price ("Price Determining Order"), which may be modified based on the LULD bands for execution, but not for priority purposes. Upon receiving an order, or upon a market data update, the UBS ATS will attempt to match orders. After that process completes, the UBS ATS will then combine and sort all remaining orders and CIs according to their respective priority to generate invitations to CIs (an "Invite" or "Invitation"). Invites will only be generated if the Invite would not violate any crossing restrictions (e.g., minimum quantity, Source Category restrictions, conditional invite grade restriction, etc.). ii. If the Price Determining Order's limit price is more aggressive than the far band, and the relevant band is inside the NBBO, the effective price will be either adjusted to be equal to the far band for Price Determining Orders that are Limit Orders or excluded from execution consideration for Price Determining Orders that are Pegged Orders. iii. The UBS ATS does not currently support an order type designed solely for the purpose of not removing liquidity. iv. The UBS ATS supports Pegged Orders and Pegged CIs, which may or may not have a limit price. For the avoidance of doubt, the priority of a Pegged Order or CI can be determined either by the limit price, or the peg price, depending on which price is less aggressive. Therefore, two Pegged Orders or CIs pegged to the same price but with different limit prices may have different priority based on where the limit prices are with respect to the pegged price. PeggedMidPointMode: The UBS ATS supports two variants of midpoint Pegged Orders or CIs: (1) FillToLimit (default), and (2) FillToMidpoint. For orders, the variant only affects execution price if the limit price on the order is less aggressive than the midpoint (i.e., a buy order with a limit price below the midpoint or a sell order with a limit price above the midpoint). If FillToLimit is selected, these orders may fill away from the midpoint, whereas orders with FillToMidpoint selected will not. For CIs, the variant affects whether an Invite can be generated. v. The UBS ATS does not route orders or CIs to other trading centers. vi. The UBS ATS accepts orders with an instruction that the order post within the UBS ATS until executed, canceled, or expired at day's end ("Day Orders") or with an instruction that the order be immediately crossed with other orders in the UBS ATS or cancelled ("IOC Orders"). CIs can only be sent as Day Orders because IOC Orders are not supported. vii. The UBS ATS does not support replacing the order type of an order or CI. viii. UBP does not support the sending of market peg orders or CIs. Both market pegged orders and CIs are supported via FIX 4.2.

order_types

The following order and CI types are offered by the UBS ATS: -- Pegged Orders and CIs - A pegged order may be pegged to the near, midpoint, or far side of the national best bid or offer (NBBO), and may be executed at any price at or within the NBBO. Pegged orders may optionally have a limit price. -- Limit Orders and CIs - An order to buy or sell a stated amount of a security at a specified price or better. A marketable limit order is a limit order to buy (sell) at or above (below) the lowest (highest) Protected Offer (Bid) for the security. -- Market Orders - An order to buy or sell a stated amount of a security that is to be executed at or better than the NBBO at the time the order reaches the UBS ATS. Market Orders are treated the same as market Pegged Orders. i. The priority of an order is determined first by its effective price, and next by the time of receipt by the UBS ATS. The priority of a Conditional Indication (CI) is determined by its effective price, then by its quantity, and then by its time of receipt by the UBS ATS. For priority purposes, the effective price of an order or CI is defined based on its type: -- For Pegged Orders and CIs: The effective price is considered to be the less aggressive of the limit price (if provided) and the pegged price (near, mid, or far). For midpeg orders, there is an additional option, 'PeggedMidpointMode', which is described below. -- For Limit Orders and CIs: The effective price is considered to be the limit price. In all cases, the effective price of an order or CI will not be allowed to exceed the far price (i.e., for buy orders or CIs, the NBO, and for sell orders or CIs, the NBB). Limit orders or CIs with limit prices that exceed the far price (i.e., marketable limit order or CI) will be treated as though they are at equivalent prices (i.e., the far price) for priority purposes. An order will be matched with the highest priority order(s) that would not violate any crossing restrictions. So, for example, the highest priority buy order may cross against the second-highest priority sell order if there is a crossing restriction on the highest priority buy order or the highest priority sell order that prevents crossing between those two orders. All modifications of orders and CIs processed by UBS will cause an order or CI to lose its original time priority. The time priority of a modified order or CI will correspond to the time when the modified order or CI is received by the UBS ATS. In all cases, the timestamp used by the UBS ATS is measured in microseconds. When two orders are matched in the UBS ATS, they will be matched at the earlier received order's effective price ("Price Determining Order"), which may be modified based on the LULD bands for execution, but not for priority purposes. Upon receiving an order, or upon a market data update, the UBS ATS will attempt to match orders. After that process completes, the UBS ATS will then combine and sort all remaining orders and CIs according to priority (order priority is price/time and CI priority is price/size/time) to generate invitations to CIs (an "Invite" or "Invitation"). Invites will only be generated if the Invite would not violate any crossing restrictions (e.g., minimum quantity, Source Category restrictions, conditional invite grade restriction, etc.). ii. If the Price Determining Order's limit price is more aggressive than the far band, and the relevant band is inside the NBBO, the effective price will be either adjusted to be equal to the far band for Price Determining Orders that are Limit Orders or excluded from execution consideration for Price Determining Orders that are Pegged Orders. iii. The UBS ATS does not currently support an order type designed solely for the purpose of not removing liquidity. iv. The UBS ATS supports Pegged Orders and Pegged CIs, which may or may not have a limit price. For the avoidance of doubt, the priority of a Pegged Order or CI can be determined either by the limit price, or the peg price, depending on which price is less aggressive. Therefore, two Pegged Orders or CIs pegged to the same price but with different limit prices may have different priority based on where the limit prices are with respect to the pegged price. PeggedMidPointMode: The UBS ATS supports two variants of midpoint Pegged Orders or CIs: (1) FillToLimit (default), and (2) FillToMidpoint. For orders, the variant only affects execution price if the limit price on the order is less aggressive than the midpoint (i.e., a buy order with a limit price below the midpoint or a sell order with a limit price above the midpoint). If FillToLimit is selected, these orders may fill away from the midpoint, whereas orders with FillToMidpoint selected will not. For CIs, the variant affects whether an Invite can be generated. v. The UBS ATS does not route orders or CIs to other trading centers. vi. The UBS ATS accepts orders with an instruction that the order post within the UBS ATS until executed, canceled, or expired at day's end ("Day Orders") or with an instruction that the order be immediately crossed with other orders in the UBS ATS or cancelled ("IOC Orders"). CIs can only be sent as Day Orders because IOC Orders are not supported. vii. The UBS ATS does not support replacing the order type of an order or CI. viii. UBP does not support the sending of market peg orders or CIs. Both market pegged orders and CIs are supported via FIX 4.2.

order_types

The following order and CI types are offered by the UBS ATS: -- Pegged Orders and CIs - A pegged order may be pegged to the near, midpoint, or far side of the national best bid or offer (NBBO), and may be executed at any price at or within the NBBO. Pegged orders may optionally have a limit price. -- Limit Orders and CIs - An order to buy or sell a stated amount of a security at a specified price or better. A marketable limit order is a limit order to buy (sell) at or above (below) the lowest (highest) Protected Offer (Bid) for the security. -- Market Orders - An order to buy or sell a stated amount of a security that is to be executed at or better than the NBBO at the time the order reaches the UBS ATS. Market Orders are treated the same as market Pegged Orders. i. The priority of an order is determined first by its effective price, and next by the time of receipt by the UBS ATS. The priority of a Conditional Indication (CI) is determined by its effective price, then by its quantity, and then by its time of receipt by the UBS ATS. For priority purposes, the effective price of an order or CI is defined based on its type: -- For Pegged Orders and CIs: The effective price is considered to be the less aggressive of the limit price (if provided) and the pegged price (near, mid, or far). For midpeg orders, there is an additional option, 'PeggedMidpointMode', which is described below. -- For Limit Orders and CIs: The effective price is considered to be the limit price. In all cases, the effective price of an order or CI will not be allowed to exceed the far price (i.e., for buy orders or CIs, the NBO, and for sell orders or CIs, the NBB). Limit orders or CIs with limit prices that exceed the far price (i.e., marketable limit order or CI) will be treated as though they are at equivalent prices (i.e., the far price) for priority purposes. An order will be matched with the highest priority order(s) that would not violate any crossing restrictions. So, for example, the highest priority buy order may cross against the second-highest priority sell order if there is a crossing restriction on the highest priority buy order or the highest priority sell order that prevents crossing between those two orders. All modifications of orders and CIs processed by UBS will cause an order or CI to lose its original time priority. The time priority of a modified order or CI will correspond to the time when the modified order or CI is received by the UBS ATS. In all cases, the timestamp used by the UBS ATS is measured in microseconds. When two orders are matched in the UBS ATS, they will be matched at the earlier received order's effective price ("Price Determining Order"), which may be modified based on the LULD bands for execution, but not for priority purposes. Upon receiving an order, or upon a market data update, the UBS ATS will attempt to match orders. After that process completes, the UBS ATS will then combine and sort all remaining orders and CIs according to priority (order priority is price/time and CI priority is price/size/time) to generate invitations to CIs (an "Invite" or "Invitation"). Invites will only be generated if the Invite would not violate any crossing restrictions (e.g., minimum quantity, Source Category restrictions, conditional invite grade restriction, etc.). ii. If the Price Determining Order's limit price is more aggressive than the far band, and the relevant band is inside the NBBO, the effective price will be either adjusted to be equal to the far band for Price Determining Orders that are Limit Orders or excluded from execution consideration for Price Determining Orders that are Pegged Orders. iii. The UBS ATS does not currently support an order type designed solely for the purpose of not removing liquidity. iv. The UBS ATS supports Pegged Orders and Pegged CIs, which may or may not have a limit price. For the avoidance of doubt, the priority of a Pegged Order or CI can be determined either by the limit price, or the peg price, depending on which price is less aggressive. Therefore, two Pegged Orders or CIs pegged to the same price but with different limit prices may have different priority based on where the limit prices are with respect to the pegged price. PeggedMidPointMode: The UBS ATS supports two variants of midpoint Pegged Orders or CIs: (1) FillToLimit (default), and (2) FillToMidpoint. For orders, the variant only affects execution price if the limit price on the order is less aggressive than the midpoint (i.e., a buy order with a limit price below the midpoint or a sell order with a limit price above the midpoint). If FillToLimit is selected, these orders may fill away from the midpoint, whereas orders with FillToMidpoint selected will not. For CIs, the variant affects whether an Invite can be generated. v. The UBS ATS does not route orders or CIs to other trading centers. vi. The UBS ATS accepts orders with an instruction that the order post within the UBS ATS until executed, canceled, or expired at day's end ("Day Orders") or with an instruction that the order be immediately crossed with other orders in the UBS ATS or cancelled ("IOC Orders"). CIs can only be sent as Day Orders because IOC Orders are not supported. vii. The UBS ATS does not support replacing the order type of an order or CI. viii. UBP does not support the sending of market peg orders or CIs. Both market pegged orders and CIs are supported via FIX 4.2.

