Overview→Venues→LeveL Markets ATS

LeveL Markets ATS

LEVEL MARKETS LLC ATS

ATS● ACTIVEest. 2022

Institutional equity ATS operated by Level Markets, LLC (CIK 0001609177). Address: 10 Post Office Square, 14th Floor, Boston MA 02109. SEC file number 013-00192. Initial ATS-N filed 2022-02-25 under Kezar Trading LLC; entity subsequently renamed to Level Markets LLC (2025-03-03). Actively amended through 2026-03-27 (most recent: ATS-N/UA accession 0001609177-26-000011). Distinct from two other ceased ATSs on the same CIK: Level ATS EBXL (ceased 2022-02-28) and Luminex ATS LMNX (ceased 2026-03-27). Formerly: Kezar Trading LLC (filings through 2025-03-03), Luminex Trading & Analytics LLC (filings through 2022-10-31).

CALCGUARD TAXONOMY

SOPHISTICATED DARK POOL

CONTPTTRTH

MARKET STRUCTURE

Continuous Midpoint

PRIORITY

Price-Tier-Time

TEMPORAL

Regular Trading Hours

DATA CENTEREquinix NY4

PLATFORMSelf-built

SEC FILE013-00192 ↗

SEGMENTATION & INNOVATION

SEGMENTATION METHODOLOGY

Channel-based segmentation with granular flow partitioning by business unit; PTT priority with multi-channel architecture

STRUCTURAL DETAIL

Flow partitioned into discrete named channels based on subscriber business unit classification; allows routing to specific liquidity pools within the venue; unusual granularity of internal segmentation

IDENTIFIERS

MPID

EBXL

conf: 0.98 · SEC_EDGAR

CIK

0001609177

conf: 1.00 · SEC_EDGAR

NMS VOLUME

// LOADING...

SIGINT Processing

Analyzing SEC filing intelligence... stand by for assessment

FEATURES

Cover Page

amendment_reason

This filing updates the 2/20/2026 Material Amendment, with the changes to take effect on 3/30/2026. The filing reflects the inclusion of Buyside Subscribers to the LeveL ATS and the activities of and functionality available to such Buyside Subscribers, as described in Part II Items 1, 2, 3, 4, and 5; and Part III Items 1, 2, 5, 8, 13, 14, 19, and 22. The filing reflects the termination of the LeveLUp service as of 3/30/2026, as described in Part II Items 1, 3, and 4; and Part III Items 13 and 14. The filing changes the activities of service providers and the protection of confidential trading information in Part II Items 6 and 7. The filing notes that the cessation of trade advertising on Bloomberg as of 3/30/2026 in Part II Item 7. Part III Item 14 includes a description of a new "waterfall" feature to go into effect on 3/30/2026. These changes apply to all subscribers and to the broker-dealer operator.

amendment_reason

This Updating Amendment updates the amendment filed on March 23, 2026. These updates reflect the effectiveness of the functionality and features available to Buyside Subscribers and the effectiveness of the "waterfall" functionality of the LeveL ATS. Buyside Subscriber-related updates can be found in Part II, Items 1, 2, 3, 4, 5, 6 and 7, and Part III Items 5, 13, and 14. Updates relating to the effectiveness of the "waterfall" feature can be found in Part III Item 14. This amendment also updates and clarifies how LeveL Markets has established "channels" for Buyside Subscribers. These updates can be found in Part III Item 13. These changes apply to all subscribers and to the broker-dealer operator.

amendment_reason

This Material Amendment pertains to certain attributes of order types, including Conditional Orders, on the LeveL ATS. Specifically, the changes pertain to the requirement to specify a Minimum Quantity or a Minimum Block Size on Conditional Orders (Part III Items 7 and 9) and describe the new ability of subscribers to specify a Minimum Fill Size or a Maximum Contra Side Order Quantity, if desired, as described in Part III Item 7. Part III Item 7 also discloses that the Maximum Contra Side Order Quantity functionality is only available in unilateral, bilateral, and multilateral trading arrangements as described in Part III Item 14. The amendment in Part III Item 7 also discloses that a Minimum Quantity and Minimum Fill Size may be reduced on a firm-up from the values specified in the original conditional order. In that regard, Part III Items 7 and 9 each reflect the removal of the prior requirement that the minimum block size quantity be the same on a firm-up as on the original conditional order. These changes apply to all subscribers and to the broker-dealer operator.

amendment_reason

This Correcting Amendment corrects certain portions of the March 27, 2026 Updating Amendment and includes disclosures with respect to the participation in the LeveL ATS and especially in the Buyside Subscriber trading arrangement by Sponsored Buyside Entities and Outsourced Trading Brokers. These participants are defined in Part II Item 1, and their capabilities and any applicable exclusions relating to the services of the LeveL ATS are disclosed in Part II Item 5 and Part III, Items 5, 13, and 14. This amendment also reflects a correction to Part III Item 5, Means of Entry, with respect to Buyside Subscribers and Sponsored Buyside Entities. Separately, Part III Items 8 and 22 reflect the removal of certain effective dates that are now past and which were not removed in the March 27, 2026 filing being amended. These changes apply to all subscribers and to the broker-dealer operator.

amendment_reason

This Updating Amendment reflects an implementation date of July 31, 2026 for the Minimum Fill Size feature as described in Part III Item 7. This update applies to all subscribers and to the broker-dealer operator.

amendment_reason

This Updating Amendment pertains to the Buyside Subscriber trading arrangement within the LeveL ATS and the ability of Buyside Subscribers to interact within the Buyside Subscriber trading arrangement and with the general LeveL pool depending upon the election of the particular Buyside Subscriber. This amendment also reflects that the Buyside Subscriber trading arrangement has a default minimum order size of 5,000 shares. These updates can be found in Part III Item 14. The Updating Amendment, in Part III Item 19, also changes the range of potential rebates paid by LeveL Markets with respect to subscriber trading arrangements that include rebates to be paid by LeveL Markets. These updates apply to all subscribers and to the broker-dealer operator.

ats_name

LeveL Markets

ats_name

LeveL Markets

ats_name

LeveL Markets

ats_name

LeveL Markets

ats_name

LeveL Markets

ats_name

LeveL Markets

Item 1 (Part I)

operator_crd

000171752

operator_crd

000171752

operator_crd

000171752

operator_crd

000171752

operator_crd

000171752

operator_crd

000171752

operator_name

LEVEL MARKETS, LLC

operator_name

LEVEL MARKETS, LLC

operator_name

LEVEL MARKETS, LLC

operator_name

LEVEL MARKETS, LLC

operator_name

LEVEL MARKETS, LLC

operator_name

LEVEL MARKETS, LLC

Item 10 (Part II)

order_types

Order Types (Generally): As further discussed herein, the LeveL ATS accepts firm orders, including Firm-Up Orders, conditional orders, Full Day VWAP Orders, VWAP Block Orders and VWAP Sliced Orders (VWAP Sliced Orders, together with Full Day VWAP Orders and VWAP Block Orders, the "VWAP Order Types"). Except where otherwise noted, references to firm orders include Firm-Up Orders (as that term is defined herein). Orders of a particular VWAP Order Type may only interact with orders of the same VWAP Order type (e.g., Full Day VWAP Orders may only interact with other Full Day VWAP Orders). Except where noted below, all orders may be cancelled by timely submission to the LeveL ATS of cancellation instructions. Firm Orders (Excluding Firm-Up Orders): Firm orders may include market, limit or pegged price instructions. Subscribers may designate firm orders as immediate-or-cancel ("IOC"), "Day," good-til-time ("GTT," expressed either in seconds or by specifying an expiration time) or "enhanced" IOC (such orders "Enhanced IOC" orders, further discussed below). Subscribers may designate firm orders as ineligible to interact with other orders if the NBBO spread, as calculated by the ATS, is greater than $0.01 (or greater than $0.0001 where an execution would occur at a price that is less than $1.00). Subscribers may designate firm orders as add-liquidity-only ("ALO"). ALO orders will only interact with other orders if the ALO order would be deemed to be adding liquidity. See Part III Item 11 for further discussion of when an order is deemed to "add" or "remove" liquidity. Where, upon receipt, an ALO order is marketable against trading interest on the LeveL ATS, the LeveL ATS will accept the ALO order for further processing (e.g., potential matching where the ALO would be deemed to be adding liquidity). Pegged orders are limit orders with a limit price that constantly changes based on movements in the designated reference price. Pegged orders may, but are not required to, include an ultimate limit price (e.g. buy 100 shares of ABC pegged to the offer but limited to $20.05) and, for orders other than IOC and Enhanced IOC orders, may also include an offset price (e.g., buy 100 shares of ABC pegged to the national best offer ("NBO") minus $0.02). Firm orders may be pegged to the NBO, the national best bid ("NBB") or midpoint of the national best bid or offer ("NBBO"). Offset prices must be expressed in penny increments per share for securities priced equal to or greater than $1.00 per share and hundredths of a cent for securities priced less than $1.00 per share or the LeveL ATS will reject the order. Resting orders with offsets expressed in hundredths of a cent will be cancelled if the bid or offer becomes equal to or greater than $1.00 per share. Orders pegged to the midpoint of the NBBO may not include a peg-offset. As noted above, subscribers may designate orders as "Enhanced IOC" orders. Only firm orders may be designated as Enhanced IOC orders. Generally, an Enhanced IOC order operates like a "standard" IOC order and either immediately executes (in whole or in part) against resting contraside interest or is cancelled by the LeveL ATS. However, where there is a resting eligible contraside conditional order or orders in the LeveL ATS at the time the LeveL ATS receives the Enhanced IOC order, the Enhanced IOC order will remain in the LeveL ATS for a subscriber-configured period of time of at least 100 milliseconds (such period, which is configurable in millisecond increments, the "Hold Period"). For clarity, where there is both resting firm and conditional trading interest in the LeveL ATS at the time the LeveL ATS receives the Enhanced IOC order, the Enhanced IOC will execute, in whole or in part, against the firm order (which may be a firm or Firm-Up Order) and the leaves quantity will be immediately cancelled. During the Hold Period the Enhanced IOC order is eligible to interact with any eligible contraside trading interest in the LeveL ATS and may "invite" other conditional orders to "firm-up." In the event the Enhanced IOC order receives a partial fill during the Hold Period the LeveL ATS will immediately cancel the order's leaves quantity (even where the Hold Period has not expired). Subscribers may not cancel an Enhanced IOC order during the Hold Period. For clarity, the Hold Period on a given order is not "extended" or "reset" for any reason. By default, the LeveL ATS designates firm orders (including Enhanced IOC orders) as ineligible to interact with conditional orders. However, LeveL Markets will remove the default designation upon subscriber request and permit the subscriber to designate firm orders as either eligible or ineligible to interact with conditional orders on an order-by-order basis. Firm orders designated as ineligible to interact with conditional orders will not invite a conditional order to firm-up, but are nevertheless eligible to interact with Firm-Up Orders (other than Firm-Up Orders that include a "conditional only" order instruction). Firm orders may be modified, but their firm status cannot be modified (i.e., a firm order cannot be modified to be a conditional order). A modified firm order will receive a new time of receipt for priority purposes, except where the only modification is a reduction in order quantity. Conditional Orders: A conditional order is an instruction to the LeveL ATS that the subscriber wants to interact with the order book on a conditional basis. A conditional order never executes; instead, when a conditional order would have otherwise matched with another order, the conditional order is cancelled by the LeveL ATS and an invitation (i.e., an "Invite" as defined at Part III Item 9) is sent to the originating subscriber, inviting the subscriber to send a Firm-Up Order in response. As further discussed below, conditional orders, by default, may only interact at the midpoint of the prevailing NBBO. However, upon subscriber request to LeveL Markets, however made, LeveL Markets will remove the default logic and allow conditional orders that utilize Session Permissioning instructions to interact at any price at or inside the prevailing NBBO (such conditional orders designated as eligible to interact at any price at or inside the prevailing NBBO, "Session Conditional Orders," all other conditional orders, "Non-Session Conditional Orders"). For clarity, as used herein, the term "conditional order" includes both Session and Non-Session Conditional Orders and Extended Firm-Up Time Required ("EFUT") Conditional Orders, as defined in this Item and in Part III Item 9(a), unless otherwise specified. Conditional orders may include market, limit or pegged pricing instructions. Subject to the restrictions discussed in this paragraph, conditional orders may be pegged to the NBB, the NBO or midpoint of the NBBO. Conditional orders pegged to the market (i.e., sell order pegged to the NBB or buy order pegged to the NBO) may include an offset price (e.g., buy 100 shares of ABC pegged to the NBO minus $0.02). Conditional orders pegged to the midpoint of the NBBO may not include an offset price. Session Conditional Orders may be pegged to the primary (i.e. sell order pegged to the NBO or buy order pegged to the NBB) and may include an offset price. Non-Session Conditional Orders may not be pegged to the primary; the LeveL ATS will reject any Non-Session Conditional Orders pegged to the primary. As further discussed below, conditional orders must include a Minimum Block Size quantity. Subscribers may designate conditional orders as "Day" or GTT. Conditional orders may not be designated as IOC or Enhanced IOC. Conditional orders may be modified, but their conditional status cannot be modified (i.e., a conditional order cannot be modified to be a firm order). Conditional and Firm-Up orders may include instructions to not interact with firm orders other than Firm-Up Orders. Firm orders, other than Firm-Up Orders, may not include a conditional-only order attribute. Non-Session Conditional Orders will only interact with contraside interest (i.e., "generate" an Invite) where the midpoint of the NBBO is an eligible execution price at the time of the match (that is, assuming both the Non-Session Conditional Order and contraside interest were firm orders). Session Conditional Orders are eligible to interact at any price at or inside the NBBO. Where "eligible" contraside interest exists, all eligible conditional orders will receive Invites, regardless of time of receipt. Conditional orders may include ALO instructions, in which case the party submitting the conditional order will only receive an Invite where the conditional order would have been deemed to add liquidity at the time of the match (that is, assuming both the conditional order and contraside interest were firm orders). Subscribers may designate their conditional orders as ineligible to interact with other orders if the NBBO spread, as calculated by the ATS, is greater than $0.01 (or greater than $0.0001 where an execution would occur at a price that is less than $1.00). Firm-Up Orders: Firm-Up Orders are firm orders submitted in response to an Invite (as defined at Item III Part 9). A Firm-Up Order must contain the same symbol, side, MPID and minimum block size quantity as the conditional order related to the Invite or it will be rejected by the LeveL ATS. As further discussed herein, Firm-Up Orders resulting from Session Conditional Orders (such Firm-Up Orders, "Session Firm-Up Orders") and Firm-Up Orders resulting from Non-Session Conditional Orders (such Firm-Up Orders, "Non-Session Firm-Up Orders") differ in manner of operation. A Firm-Up Order's status as a Session Firm-Up Order or Non-Session Firm-Up Order is determined exclusively on the Session or Non-Session status of the underlying conditional order, and accordingly, the election of whether a Firm-Up Order operates as a Session or Non-Session Firm-Up Order is effectively made at the conditional order stage. For clarity, the term "Firm-Up Order," as used herein, includes both Session and Non-Session Firm-Up Orders unless otherwise specified. Subscribers may designate Firm-Up Orders as Day or GTT and must include a time-in-force of at least one (1) second if designated as GTT. Firm-Up Orders may not be designated as IOC or Enhanced IOC. As further discussed below, Non-Session Firm-Up Orders are only eligible to execute at the midpoint of the NBBO, while Session Firm-Up Orders are eligible to execute at any price at or inside the NBBO. Firm-Up Orders may include market, limit or pegged pricing instructions. Subject to the restrictions discussed in this paragraph, Firm-Up Orders may be pegged to the NBB, the NBO or midpoint of the NBBO. Firm-Up Orders pegged to the market (i.e., sell order pegged to the NBB or buy order pegged to the NBO) may include an offset price (e.g., buy 100 shares of ABC pegged to the NBO minus $0.02). Firm-Up Orders pegged to the midpoint of the NBBO may not include an offset price. Session Firm-Up Orders may be pegged to the primary and may include an offset price. Non-Session Firm-Up Orders may not be pegged to the primary; the LeveL ATS will reject any Non-Session Firm-Up Orders pegged to the primary. Non-Session Firm-Up Orders must either (a) have a pricing instruction that is at or better than the pricing instruction of the originating conditional order (e.g., a subscriber that submitted a market conditional order may submit a marketable limit Firm-Up Order) or (b) be priced at-or-better than the midpoint of the NBBO at the time of submission (e.g., a subscriber that submitted a market conditional order may submit a Firm-Up Order pegged to the midpoint of the NBBO). Session Firm-Up Orders must either (a) have a pricing instruction that is at or better than the pricing instruction of the originating conditional order (e.g., a subscriber that submitted a market conditional order may submit a marketable limit Firm-Up Order) or (b) have effective limit prices that, at the time of submission, are at least equal to the NBB (for buy orders) or NBO (for sell orders). Firm-Up Orders resulting from conditional orders with ALO instructions must themselves include ALO instructions; where such a Firm-Up Order does not include ALO instructions, the LeveL ATS will reject the order (as noted above, Firm-Up Orders must include a time-in-force of at least one (1) second and may interact with orders other than the contraside order from the initial match). The LeveL ATS will reject Firm-Up Orders with ALO instructions where the related conditional order did not include ALO instructions. Subscribers may designate their Firm-Up Orders as ineligible to interact with other orders if the NBBO spread, as calculated by the LeveL ATS, is greater than $0.01 (or greater than $0.0001 where an execution would occur at a price that is less than $1.00). Subscribers cannot designate their Firm-Up Orders as ineligible to interact with conditional orders, but may designate Firm-Up Orders as only eligible to interact with conditional and Firm-Up Orders. Firm-Up Orders are treated like "standard" firm orders for matching and priority purposes. However, as noted above, Non-Session Firm-Up Orders are only eligible to execute at the midpoint of the NBBO. Accordingly, Non-Session Firm-Up Orders with effective limit prices below the prevailing midpoint of the NBBO are ineligible for execution, although they will, in accordance with their terms, remain in the LeveL ATS and may subsequently become eligible for execution. Where a Non-Session Firm-Up Order matches with a "standard" firm order, the execution will occur at the midpoint of the NBBO, without regard as to which order was deemed to add or remove liquidity. Session Firm-Up Orders are treated as "standard" firm orders when determining both eligible execution prices and resulting execution price. The LeveL ATS does not prevent subscribers from submitting firm orders that are not Firm-Up Orders following receipt of an Invite, although the LeveL ATS treats the subscriber as failing to have "firmed-up" in response to the Invite. Firm-Up Orders may not be modified. Minimum Execution Size: Subscribers may specify a "Minimum Quantity" or "Minimum Block Size" associated with a firm order. Minimum Quantities and Minimum Block Sizes may be expressed in odd or mixed lots, but only where the subscriber has designated the order as eligible to execute in odd or mixed lots, as applicable. The LeveL ATS will reject any order with an odd or mixed lot Minimum Quantity or Minimum Block Size where the subscriber has not separately designated the order as eligible to execute in odd or mixed lots, as applicable. A "Minimum Quantity" instruction specifies the minimum execution size a subscriber will accept and allows for the aggregation of any number of contraside orders. A "Minimum Block Size" instruction specifies the minimum execution size a subscriber will accept and does not allow for the aggregation of contraside interest. Conditional and Firm-Up Orders must include a Minimum Block Size instruction. The LeveL ATS, however, will accept a conditional or Firm-Up Order that includes a Minimum Quantity instruction, but it will treat the Minimum Quantity instruction as a Minimum Block Size instruction. The VWAP Order Types cannot include Minimum Quantity or Minimum Block Size instructions although they do, as further discussed below, include Minimum Anchor Quantity instructions. Leaves Quantity; Minimum Quantity Orders: Subscribers may instruct whether a Minimum Quantity order, following its initial execution, should be cancelled back to the subscriber or remain eligible for additional executions. Additionally, subscribers may include an instruction such that, where the leaves quantity of a Minimum Quantity order falls below its Minimum Quantity instruction, the LeveL ATS either (x) cancels back the order or (y) removes the Minimum Quantity instruction for the order (that is, disregards the Minimum Quantity instruction and allows the order to execute in any permitted lot size). Leaves Quantity; Minimum Block Size Orders: Subscribers may instruct whether a Minimum Block Size order, following its initial execution, should be cancelled back to the subscriber or remain eligible for additional executions. Additionally, subscribers may include an instruction such that, where the leaves quantity of a Minimum Block Size order falls below its Minimum Block Size, the LeveL ATS either (x) cancels back the order or (y) reduces the Minimum Block Size instruction to the size of the leaves quantity (for instance, if a 20,000 share order with a Minimum Block Size of 10,000 shares is party to an execution for 15,000 shares, the 5,000 share leaves quantity would remain eligible for execution and, effectively, be treated as having a 5,000 share Minimum Block Size instruction). ORDER ROUTING: The LeveL ATS does not route any order flow. See ATS-N Part III ITM.7a for the remainder of this response.

