ATS-N/MA 0001957871-26-000013 LIVE 0001957871 XXXXXXXX 013-00208 false false Admiral Securities LLC Y This filing amends the disclosures regarding Part III, Items 7a, 11c, and 19c. These amendments apply in the same manner to all Subscribers and the broker dealer operator. Item 7(a) is amended to add pegged order functionality. The amended disclosure describes the types of pegged orders accepted by the ATS, including primary, market, and midpoint pegs; the applicable NBBO reference prices; the use of ultimate limit prices and offset instructions; how effective limit prices are calculated and updated as the NBBO changes; and how pegged orders are ranked and executed. Item 11(c) is amended to describe how the ATS communicates information regarding the universe of NMS securities eligible for trading. The amended disclosure states that Admiral will maintain a list of currently traded securities on its website, that Subscribers may request the current list by email or FIX, and that changes to the eligible universe will be communicated to Subscribers by email and FIX. Item 19(c) is amended to revise the criterion for qualifying for a liquidity provider rebate. The amended disclosure states that the rebate is determined on a trade-by-trade basis based on whether, at the time of execution, the Subscriber maintained a qualifying two-sided quote in the relevant security, and clarifies how the rebate is applied to executed shares. Y ADMIRAL SECURITIES LLC 008-71028 000324098 FINRA 10/21/2024 ADML www.admiral.trade 1515 Port Industrial Way Quincy 98848 US-WA 644 Logistics Dr Cheyenne 82009 US-WY false false The Admiral ATS is operated by Admiral Securities LLC, henceforth "Admiral". Admiral operates no business lines other than the Admiral ATS. Admiral personnel may enter or direct the entry of orders, as principal, into the ATS in the event of an error, a clearly erroneous execution or as a result of a fail to deliver or receive that have violated the Admiral ATS Rulebook. The applicable MPID used is ADML. As described in Part III, Item 22, Admiral's clearing broker is Vision Financial Markets ("Vision"), FINRA member firm and a member of the National Securities Clearing Corporation and Depository Trust and Clearing Corporation. Vision acts as the clearing broker for all transactions executed on the ATS. In addition, Vision is a subscriber to the Admiral ATS and, as such, can send orders to the Admiral ATS, but only in an agency capacity. Vision's MPID is VSIN. All orders to the Admiral ATS pass through Vision. Before orders reach the Admiral ATS, Vision performs numerous risk checks. Vision performs these exact same checks to all orders sent by its correspondents and customers. These checks include buying power, duplicate orders, sub-penny stocks, price checks, and wash trades. If an Admiral subscriber order fails any of these Vision risk checks, the order will not be sent to the Admiral ATS. If an order passes the Vision risk checks, Vision sends the order to the Admiral ATS via a FIX connection. Y N N N N N N N N N N Admiral utilizes the services of independent contractors to conduct the business. These include the following: Chief Executive Officer (CEO): The CEO's role is to oversee the company as a whole, which includes the operation of the ATS. He is thus responsible for supervising the individuals operating the ATS and its operations as described in Part III, Items 1-5, 7, 8, 10, 11, 15, and 19-23. Chief Operations Officer (COO): The COO's core responsibility is to oversee the daily operations of the ATS as described in Part III, Items 1-5, 7, 8, 10, 11, 15, and 19-23 Chief Compliance Officer (CCO): The Firm's CCO is responsible for ensuring a robust compliance scheme, monitoring adherence to the rules, policies, and procedures. The CCO's key responsibility is to identify and address potential compliance issues by monitoring activities and reporting violations to relevant authorities. Financial and Operations Principal (FINOP): The FINOP is an employee of Accounting & Compliance International, and is responsible for overseeing Admiral's financials and bookkeeping, the financial and operational aspects, ensuring compliance with regulations, maintaining accurate books and records, and submitting financial reports. Together, the CEO, COO, and CCO constitute Admiral Management. Admiral has engaged Connamara Systems, LLC ("Connamara"), a software engineering company, to provide technology development of the matching engine, upgrades, order entry