means_of_entry

The UBS ATS is equipped to receive orders directly entered through via industry standard FIX 4.2 protocol and via UBS Binary Protocol ("UBP"). Conditional Indications (CIs) can only be directed to the UBS ATS via FIX 4.2 protocol. CIs are first defined in Part III, Item 9. Orders and CIs may also be entered into the ATS through the UBS SOR, which sends orders to the UBS ATS using FIX 4.2.

pricing_methodology

The UBS ATS consumes three functionally identical sources of direct market data for Nasdaq, Nasdaq PSX, Nasdaq BX, NYSE, NYSE ARCA, and NYSE National where, weather permitting, the third source uses a faster transport layer over wireless technology. All other exchange direct market data feeds are transmitted over landline only. All events that require market data use the direct feeds when possible, but may alternatively use the Securities Information Processor (SIP) when necessary. As an example, the UBS ATS uses the SIP for the Limit-Up Limit-Down bands. Matches in the UBS ATS are priced based on a Best Bid Offer ("BBO") aggregated from the "top of book" quotations of all U.S. equities exchanges using direct market data feeds maintained by the UBS ATS. If quotations from one or more exchanges are not available from the UBS direct market data feeds for any reason, the UBS ATS will rely on quotation data from the SIP for the affected exchange feed(s) to calculate the BBO. For example, if UBS's direct market data feed from an exchange is not available, the UBS ATS will use the attributed quote for that exchange from the SIP. Additionally, when aggregating the top of book quotations to determine the BBO, the UBS ATS seeks to mitigate quote flickering through performance optimizations. As an example, if an individual network data packet received from an exchange contains multiple price updates for a security, UBS ATS will recognize and use only the last sequential price update contained in the packet. In the case of the Broker-Dealer Operator declaring "self-help" against a trading center's protected quote due to inaccurate or inaccessible quotes, the UBS ATS BBO may exclude all quotes from that trading center from the calculation of the BBO until "self-help" is revoked. LULD bands will be taken from the most direct source, which typically will be the SIP that calculates the bands for the particular security.

pricing_methodology

The UBS ATS consumes three functionally identical sources of direct market data for Nasdaq, Nasdaq PSX, Nasdaq BX, NYSE, and NYSE ARCA where, weather permitting, the third source uses a faster transport layer over wireless technology. All other exchange direct market data feeds are transmitted over landline only. All events that require market data use the direct feeds when possible, but may alternatively use the Securities Information Processor (SIP) when necessary. As an example, the UBS ATS uses the SIP for the Limit-Up Limit-Down bands. Matches in the UBS ATS are priced based on a Best Bid Offer ("BBO") aggregated from the "top of book" quotations of all U.S. equities exchanges using direct market data feeds maintained by the UBS ATS. If quotations from one or more exchanges are not available from the UBS direct market data feeds for any reason, the UBS ATS will rely on quotation data from the SIP for the affected exchange feed(s) to calculate the BBO. For example, if UBS's direct market data feed from an exchange is not available, the UBS ATS will use the attributed quote for that exchange from the SIP. Additionally, when aggregating the top of book quotations to determine the BBO, the UBS ATS seeks to mitigate quote flickering through performance optimizations. As an example, if an individual network data packet received from an exchange contains multiple price updates for a security, UBS ATS will recognize and use only the last sequential price update contained in the packet. In the case of the Broker-Dealer Operator declaring "self-help" against a trading center's protected quote due to inaccurate or inaccessible quotes, the UBS ATS BBO may exclude all quotes from that trading center from the calculation of the BBO until "self-help" is revoked. LULD bands will be taken from the most direct source, which typically will be the SIP that calculates the bands for the particular security.

counterparty_selection

Crossing Restrictions: The UBS ATS allows all Subscribers to use the following optional crossing restrictions to limit interactions with certain orders, CIs and trading interest: -- No Self Cross: To prevent crossing against a Subscribers "own orders or CIs" (orders or CIs sent that have the same flow identifying name). The No Self Cross restriction can be configured at the UBS ATS upon request to prevent self-crossing across multiple flow identifying names ("Family Group"). It can also be managed by the Subscriber on an order-by-order basis within the same flow identifying name. However, no self cross is always assumed to have been sent if the flow identifying name is in a Family Group. -- No UBS Principal: To prevent crossing against UBS Principal Orders or CIs; managed by Subscribers on an order-by-order basis. -- Round Lot Only: To prevent crossing in other than round lot quantities; managed by Subscribers on an order-by-order basis. -- No Locked: To prevent crossing on a pegged order when the NBBO is locked (NBB = NBO); managed by UBS ATS and would apply to all orders on a specific flow identifying name. This crossing restriction also will prevent an Invite during a locked market for pegged CIs. -- PeggedMidPointMode: The UBS ATS supports two variants of midpoint Pegged Orders or CIs: (1) FillToLimit (default), and (2) FillToMidpoint. For orders, the variant only affects execution price if the limit price on the order is less aggressive than the midpoint (i.e., a buy order with a limit price below the midpoint or a sell order with a limit price above the midpoint). If FillToLimit is selected, these orders may fill away from the midpoint, whereas orders with FillToMidpoint selected will not. For CIs, the variant may affect if an Invite can be generated. -- Enable Conditionals: To enable a Day Order to interact with Conditional Indications; this crossing restriction can be managed by Subscribers on an order-by-order basis. -- Minimum Quantity: Orders and CIs may be sent to the UBS ATS with a minimum quantity value specified, and managed by Subscribers on an order-by-order basis. When used, UBS ATS will only match or generate an Invite when at least the specified number of shares is available from a single eligible contra side order or CI. By default, when the leaves quantity on an order becomes smaller than the specified minimum quantity, the minimum quantity constraint will no longer be in effect. Subscribers have the ability to change that behavior by sending a specific MinQuantityLeaveMode value in the order message. The available options are to have the leaves quantity become the minimum quantity or the order can be cancelled. In the latter case, an unsolicited cancel message is sent to the sender of the order and the order is removed from the ATS book. Restricting Crossing Against a Specific Source Category The below crossing restrictions are managed by each Subscriber on an order by order basis by sending the appropriate crossing restriction value on each order. For details regarding available values please see the UBS ATS Specification at www.ubs.com/ats. -- Class A Direct Subscriber orders received from RMM may opt out of crossing with contras in Source Categories 3, 4 and/or 5. -- Class A Direct Subscriber orders categorized as Source Category 2 may opt out of crossing with contras in Source Categories 3, 4 and/or 5. -- Class A Direct Subscriber orders categorized as Source Category 3 may opt out of crossing with contras in Source Categories 4 and/or 5. -- Class A Indirect Subscriber orders categorized as Source Category 2 or 3 may opt out of crossing with contras in Source Category 4 and/or 5. -- All Subscribers in the UBS ATS may opt out of crossing with contras in Source Category 5. Conditional Indication Restrictions: Conditional Indication restrictions can be used to limit interactions to certain types of Conditional Indications. More specifically, the Conditional Indication restrictions are available for Conditional Indications and firm order messages, on an order-by-order basis, by inserting one of the below designated values in the Conditional Invite Grade field: -- Generate Invites to all Conditional Indications (Invite Grade = 1) -- Generate Invites to Conditional Indications with a Medium Score or better (Invite Grade = 2) -- Generate Invites to Conditional Indications with a High Score or better (Invite Grade = 3) -- Generate Invites to Conditional Indications from UBS Algorithms only (Invite Grade = 4)