order_types

Order Types (Generally): As further discussed herein, the LeveL ATS accepts firm orders, including Firm-Up Orders, conditional orders, Full Day VWAP Orders, VWAP Block Orders and VWAP Sliced Orders (VWAP Sliced Orders, together with Full Day VWAP Orders and VWAP Block Orders, the "VWAP Order Types"). Except where otherwise noted, references to firm orders include Firm-Up Orders (as that term is defined herein). Orders of a particular VWAP Order Type may only interact with orders of the same VWAP Order type (e.g., Full Day VWAP Orders may only interact with other Full Day VWAP Orders). Except where noted below, all orders may be cancelled by timely submission to the LeveL ATS of cancellation instructions. Firm Orders (Excluding Firm-Up Orders): Firm orders may include market, limit or pegged price instructions. Subscribers may designate firm orders as immediate-or-cancel ("IOC"), "Day," good-til-time ("GTT," expressed either in seconds or by specifying an expiration time) or "enhanced" IOC (such orders "Enhanced IOC" orders, further discussed below). Subscribers may designate firm orders as ineligible to interact with other orders if the NBBO spread, as calculated by the ATS, is greater than $0.01 (or greater than $0.0001 where an execution would occur at a price that is less than $1.00). Subscribers may designate firm orders as add-liquidity-only ("ALO"). ALO orders will only interact with other orders if the ALO order would be deemed to be adding liquidity. See Part III Item 11 for further discussion of when an order is deemed to "add" or "remove" liquidity. Where, upon receipt, an ALO order is marketable against trading interest on the LeveL ATS, the LeveL ATS will accept the ALO order for further processing (e.g., potential matching where the ALO would be deemed to be adding liquidity). Pegged orders are limit orders with a limit price that constantly changes based on movements in the designated reference price. Pegged orders may, but are not required to, include an ultimate limit price (e.g. buy 100 shares of ABC pegged to the offer but limited to $20.05) and, for orders other than IOC and Enhanced IOC orders, may also include an offset price (e.g., buy 100 shares of ABC pegged to the national best offer ("NBO") minus $0.02). Firm orders may be pegged to the NBO, the national best bid ("NBB") or midpoint of the national best bid or offer ("NBBO"). Offset prices must be expressed in penny increments per share for securities priced equal to or greater than $1.00 per share and hundredths of a cent for securities priced less than $1.00 per share or the LeveL ATS will reject the order. Resting orders with offsets expressed in hundredths of a cent will be cancelled if the bid or offer becomes equal to or greater than $1.00 per share. Orders pegged to the midpoint of the NBBO may not include a peg-offset. As noted above, subscribers may designate orders as "Enhanced IOC" orders. Only firm orders may be designated as Enhanced IOC orders. Generally, an Enhanced IOC order operates like a "standard" IOC order and either immediately executes (in whole or in part) against resting contraside interest or is cancelled by the LeveL ATS. However, where there is a resting eligible contraside conditional order or orders in the LeveL ATS at the time the LeveL ATS receives the Enhanced IOC order, the Enhanced IOC order will remain in the LeveL ATS for a subscriber-configured period of time of at least 100 milliseconds (such period, which is configurable in millisecond increments, the "Hold Period"). For clarity, where there is both resting firm and conditional trading interest in the LeveL ATS at the time the LeveL ATS receives the Enhanced IOC order, the Enhanced IOC will execute, in whole or in part, against the firm order (which may be a firm or Firm-Up Order) and the leaves quantity will be immediately cancelled. During the Hold Period the Enhanced IOC order is eligible to interact with any eligible contraside trading interest in the LeveL ATS and may "invite" other conditional orders to "firm-up." In the event the Enhanced IOC order receives a partial fill during the Hold Period the LeveL ATS will immediately cancel the order's leaves quantity (even where the Hold Period has not expired). Subscribers may not cancel an Enhanced IOC order during the Hold Period. For clarity, the Hold Period on a given order is not "extended" or "reset" for any reason. By default, the LeveL ATS designates firm orders (including Enhanced IOC orders) as ineligible to interact with conditional orders. However, LeveL Markets will remove the default designation upon subscriber request and permit the subscriber to designate firm orders as either eligible or ineligible to interact with conditional orders on an order-by-order basis. Firm orders designated as ineligible to interact with conditional orders will not invite a conditional order to firm-up, but are nevertheless eligible to interact with Firm-Up Orders (other than Firm-Up Orders that include a "conditional only" order instruction). Firm orders may be modified, but their firm status cannot be modified (i.e., a firm order cannot be modified to be a conditional order). A modified firm order will receive a new time of receipt for priority purposes, except where the only modification is a reduction in order quantity. Conditional Orders: A conditional order is an instruction to the LeveL ATS that the subscriber wants to interact with the order book on a conditional basis. A conditional order never executes; instead, when a conditional order would have otherwise matched with another order, the conditional order is cancelled by the LeveL ATS and an invitation (i.e., an "Invite" as defined at Part III Item 9) is sent to the originating subscriber, inviting the subscriber to send a Firm-Up Order in response. As further discussed below, conditional orders, by default, may only interact at the midpoint of the prevailing NBBO. However, upon subscriber request to LeveL Markets, however made, LeveL Markets will remove the default logic and allow conditional orders that utilize Session Permissioning instructions to interact at any price at or inside the prevailing NBBO (such conditional orders designated as eligible to interact at any price at or inside the prevailing NBBO, "Session Conditional Orders," all other conditional orders, "Non-Session Conditional Orders"). For clarity, as used herein, the term "conditional order" includes both Session and Non-Session Conditional Orders and Extended Firm-Up Time Required ("EFUT") Conditional Orders, as defined in this Item and in Part III Item 9(a), unless otherwise specified. Conditional orders may include market, limit or pegged pricing instructions. Subject to the restrictions discussed in this paragraph, conditional orders may be pegged to the NBB, the NBO or midpoint of the NBBO. Conditional orders pegged to the market (i.e., sell order pegged to the NBB or buy order pegged to the NBO) may include an offset price (e.g., buy 100 shares of ABC pegged to the NBO minus $0.02). Conditional orders pegged to the midpoint of the NBBO may not include an offset price. Session Conditional Orders may be pegged to the primary (i.e. sell order pegged to the NBO or buy order pegged to the NBB) and may include an offset price. Non-Session Conditional Orders may not be pegged to the primary; the LeveL ATS will reject any Non-Session Conditional Orders pegged to the primary. As further discussed below, conditional orders must include a Minimum Quantity or a Minimum Block Size. Subscribers may designate conditional orders as "Day" or GTT. Conditional orders may not be designated as IOC or Enhanced IOC. Conditional orders may be modified, but their conditional status cannot be modified (i.e., a conditional order cannot be modified to be a firm order). Conditional and Firm-Up orders may include instructions to not interact with firm orders other than Firm-Up Orders. Firm orders, other than Firm-Up Orders, may not include a conditional-only order attribute. Non-Session Conditional Orders will only interact with contraside interest (i.e., "generate" an Invite) where the midpoint of the NBBO is an eligible execution price at the time of the match (that is, assuming both the Non-Session Conditional Order and contraside interest were firm orders). Session Conditional Orders are eligible to interact at any price at or inside the NBBO. Where "eligible" contraside interest exists, all eligible conditional orders will receive Invites, regardless of time of receipt. Conditional orders may include ALO instructions, in which case the party submitting the conditional order will only receive an Invite where the conditional order would have been deemed to add liquidity at the time of the match (that is, assuming both the conditional order and contraside interest were firm orders). Subscribers may designate their conditional orders as ineligible to interact with other orders if the NBBO spread, as calculated by the ATS, is greater than $0.01 (or greater than $0.0001 where an execution would occur at a price that is less than $1.00). Firm-Up Orders: Firm-Up Orders are firm orders submitted in response to an Invite (as defined at Item III Part 9). A Firm-Up Order must contain the same symbol, side, and MPID as the conditional order related to the Invite or it will be rejected by the LeveL ATS. As further discussed herein, Firm-Up Orders resulting from Session Conditional Orders (such Firm-Up Orders, "Session Firm-Up Orders") and Firm-Up Orders resulting from Non-Session Conditional Orders (such Firm-Up Orders, "Non-Session Firm-Up Orders") differ in manner of operation. A Firm-Up Order's status as a Session Firm-Up Order or Non-Session Firm-Up Order is determined exclusively on the Session or Non-Session status of the underlying conditional order, and accordingly, the election of whether a Firm-Up Order operates as a Session or Non-Session Firm-Up Order is effectively made at the conditional order stage. For clarity, the term "Firm-Up Order," as used herein, includes both Session and Non-Session Firm-Up Orders unless otherwise specified. Subscribers may designate Firm-Up Orders as Day or GTT and must include a time-in-force of at least one (1) second if designated as GTT. Firm-Up Orders may not be designated as IOC or Enhanced IOC. As further discussed below, Non-Session Firm-Up Orders are only eligible to execute at the midpoint of the NBBO, while Session Firm-Up Orders are eligible to execute at any price at or inside the NBBO. Firm-Up Orders may include market, limit or pegged pricing instructions. Subject to the restrictions discussed in this paragraph, Firm-Up Orders may be pegged to the NBB, the NBO or midpoint of the NBBO. Firm-Up Orders pegged to the market (i.e., sell order pegged to the NBB or buy order pegged to the NBO) may include an offset price (e.g., buy 100 shares of ABC pegged to the NBO minus $0.02). Firm-Up Orders pegged to the midpoint of the NBBO may not include an offset price. Session Firm-Up Orders may be pegged to the primary and may include an offset price. Non-Session Firm-Up Orders may not be pegged to the primary; the LeveL ATS will reject any Non-Session Firm-Up Orders pegged to the primary. Non-Session Firm-Up Orders must either (a) have a pricing instruction that is at or better than the pricing instruction of the originating conditional order (e.g., a subscriber that submitted a market conditional order may submit a marketable limit Firm-Up Order) or (b) be priced at-or-better than the midpoint of the NBBO at the time of submission (e.g., a subscriber that submitted a market conditional order may submit a Firm-Up Order pegged to the midpoint of the NBBO). Session Firm-Up Orders must either (a) have a pricing instruction that is at or better than the pricing instruction of the originating conditional order (e.g., a subscriber that submitted a market conditional order may submit a marketable limit Firm-Up Order) or (b) have effective limit prices that, at the time of submission, are at least equal to the NBB (for buy orders) or NBO (for sell orders). Firm-Up Orders resulting from conditional orders with ALO instructions must themselves include ALO instructions; where such a Firm-Up Order does not include ALO instructions, the LeveL ATS will reject the order (as noted above, Firm-Up Orders must include a time-in-force of at least one (1) second and may interact with orders other than the contraside order from the initial match). The LeveL ATS will reject Firm-Up Orders with ALO instructions where the related conditional order did not include ALO instructions. Subscribers may designate their Firm-Up Orders as ineligible to interact with other orders if the NBBO spread, as calculated by the LeveL ATS, is greater than $0.01 (or greater than $0.0001 where an execution would occur at a price that is less than $1.00). Subscribers cannot designate their Firm-Up Orders as ineligible to interact with conditional orders, but may designate Firm-Up Orders as only eligible to interact with conditional and Firm-Up Orders. Firm-Up Orders are treated like "standard" firm orders for matching and priority purposes. However, as noted above, Non-Session Firm-Up Orders are only eligible to execute at the midpoint of the NBBO. Accordingly, Non-Session Firm-Up Orders with effective limit prices below the prevailing midpoint of the NBBO are ineligible for execution, although they will, in accordance with their terms, remain in the LeveL ATS and may subsequently become eligible for execution. Where a Non-Session Firm-Up Order matches with a "standard" firm order, the execution will occur at the midpoint of the NBBO, without regard as to which order was deemed to add or remove liquidity. Session Firm-Up Orders are treated as "standard" firm orders when determining both eligible execution prices and resulting execution price. The LeveL ATS does not prevent subscribers from submitting firm orders that are not Firm-Up Orders following receipt of an Invite, although the LeveL ATS treats the subscriber as failing to have "firmed-up" in response to the Invite. Firm-Up Orders may not be modified. Minimum Execution Size: Subscribers may specify a "Minimum Quantity" or "Minimum Block Size" associated with a firm order. Minimum Quantities and Minimum Block Sizes may be expressed in odd or mixed lots, but only where the subscriber has designated the order as eligible to execute in odd or mixed lots, as applicable. The LeveL ATS will reject any order with an odd or mixed lot Minimum Quantity or Minimum Block Size where the subscriber has not separately designated the order as eligible to execute in odd or mixed lots, as applicable. A "Minimum Quantity" instruction specifies the minimum execution size a subscriber will accept and allows for the aggregation of any number of contraside orders. A subscriber may specify a "floor" or minimum quantity of the partial fills that can be aggregated to meet the Minimum Quantity as defined above (the "Minimum Fill Size"). For example, if a subscriber enters an order to buy 10,000 shares of the security ABCD with a Minimum Quantity of 5,000 shares, the subscriber can, if they choose, specify that any fills that can be aggregated to make up the 5,000 share Minimum Quantity be for a specified minimum amount, such as 1,000 shares. In that case, none of the fills that would be able to be aggregated to meet the 5,000 share Minimum Quantity could be for less than 1,000 shares, the specified Minimum Fill Size. Any Minimum Quantity and Minimum Fill Size may be reduced on a firm-up from the values specified in the original conditional order, if desired by the subscriber. A "Minimum Block Size" instruction specifies the minimum execution size a subscriber will accept and does not allow for the aggregation of contraside interest. Conditional and Firm-Up Orders must include a Minimum Quantity or a Minimum Block Size instruction. If a conditional or Firm-Up Order includes a Minimum Quantity instruction but does not also include a Minimum Fill Size instruction, the LeveL ATS will treat the Minimum Quantity instruction as a Minimum Block Size instruction. The VWAP Order Types cannot include Minimum Quantity or Minimum Block Size instructions although they do, as further discussed below, include Minimum Anchor Quantity instructions. Leaves Quantity; Minimum Quantity Orders: Subscribers may instruct whether a Minimum Quantity order, following its initial execution, should be cancelled back to the subscriber or remain eligible for additional executions. Additionally, subscribers may include an instruction such that, where the leaves quantity of a Minimum Quantity order falls below its Minimum Quantity instruction, the LeveL ATS either (x) cancels back the order or (y) removes the Minimum Quantity instruction for the order (that is, disregards the Minimum Quantity instruction and allows the order to execute in any permitted lot size). In scenario (y) above, any specified Minimum Fill Size, as described above, will similarly be disregarded. Leaves Quantity; Minimum Block Size Orders: Subscribers may instruct whether a Minimum Block Size order, following its initial execution, should be cancelled back to the subscriber or remain eligible for additional executions. Additionally, subscribers may include an instruction such that, where the leaves quantity of a Minimum Block Size order falls below its Minimum Block Size, the LeveL ATS either (x) cancels back the order or (y) reduces the Minimum Block Size instruction to the size of the leaves quantity (for instance, if a 20,000 share order with a Minimum Block Size of 10,000 shares is party to an execution for 15,000 shares, the 5,000 share leaves quantity would remain eligible for execution and, effectively, be treated as having a 5,000 share Minimum Block Size instruction). Subscribers that are parties to unilateral (self-matching), bilateral, or multilateral trading arrangements, as described in Part III Item 14, are able to specify a "ceiling" or maximum quantity of a contra side order that it wishes to potentially match against (the "Maximum Contra Side Order Quantity"). For example, if a subscriber enters an order to buy 10,000 shares of the security WXYZ designated for a unilateral, bilateral, or multilateral trading arrangement, that subscriber can, if they choose, specify that any orders that it can potentially match against be for a specified maximum amount, such as 1,000 shares. In this example, none of the orders that could potentially match against that entering subscriber's order could be for more than 1,000 shares, the specified Maximum Contra Side Order Quantity. In this case, if the original quantity of a contra side order was 2,000 shares but whose leaves quantity was reduced to below 1,000 shares due to partial fills, that contra side order would still not be eligible to match against the subscriber order with the specified 1,000 share Maximum Contra Side Order Quantity because the original quantity of the contra side order was for 2,000 shares. ORDER ROUTING: The LeveL ATS does not route any order flow. See ATS-N Part III ITM.7a for the remainder of this response.