support, maintenance and regulatory reporting in connection with the Admiral ATS. Connamara has successfully completed a SOC 2 Type II examination. This includes functionalities described in Part III, Items 5, 7, 11, 15, 20, and 21. The Admiral ATS is hosted on the Microsoft Azure cloud platform (see Part III, Item 11). This means that the ATS's servers, storage, networking, and ancillary services run inside Microsoft Azure's data-center infrastructure leveraging Azure resources (VMs, VNets, managed databases, security and monitoring services) that are provisioned, scaled, and maintained through Azure's cloud platform. As described in Part III, Item 22, Admiral's clearing broker is Vision Financial Markets ("Vision"). As discussed in Part III, Item 23, Admiral's market data provider is Options Technology. Throughout, "market data" refers to publicly disseminated equity market data and not data from the Admiral ATS. As discussed in Part II Item 1 above, Vision is a subscriber to the Admiral ATS and, as such, can send orders to the Admiral ATS, but only in an agency capacity. Y DEFINITION OF CONFIDENTIAL TRADING INFORMATION Confidential trading information (CTI) of subscribers to the Admiral ATS consists of: *The identity of the subscriber *All orders and related messages transmitted to the Admiral ATS by a subscriber *All transactions executed in the Admiral ATS *FIX logs of incoming subscribers' order management operations and outgoing order states reports. *Database Information: Transaction and configuration data stored in the Admiral ATS databases *ATS System Logs: ATS order management/execution management system logs, ATS matching engine logs, ATS Market Data Feeder logs, EOD/BOD process logs, logs of the ATS Administrative front-end *E-mail, issue tracking system communications, and notes related to the ATS system support operations between the subscriber and Admiral Please find additional information regarding safeguards and procedures for protecting CTI in the attached document. N Access to CTI is provided only to 1) Persons associated with Admiral directly (i.e. the CEO, CCO, COO, and FINOP and their direct reports (if any)), and 2) Certain third party providers. As discussed above (Part II, Item 6), the primary associated persons are the Chief Executive Officer (CEO), Chief Operations Officer (COO), Chief Compliance Officer (CCO), and Financial and Operations Principal (FINOP), all of whom have access to CTI. We will now discuss the basis for this access in turn. CEO: The CEO's role is to oversee the company as a whole, which includes the operation of the ATS. As such, the CEO has access to CTI, including daily subscriber activity reports, the resolution of errors, and other situations that are necessary to support the ATS. COO: The COO's core responsibility is to oversee the daily operations of the ATS, including troubleshooting system issues, resolution of errors, erroneous transactions, etc. As such, the COO has access to CTI on a regular basis as needed to support the ATS. CCO: The CCO has access to real-time and post-trade CTI in order to help ensure compliance with the requirements of Regulations ATS and SCI. FINOP: The FINOP has access to post-trade CTI as well as the identity of Admiral's subscribers and fees as identified in Part III item 19. As discussed in Item 6b, Admiral has engaged Connamara for ongoing technical support, for instance (but not limited to) issues relating to latency spikes, order mismatches, system crashes or hangs, connectivity drops. This means that Connamara personnel will occasionally need access to the Admiral ATS technology stack, which contains CTI. As discussed below (Part III Item 5), TRAFiX is a broker-neutral execution management system that provides a system to effectively manage the order flow, connectivity, routing, risks checks, compliance checks and post trade processing. TRAFiX has access to all CTI to perform these functions. Admiral's clearing broker Vision has access to all CTI to perform the functions as described in Part III, Items 5 and 22(a). Brokers Dealers Y The Admiral ATS accepts Subscriber applicants that meet the following requirements: 1. Be a U.S. Securities Exchange Commission and FINRA registered broker-dealer in good standing. 2. Be a correspondent of Vision. 3. Execute a Subscriber agreement. 4. Satisfy Admiral's onboarding process (e.g., KYC/AML review, OFAC checks, disciplinary review). 