counterparty_selection

Crossing Restrictions: The UBS ATS allows all Subscribers to use the following optional crossing restrictions to limit interactions with certain orders, CIs and trading interest: -- No Self Cross: To prevent crossing against a Subscribers "own orders or CIs" (orders or CIs sent that have the same flow identifying name). The No Self Cross restriction can be configured at the UBS ATS upon request to prevent self-crossing across multiple flow identifying names ("Family Group"). It can also be managed by the Subscriber on an order-by-order basis within the same flow identifying name. However, no self cross is always assumed to have been sent if the flow identifying name is in a Family Group. -- No UBS Principal: To prevent crossing against UBS Principal Orders or CIs; managed by Subscribers on an order-by-order basis. -- Round Lot Only: To prevent crossing in other than round lot quantities; managed by Subscribers on an order-by-order basis. -- PeggedMidPointMode: The UBS ATS supports two variants of midpoint Pegged Orders or CIs: (1) FillToLimit (default), and (2) FillToMidpoint. For orders, the variant only affects execution price if the limit price on the order is less aggressive than the midpoint (i.e., a buy order with a limit price below the midpoint or a sell order with a limit price above the midpoint). If FillToLimit is selected, these orders may fill away from the midpoint, whereas orders with FillToMidpoint selected will not. For CIs, the variant may affect if an Invite can be generated. -- Enable Conditionals: To enable a Day Order to interact with Conditional Indications; this crossing restriction can be managed by Subscribers on an order-by-order basis. -- Minimum Quantity: Orders and CIs may be sent to the UBS ATS with a minimum quantity value specified, and managed by Subscribers on an order-by-order basis. When used, UBS ATS will only match or generate an Invite when at least the specified number of shares is available from a single eligible contra side order or CI. By default, when the leaves quantity on an order becomes smaller than the specified minimum quantity, the minimum quantity constraint will no longer be in effect. Subscribers have the ability to change that behavior by sending a specific MinQuantityLeaveMode value in the order message. The available options are to have the leaves quantity become the minimum quantity or the order can be cancelled. In the latter case, an unsolicited cancel message is sent to the sender of the order and the order is removed from the ATS book. Restricting Crossing Against a Specific Source Category The below crossing restrictions may be sent to the UBS ATS by each Subscriber on an order by order basis by sending the appropriate crossing restriction value on each order, or by the UBS SOR on behalf of the Subscriber. For details regarding available values please see the UBS ATS Specification at www.ubs.com/ats. -- Class A Direct Subscriber orders originating from RMM could be opted out of crossing with contras in Source Categories 3, 4 and/or 5. These crossing restrictions are determined by RMM and sent to the UBS ATS by the UBS SOR on behalf of RMM. -- Class A Direct Subscriber orders categorized as Source Category 2 could be opted out of crossing with contras in Source Categories 3, 4 and/or 5. These crossing restrictions are sent to the UBS ATS by the UBS SOR on behalf of the Subscriber. For this case, the Subscriber may only determine to opt out of crossing with contras in Source Categories 4 and/or 5. Only the UBS SOR may determine to opt out of crossing with contras in Source Category 3. -- Class A Direct Subscriber orders categorized as Source Category 3 could be opted out of crossing with contras in Source Categories 4 and/or 5. These crossing restrictions could be sent to the UBS ATS by the Subscriber and/or by the UBS SOR on behalf of the Subscriber, and may be determined by the Subscriber or the UBS SOR. -- Class A Indirect Subscriber orders categorized as Source Category 2 or 3 could be opted out of crossing with contras in Source Category 4 and/or 5. These crossing restrictions could be sent to the UBS ATS by the Subscriber and/or by the UBS SOR on behalf of the Subscriber and may be determined by the Subscriber or the UBS SOR. -- Class A Indirect Subscriber orders categorized as Source Category 2 could be opted out of crossing with contras in Source Category 3, 4 and/or 5. For this case, the Subscriber may only request UBS to opt out of crossing with contras in Source Categories 4 and/or 5. Only the UBS SOR may determine to opt out of crossing with contras in Source Category 3. -- All Subscribers in the UBS ATS could opt out of crossing with contras in Source Category 5. These crossing restrictions could be determined and sent to the UBS ATS by Subscribers and/or by the UBS SOR on behalf the Subscriber. Conditional Indication Restrictions: Conditional Indication restrictions can be used to limit interactions to certain types of Conditional Indications. More specifically, the Conditional Indication restrictions are available for Conditional Indications and firm order messages, on an order-by-order basis, by inserting one of the below designated values in the Conditional Invite Grade field: -- Generate Invites to all Conditional Indications (Invite Grade = 1) -- Generate Invites to Conditional Indications with a Medium Score or better (Invite Grade = 2) -- Generate Invites to Conditional Indications with a High Score or better (Invite Grade = 3) -- Generate Invites to Conditional Indications from UBS Algorithms only (Invite Grade = 4)

counterparty_selection

Crossing Restrictions: The UBS ATS allows all Subscribers to use the following optional crossing restrictions to limit interactions with certain orders, CIs and trading interest: -- No Self Cross: To prevent crossing against a Subscribers "own orders or CIs" (orders or CIs sent that have the same flow identifying name). The No Self Cross restriction can be configured at the UBS ATS upon request to prevent self-crossing across multiple flow identifying names ("Family Group"). It can also be managed by the Subscriber on an order-by-order basis within the same flow identifying name. However, no self cross is always assumed to have been sent if the flow identifying name is in a Family Group. -- No UBS Principal: To prevent crossing against UBS Principal Orders or CIs; managed by Subscribers on an order-by-order basis. -- Round Lot Only: To prevent crossing in other than round lot quantities; managed by Subscribers on an order-by-order basis. -- No Locked: To prevent crossing on a pegged order when the NBBO is locked (NBB = NBO); managed by UBS ATS and would apply to all orders on a specific flow identifying name. This crossing restriction also will prevent an Invite during a locked market for pegged CIs. -- PeggedMidPointMode: The UBS ATS supports two variants of midpoint Pegged Orders or CIs: (1) FillToLimit (default), and (2) FillToMidpoint. For orders, the variant only affects execution price if the limit price on the order is less aggressive than the midpoint (i.e., a buy order with a limit price below the midpoint or a sell order with a limit price above the midpoint). If FillToLimit is selected, these orders may fill away from the midpoint, whereas orders with FillToMidpoint selected will not. For CIs, the variant may affect if an Invite can be generated. -- Enable Conditionals: To enable a Day Order to interact with Conditional Indications; this crossing restriction can be managed by Subscribers on an order-by-order basis. -- Minimum Quantity: Orders and CIs may be sent to the UBS ATS with a minimum quantity value specified, and managed by Subscribers on an order-by-order basis. When used, UBS ATS will only match or generate an Invite when at least the specified number of shares is available from a single eligible contra side order or CI. By default, when the leaves quantity on an order becomes smaller than the specified minimum quantity, the minimum quantity constraint will no longer be in effect. Subscribers have the ability to change that behavior by sending a specific MinQuantityLeaveMode value in the order message. The available options are to have the leaves quantity become the minimum quantity or the order can be cancelled. In the latter case, an unsolicited cancel message is sent to the sender of the order and the order is removed from the ATS book. Restricting Crossing Against a Specific Source Category The below crossing restrictions may be sent to the UBS ATS by each Subscriber on an order by order basis by sending the appropriate crossing restriction value on each order, or by the UBS SOR on behalf of the Subscriber. For details regarding available values please see the UBS ATS Specification at www.ubs.com/ats. -- Class A Direct Subscriber orders originating from RMM could be opted out of crossing with contras in Source Categories 3, 4 and/or 5. These crossing restrictions are determined by RMM and sent to the UBS ATS by the UBS SOR on behalf of RMM. -- Class A Direct Subscriber orders categorized as Source Category 2 could be opted out of crossing with contras in Source Categories 3, 4 and/or 5. These crossing restrictions are sent to the UBS ATS by the UBS SOR on behalf of the Subscriber. For this case, the Subscriber may only determine to opt out of crossing with contras in Source Categories 4 and/or 5. Only the UBS SOR may determine to opt out of crossing with contras in Source Category 3. -- Class A Direct Subscriber orders categorized as Source Category 3 could be opted out of crossing with contras in Source Categories 4 and/or 5. These crossing restrictions could be sent to the UBS ATS by the Subscriber and/or by the UBS SOR on behalf of the Subscriber, and may be determined by the Subscriber or the UBS SOR. -- Class A Indirect Subscriber orders categorized as Source Category 2 or 3 could be opted out of crossing with contras in Source Category 4 and/or 5. These crossing restrictions could be sent to the UBS ATS by the Subscriber and/or by the UBS SOR on behalf of the Subscriber and may be determined by the Subscriber or the UBS SOR. -- Class A Indirect Subscriber orders categorized as Source Category 2 could be opted out of crossing with contras in Source Category 3, 4 and/or 5. For this case, the Subscriber may only request UBS to opt out of crossing with contras in Source Categories 4 and/or 5. Only the UBS SOR may determine to opt out of crossing with contras in Source Category 3. -- All Subscribers in the UBS ATS could opt out of crossing with contras in Source Category 5. These crossing restrictions could be determined and sent to the UBS ATS by Subscribers and/or by the UBS SOR on behalf the Subscriber. Conditional Indication Restrictions: Conditional Indication restrictions can be used to limit interactions to certain types of Conditional Indications. More specifically, the Conditional Indication restrictions are available for Conditional Indications and firm order messages, on an order-by-order basis, by inserting one of the below designated values in the Conditional Invite Grade field: -- Generate Invites to all Conditional Indications (Invite Grade = 1) -- Generate Invites to Conditional Indications with a Medium Score or better (Invite Grade = 2) -- Generate Invites to Conditional Indications with a High Score or better (Invite Grade = 3) -- Generate Invites to Conditional Indications from UBS Algorithms only (Invite Grade = 4)

financial_condition_summary

Class B Direct and Indirect Subscriber fees are standard and publicly disclosed on the UBS ATS website at www.ubs.com/ats. Class B Direct and Indirect Subscriber fees are as follows: -- Agency Broker-Dealers are charged a fee of $0.0010 per share to add liquidity or remove liquidity. -- Proprietary Broker-Dealers are charged a fee of $0.0005 per share to add liquidity and $0.0010 per share to remove liquidity. -- Retail Broker-Dealers are not charged a fee for either adding or removing liquidity. Class A Direct Subscribers are not charged an ATS fee. There are no additional fees charged by UBS for connectivity to the UBS ATS Please note, however, that a third party service provider, such as Equinix, may charge Subscribers a fee to establish connectivity.