order_types

Order Types (Generally): As further discussed herein, the LeveL ATS accepts firm orders, including Firm-Up Orders, conditional orders, Full Day VWAP Orders, VWAP Block Orders and VWAP Sliced Orders (VWAP Sliced Orders, together with Full Day VWAP Orders and VWAP Block Orders, the "VWAP Order Types"). Except where otherwise noted, references to firm orders include Firm-Up Orders (as that term is defined herein). Orders of a particular VWAP Order Type may only interact with orders of the same VWAP Order type (e.g., Full Day VWAP Orders may only interact with other Full Day VWAP Orders). Except where noted below, all orders may be cancelled by timely submission to the LeveL ATS of cancellation instructions. Firm Orders (Excluding Firm-Up Orders): Firm orders may include market, limit or pegged price instructions. Subscribers may designate firm orders as immediate-or-cancel ("IOC"), "Day," good-til-time ("GTT," expressed either in seconds or by specifying an expiration time) or "enhanced" IOC (such orders "Enhanced IOC" orders, further discussed below). Subscribers may designate firm orders as ineligible to interact with other orders if the NBBO spread, as calculated by the ATS, is greater than $0.01 (or greater than $0.0001 where an execution would occur at a price that is less than $1.00). Subscribers may designate firm orders as add-liquidity-only ("ALO"). ALO orders will only interact with other orders if the ALO order would be deemed to be adding liquidity. See Part III Item 11 for further discussion of when an order is deemed to "add" or "remove" liquidity. Where, upon receipt, an ALO order is marketable against trading interest on the LeveL ATS, the LeveL ATS will accept the ALO order for further processing (e.g., potential matching where the ALO would be deemed to be adding liquidity). Pegged orders are limit orders with a limit price that constantly changes based on movements in the designated reference price. Pegged orders may, but are not required to, include an ultimate limit price (e.g. buy 100 shares of ABC pegged to the offer but limited to $20.05) and, for orders other than IOC and Enhanced IOC orders, may also include an offset price (e.g., buy 100 shares of ABC pegged to the national best offer ("NBO") minus $0.02). Firm orders may be pegged to the NBO, the national best bid ("NBB") or midpoint of the national best bid or offer ("NBBO"). Offset prices must be expressed in penny increments per share for securities priced equal to or greater than $1.00 per share and hundredths of a cent for securities priced less than $1.00 per share or the LeveL ATS will reject the order. Resting orders with offsets expressed in hundredths of a cent will be cancelled if the bid or offer becomes equal to or greater than $1.00 per share. Orders pegged to the midpoint of the NBBO may not include a peg-offset. As noted above, subscribers may designate orders as "Enhanced IOC" orders. Only firm orders may be designated as Enhanced IOC orders. Generally, an Enhanced IOC order operates like a "standard" IOC order and either immediately executes (in whole or in part) against resting contraside interest or is cancelled by the LeveL ATS. However, where there is a resting eligible contraside conditional order or orders in the LeveL ATS at the time the LeveL ATS receives the Enhanced IOC order, the Enhanced IOC order will remain in the LeveL ATS for a subscriber-configured period of time of at least 100 milliseconds (such period, which is configurable in millisecond increments, the "Hold Period"). For clarity, where there is both resting firm and conditional trading interest in the LeveL ATS at the time the LeveL ATS receives the Enhanced IOC order, the Enhanced IOC will execute, in whole or in part, against the firm order (which may be a firm or Firm-Up Order) and the leaves quantity will be immediately cancelled. During the Hold Period the Enhanced IOC order is eligible to interact with any eligible contraside trading interest in the LeveL ATS and may "invite" other conditional orders to "firm-up." In the event the Enhanced IOC order receives a partial fill during the Hold Period the LeveL ATS will immediately cancel the order's leaves quantity (even where the Hold Period has not expired). Subscribers may not cancel an Enhanced IOC order during the Hold Period. For clarity, the Hold Period on a given order is not "extended" or "reset" for any reason. By default, the LeveL ATS designates firm orders (including Enhanced IOC orders) as ineligible to interact with conditional orders. However, LeveL Markets will remove the default designation upon subscriber request and permit the subscriber to designate firm orders as either eligible or ineligible to interact with conditional orders on an order-by-order basis. Firm orders designated as ineligible to interact with conditional orders will not invite a conditional order to firm-up, but are nevertheless eligible to interact with Firm-Up Orders (other than Firm-Up Orders that include a "conditional only" order instruction). Firm orders may be modified, but their firm status cannot be modified (i.e., a firm order cannot be modified to be a conditional order). A modified firm order will receive a new time of receipt for priority purposes, except where the only modification is a reduction in order quantity. Conditional Orders: A conditional order is an instruction to the LeveL ATS that the subscriber wants to interact with the order book on a conditional basis. A conditional order never executes; instead, when a conditional order would have otherwise matched with another order, the conditional order is cancelled by the LeveL ATS and an invitation (i.e., an "Invite" as defined at Part III Item 9) is sent to the originating subscriber, inviting the subscriber to send a Firm-Up Order in response. As further discussed below, conditional orders, by default, may only interact at the midpoint of the prevailing NBBO. However, upon subscriber request to LeveL Markets, however made, LeveL Markets will remove the default logic and allow conditional orders that utilize Session Permissioning instructions to interact at any price at or inside the prevailing NBBO (such conditional orders designated as eligible to interact at any price at or inside the prevailing NBBO, "Session Conditional Orders," all other conditional orders, "Non-Session Conditional Orders"). For clarity, as used herein, the term "conditional order" includes both Session and Non-Session Conditional Orders and Extended Firm-Up Time Required ("EFUT") Conditional Orders, as defined in this Item and in Part III Item 9(a), unless otherwise specified. Conditional orders may include market, limit or pegged pricing instructions. Subject to the restrictions discussed in this paragraph, conditional orders may be pegged to the NBB, the NBO or midpoint of the NBBO. Conditional orders pegged to the market (i.e., sell order pegged to the NBB or buy order pegged to the NBO) may include an offset price (e.g., buy 100 shares of ABC pegged to the NBO minus $0.02). Conditional orders pegged to the midpoint of the NBBO may not include an offset price. Session Conditional Orders may be pegged to the primary (i.e. sell order pegged to the NBO or buy order pegged to the NBB) and may include an offset price. Non-Session Conditional Orders may not be pegged to the primary; the LeveL ATS will reject any Non-Session Conditional Orders pegged to the primary. As further discussed below, conditional orders must include a Minimum Quantity or a Minimum Block Size. Subscribers may designate conditional orders as "Day" or GTT. Conditional orders may not be designated as IOC or Enhanced IOC. Conditional orders may be modified, but their conditional status cannot be modified (i.e., a conditional order cannot be modified to be a firm order). Conditional and Firm-Up orders may include instructions to not interact with firm orders other than Firm-Up Orders. Firm orders, other than Firm-Up Orders, may not include a conditional-only order attribute. Non-Session Conditional Orders will only interact with contraside interest (i.e., "generate" an Invite) where the midpoint of the NBBO is an eligible execution price at the time of the match (that is, assuming both the Non-Session Conditional Order and contraside interest were firm orders). Session Conditional Orders are eligible to interact at any price at or inside the NBBO. Where "eligible" contraside interest exists, all eligible conditional orders will receive Invites, regardless of time of receipt. Conditional orders may include ALO instructions, in which case the party submitting the conditional order will only receive an Invite where the conditional order would have been deemed to add liquidity at the time of the match (that is, assuming both the conditional order and contraside interest were firm orders). Subscribers may designate their conditional orders as ineligible to interact with other orders if the NBBO spread, as calculated by the ATS, is greater than $0.01 (or greater than $0.0001 where an execution would occur at a price that is less than $1.00). Firm-Up Orders: Firm-Up Orders are firm orders submitted in response to an Invite (as defined at Item III Part 9). A Firm-Up Order must contain the same symbol, side, and MPID as the conditional order related to the Invite or it will be rejected by the LeveL ATS. As further discussed herein, Firm-Up Orders resulting from Session Conditional Orders (such Firm-Up Orders, "Session Firm-Up Orders") and Firm-Up Orders resulting from Non-Session Conditional Orders (such Firm-Up Orders, "Non-Session Firm-Up Orders") differ in manner of operation. A Firm-Up Order's status as a Session Firm-Up Order or Non-Session Firm-Up Order is determined exclusively on the Session or Non-Session status of the underlying conditional order, and accordingly, the election of whether a Firm-Up Order operates as a Session or Non-Session Firm-Up Order is effectively made at the conditional order stage. For clarity, the term "Firm-Up Order," as used herein, includes both Session and Non-Session Firm-Up Orders unless otherwise specified. Subscribers may designate Firm-Up Orders as Day or GTT and must include a time-in-force of at least one (1) second if designated as GTT. Firm-Up Orders may not be designated as IOC or Enhanced IOC. As further discussed below, Non-Session Firm-Up Orders are only eligible to execute at the midpoint of the NBBO, while Session Firm-Up Orders are eligible to execute at any price at or inside the NBBO. Firm-Up Orders may include market, limit or pegged pricing instructions. Subject to the restrictions discussed in this paragraph, Firm-Up Orders may be pegged to the NBB, the NBO or midpoint of the NBBO. Firm-Up Orders pegged to the market (i.e., sell order pegged to the NBB or buy order pegged to the NBO) may include an offset price (e.g., buy 100 shares of ABC pegged to the NBO minus $0.02). Firm-Up Orders pegged to the midpoint of the NBBO may not include an offset price. Session Firm-Up Orders may be pegged to the primary and may include an offset price. Non-Session Firm-Up Orders may not be pegged to the primary; the LeveL ATS will reject any Non-Session Firm-Up Orders pegged to the primary. Non-Session Firm-Up Orders must either (a) have a pricing instruction that is at or better than the pricing instruction of the originating conditional order (e.g., a subscriber that submitted a market conditional order may submit a marketable limit Firm-Up Order) or (b) be priced at-or-better than the midpoint of the NBBO at the time of submission (e.g., a subscriber that submitted a market conditional order may submit a Firm-Up Order pegged to the midpoint of the NBBO). Session Firm-Up Orders must either (a) have a pricing instruction that is at or better than the pricing instruction of the originating conditional order (e.g., a subscriber that submitted a market conditional order may submit a marketable limit Firm-Up Order) or (b) have effective limit prices that, at the time of submission, are at least equal to the NBB (for buy orders) or NBO (for sell orders). Firm-Up Orders resulting from conditional orders with ALO instructions must themselves include ALO instructions; where such a Firm-Up Order does not include ALO instructions, the LeveL ATS will reject the order (as noted above, Firm-Up Orders must include a time-in-force of at least one (1) second and may interact with orders other than the contraside order from the initial match). The LeveL ATS will reject Firm-Up Orders with ALO instructions where the related conditional order did not include ALO instructions. Subscribers may designate their Firm-Up Orders as ineligible to interact with other orders if the NBBO spread, as calculated by the LeveL ATS, is greater than $0.01 (or greater than $0.0001 where an execution would occur at a price that is less than $1.00). Subscribers cannot designate their Firm-Up Orders as ineligible to interact with conditional orders, but may designate Firm-Up Orders as only eligible to interact with conditional and Firm-Up Orders. Firm-Up Orders are treated like "standard" firm orders for matching and priority purposes. However, as noted above, Non-Session Firm-Up Orders are only eligible to execute at the midpoint of the NBBO. Accordingly, Non-Session Firm-Up Orders with effective limit prices below the prevailing midpoint of the NBBO are ineligible for execution, although they will, in accordance with their terms, remain in the LeveL ATS and may subsequently become eligible for execution. Where a Non-Session Firm-Up Order matches with a "standard" firm order, the execution will occur at the midpoint of the NBBO, without regard as to which order was deemed to add or remove liquidity. Session Firm-Up Orders are treated as "standard" firm orders when determining both eligible execution prices and resulting execution price. The LeveL ATS does not prevent subscribers from submitting firm orders that are not Firm-Up Orders following receipt of an Invite, although the LeveL ATS treats the subscriber as failing to have "firmed-up" in response to the Invite. Firm-Up Orders may not be modified. Minimum Execution Size: Subscribers may specify a "Minimum Quantity" or "Minimum Block Size" associated with a firm order. Minimum Quantities and Minimum Block Sizes may be expressed in odd or mixed lots, but only where the subscriber has designated the order as eligible to execute in odd or mixed lots, as applicable. The LeveL ATS will reject any order with an odd or mixed lot Minimum Quantity or Minimum Block Size where the subscriber has not separately designated the order as eligible to execute in odd or mixed lots, as applicable. A "Minimum Quantity" instruction specifies the minimum execution size a subscriber will accept and allows for the aggregation of any number of contraside orders. Effective July 31, 2026, a subscriber may specify a "floor" or minimum quantity of the partial fills that can be aggregated to meet the Minimum Quantity as defined above (the "Minimum Fill Size"). For example, if a subscriber enters an order to buy 10,000 shares of the security ABCD with a Minimum Quantity of 5,000 shares, the subscriber, if they choose, will be able to specify that any fills that can be aggregated to make up the 5,000 share Minimum Quantity be for a specified minimum amount, such as 1,000 shares. In that case, none of the fills that would be able to be aggregated to meet the 5,000 share Minimum Quantity could be for less than 1,000 shares, the specified Minimum Fill Size. Any Minimum Quantity and Minimum Fill Size (when implemented) may be reduced on a firm-up from the values specified in the original conditional order, if desired by the subscriber. A "Minimum Block Size" instruction specifies the minimum execution size a subscriber will accept and does not allow for the aggregation of contraside interest. Conditional and Firm-Up Orders must include a Minimum Quantity or a Minimum Block Size instruction. If a conditional or Firm-Up Order includes a Minimum Quantity instruction but does not also include a Minimum Fill Size instruction (when implemented), the LeveL ATS will treat the Minimum Quantity instruction as a Minimum Block Size instruction. The VWAP Order Types cannot include Minimum Quantity or Minimum Block Size instructions although they do, as further discussed below, include Minimum Anchor Quantity instructions. As noted above, the Minimum Fill Size feature is expected to be implemented by July 31, 2026. Leaves Quantity; Minimum Quantity Orders: Subscribers may instruct whether a Minimum Quantity order, following its initial execution, should be cancelled back to the subscriber or remain eligible for additional executions. Additionally, subscribers may include an instruction such that, where the leaves quantity of a Minimum Quantity order falls below its Minimum Quantity instruction, the LeveL ATS either (x) cancels back the order or (y) removes the Minimum Quantity instruction for the order (that is, disregards the Minimum Quantity instruction and allows the order to execute in any permitted lot size). In scenario (y) above, any specified Minimum Fill Size, as described above, will similarly be disregarded. Leaves Quantity; Minimum Block Size Orders: Subscribers may instruct whether a Minimum Block Size order, following its initial execution, should be cancelled back to the subscriber or remain eligible for additional executions. Additionally, subscribers may include an instruction such that, where the leaves quantity of a Minimum Block Size order falls below its Minimum Block Size, the LeveL ATS either (x) cancels back the order or (y) reduces the Minimum Block Size instruction to the size of the leaves quantity (for instance, if a 20,000 share order with a Minimum Block Size of 10,000 shares is party to an execution for 15,000 shares, the 5,000 share leaves quantity would remain eligible for execution and, effectively, be treated as having a 5,000 share Minimum Block Size instruction). Subscribers that are parties to unilateral (self-matching), bilateral, or multilateral trading arrangements, as described in Part III Item 14, are able to specify a "ceiling" or maximum quantity of a contra side order that it wishes to potentially match against (the "Maximum Contra Side Order Quantity"). For example, if a subscriber enters an order to buy 10,000 shares of the security WXYZ designated for a unilateral, bilateral, or multilateral trading arrangement, that subscriber can, if they choose, specify that any orders that it can potentially match against be for a specified maximum amount, such as 1,000 shares. In this example, none of the orders that could potentially match against that entering subscriber's order could be for more than 1,000 shares, the specified Maximum Contra Side Order Quantity. In this case, if the original quantity of a contra side order was 2,000 shares but whose leaves quantity was reduced to below 1,000 shares due to partial fills, that contra side order would still not be eligible to match against the subscriber order with the specified 1,000 share Maximum Contra Side Order Quantity because the original quantity of the contra side order was for 2,000 shares. ORDER ROUTING: The LeveL ATS does not route any order flow. See ATS-N Part III ITM.7a for the remainder of this response.

Item 11 (Part II)

means_of_entry

Trading interest must be submitted via FIX protocol. The LeveL ATS is compliant with version 4.2 of the FIX protocol. Subscribers can connect via cross connects within Equinix NY4 or through various extranet providers. Buyside Subscribers can submit orders via FIX to LeveL Markets, which routes such orders to the LeveL ATS. The LeveL ATS does not accept and does not have the ability to accept manual orders or trading interest.

means_of_entry

Trading interest must be submitted via FIX protocol. The LeveL ATS is compliant with version 4.2 of the FIX protocol. Subscribers can connect via cross connects within Equinix NY4 or through various extranet providers. Effective March 30, 2026, Buyside Subscribers can submit orders via FIX to LeveL Markets, which routes such orders to the LeveL ATS. The LeveL ATS does not accept and does not have the ability to accept manual orders or trading interest.

Item 12 (Part II)

pricing_methodology

The LeveL ATS utilizes data provided by the Securities Information Processor ("SIP") feeds in determining the relevant NBBO for each security. Message data from the SIP feeds is processed by LeveL Markets's feed handler system (the "Feed Handler"), which creates, and provides to the LeveL ATS matching engine, messages that indicate the NBBO for each security. Where two orders submitted to the LeveL ATS have overlapping limit prices, the LeveL ATS matching engine will review the most recent NBBO message provided by the Feed Handler in determining whether an eligible execution price inside the NBBO exists.