5. Satisfy any technical or system requirements that Admiral may prescribe (i.e., connectivity certification, certification of applicable order and trade functionality, ability to receive trades/cancellations, rejects and trade breaks from the ATS). Given that all subscribers to the Admiral ATS must be correspondents of Vision, if a subscriber ceases to be a correspondent of Vision, they will no longer be eligible to trade on the Admiral ATS. All orders from Vision's correspondents pass through Vision first, and so broker dealers who are not (or no longer) Vision correspondents will not be able to send orders to the Admiral ATS. While Admiral intends to treat each prospective subscriber equally, Admiral retains the discretion to refuse access to the Admiral ATS due to legal, regulatory, credit, or other concerns, including negative news reports relating to the prospective subscriber, such as criminal allegations or charges, civil litigation, cybersecurity breaches, and ties to sanctioned entities or jurisdictions. Vision eligibility requirements Whether or not to onboard a new correspondent is ultimately a business decision made by Vision, and Vision retains full discretion to decide whether or not to onboard a new correspondent. Vision sets various criteria regardless of whether the new correspondent intends to subscribe to the Admiral ATS. -To start the process, a potential correspondent will first complete Vision's Correspondent Questionnaire and provide all required documents listed in the Questionnaire. After the Questionnaire is completed and the requested documents have been provided, the relevant documents will be submitted to Vision's Correspondent Review Committee ("CRC") for discussion. -The CRC may then circulate questions internally for discussion or to the potential correspondent to get clarity on any of the information provided. -A CRC meeting will then be scheduled where the members will discuss the prospective correspondent relationship. Each team member completes their review based on their area of expertise including, but not limited to, the correspondent's regulatory history and current standing, financial information, anticipated trade flow, potential use of internal resources and commercial terms of the relationship. The CRC then will decide as a group to either accept or reject the new correspondent. -Upon approval of a new correspondent by the CRC, Vision will then enter into a written clearing agreement with the correspondent. The clearing agreement will then be submitted to FINRA for final approval. After receiving FINRA approval, Vision will begin the process of onboarding the new correspondent. Vision retains full discretion to refuse broker-dealers as new correspondents and terminate existing correspondent clearing relationships. As such, there is no guarantee of full equality of conditions. Y While Admiral intends to treat each prospective subscriber equally, Admiral retains the sole discretion to refuse access to the Admiral ATS. Reasons may include failure to meet the eligibility requirements outlined in Item 2 above, as well as legal, regulatory, credit, or other concerns, including negative news reports relating to the (prospective) subscriber, such as criminal allegations or charges, civil litigation, cybersecurity breaches, and ties to sanctioned entities or jurisdictions. Moreover, as discussed above, subscribers need to be correspondents of Vision, and therefore remain in good standing with Vision. In addition, as discussed in Item 7 below, a subscriber's failure to settle on T+0is financially liable to Admiral and Vision for the costs of remediation (e.g. loss in value of position or borrowing costs) and this could also result in a temporary or permanent expulsion from the Admiral ATS. Y The ATS accepts orders between 9:30am ET and 4:00pm ET on weekdays, and follows the New York Stock Exchange hours of operation on partial trading days and holidays. Y All trading communications between subscribers and the Admiral ATS pass through Vision using FIX 4.2 protocol. Before orders reach the Admiral ATS, Vision performs numerous risk checks. Vision performs these exact same checks to all orders sent by its correspondents and customers. These checks include buying power, duplicate orders, sub-penny stocks, price checks, and wash trades. If an Admiral subscriber order fails any of these Vision risk checks, the order will be rejected, and thus not reach the Admiral ATS. If an order passes the Vision risk checks, Vision sends the order to the Admiral ATS via a FIX connection. In addition, TRAFiX