financial_condition_summary

Class B Direct and Indirect Subscriber fees are standard and publicly disclosed on the UBS ATS website at www.ubs.com/ats. Class B Direct and Indirect Subscriber fees are as follows: -- Agency Broker-Dealers are charged a fee of $0.0010 per share to add liquidity or remove liquidity. -- Proprietary Broker-Dealers are charged a fee of $0.0005 per share to add liquidity and $0.0010 per share to remove liquidity. -- Retail Broker-Dealers are not charged a fee for either adding or removing liquidity. Class A Direct Subscribers are not charged an ATS fee. There are no additional fees charged by UBS for connectivity to the UBS ATS Please note, however, that a third party service provider, such as Equinix, may charge Subscribers a fee to establish connectivity. UBS ATS (UBSA) is assessed certain regulatory fees from time-to-time, including fees relating to the Consolidated Audit Trail (CAT). These regulatory fees are externally imposed and do not represent a charge or fee assessed by UBSA for its trading services. UBSA serves as the "CAT Executing Broker" only when it acts as agent for Subscribers buying securities. UBSA passes through to the buying Subscriber these CAT-related fees that UBSA is assessed on behalf of those buying Subscribers. All CAT and other regulatory fees charged to UBSA as an execution venue will be passed back to Subscribers without a markup.

conflict_description

Affiliates of the Broker-Dealer Operator are permitted to enter or direct the entry of orders and trading interest into UBS ATS through the UBS SOR using FIX 4.2. For purposes of this Form ATS-N, UBS has defined the term "Affiliate Orders" to mean orders and Conditional Indications (CIs) sent to the UBS ATS on behalf of an affiliate of the Broker Dealer Operator. Affiliate Orders use the "UBSS" MPID and may be sent as principal or agency but all Affiliate Orders are handled by the UBS ATS on an agency basis (i.e., the Broker-Dealer Operator, UBS Securities LLC, acts as agent for its Affiliates). Affiliate Orders are classified as either Class A Direct Subscriber or Class A Indirect Subscriber depending on from where the Affiliate Order originates. If the Affiliate Orders originates from either the UBS Algorithmic platform or Retail Market Making (RMM) then that Affiliate Order would be classified as a Class A Direct Subscriber, otherwise it would be classified as a Class A Indirect Subscriber. Since the effective date of the initial Form ATS-N for the UBS ATS, the following Affiliates have executed orders in UBS ATS: -- UBS AG, acting through various global branches (e.g., UBS AG London Branch) -- UBS Financial Services Inc. -- UBS Europe SE -- UBS Securities Canada Inc. -- UBS Securities Australia Limited -- UBS Switzerland AG The above is a list of Affiliates that have historically executed orders in the UBS ATS. The Broker-Dealer Operator will update this list as necessary to (1) add any Affiliate that newly executes orders in the UBS ATS, and (2) remove any entity that ceases to be an Affiliate of the Broker-Dealer Operator. In general, these Affiliates are members of the following types of business operated within the larger UBS organization: -- Investment Bank: provides investment banking, advisory, capital markets, research, and sales and trading services to institutional clients around the world. -- Wealth Management: provides comprehensive financial advice, solutions and services to wealthy families and individuals around the world. -- Personal & Corporate Banking: provides comprehensive financial products and services to UBS's private, corporate and institutional clients in Switzerland. -- Asset Management: offers investment capabilities and investment styles across all major traditional and alternative asset classes to institutions, wholesale intermediaries and wealth management clients around the world. -- Corporate Center: comprised of Services, Group Treasury, Asset and Liability Management, and Non-core and Legacy Portfolio. Please note the above does not represent an exhaustive listing of all Affiliates that have the ability to enter or direct the entry of orders and trading interest into UBS ATS.

conflict_description

Affiliates of the Broker-Dealer Operator are permitted to enter or direct the entry of orders and trading interest into UBS ATS through the UBS SOR using FIX 4.2. For purposes of this Form ATS-N, UBS has defined the term "Affiliate Orders" to mean orders and Conditional Indications (CIs) sent to the UBS ATS on behalf of an affiliate of the Broker Dealer Operator. Affiliate Orders use the "UBSS" MPID and may be sent as principal or agency but all Affiliate Orders are handled by the UBS ATS on an agency basis (i.e., the Broker-Dealer Operator, UBS Securities LLC, acts as agent for its Affiliates). Affiliate Orders are classified as either Class A Direct Subscriber or Class A Indirect Subscriber depending on from where the Affiliate Order originates. If the Affiliate Orders originates from either the UBS Algorithmic platform or Retail Market Making (RMM) then that Affiliate Order would be classified as a Class A Direct Subscriber, otherwise it would be classified as a Class A Indirect Subscriber. Since the effective date of the initial Form ATS-N for the UBS ATS, the following Affiliates have executed orders in UBS ATS: -- UBS AG, acting through various global branches (e.g., UBS AG London Branch) -- UBS Financial Services Inc. -- UBS Europe SE -- UBS Securities Canada Inc. -- UBS Securities Australia Limited -- UBS Switzerland AG -- Credit Suisse Asset Management (Schweiz) AG -- Credit Suisse (Schweiz) AG -- CREDIT SUISSE AG The above is a list of Affiliates that have historically executed orders in the UBS ATS. The Broker-Dealer Operator will update this list as necessary to (1) add any Affiliate that newly executes orders in the UBS ATS, and (2) remove any entity that ceases to be an Affiliate of the Broker-Dealer Operator. In general, these Affiliates are members of the following types of business operated within the larger UBS organization: -- Investment Bank: provides investment banking, advisory, capital markets, research, and sales and trading services to institutional clients around the world. -- Wealth Management: provides comprehensive financial advice, solutions and services to wealthy families and individuals around the world. -- Personal & Corporate Banking: provides comprehensive financial products and services to UBS's private, corporate and institutional clients in Switzerland. -- Asset Management: offers investment capabilities and investment styles across all major traditional and alternative asset classes to institutions, wholesale intermediaries and wealth management clients around the world. -- Corporate Center: comprised of Services, Group Treasury, Asset and Liability Management, and Non-core and Legacy Portfolio. Please note the above does not represent an exhaustive listing of all Affiliates that have the ability to enter or direct the entry of orders and trading interest into UBS ATS.

conflict_description

Affiliates of the Broker-Dealer Operator are permitted to enter or direct the entry of orders and trading interest into UBS ATS through the UBS SOR using FIX 4.2. For purposes of this Form ATS-N, UBS has defined the term "Affiliate Orders" to mean orders and Conditional Indications (CIs) sent to the UBS ATS on behalf of an affiliate of the Broker Dealer Operator. Affiliate Orders use the "UBSS" MPID and may be sent as principal or agency but all Affiliate Orders are handled by the UBS ATS on an agency basis (i.e., the Broker-Dealer Operator, UBS Securities LLC, acts as agent for its Affiliates). Affiliate Orders are classified as either Class A Direct Subscriber or Class A Indirect Subscriber depending on from where the Affiliate Order originates. If the Affiliate Orders originates from either the UBS Algorithmic platform or Retail Market Making (RMM) then that Affiliate Order would be classified as a Class A Direct Subscriber, otherwise it would be classified as a Class A Indirect Subscriber. The following Affiliates entered or directed the entry of agency and principal orders, CIs and trading interest into UBS ATS in Q2 2019: -- UBS AG, acting through various global branches (e.g., UBS AG London Branch) -- UBS Financial Services Inc. -- UBS Europe SE -- UBS Securities Canada Inc. -- UBS Securities Australia Limited -- UBS Switzerland AG In general, these Affiliates are members of the following types of business operated within the larger UBS organization: -- Investment Bank: provides investment banking, advisory, capital markets, research, and sales and trading services to institutional clients around the world. -- Wealth Management: provides comprehensive financial advice, solutions and services to wealthy families and individuals around the world. -- Personal & Corporate Banking: provides comprehensive financial products and services to UBS's private, corporate and institutional clients in Switzerland. -- Asset Management: offers investment capabilities and investment styles across all major traditional and alternative asset classes to institutions, wholesale intermediaries and wealth management clients around the world. -- Corporate Center: comprised of Services, Group Treasury, Asset and Liability Management, and Non-core and Legacy Portfolio. Please note the above does not represent an exhaustive listing of all Affiliates that have the ability to enter or direct the entry of orders and trading interest into UBS ATS.