pricing_methodology

Item 13 (Part II)

counterparty_selection

As further discussed below, subscribers may designate their trading interest as eligible or ineligible to interact with certain orders or trading interest in the LeveL ATS. Such permissioning elections may be made at the MPID, FIX-session level, or Channel level. Subscriber Channels LeveL Markets will enable a LeveL ATS subscriber to partition or to direct LeveL Markets to partition the subscriber's order flow into one or more "channels." Channels are designed to distinguish meaningfully different types of business from a given subscriber. As discussed above, these can be based on trading behaviors, business units within the subscriber's organization, or some combination thereof. A subscriber can designate to which channel an order belongs either explicitly (by some agreed upon FIX field) or implicitly (for example, by some combination of order attributes or specific gateway sessions) via coordination with LeveL Markets. For example, a subscriber may have a proprietary trading desk with three distinct teams. Each team may have different strategies or investment objectives, and each may have different contra party instruction lists; thus, each of these teams may be identified by the subscriber to LeveL Markets as distinct channels. This channel-based segmentation is made available to all subscribers. LeveL Markets may also, at its sole discretion, designate new channels or consolidate existing channels without communication to the subscriber. (See Item 13 above.). Any changes to channels requested by a subscriber would generally be put into production the following business day. As discussed in Item 13 above, subscribers may run a "mark-out" or other trading analysis of its activity in the LeveL ATS or request that LeveL Markets run one on the subscriber's behalf and use the results of such an analysis to identify activity that it deems to be favorable or unfavorable to that subscriber. The subscriber may request that its order flow - either a specific channel, multiple channels, or all of its order flow - not interact with particular channels that are anonymously selected in the outcome of the contra party analyses of its trading activity. LeveL Markets will review the subscriber's executions during an agreed-upon historical time period, and on the basis of a performance metric defined by the subscriber, LeveL Markets will block or prevent future interactions with contra channels that are not in-line with the subscriber's performance threshold from the subscriber's interaction pool. For example, if a trading analysis of a subscriber's executions in the LeveL ATS shows that a stock tends to move in an unfavorable direction (to them) following certain executions but not others, the subscriber may request that their order flow not interact with any contra channel whose combined executions against the subscriber lead to those unfavorable outcomes. Contra-party Exclusions As discussed in Item 13 above, the channel-based segmentation for the LeveL ATS is replacing the prior segmentation protocol that involved grouping subscribers into different categories such as agency algorithms or smart order routers, broker-dealers, exchanges or other ATSs, electronic market makers, high-touch agency broker-dealers, high-touch proprietary broker-dealers, low-touch prop, and sponsored access arrangements. While these categories are no longer being supported, as described more fully in Item 13, LeveL Markets has mapped those legacy segments into channel-based equivalents and has carried over any existing subscriber exclusion elections utilizing the channel-based equivalents to the previous segments. These exclusion elections can be modified by the subscriber through a request to LeveL Markets, as described below. Subscribers can provide LeveL Markets with a list of market-participant IDs (MPIDs) which it wishes to be excluded from their interactions. As described above, subscribers can also request that LeveL Markets carry out an anonymous contra-party exclusion analysis on their behalf, in which contra-parties are deselected (exclusions) at the channel level, on the basis of a performance metric defined by the subscriber. These analyses are based solely on the subscriber's own performance metric applied to the subscriber's past interactions (executions) with the contra-party channels over some designated time period and with some designated performance threshold. LeveL Markets provides this analysis to all of its subscribers who request it, so long as such requests are reasonable in the Firm's judgment and in its sole discretion. For example, if the subscriber requests the identity or nature of specific counterparties to its executions in the LeveL ATS, if the requests require data that the Firm does not possess, or if the requests are so frequent that the Firm doesn't have the resources to reasonably address them all, those requests will be rejected. A subscriber can have a different set of inclusions or exclusions for each of their own channels. Any contra-party channels that are excluded are done so on an anonymous basis. Note that a subscriber's contra-party exclusions apply asymmetrically - only when the subscriber is providing liquidity in the prospective execution. For the LeveL ATS, an order "provides liquidity" when that order arrives before other orders and rests on the LeveL ATS as a potential counterparty to subsequent orders in that same security. A request for contra-party exclusions to be implemented regardless of liquidity flag (providing or removing) can be made in writing to LeveL Markets and will be evaluated on a case-by-case basis. In circumstances where LeveL Markets has determined to divide a subscriber's order flow into multiple channels based upon its own determination that the subscriber's order flow contained meaningfully distinguishable types of flow, any contra party exclusion requests from the subscriber that had been in place for the single channel will be applied to each new channel created by LeveL Markets unless and until the subscriber requests different exclusions. In addition, if a subscriber had multiple established channels that, in the judgment of LeveL Markets, did not represent meaningfully distinguishable types of flow, but those channels had different contra party exclusions, LeveL Markets would not combine those similar channels into one channel. Subscriber Trading Arrangements A subscriber can engage in unilateral, bilateral, or multilateral trading arrangements with one or more contra parties. These arrangements require the explicit consent from all involved parties and can be configured at the channel level or at the subscriber or MPID level. Provided that LeveL Markets receives the express permission of all subscribers intended to be parties to that arrangement, LeveL Markets will generally approve all such requests. Note that a subscriber channel can have its orders participate in a trading arrangement only, participate in the trading arrangement first and then if not match interact with the general pool of subscribers to the ATS, or simultaneously be eligible to interact outside the arrangement as requested by the subscriber. Such arrangements can be requested via a communication (oral or written, including electronic) to LeveL Markets. There is no default arrangement priority implemented by LeveL Markets. Subscribers may also have multiple trading arrangements and may interact within and among those arrangements and with the broader LeveL pool in whatever order preferred by that subscriber. Orders sent simultaneously to multiple trading arrangements or one or more trading arrangements and the broader LeveL pool will match according to the priority specified by the subscriber, if any, and otherwise by the priority rules of the LeveL ATS as specified herein. There are no different order types or other differences relating to the operation of a trading arrangement from the order types or rules relating to the operation of the LeveL ATS as disclosed in this ATS-N. LeveL Markets will not create or modify subscriber trading arrangements unless directed by the relevant subscriber. On behalf of Buyside Subscribers, LeveL Markets sponsors a trading arrangement through which Buyside Subscribers can trade between themselves and not with the broader LeveL pool. Such Buyside Subscribers can also, if they elect, have LeveL Markets represent their orders within that Buyside Subscriber-specific trading arrangement and in the LeveL pool simultaneously or after seeking a potential match within that trading arrangement first, at the Buyside Subscriber's election and dependent upon the system used by such Buyside Subscriber to route orders to the LeveL ATS. Buyside Subscribers who utilize the UI will be able to interact with the broader LeveL pool after first seeking a match within the Buyside Subscriber trading arrangement and can also have LeveL Markets represent their orders within the Buyside Subscriber trading arrangement and in the LeveL pool simultaneously. Buyside Subscribers routing orders via broker-dealer routers or via Fidelity Service Bureau are only able to interact with orders within the Buyside Subscriber trading arrangement and not with the broader LeveL pool. The default order size for Buyside Subscribers for the Buyside Subscriber trading arrangement is 5,000 shares, which can be increased or decreased upon client request to LeveL Markets. Sponsored Buyside Entities and Outsourced Trading Brokers, as defined in Part II Item 1, are also able to interact with the Buyside Subscriber trading arrangement. Orders sent by Sponsored Buyside Entities to the Buyside Subscriber trading arrangement are only eligible to trade within that trading arrangement and not with the general LeveL pool. Orders sent by Outsourced Trading Brokers to the Buyside Subscriber trading arrangement are eligible to interact with the general LeveL pool at the Outsourced Trading Broker's election as made to LeveL Markets. Subscribers may elect that their orders only interact with other orders submitted by the same subscriber ("Internalization Only"). These subscribers may elect to have orders from certain of their channels (such as desks or other business units) interact or not interact with orders from certain other channels within the same subscriber ("Channel-based Permissioning"). In addition, these subscribers may elect to prioritize potential contra parties to their orders in the LeveL ATS (a "Contra Priority List"). For example, a subscriber may wish to execute internally first if there is a match and then execute against a particular counterparty if not. Similarly, a subscriber may wish to execute against certain potential counterparties in a specific order if there are matching opportunities against such counterparties. For example, a subscriber may want to first look for a match against one or more potential counterparties (Counterparty Set A). If there are no eligible orders from Counterparty Set A, then the subscriber may want to look for a match against Counterparty Set B, and so on. Subscribers electing to use Contra Priority List functionality may, but are not required to, obtain permission from the potential counterparties to prioritize the contra parties in that arrangement. By default, this Contra Priority List functionality only applies when an order is first entered onto the LeveL ATS; instructions unrelated to a Contra Priority List will be followed in the event of a subsequent match in the ATS. As noted above, the subscriber may elect that these orders then be exposed to orders from the rest of the LeveL ATS pool of subscribers or not, at the subscriber's option. Subscribers utilizing Contra Priority List are able to customize their experience within a Contra Priority List in various "waterfall" scenarios. Subscribers may elect that their orders proceed from one contra party in its Contra Priority List to the next (and then to the next, and so on) based upon execution units, based upon time, or a combination of the two. If the "execution" based criterion is elected by the subscriber, the subscriber's order will "fall" from one Counterparty Set to the next in priority following the execution of a subscriber-defined number of shares from the subscriber's orders. In the Contra Priority List example described above, a subscriber may configure that its order to buy 1,000 shares of security ABCD first execute against Counterparty Set A until it has executed at least some number of shares, determined by the subscriber on an order-by-order basis (for example, 200 shares). Once at least 200 shares are executed against Counterparty Set A, the order would then additionally be able to execute against Counterparty Set B (while continuing to be eligible to execute against Counterparty Set A). Once an additional 200 or more shares have been executed against Counterparty Sets A or B, it would then additionally be eligible to execute against Counterparty Set C, and so on. For clarity, in this scenario, the order will not be eligible to execute against Counterparty Set C if the order does not execute for at least the required amount of shares against Counterparty Set A or B first. If the "time" based criterion is elected by the subscriber, the subscriber can configure the order to buy the security ABCD to execute (and continue to execute) against Counterparty Set A, if possible, until some amount of time, determined by the subscriber on an order-by-order basis (for example, one second) has elapsed without a match. The order will then additionally be able to execute against Counterparty Set B, and so on. A subscriber may use both the execution and time parameters in combination. In this configuration, the subscriber has two options, which may be chosen on an order-by-order basis: "either," or "both." If "either" is used, the order will waterfall from one priority level to the next if either criterion is met; if "both" is used, both criteria must be met for an order to waterfall from one Counterparty Set to the next. Any elected "waterfall" scenario will continue in the expressed priority order as long as all activity (firm-ups in response to invitations, etc.) is occurring over the same channel (see Item 13 above). If a firm-up response is sent via a different channel, then any waterfall instructions, if supplied, will be ignored, although "non-waterfall" priority instructions (if any) will be honored. The "execution" based option is not available for VWAP orders. Once all potential counterparties in all Contra Priority List levels (A, B, and C in the above example) are exhausted, the order (if any quantity remains from the order) will be exposed to the rest of the LeveL pool, subject to any contra-party exclusions otherwise in effect. By default, matches within the Buyside Subscriber trading arrangement will "waterfall" from that arrangement to the LeveL pool after the first execution or after fifteen (15) seconds have elapsed from a match if there was no resulting execution. Broker-Dealer Subscribers may elect that their Firm Orders or Conditional Orders not interact with EFUT Conditional Orders (as discussed more fully in Part III Item 7(a) and 9(a)) at the session level or on an order-by-order basis. Subscribers cannot elect for their EFUT Conditional Orders to not interact with other EFUT Conditional Orders.

counterparty_selection

As further discussed below, subscribers may designate their trading interest as eligible or ineligible to interact with certain orders or trading interest in the LeveL ATS. Such permissioning elections may be made at the MPID, FIX-session level, or Channel level. Subscriber Channels LeveL Markets will enable a LeveL ATS subscriber to partition or to direct LeveL Markets to partition the subscriber's order flow into one or more "channels." Channels are designed to distinguish meaningfully different types of business from a given subscriber. As discussed above, these can be based on trading behaviors, business units within the subscriber's organization, or some combination thereof. A subscriber can designate to which channel an order belongs either explicitly (by some agreed upon FIX field) or implicitly (for example, by some combination of order attributes or specific gateway sessions) via coordination with LeveL Markets. For example, a subscriber may have a proprietary trading desk with three distinct teams. Each team may have different strategies or investment objectives, and each may have different contra party instruction lists; thus, each of these teams may be identified by the subscriber to LeveL Markets as distinct channels. This channel-based segmentation is made available to all subscribers. LeveL Markets may also, at its sole discretion, designate new channels or consolidate existing channels without communication to the subscriber. (See Item 13 above.). Any changes to channels requested by a subscriber would generally be put into production the following business day. As discussed in Item 13 above, subscribers may run a "mark-out" or other trading analysis of its activity in the LeveL ATS or request that LeveL Markets run one on the subscriber's behalf and use the results of such an analysis to identify activity that it deems to be favorable or unfavorable to that subscriber. The subscriber may request that its order flow - either a specific channel, multiple channels, or all of its order flow - not interact with particular channels that are anonymously selected in the outcome of the contra party analyses of its trading activity. LeveL Markets will review the subscriber's executions during an agreed-upon historical time period, and on the basis of a performance metric defined by the subscriber, LeveL Markets will block or prevent future interactions with contra channels that are not in-line with the subscriber's performance threshold from the subscriber's interaction pool. For example, if a trading analysis of a subscriber's executions in the LeveL ATS shows that a stock tends to move in an unfavorable direction (to them) following certain executions but not others, the subscriber may request that their order flow not interact with any contra channel whose combined executions against the subscriber lead to those unfavorable outcomes. Contra-party Exclusions As discussed in Item 13 above, the channel-based segmentation for the LeveL ATS is replacing the prior segmentation protocol that involved grouping subscribers into different categories such as agency algorithms or smart order routers, broker-dealers, exchanges or other ATSs, electronic market makers, high-touch agency broker-dealers, high-touch proprietary broker-dealers, low-touch prop, and sponsored access arrangements. While these categories are no longer being supported, as described more fully in Item 13, LeveL Markets has mapped those legacy segments into channel-based equivalents and has carried over any existing subscriber exclusion elections utilizing the channel-based equivalents to the previous segments. These exclusion elections can be modified by the subscriber through a request to LeveL Markets, as described below. Subscribers can provide LeveL Markets with a list of market-participant IDs (MPIDs) which it wishes to be excluded from their interactions. As described above, subscribers can also request that LeveL Markets carry out an anonymous contra-party exclusion analysis on their behalf, in which contra-parties are deselected (exclusions) at the channel level, on the basis of a performance metric defined by the subscriber. These analyses are based solely on the subscriber's own performance metric applied to the subscriber's past interactions (executions) with the contra-party channels over some designated time period and with some designated performance threshold. LeveL Markets provides this analysis to all of its subscribers who request it, so long as such requests are reasonable in the Firm's judgment and in its sole discretion. For example, if the subscriber requests the identity or nature of specific counterparties to its executions in the LeveL ATS, if the requests require data that the Firm does not possess, or if the requests are so frequent that the Firm doesn't have the resources to reasonably address them all, those requests will be rejected. A subscriber can have a different set of inclusions or exclusions for each of their own channels. Any contra-party channels that are excluded are done so on an anonymous basis. Note that a subscriber's contra-party exclusions apply asymmetrically - only when the subscriber is providing liquidity in the prospective execution. For the LeveL ATS, an order "provides liquidity" when that order arrives before other orders and rests on the LeveL ATS as a potential counterparty to subsequent orders in that same security. A request for contra-party exclusions to be implemented regardless of liquidity flag (providing or removing) can be made in writing to LeveL Markets and will be evaluated on a case-by-case basis. In circumstances where LeveL Markets has determined to divide a subscriber's order flow into multiple channels based upon its own determination that the subscriber's order flow contained meaningfully distinguishable types of flow, any contra party exclusion requests from the subscriber that had been in place for the single channel will be applied to each new channel created by LeveL Markets unless and until the subscriber requests different exclusions. In addition, if a subscriber had multiple established channels that, in the judgment of LeveL Markets, did not represent meaningfully distinguishable types of flow, but those channels had different contra party exclusions, LeveL Markets would not combine those similar channels into one channel. Subscriber Trading Arrangements A subscriber can engage in unilateral, bilateral, or multilateral trading arrangements with one or more contra parties. These arrangements require the explicit consent from all involved parties and can be configured at the channel level or at the subscriber or MPID level. Provided that LeveL Markets receives the express permission of all subscribers intended to be parties to that arrangement, LeveL Markets will generally approve all such requests. Note that a subscriber channel can have its orders participate in a trading arrangement only, participate in the trading arrangement first and then if not match interact with the general pool of subscribers to the ATS, or simultaneously be eligible to interact outside the arrangement as requested by the subscriber. Such arrangements can be requested via a communication (oral or written, including electronic) to LeveL Markets. There is no default arrangement priority implemented by LeveL Markets. Subscribers may also have multiple trading arrangements and may interact within and among those arrangements and with the broader LeveL pool in whatever order preferred by that subscriber. Orders sent simultaneously to multiple trading arrangements or one or more trading arrangements and the broader LeveL pool will match according to the priority specified by the subscriber, if any, and otherwise by the priority rules of the LeveL ATS as specified herein. There are no different order types or other differences relating to the operation of a trading arrangement from the order types or rules relating to the operation of the LeveL ATS as disclosed in this ATS-N. LeveL Markets will not create or modify subscriber trading arrangements unless directed by the relevant subscriber. On behalf of Buyside Subscribers, LeveL Markets sponsors a trading arrangement through which Buyside Subscribers can trade between themselves and not with the broader LeveL pool. Such Buyside Subscribers can also, if they elect, have LeveL Markets represent their orders within that Buyside Subscriber-specific trading arrangement and in the LeveL pool simultaneously or after seeking a potential match within that trading arrangement first, at the Buyside Subscriber's election. The default setup is for Buyside Subscriber orders to seek a potential match within the Buyside Subscriber trading arrangement first and then seek a potential match in the broader LeveL pool. This default can be changed upon client request to LeveL Markets. The default minimum order size for the Buyside Subscriber trading arrangement is 5,000 shares, which can be increased or decreased upon client request to LeveL Markets. Sponsored Buyside Entities and Outsourced Trading Brokers, as defined in Part II Item 1, are also able to interact with the Buyside Subscriber trading arrangement. Orders sent by Sponsored Buyside Entities to the Buyside Subscriber trading arrangement are only eligible to trade within that trading arrangement and not with the general LeveL pool. Orders sent by Outsourced Trading Brokers to the Buyside Subscriber trading arrangement are eligible to interact with the general LeveL pool at the Outsourced Trading Broker's election as made to LeveL Markets. Subscribers may elect that their orders only interact with other orders submitted by the same subscriber ("Internalization Only"). These subscribers may elect to have orders from certain of their channels (such as desks or other business units) interact or not interact with orders from certain other channels within the same subscriber ("Channel-based Permissioning"). In addition, these subscribers may elect to prioritize potential contra parties to their orders in the LeveL ATS (a "Contra Priority List"). For example, a subscriber may wish to execute internally first if there is a match and then execute against a particular counterparty if not. Similarly, a subscriber may wish to execute against certain potential counterparties in a specific order if there are matching opportunities against such counterparties. For example, a subscriber may want to first look for a match against one or more potential counterparties (Counterparty Set A). If there are no eligible orders from Counterparty Set A, then the subscriber may want to look for a match against Counterparty Set B, and so on. Subscribers electing to use Contra Priority List functionality may, but are not required to, obtain permission from the potential counterparties to prioritize the contra parties in that arrangement. By default, this Contra Priority List functionality only applies when an order is first entered onto the LeveL ATS; instructions unrelated to a Contra Priority List will be followed in the event of a subsequent match in the ATS. As noted above, the subscriber may elect that these orders then be exposed to orders from the rest of the LeveL ATS pool of subscribers or not, at the subscriber's option. Subscribers utilizing Contra Priority List are able to customize their experience within a Contra Priority List in various "waterfall" scenarios. Subscribers may elect that their orders proceed from one contra party in its Contra Priority List to the next (and then to the next, and so on) based upon execution units, based upon time, or a combination of the two. If the "execution" based criterion is elected by the subscriber, the subscriber's order will "fall" from one Counterparty Set to the next in priority following the execution of a subscriber-defined number of shares from the subscriber's orders. In the Contra Priority List example described above, a subscriber may configure that its order to buy 1,000 shares of security ABCD first execute against Counterparty Set A until it has executed at least some number of shares, determined by the subscriber on an order-by-order basis (for example, 200 shares). Once at least 200 shares are executed against Counterparty Set A, the order would then additionally be able to execute against Counterparty Set B (while continuing to be eligible to execute against Counterparty Set A). Once an additional 200 or more shares have been executed against Counterparty Sets A or B, it would then additionally be eligible to execute against Counterparty Set C, and so on. For clarity, in this scenario, the order will not be eligible to execute against Counterparty Set C if the order does not execute for at least the required amount of shares against Counterparty Set A or B first. If the "time" based criterion is elected by the subscriber, the subscriber can configure the order to buy the security ABCD to execute (and continue to execute) against Counterparty Set A, if possible, until some amount of time, determined by the subscriber on an order-by-order basis (for example, one second) has elapsed without a match. The order will then additionally be able to execute against Counterparty Set B, and so on. A subscriber may use both the execution and time parameters in combination. In this configuration, the subscriber has two options, which may be chosen on an order-by-order basis: "either," or "both." If "either" is used, the order will waterfall from one priority level to the next if either criterion is met; if "both" is used, both criteria must be met for an order to waterfall from one Counterparty Set to the next. Any elected "waterfall" scenario will continue in the expressed priority order as long as all activity (firm-ups in response to invitations, etc.) is occurring over the same channel (see Item 13 above). If a firm-up response is sent via a different channel, then any waterfall instructions, if supplied, will be ignored, although "non-waterfall" priority instructions (if any) will be honored. The "execution" based option is not available for VWAP orders. Once all potential counterparties in all Contra Priority List levels (A, B, and C in the above example) are exhausted, the order (if any quantity remains from the order) will be exposed to the rest of the LeveL pool, subject to any contra-party exclusions otherwise in effect. By default, matches within the Buyside Subscriber trading arrangement will "waterfall" from that arrangement to the LeveL pool after the first execution or after fifteen (15) seconds have elapsed from a match if there was no resulting execution. Broker-Dealer Subscribers may elect that their Firm Orders or Conditional Orders not interact with EFUT Conditional Orders (as discussed more fully in Part III Item 7(a) and 9(a)) at the session level or on an order-by-order basis. Subscribers cannot elect for their EFUT Conditional Orders to not interact with other EFUT Conditional Orders.

counterparty_selection

As further discussed below, subscribers may designate their trading interest as eligible or ineligible to interact with certain orders or trading interest in the LeveL ATS. Such permissioning elections may be made at the MPID, FIX-session level, or Channel level. Subscriber Channels LeveL Markets will enable a LeveL ATS subscriber to partition or to direct LeveL Markets to partition the subscriber's order flow into one or more "channels." Channels are designed to distinguish meaningfully different types of business from a given subscriber. As discussed above, these can be based on trading behaviors, business units within the subscriber's organization, or some combination thereof. A subscriber can designate to which channel an order belongs either explicitly (by some agreed upon FIX field) or implicitly (for example, by some combination of order attributes or specific gateway sessions) via coordination with LeveL Markets. For example, a subscriber may have a proprietary trading desk with three distinct teams. Each team may have different strategies or investment objectives, and each may have different contra party instruction lists; thus, each of these teams may be identified by the subscriber to LeveL Markets as distinct channels. This channel-based segmentation is made available to all subscribers but not to LeveLUp participants. LeveL Markets may also, at its sole discretion, designate new channels or consolidate existing channels without communication to the subscriber. (See Item 13 above.). Any changes to channels requested by a subscriber would generally be put into production the following business day. As discussed in Item 13 above, subscribers may run a "mark-out" or other trading analysis of its activity in the LeveL ATS or request that LeveL Markets run one on the subscriber's behalf and use the results of such an analysis to identify activity that it deems to be favorable or unfavorable to that subscriber. The subscriber may request that its order flow - either a specific channel, multiple channels, or all of its order flow - not interact with particular channels that are anonymously selected in the outcome of the contra party analyses of its trading activity. LeveL Markets will review the subscriber's executions during an agreed-upon historical time period, and on the basis of a performance metric defined by the subscriber, LeveL Markets will block or prevent future interactions with contra channels that are not in-line with the subscriber's performance threshold from the subscriber's interaction pool. For example, if a trading analysis of a subscriber's executions in the LeveL ATS shows that a stock tends to move in an unfavorable direction (to them) following certain executions but not others, the subscriber may request that their order flow not interact with any contra channel whose combined executions against the subscriber lead to those unfavorable outcomes. LeveLUp participants may not request or present an execution analysis to select different counterparty exclusions (see below). Contra-party Exclusions As discussed in Item 13 above, the channel-based segmentation for the LeveL ATS is replacing the prior segmentation protocol that involved grouping subscribers into different categories such as agency algorithms or smart order routers, broker-dealers, exchanges or other ATSs, electronic market makers, high-touch agency broker-dealers, high-touch proprietary broker-dealers, low-touch prop, and sponsored access arrangements. While these categories are no longer being supported, as described more fully in Item 13, LeveL Markets has mapped those legacy segments into channel-based equivalents and has carried over any existing subscriber exclusion elections utilizing the channel-based equivalents to the previous segments. These exclusion elections can be modified by the subscriber through a request to LeveL Markets, as described below. Subscribers can provide LeveL Markets with a list of market-participant IDs (MPIDs) which it wishes to be excluded from their interactions. As described above, subscribers, with the exception of LeveLUp participants who access the LeveL ATS via LeveL Markets, can also request that LeveL Markets carry out an anonymous contra-party exclusion analysis on their behalf, in which contra-parties are deselected (exclusions) at the channel level, on the basis of a performance metric defined by the subscriber. These analyses are based solely on the subscriber's own performance metric applied to the subscriber's past interactions (executions) with the contra-party channels over some designated time period and with some designated performance threshold. LeveL Markets provides this analysis to all of its subscribers who request it, so long as such requests are reasonable in the Firm's judgment and in its sole discretion. For example, if the subscriber requests the identity or nature of specific counterparties to its executions in the LeveL ATS, if the requests require data that the Firm does not possess, or if the requests are so frequent that the Firm doesn't have the resources to reasonably address them all, those requests will be rejected. A subscriber can have a different set of inclusions or exclusions for each of their own channels. Any contra-party channels that are excluded are done so on an anonymous basis. Note that a subscriber's contra-party exclusions apply asymmetrically - only when the subscriber is providing liquidity in the prospective execution. For the LeveL ATS, an order "provides liquidity" when that order arrives before other orders and rests on the LeveL ATS as a potential counterparty to subsequent orders in that same security. A request for contra-party exclusions to be implemented regardless of liquidity flag (providing or removing) can be made in writing to LeveL Markets and will be evaluated on a case-by-case basis. In circumstances where LeveL Markets has determined to divide a subscriber's order flow into multiple channels based upon its own determination that the subscriber's order flow contained meaningfully distinguishable types of flow, any contra party exclusion requests from the subscriber that had been in place for the single channel will be applied to each new channel created by LeveL Markets unless and until the subscriber requests different exclusions. In addition, if a subscriber had multiple established channels that, in the judgment of LeveL Markets, did not represent meaningfully distinguishable types of flow, but those channels had different contra party exclusions, LeveL Markets would not combine those similar channels into one channel. As discussed in Part II Items 1, 3 and 4, LeveL Markets offers a service called "LeveLUp" to subscribers of the Luminex ATS whereby LeveL Markets can route Luminex ATS subscriber orders to the LeveL ATS. LeveL Markets previously offered LeveLUp participants two potential counterparty groups once the opt-in Luminex ATS participant orders reach the LeveL ATS: "BD/Agency Algo/Smart Order Router" order flow or that segment as well as electronic market makers. As stated in Item 13 above, LeveL Markets is no longer supporting these "legacy" order flow segments in the LeveL ATS. LeveL Markets has mapped these two "legacy" counterparty groups into channel-based equivalents, and orders from existing LeveLUp participants will interact with either the channel equivalent to the "BD/Agency Algo/Smart Order Router" segment or the channel-equivalent to "BD/Agency Algo/Smart Order Router and Electronic Market Makers" that the LeveLUp participant previously selected. New LeveLUp participants will be able to elect one of these two counterparty channels (a channel-based equivalent of the legacy BD/Agency Algo/Smart Order Router or a channel-based equivalent of the legacy BD/Agency Algo/Smart Order Router plus Electronic Market Makers). Subscriber Trading Arrangements A subscriber can engage in unilateral, bilateral, or multilateral trading arrangements with one or more contra parties. These arrangements require the explicit consent from all involved parties and can be configured at the channel level or at the subscriber or MPID level. Provided that LeveL Markets receives the express permission of all subscribers intended to be parties to that arrangement, LeveL Markets will generally approve all such requests. Note that a subscriber channel can have its orders participate in a trading arrangement only, participate in the trading arrangement first and then if not match interact with the general pool of subscribers to the ATS, or simultaneously be eligible to interact outside the arrangement as requested by the subscriber. Such arrangements can be requested via a communication (oral or written, including electronic) to LeveL Markets. There is no default arrangement priority implemented by LeveL Markets. Subscribers may also have multiple trading arrangements and may interact within and among those arrangements and with the broader LeveL pool in whatever order preferred by that subscriber. Orders sent simultaneously to multiple trading arrangements or one or more trading arrangements and the broader LeveL pool will match according to the priority specified by the subscriber, if any, and otherwise by the priority rules of the LeveL ATS as specified herein. There are no different order types or other differences relating to the operation of a trading arrangement from the order types or rules relating to the operation of the LeveL ATS as disclosed in this ATS-N. LeveL Markets will not create or modify subscriber trading arrangements unless directed by the relevant subscriber. LeveLUp participants cannot utilize Subscriber Trading Arrangements. As described herein, the LeveLUp service is being discontinued and replaced with LeveL ATS functionality for Buyside Subscribers that goes into effect as of March 30, 2026. On behalf of Buyside Subscribers, effective March 30, 2026, LeveL Markets will be sponsoring a trading arrangement through which Buyside Subscribers can trade between themselves and not with the broader LeveL pool. Such Buyside Subscribers can also, if they elect, have LeveL Markets represent their orders within that Buyside Subscriber-specific trading arrangement and in the LeveL pool simultaneously or after seeking a potential match within that trading arrangement first, at the Buyside Subscriber's election and dependent upon the system used by such Buyside Subscriber to route orders to the LeveL ATS. Buyside Subscribers who utilize the UI will be able to interact with the broader LeveL pool after first seeking a match within the Buyside Subscriber trading arrangement and can also have LeveL Markets represent their orders within the Buyside Subscriber trading arrangement and in the LeveL pool simultaneously. Buyside Subscribers routing orders via broker-dealer routers or via Fidelity Service Bureau are only able to interact with orders within the Buyside Subscriber trading arrangement and not with the broader LeveL pool. The default order size for Buyside Subscribers for the Buyside Subscriber trading arrangement is 5,000 shares, which can be increased or decreased upon client request to LeveL Markets. Subscribers may elect that their orders only interact with other orders submitted by the same subscriber ("Internalization Only"). These subscribers may elect to have orders from certain of their channels (such as desks or other business units) interact or not interact with orders from certain other channels within the same subscriber ("Channel-based Permissioning"). In addition, these subscribers may elect to prioritize potential contra parties to their orders in the LeveL ATS (a "Contra Priority List"). For example, a subscriber may wish to execute internally first if there is a match and then execute against a particular counterparty if not. Similarly, a subscriber may wish to execute against certain potential counterparties in a specific order if there are matching opportunities against such counterparties. For example, a subscriber may want to first look for a match against one or more potential counterparties (Counterparty Set A). If there are no eligible orders from Counterparty Set A, then the subscriber may want to look for a match against Counterparty Set B, and so on. Subscribers electing to use Contra Priority List functionality may, but are not required to, obtain permission from the potential counterparties to prioritize the contra parties in that arrangement. By default, this Contra Priority List functionality only applies when an order is first entered onto the LeveL ATS; instructions unrelated to a Contra Priority List will be followed in the event of a subsequent match in the ATS. As noted above, the subscriber may elect that these orders then be exposed to orders from the rest of the LeveL ATS pool of subscribers or not, at the subscriber's option. For clarity, Contra Priority List functionality is not available to LeveLUp participants. Effective March 30, 2026, subscribers utilizing Contra Priority List are able to customize their experience within a Contra Priority List in various "waterfall" scenarios. Subscribers may elect that their orders proceed from one contra party in its Contra Priority List to the next (and then to the next, and so on) based upon execution units, based upon time, or a combination of the two. If the "execution" based criterion is elected by the subscriber, the subscriber's order will "fall" from one Counterparty Set to the next in priority following the execution of a subscriber-defined number of shares from the subscriber's orders. In the Contra Priority List example described above, a subscriber may configure that its order to buy 1,000 shares of security ABCD first execute against Counterparty Set A until it has executed at least some number of shares, determined by the subscriber on an order-by-order basis (for example, 200 shares). Once at least 200 shares are executed against Counterparty Set A, the order would then additionally be able to execute against Counterparty Set B (while continuing to be eligible to execute against Counterparty Set A). Once an additional 200 or more shares have been executed against Counterparty Sets A or B, it would then additionally be eligible to execute against Counterparty Set C, and so on. For clarity, in this scenario, the order will not be eligible to execute against Counterparty Set C if the order does not execute for at least the required amount of shares against Counterparty Set A or B first. If the "time" based criterion is elected by the subscriber, the subscriber can configure the order to buy the security ABCD to execute (and continue to execute) against Counterparty Set A, if possible, until some amount of time, determined by the subscriber on an order-by-order basis (for example, one second) has elapsed without a match. The order will then additionally be able to execute against Counterparty Set B, and so on. A subscriber may use both the execution and time parameters in combination. In this configuration, the subscriber has two options, which may be chosen on an order-by-order basis: "either," or "both." If "either" is used, the order will waterfall from one priority level to the next if either criterion is met; if "both" is used, both criteria must be met for an order to waterfall from one Counterparty Set to the next. Any elected "waterfall" scenario will continue in the expressed priority order as long as all activity (firm-ups in response to invitations, etc.) is occurring over the same channel (see Item 13 above). If a firm-up response is sent via a different channel, then any waterfall instructions, if supplied, will be ignored, although "non-waterfall" priority instructions (if any) will be honored. The "execution" based option is not available for VWAP orders. Once all potential counterparties in all Contra Priority List levels (A, B, and C in the above example) are exhausted, the order (if any quantity remains from the order) will be exposed to the rest of the LeveL pool, subject to any contra-party exclusions otherwise in effect. By default, matches within the Buyside Subscriber trading arrangement will "waterfall" from that arrangement to the LeveL pool after the first execution or after fifteen (15) seconds have elapsed from a match if there was no resulting execution. Broker-Dealer Subscribers may elect that their Firm Orders or Conditional Orders not interact with EFUT Conditional Orders (as discussed more fully in Part III Item 7(a) and 9(a)) at the session level or on an order-by-order basis. Subscribers cannot elect for their EFUT Conditional Orders to not interact with other EFUT Conditional Orders.