conflict_description

Affiliates of the Broker-Dealer Operator are permitted to enter or direct the entry of orders and trading interest into UBS ATS through the UBS SOR using FIX 4.2. For purposes of this Form ATS-N, UBS has defined the term "Affiliate Orders" to mean orders and Conditional Indications (CIs) sent to the UBS ATS on behalf of an affiliate of the Broker Dealer Operator. Affiliate Orders use the "UBSS" MPID and may be sent as principal or agency but all Affiliate Orders are handled by the UBS ATS on an agency basis (i.e., the Broker-Dealer Operator, UBS Securities LLC, acts as agent for its Affiliates). Affiliate Orders are classified as either Class A Direct Subscriber or Class A Indirect Subscriber depending on from where the Affiliate Order originates. If the Affiliate Orders originates from either the UBS Algorithmic platform or Retail Market Making (RMM) then that Affiliate Order would be classified as a Class A Direct Subscriber, otherwise it would be classified as a Class A Indirect Subscriber. Since the effective date of the initial Form ATS-N for the UBS ATS, the following Affiliates have executed orders in UBS ATS: -- UBS AG, acting through various global branches (e.g., UBS AG London Branch) -- UBS Financial Services Inc. -- UBS Europe SE -- UBS Securities Canada Inc. -- UBS Securities Australia Limited -- UBS Switzerland AG -- Credit Suisse Asset Management (Schweiz) AG -- Credit Suisse (Schweiz) AG The above is a list of Affiliates that have historically executed orders in the UBS ATS. The Broker-Dealer Operator will update this list as necessary to (1) add any Affiliate that newly executes orders in the UBS ATS, and (2) remove any entity that ceases to be an Affiliate of the Broker-Dealer Operator. In general, these Affiliates are members of the following types of business operated within the larger UBS organization: -- Investment Bank: provides investment banking, advisory, capital markets, research, and sales and trading services to institutional clients around the world. -- Wealth Management: provides comprehensive financial advice, solutions and services to wealthy families and individuals around the world. -- Personal & Corporate Banking: provides comprehensive financial products and services to UBS's private, corporate and institutional clients in Switzerland. -- Asset Management: offers investment capabilities and investment styles across all major traditional and alternative asset classes to institutions, wholesale intermediaries and wealth management clients around the world. -- Corporate Center: comprised of Services, Group Treasury, Asset and Liability Management, and Non-core and Legacy Portfolio. Please note the above does not represent an exhaustive listing of all Affiliates that have the ability to enter or direct the entry of orders and trading interest into UBS ATS.

compliance_officer

General Background and Scope of Subscriber Confidential Trading Information: The Broker-Dealer Operator operates the UBS ATS trading systems and is involved in the execution, processing, clearing, and settling of transactions executed in the UBS ATS. UBS considers Subscriber confidential trading information (CTI) to consist of Subscribers' identities as well as Real-Time CTI and Post-Trade CTI (see below) relating to orders, trading interests, and executions in UBS ATS. UBS does not consider information publicly disseminated pursuant to regulatory requirements (e.g., information that is reported to the consolidated tape pursuant to SRO trade reporting requirements, etc.), or information of an aggregated and anonymized nature (e.g., aggregated and anonymous order, trading interest, and execution statistics (see Part III, Item 26), advertisements, etc.) to be CTI. For the purpose of this Form ATS-N, the term "Real-Time CTI" means order, trading interest, and execution information available for viewing in a Graphical User Interface (GUI) that provides visibility to such information on a near real time basis. Furthermore, for the purpose of this Form ATS-N, the term "Post-Trade CTI" means order, trading interest, and execution information available for viewing in either a database, log file, or report format solely after the event occurs (including canceled and expired orders) and the information is stored in its respective location and medium. The UBS ATS aggregates Post-Trade CTI across the entire ATS, by sector, by order type, by market capitalization, by size, by symbol or any other criteria deemed appropriate by the ATS Desk (see definition under ACE). The UBS ATS aggregates and anonymizes Post-Trade CTI on a daily, weekly, monthly, quarterly, semi-annual, or annual basis. UBS administers access to CTI through a permission-based bank access system (the "Access System"). The Access System allows Persons to submit a request documenting a reason why the access to CTI is required. When a request is submitted, the Access System creates notifications for the line manager and ATS Supervisor to review the access request in the Access System and either approve or reject the request. Furthermore, the UBS ATS systems are physically segregated with dedicated permissions to the segregated trading environment. Physical Separation: The UBS ATS operates in an environment completely segregated (firewalled) from the Broker-Dealer Operator, its affiliates and all Subscribers. Due to this physical separation, access to the ATS environment is likewise segregated, maintained separately, and dedicated to the UBS ATS. Only those UBS Persons with pre-approved access may connect into the UBS ATS environment and only through dedicated remote access terminal servers using two-factor authentication. In addition, all UBS ATS servers and network equipment are located in segregated locked data center cages and cabinets, providing another layer of physical access security. Employees with Access to Subscriber Confidential Trading Information: Confidential trading information (CTI) is available to the UBS ATS Desk and shared employees described in Part II, Item 6. While UBS' written safeguards and procedures apply to all UBS Persons, the following response is specific to UBS Persons who are employees of the ATS. For information on shared employees, please refer to the response to Part II, Item 6(a). Safeguarding and Overseeing Subscriber Confidential Trading Information: UBS maintains physical restrictions and policies and procedures designed to safeguard CTI from persons not authorized to receive or access such information. Persons are granted access to CTI for the sole purpose of operating the UBS ATS or ensuring the UBS ATS' compliance with applicable rules and regulations. UBS Persons are subject to the Cyber & Information Security Policy (referred to as "The CIS Policy") restricting the use and disclosure of all confidential information, including CTI. Additionally, UBS' policies and procedures prohibit trading on material non-public information (see excerpt from UBS Personal Investments Policy below). Violations of these policies are punishable under UBS' Violation Policy, which may result in disciplinary action up to and including dismissal. All Persons described in Part II, Item 6a have access to CTI. UBS restricts access to systems that contain CTI through physical restrictions as well as policies and procedures. The aforementioned policies and procedures apply across all of UBS. Access to the UBS ATS dedicated environment and UBS ATS data, including CTI, requires appropriate permissions to prevent information leakage. Permissions and access are handled either through the Access System or by a separate supervisory approval (with consultation of Compliance and/or Legal if necessary). Unless noted otherwise, the ATS Supervisor or delegate must approve access to CTI. Access requests require approval by the UBS ATS Supervisor or delegate. In reviewing such access requests, the UBS ATS Supervisor or delegate considers factors including the individual's job function and responsibilities related to the UBS ATS. An access request will be denied if it is determined that the access requested is unnecessary or inappropriate. The UBS ATS Supervisor or delegate reviews access rights at least annually, makes the appropriate adjustments, and signs off on the access rights. During this process, permissions will be terminated if access is no longer required or appropriate. A request to remove access to CTI must be entered in the Access System by the ATS Supervisor, and the Access System will generate a notification to the Support team to action the removal request. On a weekly basis, the Access System compares approved permissions to configured permissions and generates notifications to the ATS Desk and the Support team to remove any non-approved permissions. Furthermore, as part of its leaver process, when a relevant person leaves the firm the Access System automatically generates a removal request to prompt the Support team to restrict all system access for the leaver (including access to UBS ATS and CTI). As part of its mover process, if an employee changes roles, the Access System automatically generates a required review notification to the ATS Supervisor or delegate. The Supervisor or delegate is required to review the permissions to determine whether they are still required. If the permissions are no longer required, the Supervisor or delegate will initiate the removal through the Access System and will follow the process described above. Written Supervisory Procedures and Supervisory Controls: The UBS ATS maintains Written Supervisory Procedures ("WSPs") with regards to access rights, confidential information (including CTI), and information barriers. On a monthly basis, these WSPs are reviewed by the ATS Supervisor or delegate and signed off through a supervisory control process in a bank standard tool. This tool is used to evidence the appropriate reviews, sign off, and evidence. Personal Investments: UBS maintains a Global Policy on Personal Investments (referred to as "The PI Policy") which is applicable to all UBS Persons. Furthermore, except where prohibited under local law, various provisions of The PI Policy also apply to individuals with a