counterparty_selection

As further discussed below, subscribers may designate their trading interest as eligible or ineligible to interact with certain orders or trading interest in the LeveL ATS. Such permissioning elections may be made at the MPID, FIX-session level, or Channel level. Subscriber Channels LeveL Markets will enable a LeveL ATS subscriber to partition or to direct LeveL Markets to partition the subscriber's order flow into one or more "channels." Channels are designed to distinguish meaningfully different types of business from a given subscriber. As discussed above, these can be based on trading behaviors, business units within the subscriber's organization, or some combination thereof. A subscriber can designate to which channel an order belongs either explicitly (by some agreed upon FIX field) or implicitly (for example, by some combination of order attributes or specific gateway sessions) via coordination with LeveL Markets. For example, a subscriber may have a proprietary trading desk with three distinct teams. Each team may have different strategies or investment objectives, and each may have different contra party instruction lists; thus, each of these teams may be identified by the subscriber to LeveL Markets as distinct channels. This channel-based segmentation is made available to all subscribers. LeveL Markets may also, at its sole discretion, designate new channels or consolidate existing channels without communication to the subscriber. (See Item 13 above.). Any changes to channels requested by a subscriber would generally be put into production the following business day. As discussed in Item 13 above, subscribers may run a "mark-out" or other trading analysis of its activity in the LeveL ATS or request that LeveL Markets run one on the subscriber's behalf and use the results of such an analysis to identify activity that it deems to be favorable or unfavorable to that subscriber. The subscriber may request that its order flow - either a specific channel, multiple channels, or all of its order flow - not interact with particular channels that are anonymously selected in the outcome of the contra party analyses of its trading activity. LeveL Markets will review the subscriber's executions during an agreed-upon historical time period, and on the basis of a performance metric defined by the subscriber, LeveL Markets will block or prevent future interactions with contra channels that are not in-line with the subscriber's performance threshold from the subscriber's interaction pool. For example, if a trading analysis of a subscriber's executions in the LeveL ATS shows that a stock tends to move in an unfavorable direction (to them) following certain executions but not others, the subscriber may request that their order flow not interact with any contra channel whose combined executions against the subscriber lead to those unfavorable outcomes. Contra-party Exclusions As discussed in Item 13 above, the channel-based segmentation for the LeveL ATS is replacing the prior segmentation protocol that involved grouping subscribers into different categories such as agency algorithms or smart order routers, broker-dealers, exchanges or other ATSs, electronic market makers, high-touch agency broker-dealers, high-touch proprietary broker-dealers, low-touch prop, and sponsored access arrangements. While these categories are no longer being supported, as described more fully in Item 13, LeveL Markets has mapped those legacy segments into channel-based equivalents and has carried over any existing subscriber exclusion elections utilizing the channel-based equivalents to the previous segments. These exclusion elections can be modified by the subscriber through a request to LeveL Markets, as described below. Subscribers can provide LeveL Markets with a list of market-participant IDs (MPIDs) which it wishes to be excluded from their interactions. As described above, subscribers can also request that LeveL Markets carry out an anonymous contra-party exclusion analysis on their behalf, in which contra-parties are deselected (exclusions) at the channel level, on the basis of a performance metric defined by the subscriber. These analyses are based solely on the subscriber's own performance metric applied to the subscriber's past interactions (executions) with the contra-party channels over some designated time period and with some designated performance threshold. LeveL Markets provides this analysis to all of its subscribers who request it, so long as such requests are reasonable in the Firm's judgment and in its sole discretion. For example, if the subscriber requests the identity or nature of specific counterparties to its executions in the LeveL ATS, if the requests require data that the Firm does not possess, or if the requests are so frequent that the Firm doesn't have the resources to reasonably address them all, those requests will be rejected. A subscriber can have a different set of inclusions or exclusions for each of their own channels. Any contra-party channels that are excluded are done so on an anonymous basis. Note that a subscriber's contra-party exclusions apply asymmetrically - only when the subscriber is providing liquidity in the prospective execution. For the LeveL ATS, an order "provides liquidity" when that order arrives before other orders and rests on the LeveL ATS as a potential counterparty to subsequent orders in that same security. A request for contra-party exclusions to be implemented regardless of liquidity flag (providing or removing) can be made in writing to LeveL Markets and will be evaluated on a case-by-case basis. In circumstances where LeveL Markets has determined to divide a subscriber's order flow into multiple channels based upon its own determination that the subscriber's order flow contained meaningfully distinguishable types of flow, any contra party exclusion requests from the subscriber that had been in place for the single channel will be applied to each new channel created by LeveL Markets unless and until the subscriber requests different exclusions. In addition, if a subscriber had multiple established channels that, in the judgment of LeveL Markets, did not represent meaningfully distinguishable types of flow, but those channels had different contra party exclusions, LeveL Markets would not combine those similar channels into one channel. Subscriber Trading Arrangements A subscriber can engage in unilateral, bilateral, or multilateral trading arrangements with one or more contra parties. These arrangements require the explicit consent from all involved parties and can be configured at the channel level or at the subscriber or MPID level. Provided that LeveL Markets receives the express permission of all subscribers intended to be parties to that arrangement, LeveL Markets will generally approve all such requests. Note that a subscriber channel can have its orders participate in a trading arrangement only, participate in the trading arrangement first and then if not match interact with the general pool of subscribers to the ATS, or simultaneously be eligible to interact outside the arrangement as requested by the subscriber. Such arrangements can be requested via a communication (oral or written, including electronic) to LeveL Markets. There is no default arrangement priority implemented by LeveL Markets. Subscribers may also have multiple trading arrangements and may interact within and among those arrangements and with the broader LeveL pool in whatever order preferred by that subscriber. Orders sent simultaneously to multiple trading arrangements or one or more trading arrangements and the broader LeveL pool will match according to the priority specified by the subscriber, if any, and otherwise by the priority rules of the LeveL ATS as specified herein. There are no different order types or other differences relating to the operation of a trading arrangement from the order types or rules relating to the operation of the LeveL ATS as disclosed in this ATS-N. LeveL Markets will not create or modify subscriber trading arrangements unless directed by the relevant subscriber. On behalf of Buyside Subscribers, LeveL Markets sponsors a trading arrangement through which Buyside Subscribers can trade between themselves and not with the broader LeveL pool. Such Buyside Subscribers can also, if they elect, have LeveL Markets represent their orders within that Buyside Subscriber-specific trading arrangement and in the LeveL pool simultaneously or after seeking a potential match within that trading arrangement first, at the Buyside Subscriber's election. The default setup is for Buyside Subscriber orders to seek a potential match within the Buyside Subscriber trading arrangement first and then seek a potential match in the broader LeveL pool. This default can be changed upon client request to LeveL Markets. The default minimum order size for the Buyside Subscriber trading arrangement is 5,000 shares, which can be increased or decreased upon client request to LeveL Markets. Sponsored Buyside Entities and Outsourced Trading Brokers, as defined in Part II Item 1, are also able to interact with the Buyside Subscriber trading arrangement. Orders sent by Sponsored Buyside Entities to the Buyside Subscriber trading arrangement are only eligible to trade within that trading arrangement and not with the general LeveL pool. Orders sent by Outsourced Trading Brokers to the Buyside Subscriber trading arrangement are eligible to interact with the general LeveL pool at the Outsourced Trading Broker's election as made to LeveL Markets. Subscribers may elect that their orders only interact with other orders submitted by the same subscriber ("Internalization Only"). These subscribers may elect to have orders from certain of their channels (such as desks or other business units) interact or not interact with orders from certain other channels within the same subscriber ("Channel-based Permissioning"). In addition, these subscribers may elect to prioritize potential contra parties to their orders in the LeveL ATS (a "Contra Priority List"). For example, a subscriber may wish to execute internally first if there is a match and then execute against a particular counterparty if not. Similarly, a subscriber may wish to execute against certain potential counterparties in a specific order if there are matching opportunities against such counterparties. For example, a subscriber may want to first look for a match against one or more potential counterparties (Counterparty Set A). If there are no eligible orders from Counterparty Set A, then the subscriber may want to look for a match against Counterparty Set B, and so on. Subscribers electing to use Contra Priority List functionality may, but are not required to, obtain permission from the potential counterparties to prioritize the contra parties in that arrangement. By default, this Contra Priority List functionality only applies when an order is first entered onto the LeveL ATS; instructions unrelated to a Contra Priority List will be followed in the event of a subsequent match in the ATS. As noted above, the subscriber may elect that these orders then be exposed to orders from the rest of the LeveL ATS pool of subscribers or not, at the subscriber's option. Subscribers utilizing Contra Priority List are able to customize their experience within a Contra Priority List in various "waterfall" scenarios. Subscribers may elect that their orders proceed from one contra party in its Contra Priority List to the next (and then to the next, and so on) based upon execution units, based upon time, or a combination of the two. If the "execution" based criterion is elected by the subscriber, the subscriber's order will "fall" from one Counterparty Set to the next in priority following the execution of a subscriber-defined number of shares from the subscriber's orders. In the Contra Priority List example described above, a subscriber may configure that its order to buy 1,000 shares of security ABCD first execute against Counterparty Set A until it has executed at least some number of shares, determined by the subscriber on an order-by-order basis (for example, 200 shares). Once at least 200 shares are executed against Counterparty Set A, the order would then additionally be able to execute against Counterparty Set B (while continuing to be eligible to execute against Counterparty Set A). Once an additional 200 or more shares have been executed against Counterparty Sets A or B, it would then additionally be eligible to execute against Counterparty Set C, and so on. For clarity, in this scenario, the order will not be eligible to execute against Counterparty Set C if the order does not execute for at least the required amount of shares against Counterparty Set A or B first. If the "time" based criterion is elected by the subscriber, the subscriber can configure the order to buy the security ABCD to execute (and continue to execute) against Counterparty Set A, if possible, until some amount of time, determined by the subscriber on an order-by-order basis (for example, one second) has elapsed without a match. The order will then additionally be able to execute against Counterparty Set B, and so on. A subscriber may use both the execution and time parameters in combination. In this configuration, the subscriber has two options, which may be chosen on an order-by-order basis: "either," or "both." If "either" is used, the order will waterfall from one priority level to the next if either criterion is met; if "both" is used, both criteria must be met for an order to waterfall from one Counterparty Set to the next. Any elected "waterfall" scenario will continue in the expressed priority order as long as all activity (firm-ups in response to invitations, etc.) is occurring over the same channel (see Item 13 above). If a firm-up response is sent via a different channel, then any waterfall instructions, if supplied, will be ignored, although "non-waterfall" priority instructions (if any) will be honored. The "execution" based option is not available for VWAP orders. Once all potential counterparties in all Contra Priority List levels (A, B, and C in the above example) are exhausted, the order (if any quantity remains from the order) will be exposed to the rest of the LeveL pool, subject to any contra-party exclusions otherwise in effect. By default, matches within the Buyside Subscriber trading arrangement will "waterfall" from that arrangement to the LeveL pool after the first execution or after fifteen (15) seconds have elapsed from a match if there was no resulting execution. Broker-Dealer Subscribers may elect that their Firm Orders or Conditional Orders not interact with EFUT Conditional Orders (as discussed more fully in Part III Item 7(a) and 9(a)) at the session level or on an order-by-order basis. Subscribers cannot elect for their EFUT Conditional Orders to not interact with other EFUT Conditional Orders.

counterparty_selection

As further discussed below, subscribers may designate their trading interest as eligible or ineligible to interact with certain orders or trading interest in the LeveL ATS. Such permissioning elections may be made at the MPID, FIX-session level, or Channel level. Subscriber Channels LeveL Markets will enable a LeveL ATS subscriber to partition or to direct LeveL Markets to partition the subscriber's order flow into one or more "channels." Channels are designed to distinguish meaningfully different types of business from a given subscriber. As discussed above, these can be based on trading behaviors, business units within the subscriber's organization, or some combination thereof. A subscriber can designate to which channel an order belongs either explicitly (by some agreed upon FIX field) or implicitly (for example, by some combination of order attributes or specific gateway sessions) via coordination with LeveL Markets. For example, a subscriber may have a proprietary trading desk with three distinct teams. Each team may have different strategies or investment objectives, and each may have different contra party instruction lists; thus, each of these teams may be identified by the subscriber to LeveL Markets as distinct channels. This channel-based segmentation is made available to all subscribers. LeveL Markets may also, at its sole discretion, designate new channels or consolidate existing channels without communication to the subscriber. (See Item 13 above.). Any changes to channels requested by a subscriber would generally be put into production the following business day. As discussed in Item 13 above, subscribers may run a "mark-out" or other trading analysis of its activity in the LeveL ATS or request that LeveL Markets run one on the subscriber's behalf and use the results of such an analysis to identify activity that it deems to be favorable or unfavorable to that subscriber. The subscriber may request that its order flow - either a specific channel, multiple channels, or all of its order flow - not interact with particular channels that are anonymously selected in the outcome of the contra party analyses of its trading activity. LeveL Markets will review the subscriber's executions during an agreed-upon historical time period, and on the basis of a performance metric defined by the subscriber, LeveL Markets will block or prevent future interactions with contra channels that are not in-line with the subscriber's performance threshold from the subscriber's interaction pool. For example, if a trading analysis of a subscriber's executions in the LeveL ATS shows that a stock tends to move in an unfavorable direction (to them) following certain executions but not others, the subscriber may request that their order flow not interact with any contra channel whose combined executions against the subscriber lead to those unfavorable outcomes. Contra-party Exclusions As discussed in Item 13 above, the channel-based segmentation for the LeveL ATS is replacing the prior segmentation protocol that involved grouping subscribers into different categories such as agency algorithms or smart order routers, broker-dealers, exchanges or other ATSs, electronic market makers, high-touch agency broker-dealers, high-touch proprietary broker-dealers, low-touch prop, and sponsored access arrangements. While these categories are no longer being supported, as described more fully in Item 13, LeveL Markets has mapped those legacy segments into channel-based equivalents and has carried over any existing subscriber exclusion elections utilizing the channel-based equivalents to the previous segments. These exclusion elections can be modified by the subscriber through a request to LeveL Markets, as described below. Subscribers can provide LeveL Markets with a list of market-participant IDs (MPIDs) which it wishes to be excluded from their interactions. As described above, subscribers can also request that LeveL Markets carry out an anonymous contra-party exclusion analysis on their behalf, in which contra-parties are deselected (exclusions) at the channel level, on the basis of a performance metric defined by the subscriber. These analyses are based solely on the subscriber's own performance metric applied to the subscriber's past interactions (executions) with the contra-party channels over some designated time period and with some designated performance threshold. LeveL Markets provides this analysis to all of its subscribers who request it, so long as such requests are reasonable in the Firm's judgment and in its sole discretion. For example, if the subscriber requests the identity or nature of specific counterparties to its executions in the LeveL ATS, if the requests require data that the Firm does not possess, or if the requests are so frequent that the Firm doesn't have the resources to reasonably address them all, those requests will be rejected. A subscriber can have a different set of inclusions or exclusions for each of their own channels. Any contra-party channels that are excluded are done so on an anonymous basis. Note that a subscriber's contra-party exclusions apply asymmetrically - only when the subscriber is providing liquidity in the prospective execution. For the LeveL ATS, an order "provides liquidity" when that order arrives before other orders and rests on the LeveL ATS as a potential counterparty to subsequent orders in that same security. A request for contra-party exclusions to be implemented regardless of liquidity flag (providing or removing) can be made in writing to LeveL Markets and will be evaluated on a case-by-case basis. In circumstances where LeveL Markets has determined to divide a subscriber's order flow into multiple channels based upon its own determination that the subscriber's order flow contained meaningfully distinguishable types of flow, any contra party exclusion requests from the subscriber that had been in place for the single channel will be applied to each new channel created by LeveL Markets unless and until the subscriber requests different exclusions. In addition, if a subscriber had multiple established channels that, in the judgment of LeveL Markets, did not represent meaningfully distinguishable types of flow, but those channels had different contra party exclusions, LeveL Markets would not combine those similar channels into one channel. Subscriber Trading Arrangements A subscriber can engage in unilateral, bilateral, or multilateral trading arrangements with one or more contra parties. These arrangements require the explicit consent from all involved parties and can be configured at the channel level or at the subscriber or MPID level. Provided that LeveL Markets receives the express permission of all subscribers intended to be parties to that arrangement, LeveL Markets will generally approve all such requests. Note that a subscriber channel can have its orders participate in a trading arrangement only, participate in the trading arrangement first and then if not match interact with the general pool of subscribers to the ATS, or simultaneously be eligible to interact outside the arrangement as requested by the subscriber. Such arrangements can be requested via a communication (oral or written, including electronic) to LeveL Markets. There is no default arrangement priority implemented by LeveL Markets. Subscribers may also have multiple trading arrangements and may interact within and among those arrangements and with the broader LeveL pool in whatever order preferred by that subscriber. Orders sent simultaneously to multiple trading arrangements or one or more trading arrangements and the broader LeveL pool will match according to the priority specified by the subscriber, if any, and otherwise by the priority rules of the LeveL ATS as specified herein. There are no different order types or other differences relating to the operation of a trading arrangement from the order types or rules relating to the operation of the LeveL ATS as disclosed in this ATS-N. LeveL Markets will not create or modify subscriber trading arrangements unless directed by the relevant subscriber. On behalf of Buyside Subscribers, LeveL Markets sponsors a trading arrangement through which Buyside Subscribers can trade between themselves and not with the broader LeveL pool. Such Buyside Subscribers can also, if they elect, have LeveL Markets represent their orders within that Buyside Subscriber-specific trading arrangement and in the LeveL pool simultaneously or after seeking a potential match within that trading arrangement first, at the Buyside Subscriber's election. The default setup is for Buyside Subscriber orders to seek a potential match within the Buyside Subscriber trading arrangement first and then seek a potential match in the broader LeveL pool. This default can be changed upon client request to LeveL Markets. The default minimum order size for the Buyside Subscriber trading arrangement is 5,000 shares, which can be increased or decreased upon client request to LeveL Markets. Sponsored Buyside Entities and Outsourced Trading Brokers, as defined in Part II Item 1, are also able to interact with the Buyside Subscriber trading arrangement. Orders sent by Sponsored Buyside Entities to the Buyside Subscriber trading arrangement are only eligible to trade within that trading arrangement and not with the general LeveL pool. Orders sent by Outsourced Trading Brokers to the Buyside Subscriber trading arrangement are eligible to interact with the general LeveL pool at the Outsourced Trading Broker's election as made to LeveL Markets. Subscribers may elect that their orders only interact with other orders submitted by the same subscriber ("Internalization Only"). These subscribers may elect to have orders from certain of their channels (such as desks or other business units) interact or not interact with orders from certain other channels within the same subscriber ("Channel-based Permissioning"). In addition, these subscribers may elect to prioritize potential contra parties to their orders in the LeveL ATS (a "Contra Priority List"). For example, a subscriber may wish to execute internally first if there is a match and then execute against a particular counterparty if not. Similarly, a subscriber may wish to execute against certain potential counterparties in a specific order if there are matching opportunities against such counterparties. For example, a subscriber may want to first look for a match against one or more potential counterparties (Counterparty Set A). If there are no eligible orders from Counterparty Set A, then the subscriber may want to look for a match against Counterparty Set B, and so on. Subscribers electing to use Contra Priority List functionality may, but are not required to, obtain permission from the potential counterparties to prioritize the contra parties in that arrangement. By default, this Contra Priority List functionality only applies when an order is first entered onto the LeveL ATS; instructions unrelated to a Contra Priority List will be followed in the event of a subsequent match in the ATS. As noted above, the subscriber may elect that these orders then be exposed to orders from the rest of the LeveL ATS pool of subscribers or not, at the subscriber's option. Subscribers utilizing Contra Priority List are able to customize their experience within a Contra Priority List in various "waterfall" scenarios. Subscribers may elect that their orders proceed from one contra party in its Contra Priority List to the next (and then to the next, and so on) based upon execution units, based upon time, or a combination of the two. If the "execution" based criterion is elected by the subscriber, the subscriber's order will "fall" from one Counterparty Set to the next in priority following the execution of a subscriber-defined number of shares from the subscriber's orders. In the Contra Priority List example described above, a subscriber may configure that its order to buy 1,000 shares of security ABCD first execute against Counterparty Set A until it has executed at least some number of shares, determined by the subscriber on an order-by-order basis (for example, 200 shares). Once at least 200 shares are executed against Counterparty Set A, the order would then additionally be able to execute against Counterparty Set B (while continuing to be eligible to execute against Counterparty Set A). Once an additional 200 or more shares have been executed against Counterparty Sets A or B, it would then additionally be eligible to execute against Counterparty Set C, and so on. For clarity, in this scenario, the order will not be eligible to execute against Counterparty Set C if the order does not execute for at least the required amount of shares against Counterparty Set A or B first. If the "time" based criterion is elected by the subscriber, the subscriber can configure the order to buy the security ABCD to execute (and continue to execute) against Counterparty Set A, if possible, until some amount of time, determined by the subscriber on an order-by-order basis (for example, one second) has elapsed without a match. The order will then additionally be able to execute against Counterparty Set B, and so on. A subscriber may use both the execution and time parameters in combination. In this configuration, the subscriber has two options, which may be chosen on an order-by-order basis: "either," or "both." If "either" is used, the order will waterfall from one priority level to the next if either criterion is met; if "both" is used, both criteria must be met for an order to waterfall from one Counterparty Set to the next. Any elected "waterfall" scenario will continue in the expressed priority order as long as all activity (firm-ups in response to invitations, etc.) is occurring over the same channel (see Item 13 above). If a firm-up response is sent via a different channel, then any waterfall instructions, if supplied, will be ignored, although "non-waterfall" priority instructions (if any) will be honored. The "execution" based option is not available for VWAP orders. Once all potential counterparties in all Contra Priority List levels (A, B, and C in the above example) are exhausted, the order (if any quantity remains from the order) will be exposed to the rest of the LeveL pool, subject to any contra-party exclusions otherwise in effect. By default, matches within the Buyside Subscriber trading arrangement will "waterfall" from that arrangement to the LeveL pool after the first execution or after fifteen (15) seconds have elapsed from a match if there was no resulting execution. Broker-Dealer Subscribers may elect that their Firm Orders or Conditional Orders not interact with EFUT Conditional Orders (as discussed more fully in Part III Item 7(a) and 9(a)) at the session level or on an order-by-order basis. Subscribers cannot elect for their EFUT Conditional Orders to not interact with other EFUT Conditional Orders.

counterparty_selection

As further discussed below, subscribers may designate their trading interest as eligible or ineligible to interact with certain orders or trading interest in the LeveL ATS. Such permissioning elections may be made at the MPID, FIX-session level, or Channel level. Subscriber Channels LeveL Markets will enable a LeveL ATS subscriber to partition or to direct LeveL Markets to partition the subscriber's order flow into one or more "channels." Channels are designed to distinguish meaningfully different types of business from a given subscriber. As discussed above, these can be based on trading behaviors, business units within the subscriber's organization, or some combination thereof. A subscriber can designate to which channel an order belongs either explicitly (by some agreed upon FIX field) or implicitly (for example, by some combination of order attributes or specific gateway sessions) via coordination with LeveL Markets. For example, a subscriber may have a proprietary trading desk with three distinct teams. Each team may have different strategies or investment objectives, and each may have different contra party instruction lists; thus, each of these teams may be identified by the subscriber to LeveL Markets as distinct channels. This channel-based segmentation is made available to all subscribers. LeveL Markets may also, at its sole discretion, designate new channels or consolidate existing channels without communication to the subscriber. (See Item 13 above.). Any changes to channels requested by a subscriber would generally be put into production the following business day. As discussed in Item 13 above, subscribers may run a "mark-out" or other trading analysis of its activity in the LeveL ATS or request that LeveL Markets run one on the subscriber's behalf and use the results of such an analysis to identify activity that it deems to be favorable or unfavorable to that subscriber. The subscriber may request that its order flow - either a specific channel, multiple channels, or all of its order flow - not interact with particular channels that are anonymously selected in the outcome of the contra party analyses of its trading activity. LeveL Markets will review the subscriber's executions during an agreed-upon historical time period, and on the basis of a performance metric defined by the subscriber, LeveL Markets will block or prevent future interactions with contra channels that are not in-line with the subscriber's performance threshold from the subscriber's interaction pool. For example, if a trading analysis of a subscriber's executions in the LeveL ATS shows that a stock tends to move in an unfavorable direction (to them) following certain executions but not others, the subscriber may request that their order flow not interact with any contra channel whose combined executions against the subscriber lead to those unfavorable outcomes. Contra-party Exclusions As discussed in Item 13 above, the channel-based segmentation for the LeveL ATS is replacing the prior segmentation protocol that involved grouping subscribers into different categories such as agency algorithms or smart order routers, broker-dealers, exchanges or other ATSs, electronic market makers, high-touch agency broker-dealers, high-touch proprietary broker-dealers, low-touch prop, and sponsored access arrangements. While these categories are no longer being supported, as described more fully in Item 13, LeveL Markets has mapped those legacy segments into channel-based equivalents and has carried over any existing subscriber exclusion elections utilizing the channel-based equivalents to the previous segments. These exclusion elections can be modified by the subscriber through a request to LeveL Markets, as described below. Subscribers can provide LeveL Markets with a list of market-participant IDs (MPIDs) which it wishes to be excluded from their interactions. As described above, subscribers can also request that LeveL Markets carry out an anonymous contra-party exclusion analysis on their behalf, in which contra-parties are deselected (exclusions) at the channel level, on the basis of a performance metric defined by the subscriber. These analyses are based solely on the subscriber's own performance metric applied to the subscriber's past interactions (executions) with the contra-party channels over some designated time period and with some designated performance threshold. LeveL Markets provides this analysis to all of its subscribers who request it, so long as such requests are reasonable in the Firm's judgment and in its sole discretion. For example, if the subscriber requests the identity or nature of specific counterparties to its executions in the LeveL ATS, if the requests require data that the Firm does not possess, or if the requests are so frequent that the Firm doesn't have the resources to reasonably address them all, those requests will be rejected. A subscriber can have a different set of inclusions or exclusions for each of their own channels. Any contra-party channels that are excluded are done so on an anonymous basis. Note that a subscriber's contra-party exclusions apply asymmetrically - only when the subscriber is providing liquidity in the prospective execution. For the LeveL ATS, an order "provides liquidity" when that order arrives before other orders and rests on the LeveL ATS as a potential counterparty to subsequent orders in that same security. A request for contra-party exclusions to be implemented regardless of liquidity flag (providing or removing) can be made in writing to LeveL Markets and will be evaluated on a case-by-case basis. In circumstances where LeveL Markets has determined to divide a subscriber's order flow into multiple channels based upon its own determination that the subscriber's order flow contained meaningfully distinguishable types of flow, any contra party exclusion requests from the subscriber that had been in place for the single channel will be applied to each new channel created by LeveL Markets unless and until the subscriber requests different exclusions. In addition, if a subscriber had multiple established channels that, in the judgment of LeveL Markets, did not represent meaningfully distinguishable types of flow, but those channels had different contra party exclusions, LeveL Markets would not combine those similar channels into one channel. Subscriber Trading Arrangements A subscriber can engage in unilateral, bilateral, or multilateral trading arrangements with one or more contra parties. These arrangements require the explicit consent from all involved parties and can be configured at the channel level or at the subscriber or MPID level. Provided that LeveL Markets receives the express permission of all subscribers intended to be parties to that arrangement, LeveL Markets will generally approve all such requests. Note that a subscriber channel can have its orders participate in a trading arrangement only, participate in the trading arrangement first and then if not match interact with the general pool of subscribers to the ATS, or simultaneously be eligible to interact outside the arrangement as requested by the subscriber. Such arrangements can be requested via a communication (oral or written, including electronic) to LeveL Markets. There is no default arrangement priority implemented by LeveL Markets. Subscribers may also have multiple trading arrangements and may interact within and among those arrangements and with the broader LeveL pool in whatever order preferred by that subscriber. Orders sent simultaneously to multiple trading arrangements or one or more trading arrangements and the broader LeveL pool will match according to the priority specified by the subscriber, if any, and otherwise by the priority rules of the LeveL ATS as specified herein. There are no different order types or other differences relating to the operation of a trading arrangement from the order types or rules relating to the operation of the LeveL ATS as disclosed in this ATS-N. LeveL Markets will not create or modify subscriber trading arrangements unless directed by the relevant subscriber. On behalf of Buyside Subscribers, LeveL Markets sponsors a trading arrangement through which Buyside Subscribers can trade between themselves and not with the broader LeveL pool. Such Buyside Subscribers can also, if they elect, have LeveL Markets represent their orders within that Buyside Subscriber-specific trading arrangement and in the LeveL pool simultaneously or after seeking a potential match within that trading arrangement first, at the Buyside Subscriber's election and dependent upon the system used by such Buyside Subscriber to route orders to the LeveL ATS. Buyside Subscribers who utilize the UI will be able to interact with the broader LeveL pool after first seeking a match within the Buyside Subscriber trading arrangement and can also have LeveL Markets represent their orders within the Buyside Subscriber trading arrangement and in the LeveL pool simultaneously. Buyside Subscribers routing orders via broker-dealer routers or via Fidelity Service Bureau are only able to interact with orders within the Buyside Subscriber trading arrangement and not with the broader LeveL pool. The default order size for Buyside Subscribers for the Buyside Subscriber trading arrangement is 5,000 shares, which can be increased or decreased upon client request to LeveL Markets. Subscribers may elect that their orders only interact with other orders submitted by the same subscriber ("Internalization Only"). These subscribers may elect to have orders from certain of their channels (such as desks or other business units) interact or not interact with orders from certain other channels within the same subscriber ("Channel-based Permissioning"). In addition, these subscribers may elect to prioritize potential contra parties to their orders in the LeveL ATS (a "Contra Priority List"). For example, a subscriber may wish to execute internally first if there is a match and then execute against a particular counterparty if not. Similarly, a subscriber may wish to execute against certain potential counterparties in a specific order if there are matching opportunities against such counterparties. For example, a subscriber may want to first look for a match against one or more potential counterparties (Counterparty Set A). If there are no eligible orders from Counterparty Set A, then the subscriber may want to look for a match against Counterparty Set B, and so on. Subscribers electing to use Contra Priority List functionality may, but are not required to, obtain permission from the potential counterparties to prioritize the contra parties in that arrangement. By default, this Contra Priority List functionality only applies when an order is first entered onto the LeveL ATS; instructions unrelated to a Contra Priority List will be followed in the event of a subsequent match in the ATS. As noted above, the subscriber may elect that these orders then be exposed to orders from the rest of the LeveL ATS pool of subscribers or not, at the subscriber's option. Subscribers utilizing Contra Priority List are able to customize their experience within a Contra Priority List in various "waterfall" scenarios. Subscribers may elect that their orders proceed from one contra party in its Contra Priority List to the next (and then to the next, and so on) based upon execution units, based upon time, or a combination of the two. If the "execution" based criterion is elected by the subscriber, the subscriber's order will "fall" from one Counterparty Set to the next in priority following the execution of a subscriber-defined number of shares from the subscriber's orders. In the Contra Priority List example described above, a subscriber may configure that its order to buy 1,000 shares of security ABCD first execute against Counterparty Set A until it has executed at least some number of shares, determined by the subscriber on an order-by-order basis (for example, 200 shares). Once at least 200 shares are executed against Counterparty Set A, the order would then additionally be able to execute against Counterparty Set B (while continuing to be eligible to execute against Counterparty Set A). Once an additional 200 or more shares have been executed against Counterparty Sets A or B, it would then additionally be eligible to execute against Counterparty Set C, and so on. For clarity, in this scenario, the order will not be eligible to execute against Counterparty Set C if the order does not execute for at least the required amount of shares against Counterparty Set A or B first. If the "time" based criterion is elected by the subscriber, the subscriber can configure the order to buy the security ABCD to execute (and continue to execute) against Counterparty Set A, if possible, until some amount of time, determined by the subscriber on an order-by-order basis (for example, one second) has elapsed without a match. The order will then additionally be able to execute against Counterparty Set B, and so on. A subscriber may use both the execution and time parameters in combination. In this configuration, the subscriber has two options, which may be chosen on an order-by-order basis: "either," or "both." If "either" is used, the order will waterfall from one priority level to the next if either criterion is met; if "both" is used, both criteria must be met for an order to waterfall from one Counterparty Set to the next. Any elected "waterfall" scenario will continue in the expressed priority order as long as all activity (firm-ups in response to invitations, etc.) is occurring over the same channel (see Item 13 above). If a firm-up response is sent via a different channel, then any waterfall instructions, if supplied, will be ignored, although "non-waterfall" priority instructions (if any) will be honored. The "execution" based option is not available for VWAP orders. Once all potential counterparties in all Contra Priority List levels (A, B, and C in the above example) are exhausted, the order (if any quantity remains from the order) will be exposed to the rest of the LeveL pool, subject to any contra-party exclusions otherwise in effect. By default, matches within the Buyside Subscriber trading arrangement will "waterfall" from that arrangement to the LeveL pool after the first execution or after fifteen (15) seconds have elapsed from a match if there was no resulting execution. Broker-Dealer Subscribers may elect that their Firm Orders or Conditional Orders not interact with EFUT Conditional Orders (as discussed more fully in Part III Item 7(a) and 9(a)) at the session level or on an order-by-order basis. Subscribers cannot elect for their EFUT Conditional Orders to not interact with other EFUT Conditional Orders.

Item 18 (Part III)

financial_condition_summary

LeveL Markets charges a commission of $0.0000 to $0.05/share for executions in the LeveL ATS. Certain Buyside Subscribers (as of March 30, 2026) pay commissions in "basis points," ranging from a low of one (1) basis point to a high of six (6) basis points. Each basis point equates to one hundredth of one percent of the notional value of the transaction. Although commission rates can be impacted by a number of factors, including the subscriber's anticipated volume, anticipated make/take ratio and anticipated percentage of "internalization-only" transactions, rates are individually negotiated between LeveL Markets and the relevant subscriber. LeveL Markets does not charge different rates for executions resulting from orders utilizing Contra-party Permissioning functionality, including transactions resulting from Internalization-Only orders. Depending on the provider, LeveL Markets may "pass through" to Buyside Subscribers certain fees that it is charged by certain service bureau routers or OMS and EMS entities. These pass-through fees are fully disclosed to the applicable Buyside Subscribers and typically range from a high of 15 mills ($0.0015) to a low of zero mills per executed share. In certain instances, these vendors may charge LeveL Markets more than 15 mills and thus a pass-through fee charged to a Buyside Subscriber that uses that router, OMS, or EMS may exceed 15 mills. In some cases, Buyside Subscribers may elect to pay a rate higher than the base execution rate, and they can also apply additional commission as part of a Commission Sharing Arrangement ("CSA") in conformance with Section 28(e) of the Securities Exchange Act of 1934. This amount above the base commission rate to be attributed to the CSA program is determined solely by the Buyside Subscriber, pursuant to a written agreement with LeveL Markets. LeveL Markets does not charge any other fees for use of the LeveL ATS (i.e., LeveL Markets only charges subscribers the commission rates identified above). However, subscribers may be responsible for any connectivity fees or other costs they incur in accessing the LeveL ATS (i.e., fees not charged by LeveL Markets). As discussed in Part III Item 19(c) below, certain subscribers that are in a bilateral or multilateral trading arrangement to execute against other subscribers in the LeveL ATS may pay a higher negotiated commission rate to LeveL Markets, who will rebate part of that higher rate to the other subscriber or subscribers. As noted above, LeveL Markets charges a commission of $0.0000 to $0.005/share for executions in the LeveL ATS. LeveL Markets is assessed certain Consolidated Audit Trail (CAT) regulatory fees relating to trading on the LeveL ATS as an execution venue. In each transaction on the LeveL ATS, LeveL Markets (EBXL) is identified on transaction reports as the buyer and the selling LeveL ATS subscriber is reported as the seller. FINRA assesses CAT fees on both LeveL Markets, on behalf of the buying LeveL ATS subscriber, and on the selling LeveL ATS subscriber. LeveL Markets passes through to the buying LeveL ATS subscriber these CAT-related fees that LeveL Markets is assessed on behalf of those buying LeveL ATS subscribers. LeveL Markets does not pass through CAT fees to Buyside Subscribers.

financial_condition_summary

LeveL Markets charges a commission of $0.0000 to $0.05/share for executions in the LeveL ATS. Certain Buyside Subscribers (as of March 30, 2026) pay commissions in "basis points," ranging from a low of one (1) basis point to a high of six (6) basis points. Each basis point equates to one hundredth of one percent of the notional value of the transaction. Although commission rates can be impacted by a number of factors, including the subscriber's anticipated volume, anticipated make/take ratio and anticipated percentage of "internalization-only" transactions, rates are individually negotiated between LeveL Markets and the relevant subscriber. LeveL Markets does not charge different rates for executions resulting from orders utilizing Contra-party Permissioning functionality, including transactions resulting from Internalization-Only orders. Depending on the provider, and effective March 30, 2026, LeveL Markets may "pass through" to Buyside Subscribers certain fees that it is charged by certain service bureau routers or OMS and EMS entities. These pass-through fees are fully disclosed to the applicable Buyside Subscribers and typically range from a high of 15 mills ($0.0015) to a low of zero mills per executed share. In certain instances, these vendors may charge LeveL Markets more than 15 mills and thus a pass-through fee charged to a Buyside Subscriber that uses that router, OMS, or EMS may exceed 15 mills. In some cases, Buyside Subscribers may elect to pay a rate higher than the base execution rate, and they can also apply additional commission as part of a Commission Sharing Arrangement ("CSA") in conformance with Section 28(e) of the Securities Exchange Act of 1934. This amount above the base commission rate to be attributed to the CSA program is determined solely by the Buyside Subscriber, pursuant to a written agreement with LeveL Markets. LeveL Markets does not charge any other fees for use of the LeveL ATS (i.e., LeveL Markets only charges subscribers the commission rates identified above). However, subscribers may be responsible for any connectivity fees or other costs they incur in accessing the LeveL ATS (i.e., fees not charged by LeveL Markets). As discussed in Part III Item 19(c) below, certain subscribers that are in a bilateral or multilateral trading arrangement to execute against other subscribers in the LeveL ATS may pay a higher negotiated commission rate to LeveL Markets, who will rebate part of that higher rate to the other subscriber or subscribers. As noted above, LeveL Markets charges a commission of $0.0000 to $0.005/share for executions in the LeveL ATS. LeveL Markets is assessed certain Consolidated Audit Trail (CAT) regulatory fees relating to trading on the LeveL ATS as an execution venue. In each transaction on the LeveL ATS, LeveL Markets (EBXL) is identified on transaction reports as the buyer and the selling LeveL ATS subscriber is reported as the seller. FINRA assesses CAT fees on both LeveL Markets, on behalf of the buying LeveL ATS subscriber, and on the selling LeveL ATS subscriber. LeveL Markets passes through to the buying LeveL ATS subscriber these CAT-related fees that LeveL Markets is assessed on behalf of those buying LeveL ATS subscribers. LeveL Markets does not pass through CAT fees to Buyside Subscribers.

financial_condition_summary

LeveL Markets charges a commission of $0.0000 to $0.05/share for executions in the LeveL ATS. Certain Buyside Subscribers (as of March 30, 2026) pay commissions in "basis points," ranging from a low of one (1) basis point to a high of six (6) basis points. Each basis point equates to one hundredth of one percent of the notional value of the transaction. Although commission rates can be impacted by a number of factors, including the subscriber's anticipated volume, anticipated make/take ratio and anticipated percentage of "internalization-only" transactions, rates are individually negotiated between LeveL Markets and the relevant subscriber. LeveL Markets does not charge different rates for executions resulting from orders utilizing Contra-party Permissioning functionality, including transactions resulting from Internalization-Only orders. Depending on the provider, and effective March 30, 2026, LeveL Markets may "pass through" to Buyside Subscribers certain fees that it is charged by certain service bureau routers or OMS and EMS entities. These pass-through fees are fully disclosed to the applicable Buyside Subscribers and typically range from a high of 15 mills ($0.0015) to a low of zero mills per executed share. In certain instances, these vendors may charge LeveL Markets more than 15 mills and thus a pass-through fee charged to a Buyside Subscriber that uses that router, OMS, or EMS may exceed 15 mills. In some cases, Buyside Subscribers may elect to pay a rate higher than the base execution rate, and they can also apply additional commission as part of a Commission Sharing Arrangement ("CSA") in conformance with Section 28(e) of the Securities Exchange Act of 1934. This amount above the base commission rate to be attributed to the CSA program is determined solely by the Buyside Subscriber, pursuant to a written agreement with LeveL Markets. LeveL Markets does not charge any other fees for use of the LeveL ATS (i.e., LeveL Markets only charges subscribers the commission rates identified above). However, subscribers may be responsible for any connectivity fees or other costs they incur in accessing the LeveL ATS (i.e., fees not charged by LeveL Markets). As discussed in Part III Item 19(c) below, certain subscribers that are in a bilateral or multilateral trading arrangement to execute against other subscribers in the LeveL ATS may pay a higher negotiated commission rate to LeveL Markets, who will rebate part of that higher rate to the other subscriber or subscribers. As noted above, LeveL Markets charges a commission of $0.0000 to $0.005/share for executions in the LeveL ATS. LeveL Markets is assessed certain Consolidated Audit Trail (CAT) regulatory fees relating to trading on the LeveL ATS as an execution venue. In each transaction on the LeveL ATS, LeveL Markets (EBXL) is identified on transaction reports as the buyer and the selling LeveL ATS subscriber is reported as the seller. FINRA assesses CAT fees on both LeveL Markets, on behalf of the buying LeveL ATS subscriber, and on the selling LeveL ATS subscriber. LeveL Markets passes through to the buying LeveL ATS subscriber these CAT-related fees that LeveL Markets is assessed on behalf of those buying LeveL ATS subscribers. LeveL Markets does not pass through CAT fees to Buyside Subscribers.

financial_condition_summary

LeveL Markets charges a commission of $0.0000 to $0.05/share for executions in the LeveL ATS. Certain Buyside Subscribers (as of March 30, 2026) pay commissions in "basis points," ranging from a low of one (1) basis point to a high of six (6) basis points. Each basis point equates to one hundredth of one percent of the notional value of the transaction. Although commission rates can be impacted by a number of factors, including the subscriber's anticipated volume, anticipated make/take ratio and anticipated percentage of "internalization-only" transactions, rates are individually negotiated between LeveL Markets and the relevant subscriber. LeveL Markets does not charge different rates for executions resulting from orders utilizing Contra-party Permissioning functionality, including transactions resulting from Internalization-Only orders. Depending on the provider, and effective March 30, 2026, LeveL Markets may "pass through" to Buyside Subscribers certain fees that it is charged by certain service bureau routers or OMS and EMS entities. These pass-through fees are fully disclosed to the applicable Buyside Subscribers and typically range from a high of 15 mills ($0.0015) to a low of zero mills per executed share. In certain instances, these vendors may charge LeveL Markets more than 15 mills and thus a pass-through fee charged to a Buyside Subscriber that uses that router, OMS, or EMS may exceed 15 mills. In some cases, Buyside Subscribers may elect to pay a rate higher than the base execution rate, and they can also apply additional commission as part of a Commission Sharing Arrangement ("CSA") in conformance with Section 28(e) of the Securities Exchange Act of 1934. This amount above the base commission rate to be attributed to the CSA program is determined solely by the Buyside Subscriber, pursuant to a written agreement with LeveL Markets. LeveL Markets does not charge any other fees for use of the LeveL ATS (i.e., LeveL Markets only charges subscribers the commission rates identified above). However, subscribers may be responsible for any connectivity fees or other costs they incur in accessing the LeveL ATS (i.e., fees not charged by LeveL Markets). As discussed in Part III Item 19(c) below, certain subscribers that are in a bilateral or multilateral trading arrangement to execute against other subscribers in the LeveL ATS may pay a higher negotiated commission rate to LeveL Markets, who will rebate part of that higher rate to the other subscriber or subscribers. As noted above, LeveL Markets charges a commission of $0.0000 to $0.005/share for executions in the LeveL ATS. LeveL Markets is assessed certain Consolidated Audit Trail (CAT) regulatory fees relating to trading on the LeveL ATS as an execution venue. In each transaction on the LeveL ATS, LeveL Markets (EBXL) is identified on transaction reports as the buyer and the selling LeveL ATS subscriber is reported as the seller. FINRA assesses CAT fees on both LeveL Markets, on behalf of the buying LeveL ATS subscriber, and on the selling LeveL ATS subscriber. LeveL Markets passes through to the buying LeveL ATS subscriber these CAT-related fees that LeveL Markets is assessed on behalf of those buying LeveL ATS subscribers. LeveL Markets does not pass through CAT fees to Buyside Subscribers.