relationship to UBS Persons such as: spouse / domestic partner; minor children / step children; financial dependents; relatives who have shared the same household as the UBS Person for one year; or any other connected party whereby the UBS Person maintains direct influence over that party's investment or trading activity. The PI Policy applies throughout a UBS Person's employment lifecycle (including when former employees are on "gardening leave"), and certain prohibitions apply even after leaving UBS. In addition to all UBS employees' adherence to the UBS Code of Conduct and Ethics, The PI Policy provides the following standards for all UBS Persons: (i) disclosure of accounts; (ii) use of approved brokers; (iii) pre-approval requirements; (iv) holding periods; and (v) prohibited activities. These standards aim to: (i) ensure that UBS Persons avoid conflicts of interest when engaging in personal investment activity; (ii) prohibit misuse of sensitive information including CTI and any other unpublished price sensitive information; (iii) satisfy regulatory obligations including the disclosure of personal accounts and investment information; (iv) enable UBS and UBS Persons to avoid the appearance of impropriety; and (v) protect UBS's reputation. UBS Persons are generally prohibited from trading single name instruments, including equities, bonds (including government bonds), any derivatives, structured notes or ETFs not broadly diversified as well as FX, commodities and precious metals. Conduct Risk, a dedicated function behind information barriers, is responsible for defining an adequate monitoring and control framework and for the independent monitoring of adherence to The PI Policy. UBS maintains an operational risk framework assessment process to evaluate specific risks, and more broadly assess market and client impact. Conduct Risk also performs thematic reviews with the objective of identifying potential or actual conduct risks. Conduct Risk issues can be identified through various data and management information available from 1st Line of Defense and 2nd Line of Defense sources. The data and information is used to identify: (1) impact of any organizational drivers; (2) possible indicators of weak governance, oversight and supervision or poor risk culture; (3) whether individual behaviors or conduct are a potential indicator of a systemic issue; and (4) patterns or trends of emerging conduct risk issues. Failure to comply with the requirements set out in The PI Policy may be subject a violator to the compliance violation framework as per the "Violations Policy" which may result in disciplinary action up to and including dismissal. UBS Persons may also be subject to regulatory sanctions and civil or criminal penalties, or both. Firm-wide Confidential Information Restrictions: UBS subjects all personnel to firm-wide policies restricting the use and disclosure of confidential information, including confidential information relating to information of UBS ATS Subscribers. Additionally, firm-wide policies and procedures prohibit trading on the basis of material non-public information. Employees with access to CTI are provided additional training regarding the sensitivity of such information. Systems with Access to Subscriber Confidential Trading Information: The following systems within UBS have access to CTI: ATS SYSTEMS: All direct trading systems of the UBS ATS have access to CTI, which includes systems such as the client facing proxies that Subscribers connect to and matching engines that process (and match) orders and CIs. Other ATS systems with access to CTI include the trade reporting and clearing system, risk and market access system, static database and publisher, real time monitoring system, and transactional databases. -- CLIENT CONNECTIVITY PROXY: The UBS ATS proxy is the client connectivity layer to the UBS ATS that sits inside the ATS dedicated environment. Subscribers connect to one or more UBS ATS proxies to send messages to the UBS ATS. The UBS ATS proxy has access to CTI and that access is required to provide this functionality. -- MATCHING ENGINES: The UBS ATS matching engine performs a process that receives Subscriber orders and CIs along with market data and other static information to make matching and Conditional Invitation decisions. The UBS ATS matching engine has access to CTI and that access is required to provide this functionality. -- TRADE REPORTING AND CLEARING: The UBS ATS trade reporting system is designed to receive all ATS execution information and make the appropriate decisions, based on regulatory requirements, to report trades to a trade reporting facility. The UBS ATS trade reporting system also uses ATS information to submit all Class B Direct and Indirect Subscriber trades and certain Class A Indirect Subscriber trades for clearing via real-time QSR submission to DTCC on behalf of the Broker-Dealer Operator. -- RISK AND MARKET ACCESS SYSTEM: The UBS ATS risk and market access system is a real time application that is designed to receive all ATS order and execution information and perform the necessary calculations and compare the output against each Subscriber's allowed credit limits. The risk and market access system uses this information to calculate the remaining value of credit available to a Subscriber, generate automated alerts, and send a control message to the client connectivity proxy to prevent trading in breach of a Subscriber's credit limit. -- STATIC DATABASE AND PUBLISHER: The UBS ATS has a dedicated database in the segregated ATS environment that contains Subscriber static configuration information including but not limited to market access limits, risk checks, and trading configurations. Along with this database there is a publisher in the segregated ATS environment that reads the database and publishes the static data to the aforementioned ATS systems. -- REAL TIME MONITORING: The UBS ATS Desk and Support use three different ATS real time monitoring applications to monitor the health of the UBS ATS. One system is specifically focused on order and execution information as well as Subscriber connectivity. The second system is specifically focused on system health and alerting. The third system is specifically focused on Subscriber and system latency monitoring. These tools use CTI such as Subscriber names and session information, market access limits, connectivity, as well as order and execution information to ensure proper performance of the UBS ATS. These systems contain CTI and are located within the segregated ATS environment, which is only accessible via segregated virtual desktops that access the dedicated and segregated environment. -- TRANSACTIONAL DATABASE: The UBS ATS maintains multiple databases containing CTI relating to transactions executed in the UBS ATS. Access to these databases is restricted to the UBS ATS Desk and the shared employees discussed in Part II, Item 6a. Those individuals with access to CTI use this information to run queries, generate reports (as described in the beginning of Part II, Item 6a), investigate historic trading activity, and for other bona fide purposes. NON-ATS SYSTEMS: Non-ATS systems with access to CTI in the normal course of business include systems that either send orders and trading interest to the UBS ATS or systems that perform a service for the UBS ATS but are not dedicated to the ATS. -- ORDER MANAGEMENT SYSTEM: UBS' order management system (OMS), including the UBS algorithmic platform (UBS Algo) and UBS Smart Order Router (SOR), transmit CTI to the extent orders are routed to the ATS. This system communicates information to personnel within UBS that have the appropriate permissions to view the orders sent to the UBS ATS and identifies the Trading Center(s) to which clients' orders were routed and/or executed, including the UBS ATS. The only CTI that is available in this instance of the system is for Class A Direct and Indirect Subscribers. Class B Direct and Indirect Subscriber CTI will never be passed back to this system. -- CLIENT CONNECTIVITY PROXY: The Broker-Dealer Operator has a system for managing the client connectivity layer that is separate from that of the UBS ATS. The Broker-Dealer Operator's client connectivity system is specifically dedicated to clients of the Broker-Dealer Operator and sits outside the segregated UBS ATS environment. The only CTI that is available in this instance of the system is for Class A Direct and Indirect Subscribers. Class B Direct and Indirect Subscriber CTI will never be passed back to this system. -- REAL TIME MONITORING: The Broker-Dealer Operator has a real time monitoring system for all clients of the Broker-Dealer Operator that is specifically focused on order and execution information. This system resides in the Broker-Dealer Operators environment and not inside the UBS ATS. It provides a view into order and execution information for clients across all trading venues, including the UBS ATS, and is permissioned by desk/role so that client information and CTI are only viewable by the appropriate employees. The only CTI that is available in this instance of the system is for Class A Direct and Indirect Subscribers. Class B Direct and Indirect Subscriber CTI will never be passed back to this system. -- TRANSACTIONAL DATABASE: The Broker-Dealer Operator maintains multiple databases containing CTI relating to transactions executed in the UBS ATS. These databases are not solely dedicated to the UBS ATS and contain order and execution information for all clients of the Broker-Dealer Operator. These databases will only contain CTI for Class A Direct and Indirect Subscribers. Class B Direct and Indirect Subscriber CTI will never be stored in these databases. -- THIRD PARTY TECHNOLOGY PLATFORM: UBS offers a third-party direct market access platform to clients of the Broker-Dealer Operator that are Class A Indirect Subscribers to transmit orders and/or CIs to UBS ATS. This platform communicates to employees of the third-party responsible for managing the platform real-time information about where Subscribers' orders and/or CIs were routed and executed, which could be the UBS ATS or any other market center.

compliance_officer

General Background and Scope of Subscriber Confidential Trading Information: The Broker-Dealer Operator operates the UBS ATS trading systems and is involved in the execution, processing, clearing, and settling of transactions executed in the UBS ATS. UBS considers Subscriber confidential trading information (CTI) to consist of Subscribers' identities as well as Real-Time CTI and Post-Trade CTI (see below) relating to orders, trading interests, and executions in UBS ATS. UBS does not consider information publicly disseminated pursuant to regulatory requirements (e.g., information that is reported to the consolidated tape pursuant to SRO trade reporting requirements, etc.), or information of an aggregated and anonymized nature (e.g., aggregated and anonymous order, trading interest, and execution statistics (see Part III, Item 26), advertisements, etc.) to be CTI. For the purpose of this Form ATS-N, the term "Real-Time CTI" means order, trading interest, and execution information available for viewing in a Graphical User Interface (GUI) that provides visibility to such information on a near real time basis. Furthermore, for the purpose of this Form ATS-N, the term "Post-Trade CTI" means order, trading interest, and execution information available for viewing in either a database, log file, or report format solely after the event occurs (including canceled and expired orders) and the information is stored in its respective location and medium. The UBS ATS aggregates Post-Trade CTI across the entire ATS, by sector, by order type, by market capitalization, by size, by symbol or any other criteria deemed appropriate by the ATS Desk (see definition under ACE). The UBS ATS aggregates and anonymizes Post-Trade CTI on a daily, weekly, monthly, quarterly, semi-annual, or annual basis. UBS administers access to CTI through a permission-based bank access system (the "Access System"). The Access System allows Persons to submit a request documenting a reason why the access to CTI is required. When a request is submitted, the Access System creates notifications for the line manager and ATS Supervisor to review the access request in the Access System and either approve or reject the request. Furthermore, the UBS ATS systems are physically segregated with dedicated permissions to the segregated trading environment. Physical Separation: The UBS ATS operates in an environment completely segregated (firewalled) from the Broker-Dealer Operator, its affiliates and all Subscribers. Due to this physical separation, access to the ATS environment is likewise segregated, maintained separately, and dedicated to the UBS ATS. Only those UBS Persons with pre-approved access may connect into the UBS ATS environment and only through dedicated remote access terminal servers using two-factor authentication. In addition, all UBS ATS servers and network equipment are located in segregated locked data center cages and cabinets, providing another layer of physical access security. Employees with Access to Subscriber Confidential Trading Information: Confidential trading information (CTI) is available to the UBS ATS Desk and shared employees described in Part II, Item 6. While UBS' written safeguards and procedures apply to all UBS Persons, the following response is specific to UBS Persons who are employees of the ATS. For information on shared employees, please refer to the response to Part II, Item 6(a). Safeguarding and Overseeing Subscriber Confidential Trading Information: UBS maintains physical restrictions and policies and procedures designed to safeguard CTI from persons not authorized to receive or access such information. Persons are granted access to CTI for the sole purpose of operating the UBS ATS or ensuring the UBS ATS' compliance with applicable rules and regulations. UBS Persons are subject to the Cyber & Information Security Policy (referred to as "The CIS Policy") restricting the use and disclosure of all confidential information, including CTI. Additionally, UBS' policies and procedures prohibit trading on material non-public information (see excerpt from UBS Personal Investments Policy below). Violations of these policies are punishable under UBS' Violation Policy, which may result in disciplinary action up to and including dismissal. All Persons described in Part II, Item 6a have access to CTI. UBS restricts access to systems that contain CTI through physical restrictions as well as policies and procedures. The aforementioned policies and procedures apply across all of UBS. Access to the UBS ATS dedicated environment and UBS ATS data, including CTI, requires appropriate permissions to prevent information leakage. Permissions and access are handled either through the Access System or by a separate supervisory approval (with consultation of Compliance and/or Legal if necessary). Unless noted otherwise, the ATS Supervisor or delegate must approve access to CTI. Access requests require approval by the UBS ATS Supervisor or delegate. In reviewing such access requests, the UBS ATS Supervisor or delegate considers factors including the individual's job function and responsibilities related to the UBS ATS. An access request will be denied if it is determined that the access requested is unnecessary or inappropriate. The UBS ATS Supervisor or delegate reviews access rights at least annually, makes the appropriate adjustments, and signs off on the access rights. During this process, permissions will be terminated if access is no longer required or appropriate. A request to remove access to CTI must be entered in the Access System by the ATS Supervisor, and the Access System will generate a notification to the Support team to action the removal request. On a weekly basis, the Access System compares approved permissions to configured permissions and generates notifications to the ATS Desk and the Support team to remove any non-approved permissions. Furthermore, as part of its leaver process, when a relevant person leaves the firm the Access System automatically generates a removal request to prompt the Support team to restrict all system access for the leaver (including access to UBS ATS and CTI). As part of its mover process, if an employee changes roles, the Access System automatically generates a required review notification to the ATS Supervisor or delegate. The Supervisor or delegate is required to review the permissions to determine whether they are still required. If the permissions are no longer required, the Supervisor or delegate will initiate the removal through the Access System and will follow the process described above. Written Supervisory Procedures and Supervisory Controls: The UBS ATS maintains Written Supervisory Procedures ("WSPs") with regards to access rights, confidential information (including CTI), and information barriers. On a monthly basis, these WSPs are reviewed by the ATS Supervisor or delegate and signed off through a supervisory control process in a bank standard tool. This tool is used to evidence the appropriate reviews, sign off, and evidence. Personal Investments: UBS maintains a Global Policy on Personal Investments (referred to as "The PI Policy") which is applicable to all UBS Persons. Furthermore, except where prohibited under local law, various provisions of The PI Policy also apply to individuals with a relationship to UBS Persons such as: spouse / domestic partner; minor children / step children; financial dependents; relatives who have shared the same household as the UBS Person for one year; or any other connected party whereby the UBS Person maintains direct influence over that party's investment or trading activity. The PI Policy applies throughout a UBS Person's employment lifecycle (including when former employees are on "gardening leave"), and certain prohibitions apply even after leaving UBS. In addition to all UBS employees' adherence to the UBS Code of Conduct and Ethics, The PI Policy provides the following standards for all UBS Persons: (i) disclosure of accounts; (ii) use of approved brokers; (iii) pre-approval requirements; (iv) holding periods; and (v) prohibited activities. These standards aim to: (i) ensure that UBS Persons avoid conflicts of interest when engaging in personal investment activity; (ii) prohibit misuse of sensitive information including CTI and any other unpublished price sensitive information; (iii) satisfy regulatory obligations including the disclosure of personal accounts and investment information; (iv) enable UBS and UBS Persons to avoid the appearance of impropriety; and (v) protect UBS's reputation. UBS Persons are generally prohibited from trading single name instruments, including equities, bonds (including government bonds), any derivatives, structured notes or ETFs not broadly diversified as well as FX, commodities and precious metals. Conduct Risk, a dedicated function behind information barriers, is responsible for defining an adequate monitoring and control framework and for the independent monitoring of adherence to The PI Policy. UBS maintains an operational risk framework assessment process to evaluate specific risks, and more broadly assess market and client impact. Conduct Risk also performs thematic reviews with the objective of identifying potential or actual conduct risks. Conduct Risk issues can be identified through various data and management information available from 1st Line of Defense and 2nd Line of Defense sources. The data and information is used to identify: (1) impact of any organizational drivers; (2) possible indicators of weak governance, oversight and supervision or poor risk culture; (3) whether individual behaviors or conduct are a potential indicator of a systemic issue; and (4) patterns or trends of emerging conduct risk issues. Failure to comply with the requirements set out in The PI Policy may be subject a violator to the compliance violation framework as per the "Violations Policy" which may result in disciplinary action up to and including dismissal. UBS Persons may also be subject to regulatory sanctions and civil or criminal penalties, or both. Firm-wide Confidential Information Restrictions: UBS subjects all personnel to firm-wide policies restricting the use and disclosure of confidential information, including confidential information relating to information of UBS ATS Subscribers. Additionally, firm-wide policies and procedures prohibit trading on the basis of material non-public information. Employees with access to CTI are provided additional training regarding the sensitivity of such information. Systems with Access to Subscriber Confidential Trading Information: The following systems within UBS have access to CTI: ATS SYSTEMS: All direct trading systems of the UBS ATS have access to CTI, which includes systems such as the client facing proxies that Subscribers connect to and matching engines that process (and match) orders and CIs. Other ATS systems with access to CTI include the trade reporting and clearing system, risk and market access system, static database and publisher, real time monitoring system, transactional databases, and the Adaptive Cross Model. -- CLIENT CONNECTIVITY PROXY: The UBS ATS proxy is the client connectivity layer to the UBS ATS that sits inside the ATS dedicated environment. Subscribers connect to one or more UBS ATS proxies to send messages to the UBS ATS. The UBS ATS proxy has access to CTI and that access is required to provide this functionality. -- MATCHING ENGINES: The UBS ATS matching engine performs a process that receives Subscriber orders and CIs along with market data and other static information to make matching and Conditional Invitation decisions. The UBS ATS matching engine has access to CTI and that access is required to provide this functionality. -- TRADE REPORTING AND CLEARING: The UBS ATS trade reporting system is designed to receive all ATS execution information and make the appropriate decisions, based on regulatory requirements, to report trades to a trade reporting facility. The UBS ATS trade reporting system also uses ATS information to submit all Class B Direct and Indirect Subscriber trades and certain Class A Indirect Subscriber trades for clearing via real-time QSR submission to DTCC on behalf of the Broker-Dealer Operator. -- RISK AND MARKET ACCESS SYSTEM: The UBS ATS risk and market access system is a real time application that is designed to receive all ATS order and execution information and perform the necessary calculations and compare the output against each Subscriber's allowed credit limits. The risk and market access system uses this information to calculate the remaining value of credit available to a Subscriber, generate automated alerts, and send a control message to the client connectivity proxy to prevent trading in breach of a Subscriber's credit limit. -- STATIC DATABASE AND PUBLISHER: The UBS ATS has a dedicated database in the segregated ATS environment that contains Subscriber static configuration information including but not limited to market access limits, risk checks, and trading configurations. Along with this database there is a publisher in the segregated ATS environment that reads the database and publishes the static data to the aforementioned ATS systems. -- REAL TIME MONITORING: The UBS ATS Desk and Support use three different ATS real time monitoring applications to monitor the health of the UBS ATS. One system is specifically focused on order and execution information as well as Subscriber connectivity. The second system is specifically focused on system health and alerting. The third system is specifically focused on Subscriber and system latency monitoring. These tools use CTI such as Subscriber names and session information, market access limits, connectivity, as well as order and execution information to ensure proper performance of the UBS ATS. These systems contain CTI and are located within the segregated ATS environment, which is only accessible via segregated virtual desktops that access the dedicated and segregated environment. -- TRANSACTIONAL DATABASE: The UBS ATS maintains multiple databases containing CTI relating to transactions executed in the UBS ATS. Access to these databases is restricted to the UBS ATS Desk and the shared employees discussed in Part II, Item 6a. Those individuals with access to CTI use this information to run queries, generate reports (as described in the beginning of Part II, Item 6a), investigate historic trading activity, and for other bona fide purposes. -- Adaptive Cross Model (AdaptiveX Model): The AdaptiveX Model is a component within the UBS ATS that receives order and execution information for all classes of Subscribers (See Part II, Item 5 for Subscriber classification definitions) from the Adaptive Cross Bot at randomized, predetermined intervals. It uses this information to calculate an Adaptive Cross Score, which is then sent to the Adaptive Cross Bot for further processing. The AdaptiveX Model operates during the hours of operations disclosed in Part III, Item 4 of this Form ATS-N (with exceptions noted in Part III, Item 11). Data related to Adaptive Cross, including but not limited to AdaptiveX Score and AdaptiveX Priority, is considered CTI and is protected in the same manner as all other CTI. NON-ATS SYSTEMS: Non-ATS systems with access to CTI in the normal course of business include systems that either send orders and trading interest to the UBS ATS or systems that perform a service for the UBS ATS but are not dedicated to the ATS. -- ORDER MANAGEMENT SYSTEM: UBS' order management system (OMS), including the UBS algorithmic platform (UBS Algo) and UBS Smart Order Router (SOR), transmit CTI to the extent orders are routed to the ATS. This system communicates information to personnel within UBS that have the appropriate permissions to view the orders sent to the UBS ATS and identifies the Trading Center(s) to which clients' orders were routed and/or executed, including the UBS ATS. The only CTI that is available in this instance of the system is for Class A Direct and Indirect Subscribers. Class B Direct and Indirect Subscriber CTI will never be passed back to this system. -- CLIENT CONNECTIVITY PROXY: The Broker-Dealer Operator has a system for managing the client connectivity layer that is separate from that of the UBS ATS. The Broker-Dealer Operator's client connectivity system is specifically dedicated to clients of the Broker-Dealer Operator and sits outside the segregated UBS ATS environment. The only CTI that is available in this instance of the system is for Class A Direct and Indirect Subscribers. Class B Direct and Indirect Subscriber CTI will never be passed back to this system. -- REAL TIME MONITORING: The Broker-Dealer Operator has a real time monitoring system for all clients of the Broker-Dealer Operator that is specifically focused on order and execution information. This system resides in the Broker-Dealer Operators environment and not inside the UBS ATS. It provides a view into order and execution information for clients across all trading venues, including the UBS ATS, and is permissioned by desk/role so that client information and CTI are only viewable by the appropriate employees. The only CTI that is available in this instance of the system is for Class A Direct and Indirect Subscribers. Class B Direct and Indirect Subscriber CTI will never be passed back to this system. -- TRANSACTIONAL DATABASE: The Broker-Dealer Operator maintains multiple databases containing CTI relating to transactions executed in the UBS ATS. These databases are not solely dedicated to the UBS ATS and contain order and execution information for all clients of the Broker-Dealer Operator. These databases will only contain CTI for Class A Direct and Indirect Subscribers. Class B Direct and Indirect Subscriber CTI will never be stored in these databases. -- THIRD PARTY TECHNOLOGY PLATFORM: UBS offers a third-party direct market access platform to clients of the Broker-Dealer Operator that are Class A Indirect Subscribers to transmit orders and/or CIs to UBS ATS. This platform communicates to employees of the third-party responsible for managing the platform real-time information about where Subscribers' orders and/or CIs were routed and executed, which could be the UBS ATS or any other market center.