financial_condition_summary

Item 21 (Part III)

conflict_description

FMR Sakura Holdings, Inc. ("FMR Sakura") owns a minority stake in LeveL Holdings, LLC ("LeveL Holdings"). LeveL Markets is a wholly owned subsidiary of LeveL Holdings. Fidelity Global Brokerage Group, Inc. ("FGBG") owns a separate, smaller stake in LeveL Holdings. FMR Sakura and FGBG are wholly owned subsidiaries of FMR LLC, which operates a number of businesses under the trade name Fidelity Investments ("Fidelity"). By virtue of FMR Sakura's and FGBG's stakes in LeveL Holdings, both FMR Sakura and FGBG are indirect affiliates of LeveL Markets. Fidelity's National Financial Services LLC ("NFSC" - a registered broker-dealer) is a subscriber to the LeveL ATS and may enter orders or trading interest to the ATS on an agency or principal basis. Fidelity's asset management entity - Fidelity Management & Research Company ("FMR Co.") - is a Buyside Subscriber to the LeveL ATS. In that regard, FMR Co. can enter trading interest and orders and execute transactions on the ATS and has no special access to or privileges in the ATS beyond what any other LeveL ATS subscriber can have. FMR Co. is not a broker-dealer and does not have an MPID. The orders and trading interest entered by FMR Co. into the LeveL ATS is in an agency capacity.

conflict_description

FMR Sakura Holdings, Inc. ("FMR Sakura") owns a minority stake in LeveL Holdings, LLC ("LeveL Holdings"). LeveL Markets is a wholly owned subsidiary of LeveL Holdings. Fidelity Global Brokerage Group, Inc. ("FGBG") owns a separate, smaller stake in LeveL Holdings. FMR Sakura and FGBG are wholly owned subsidiaries of FMR LLC, which operates a number of businesses under the trade name Fidelity Investments ("Fidelity"). By virtue of FMR Sakura's and FGBG's stakes in LeveL Holdings, both FMR Sakura and FGBG are indirect affiliates of LeveL Markets. Fidelity's National Financial Services LLC ("NFSC" - a registered broker-dealer) is a subscriber to the LeveL ATS and may enter orders or trading interest to the ATS on an agency or principal basis. As of March 30, 2026, Fidelity's asset management entity - Fidelity Management & Research Company ("FMR Co.") - will be a Buyside Subscriber to the LeveL ATS. In that regard, FMR Co. will enter trading interest and orders and execute transactions on the ATS and will have no special access to or privileges in the ATS beyond what any other LeveL ATS subscriber can have. FMR Co. is not a broker-dealer and does not have an MPID. The orders and trading interest entered by FMR Co. into the LeveL ATS will be in an agency capacity.

conflict_description

Item 23 (Part III)

compliance_officer

LeveL Markets's sole brokerage business is the operation of the LeveL ATS and the handling and routing of orders from Buyside Subscribers. Access to the LeveL ATS systems is controlled by user credentials, passwords, and security certificates assigned by LeveL Markets staff. Access to individual parts of the LeveL ATS trading systems (e.g., to subscriber confidential trading information) is permissioned at the user level. The only employees of LeveL Holdings or LeveL Markets with the ability to view open order interest in the LeveL ATS are certain members of LeveL Holdings's or LeveL Markets's Technology department that support the LeveL ATS and the LeveL Markets Sales and Operations teams. (Please see Item 6 above for a description of the responsibilities of these employees.). LeveL Holdings and LeveL Markets Technology department staff, the LeveL Markets Sales team, and the LeveL Markets Operations team that support the LeveL ATS are located in or based out of LeveL Markets's Charleston, SC and Boston, MA offices. LeveL Markets's Boston, MA and Charleston, SC offices require keycard access for entry. LeveL Markets may grant access to proprietary or confidential information within the LeveL ATS after ensuring an employee or contractor has, where appropriate, undergone a background check and signed non-disclosure and confidentiality agreements. LeveL Markets's CCO reviews all requests for access to ensure that the requested access is appropriate given the individual's anticipated responsibilities at LeveL Markets. LeveL Markets policy prohibits personnel with access to subscriber confidential trading information from sharing such information with personnel not authorized to receive such information and from otherwise using such information for any purpose other than supporting the operation of the LeveL ATS or its compliance with applicable rules and regulations. LeveL Markets policy prohibits these employees from sharing LeveL ATS subscriber confidential trading information with other LeveL Markets personnel or Nasdaq personnel. LeveL Markets uses a privileged access system as an access control with respect to LeveL Markets systems, applications, and accounts and any Confidential Trading Information contained therein. LeveL Markets's network configuration utilizes Access Control Lists to limit access from a specific source IP to a specific destination IP. The LeveL ATS servers are kept in a secure data center located in New Jersey which restricts access to essential authorized personnel. Authorized personnel must identify themselves with a government issued Photo ID. While subscriber confidential trading information is not encrypted within the secured LeveL ATS systems, such information is encrypted when exported to third-parties (e.g., for clearance and settlement). Upon request, LeveL Markets will provide subscribers with contra-party execution reports relating to the subscriber's own activity in the LeveL ATS and the categorization of its contra-parties. These reports are provided on a two-week delayed basis (i.e., no execution noted in any such report will have occurred within the two weeks prior to the report date). Subscribers may also request that the FIX messages disseminated to the subscriber in connection with each execution in the LeveL ATS identify, as applicable, (i) whether the subscriber's order was deemed to provide or remove liquidity, (ii) whether the subscriber executed against itself, (iii) whether the subscriber executed against a third-party (rather than against itself), and (iv) whether the subscriber's Firm Order executed against a Firm-Up Order. Additionally, LeveL Markets makes certain aggregated monthly order and execution statistics available on its website. Subscribers may not opt-out from having their information included in these reports. EMPLOYEE TRADING: All LeveL Holdings and LeveL Markets employees, including but not limited to the Technology, Sales, Operations, Legal and Compliance staff who support the LeveL ATS are subject to trading restrictions to ensure that such persons' trading activities do not conflict with the interests of LeveL ATS subscribers. LeveL Markets does not have any individual or retail customer accounts, including employee accounts. As such, employee trading accounts must be opened and maintained at other broker-dealers, upon approval by the LeveL Markets Chief Compliance Officer (CCO). All employees are required to disclose to Compliance all outside brokerage accounts, and duplicate trade confirmations and account statements (hard copy or via electronic feed) are required to be provided to Compliance for all employee-related accounts held outside the Firm. LeveL Markets Compliance reviews all employee trade data received for indications of potential misuse of subscriber confidential trading information. Certain trading restrictions, such as Compliance pre-approvals and mandatory hold periods, are in place for less liquid securities (generally, non-large cap securities). Exceptions to these restrictions must be approved in advance by Compliance, and the approval and hold period requirements do not apply to employee accounts which are managed by an advisor (human or automated) that has full investment discretion while the employee has none. All employees must also comply with other trading-related Firm policies such as, but not limited to, its Insider Trading policy. AFFILIATION WITH NASDAQ: Nasdaq owns a minority interest in LeveL Markets's parent company, LeveL Holdings. LeveL Holdings and Nasdaq each have information barriers, controls and related policies that prohibit the sharing of non-public confidential trading information between LeveL Markets and the Nasdaq Entities (including, for clarity, the sharing of LeveL ATS subscriber confidential trading information with any Nasdaq Entity, and the sharing of any non-public trading information of any Nasdaq Securities Exchange with LeveL Markets). Further, LeveL Markets personnel and Nasdaq Personnel are subject to policies and procedures that are designed to preserve the independent governance and operation of the LeveL ATS and the Nasdaq Securities Exchanges. The Nasdaq Securities Exchanges and the LeveL ATS utilize wholly separate technology and systems. Nasdaq personnel do not have access to the LeveL ATS systems, and LeveL Markets personnel do not have access to the systems used in connection with the operation of the Nasdaq Securities Exchanges. LeveL Markets does not share any office space with any Nasdaq entity. LeveL Markets policies and procedures treat Nasdaq Personnel in the same manner as personnel of any unaffiliated third-party. Accordingly, Nasdaq Personnel are restricted from accessing LeveL Markets premises and systems, and from obtaining order, execution and other system data relating to LeveL Markets's operations.

compliance_officer

LeveL Markets's sole brokerage business is the operation of the LeveL ATS and Luminex ATSs. Access to the LeveL ATS systems is controlled by user credentials, passwords, and security certificates assigned by LeveL Markets staff. Access to individual parts of the LeveL ATS trading systems (e.g., to subscriber confidential trading information) is permissioned at the user level. The only employees of LeveL Holdings or LeveL Markets with the ability to view open order interest in the LeveL ATS are certain members of LeveL Holdings's or LeveL Markets's Technology department that support the LeveL ATS and the LeveL Markets Sales and Operations teams. (Please see Item 6 above for a description of the responsibilities of these employees.). LeveL Holdings and LeveL Markets Technology department staff, the LeveL Markets Sales team, and the LeveL Markets Operations team that support both the LeveL ATS and the Luminex ATS are located in or based out of LeveL Markets's Charleston, SC and Boston, MA offices. LeveL Markets's Boston, MA and Charleston, SC offices require keycard access for entry. LeveL Markets may grant access to proprietary or confidential information within the LeveL ATS after ensuring an employee or contractor has, where appropriate, undergone a background check and signed non-disclosure and confidentiality agreements. LeveL Markets's CCO reviews all requests for access to ensure that the requested access is appropriate given the individual's anticipated responsibilities at LeveL Markets. LeveL Markets policy prohibits personnel with access to subscriber confidential trading information from sharing such information with personnel not authorized to receive such information and from otherwise using such information for any purpose other than supporting the operation of the LeveL ATS or its compliance with applicable rules and regulations. Specifically, Technology department staff as well as LeveL Markets Sales, Operations, Legal and Compliance staff are prohibited from using confidential trading information from the LeveL ATS in any way relating to their support and operations of the Luminex ATS. LeveL Markets policy prohibits these employees from sharing LeveL ATS subscriber confidential trading information with other LeveL Markets personnel or Nasdaq personnel. LeveL Markets uses a privileged access system as an access control with respect to LeveL Markets systems, applications, and accounts and any Confidential Trading Information contained therein. LeveL Markets's network configuration utilizes Access Control Lists to limit access from a specific source IP to a specific destination IP. The LeveL ATS servers are kept in a secure data center located in New Jersey which restricts access to essential authorized personnel. Authorized personnel must identify themselves with a government issued Photo ID. While subscriber confidential trading information is not encrypted within the secured LeveL ATS systems, such information is encrypted when exported to third-parties (e.g., for clearance and settlement). Upon request, LeveL Markets will provide subscribers with contra-party execution reports relating to the subscriber's own activity in the LeveL ATS and the categorization of its contra-parties. These reports are provided on a two-week delayed basis (i.e., no execution noted in any such report will have occurred within the two weeks prior to the report date). Subscribers may also request that the FIX messages disseminated to the subscriber in connection with each execution in the LeveL ATS identify, as applicable, (i) whether the subscriber's order was deemed to provide or remove liquidity, (ii) whether the subscriber executed against itself, (iii) whether the subscriber executed against a third-party (rather than against itself), and (iv) whether the subscriber's Firm Order executed against a Firm-Up Order. Additionally, LeveL Markets makes certain aggregated monthly order and execution statistics available on its website. Subscribers may not opt-out from having their information included in these reports. EMPLOYEE TRADING: All LeveL Holdings and LeveL Markets employees, including but not limited to the Technology, Sales, Operations, Legal and Compliance staff who support both the LeveL ATS and the Luminex ATS are subject to trading restrictions to ensure that such persons' trading activities do not conflict with the interests of LeveL ATS subscribers and Luminex ATS Subscribers. LeveL Markets does not have any individual or retail customer accounts, including employee accounts. As such, employee trading accounts must be opened and maintained at other broker-dealers, upon approval by the LeveL Markets Chief Compliance Officer (CCO). All employees are required to disclose to Compliance all outside brokerage accounts, and duplicate trade confirmations and account statements (hard copy or via electronic feed) are required to be provided to Compliance for all employee-related accounts held outside the Firm. LeveL Markets Compliance reviews all employee trade data received for indications of potential misuse of subscriber confidential trading information. Certain trading restrictions, such as Compliance pre-approvals and mandatory hold periods, are in place for less liquid securities (generally, non-large cap securities). Exceptions to these restrictions must be approved in advance by Compliance, and the approval and hold period requirements do not apply to employee accounts which are managed by an advisor (human or automated) that has full investment discretion while the employee has none. All employees must also comply with other trading-related Firm policies such as, but not limited to, its Insider Trading policy. AFFILIATION WITH NASDAQ: Nasdaq owns a minority interest in LeveL Markets's parent company, LeveL Holdings. LeveL Holdings and Nasdaq each have information barriers, controls and related policies that prohibit the sharing of non-public confidential trading information between LeveL Markets and the Nasdaq Entities (including, for clarity, the sharing of LeveL ATS subscriber confidential trading information with any Nasdaq Entity, and the sharing of any non-public trading information of any Nasdaq Securities Exchange with LeveL Markets). Further, LeveL Markets personnel and Nasdaq Personnel are subject to policies and procedures that are designed to preserve the independent governance and operation of the LeveL ATS and the Nasdaq Securities Exchanges. The Nasdaq Securities Exchanges and the LeveL ATS utilize wholly separate technology and systems. Nasdaq personnel do not have access to the LeveL ATS systems, and LeveL Markets personnel do not have access to the systems used in connection with the operation of the Nasdaq Securities Exchanges. LeveL Markets does not share any office space with any Nasdaq entity. LeveL Markets policies and procedures treat Nasdaq Personnel in the same manner as personnel of any unaffiliated third-party. Accordingly, Nasdaq Personnel are restricted from accessing LeveL Markets premises and systems, and from obtaining order, execution and other system data relating to LeveL Markets's operations.

compliance_officer

Item 5 (Part II)

nms_equity

true

nms_equity

true

nms_equity

true

nms_equity

true

nms_equity

true

nms_equity

true

Item 6 (Part II)

subscriber_types

Brokers

subscriber_types

Brokers

subscriber_types

Brokers

subscriber_types

Brokers

subscriber_types

Brokers

subscriber_types

Brokers

Item 7 (Part II)

hours_of_operation

The LeveL ATS accepts orders on days that the New York Stock Exchange ("NYSE") is open and observes NYSE's holiday and early close schedule. The LeveL ATS accepts orders that are not IOC or Enhanced IOC orders from 7:30 a.m. to 4:00 p.m. ET. The ATS accepts IOC and Enhanced IOC orders from 9:30 a.m. to 4:00 p.m. ET. The LeveL ATS, on a security-by-security basis, creates matches from the time it receives the Opening Trade Report (as that term is defined in Part III Item 10) for the relevant security until 4:00 p.m. ET.

hours_of_operation

Item 8 (Part II)

display_trading_interest

false

display_trading_interest

false

display_trading_interest

false

display_trading_interest

false

display_trading_interest

false

display_trading_interest

false

Item 9 (Part II)

execution_services

Firm Orders: The LeveL ATS attempts to effect an "Opening Cross" of all firm orders on a security-by-security basis. For each security, after the LeveL ATS has received a trade report marked "last sale eligible" (the "Opening Trade Report"), the LeveL ATS will attempt to cross all eligible open firm orders at the price noted in the Opening Trade Report. If the LeveL ATS attempts to effect an Opening Cross at a price outside the NBBO, the Opening Cross will not occur. For purposes of the Opening Cross, firm orders are matched on strict time priority (e.g., to the extent both orders have eligible limit prices, a buy order with a higher limit price will not have priority over a buy order received earlier with a lower limit price and orders are not crossed on a pro rata basis). IOC and Enhanced IOC firm orders are not eligible to participate in the Opening Cross. After the security's Opening Cross (or any attempted Opening Cross), any unmatched firm orders (including the unmatched portion of any order) will, subject to their terms, remain eligible for execution and will match in accordance with the LeveL ATS's standard matching logic. The LeveL ATS accepts conditional orders prior to any Opening Cross, but conditional orders are not eligible to participate in an Opening Cross. Firm-Up Orders, by their terms, will not participate in an Opening Cross. The LeveL ATS does not effect a "reopening cross" of firm orders following a suspension in trading. Rather, all open interest will be eligible for matching and execution in accordance with the ATS's standard matching logic. Full Day VWAP Orders: The LeveL ATS separately attempts to cross all open Full Day VWAP Orders at 9:28 a.m. ET (the "Full Day VWAP Cross"). A single Full Day VWAP Order may match with multiple contraside Full Day VWAP Orders. Where multiple eligible contra-party Full Day VWAP Orders exist, priority is determined based on the following factors in the following order: (i) size and (ii) time of order receipt. Full Day VWAP Orders that match and anchor during the Full Day VWAP Cross receive an execution price equal to the security's VWAP for the trading day. The LeveL ATS cancels any fully unanchored Full Day VWAP Order following the Full Day VWAP Cross. The priority or matching logic processes described in Item 10a are not impacted by any Contra Priority list that may be implemented by LeveL Markets at the request of a subscriber, as described more fully in Item 14 below.

execution_services

Section 8 + 9

taxonomy_ex_code

SSEG

SEC FILINGS (6)

ATS-N/UA2026-06-26T00:00:00.000Z0001609177-26-000018 ↗PARSED

ATS-N/MA2026-05-11T00:00:00.000Z0001609177-26-000017 ↗PARSED

ATS-N/UA2026-05-01T00:00:00.000Z0001609177-26-000014 ↗PARSED

ATS-N/CA2026-04-30T00:00:00.000Z0001609177-26-000013 ↗PARSED

ATS-N/UA2026-03-27T00:00:00.000Z0001609177-26-000011 ↗PARSED

ATS-N/UA2026-03-23T00:00:00.000Z0001609177-26-000010 ↗PARSED