hours_of_operation

The UBS ATS is operational during regular US market hours, generally 9:30 AM to 4:00 PM Eastern Time. The UBS ATS observes the holiday schedule (including shortened market hours preceding or following certain holidays) published by the NYSE. The UBS ATS will not accept an order or CI outside of the trading hours described above. The UBS ATS will not match in a security until a transaction in such security has been executed on a national securities exchange, the UBS ATS has opened for trading, and Limit Up/Limit Down price bands ("LULD bands") for the security have been publicly disseminated.

display_best_quotes

The UBS ATS does not display the ATS order book to any Persons. When handling Conditional Indications (CIs), however, the UBS ATS will communicate an Invite message to the sender of a CI making them aware that eligible contra trading interest exists (see Part III, Item 9). Class A Indirect Subscribers may direct an order to the UBS ATS through the UBS SOR, thus the UBS SOR is aware of an order being sent to the UBS ATS. For orders that are flagged as DMA where the UBS SOR has no discretion on child order routing, the UBS SOR does not use any information for routing decisions.

execution_services

The UBS ATS is operational during regular US market hours, generally 9:30 AM to 4:00 PM Eastern Time; any orders and CIs received outside of this timeframe are rejected. The UBS ATS will not match in a security until a transaction in such security has been executed on a national securities exchange, the UBS ATS has opened for trading, LULD bands for the security have been publicly disseminated, and there is a valid two-sided quote available (valid, non-crossed NBB and NBO are present). With respect to IPO securities, the UBS ATS will reject orders and CIs in IPO securities received prior to 9:30 AM Eastern Time, and will not match in an IPO security until a transaction in such security has been executed on the security's listing exchange, the UBS ATS has opened for trading, LULD bands for the security have been publicly disseminated, and there is a valid two-sided quote available (valid, non-crossed NBB and NBO are present). Limit Up/Limit Down Bands: Rights and Warrants are currently exempt from LULD, and UBS ATS will match in such securities without regard to LULD bands. For all other eligible securities, UBS ATS will match only if LULD bands are present and the effective price of a potential match is not constrained by a LULD band. Trading Halts: The UBS ATS will promptly react to "halt" or "pause" messages it receives from the direct market data feeds or the SIP from all U.S. equities exchanges. Upon receipt and processing of halt messages, the UBS ATS will not match in a security during periods in which a security is halted (e.g., subject to a LULD Trading Pause, Single Stock Circuit Breaker, or regulatory halt). The UBS ATS will resume matching when it receives a message from the SIP or direct market data feed of the primary market indicating that trading has resumed in the security (a transaction has occurred on at least one exchange), LULD bands are present, and there is a valid two-sided quote available (valid, non-crossed NBB and NBO are present). Pricing Methodology: Matches in the UBS ATS are priced based on the NBBO as calculated by UBS by aggregating the "top of book" quotations of all U.S. equities exchanges using direct market data feeds maintained by the UBS ATS. If quotations from one or more exchanges are not available from the UBS direct market data feeds for any reason, the UBS ATS will rely on quotation data from the SIP (for the affected exchange feed(s)) to calculate an NBBO. For example, if UBS's direct market data feed from an exchange is not available the UBS ATS will use the attributed quote for that exchange from the SIP. Additionally, when aggregating the top of book quotations to determine the NBBO, the UBS ATS seeks to mitigate quote flickering through performance optimizations. As an example, if an individual network data packet received from an exchange contains multiple price updates for a security, UBS ATS will recognize and use only the last sequential price update contained in the packet. In the case of the Broker-Dealer Operator declaring "self-help" against a trading center's protected quote due to inaccurate or inaccessible quotes, the UBS ATS NBBO may exclude all quotes from that trading center from the calculation of the NBBO until "self-help" is revoked. The UBS ATS uses the Limit-Up/Limit-down (LULD) bands communicated through the Securities Information Processor (SIP) market data feeds. Both Day Orders and IOC Orders are eligible to receive price improvement. Incoming orders are executed against the best priced (lowest seller, or highest buyer) eligible order that is not constrained by a LULD band. When a Day Order is eligible for crossing with an IOC Order, the crossing price is determined by the Day Order's price. In the case of Conditional Indications (CIs), if a CI sender receives an Invite and responds by sending a Day Order, a match may occur as described above. The UBS ATS will prevent matches at a price that is determined to be excessively wide. More specifically, if the spread is greater than $0.01 and larger than 10 percent of the offer, the UBS ATS will prevent a match from occurring.

execution_services

The UBS ATS is operational during regular US market hours, generally 9:30 AM to 4:00 PM Eastern Time; any orders and CIs received outside of this timeframe are rejected. The UBS ATS will not match in a security until a transaction in such security has been executed on a national securities exchange, the UBS ATS has opened for trading, LULD bands for the security have been publicly disseminated, and there is a valid two-sided quote available (valid, non-crossed, non-locked NBB and NBO are present). With respect to IPO securities, the UBS ATS will reject orders and CIs in IPO securities received prior to 9:30 AM Eastern Time, and will not match in an IPO security until a transaction in such security has been executed on the security's listing exchange, the UBS ATS has opened for trading, LULD bands for the security have been publicly disseminated, and there is a valid two-sided quote available (valid, non-crossed and non-locked NBB and NBO are present). Limit Up/Limit Down Bands: Rights and Warrants are currently exempt from LULD, and UBS ATS will match in such securities without regard to LULD bands. For all other eligible securities, UBS ATS will match only if LULD bands are present and the effective price of a potential match is not constrained by a LULD band. Trading Halts: The UBS ATS will promptly react to "halt" or "pause" messages it receives from the direct market data feeds or the SIP from all U.S. equities exchanges. Upon receipt and processing of halt messages, the UBS ATS will not match in a security during periods in which a security is halted (e.g., subject to a LULD Trading Pause, Single Stock Circuit Breaker, or regulatory halt). The UBS ATS will resume matching when it receives a message from the SIP or direct market data feed of the primary market indicating that trading has resumed in the security (a transaction has occurred on at least one exchange), LULD bands are present, and there is a valid two-sided quote available (valid, non-crossed and non-locked NBB and NBO are present). Pricing Methodology: Matches in the UBS ATS are priced based on the NBBO as calculated by UBS by aggregating the "top of book" quotations of all U.S. equities exchanges using direct market data feeds maintained by the UBS ATS. If quotations from one or more exchanges are not available from the UBS direct market data feeds for any reason, the UBS ATS will rely on quotation data from the SIP (for the affected exchange feed(s)) to calculate an NBBO. For example, if UBS's direct market data feed from an exchange is not available the UBS ATS will use the attributed quote for that exchange from the SIP. Additionally, when aggregating the top of book quotations to determine the NBBO, the UBS ATS seeks to mitigate quote flickering through performance optimizations. As an example, if an individual network data packet received from an exchange contains multiple price updates for a security, UBS ATS will recognize and use only the last sequential price update contained in the packet. In the case of the Broker-Dealer Operator declaring "self-help" against a trading center's protected quote due to inaccurate or inaccessible quotes, the UBS ATS NBBO may exclude all quotes from that trading center from the calculation of the NBBO until "self-help" is revoked. The UBS ATS uses the Limit-Up/Limit-down (LULD) bands communicated through the Securities Information Processor (SIP) market data feeds. Both Day Orders and IOC Orders are eligible to receive price improvement. Incoming orders are executed against the best priced (lowest seller, or highest buyer) eligible order that is not constrained by a LULD band. When a Day Order is eligible for crossing with an IOC Order, the crossing price is determined by the Day Order's price. In the case of Conditional Indications (CIs), if a CI sender receives an Invite and responds by sending a Day Order, a match may occur as described above. The UBS ATS will prevent matches at a price that is determined to be excessively wide. More specifically, if the spread is greater than $0.01 and larger than 10 percent of the offer, the UBS ATS will prevent a match from occurring.