is a broker-neutral execution management system that provides a system to effectively manage the order flow for Vision's execution business. TRAFiX technology sits in the middle of the trading stack as the hosted OMS/EMS that receives inbound order flow, normalizes it, and routes it out to execution venues using Vision's routing rules. It enforces Vision's pre-trade risk controls (Rule 15c3-5 style checks and firm/trader/account limits) before orders leave Vision. If an order passes the risk checks, Vision sends the order to the Admiral ATS via a FIX connection. When an order reaches the Admiral ATS, Admiral performs a number of checks before the order enters the order book. These checks include, but are not limited to, the validity of the ticker, the order type (e.g. Admiral does not accept market orders), and the order size. If an order fails any Admiral check, it is rejected and sent back. TRAFiX also produces the compliance/audit outputs Vision needs (e.g., CAT lifecycle reporting and trade-reporting interfaces like ACT/ORF, along with order marking and supervisory controls). After fills, TRAFiX pushes post-trade messages into Vision's downstream workflow via real-time FIX drop copies and/or end-of-day files. In sum, Vision uses TRAFiX as the plumbing that ties together connectivity, routing, risk/compliance, and post-trade processing across the full order lifecycle. Y N N N N The Admiral ATS utilizes the price-time priority matching algorithm. In this algorithm, all orders at the same price level are filled according to time priority; the first order at a price level is the first order matched. All orders entered into the Admiral ATS are firm orders. An order is actionable and eligible for matching at any time until such order has expired by its terms, is canceled, or is executed. A reduction in an order's size does not affect the order's original time priority. The Admiral ATS accepts buy, sell, and sell short orders. The Admiral ATS accepts limit and post-only orders. Post-only orders can only post (i.e., add liquidity) and cannot remove liquidity on entry. If the post-only order is marketable on entry, it is rejected. Here is an example of how orders might come in, rest, and then match: ORDER A: tagged with identifier SUBSCRIBER1, a post-only, LIMIT DAY buy order to buy 500 shares of ABC @ $10 is entered in the system at 2:00 p.m.; ORDER B: tagged with identifier SUBSCRIBER2, a post-only , LIMIT DAY order to sell 500 shares of ZZZ @ $10 is entered in the system at 2:01 p.m.; ORDER A and ORDER B are "resting" orders i.e., they are posted on the ATS and they are awaiting a contra aggressive interest; ORDER C: tagged with identifier SUBSCRIBER3, a LIMIT DAY sell order to sell 500 shares of ABC @ $10 is entered in the system at 2:02 p.m.; ORDER C is immediately executed (matched with a contra interest) @ $10 at 2:02 p.m. against resting ORDER A; ORDER B remains resting on the ATS and will be held on the ATS until the end of the session, until the order is canceled, or until it is executed (matched with a contra interest) Day orders are canceled at 4:00 p.m. The minimum price variation ("MPV") or minimum trading increment is $0.01. Orders that do not meet this criterion are rejected. The Admiral ATS only accepts orders that are marked for cash (T+0) settlement. Orders must be marked with FIX tag <63> ("SettlType") equal to value 1 ("Cash") in order to be accepted. Subscribers are responsible for ensuring that orders sent to the Admiral ATS can settle on T+0. A subscriber sending orders that cannot settle on T+0 is financially liable to Admiral and Vision for the costs of remediation (e.g. loss in value of position or borrowing costs) and this could also result in a temporary or permanent expulsion from the Admiral ATS. Orders are rejected if they contain instructions or order attributes that are not supported by the ATS, such as a non-existent stock symbol or invalid time in force. The ATS accepts pegged orders. Pegged orders may include the following reference prices: (i) primary (i.e., NBB for buy orders, NBO for sell orders); (ii) market (i.e., NBO for buy orders, NBB for sell orders); and (iii) midpoint of the NBBO. Pegged orders may include an ultimate limit price. Pegged to the midpoint of the NBBO must include an ultimate limit price. Primary pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged primary plus $0.01). Market pegged orders may include dollar offset instructions expressed in penny increments (e.g., pegged market minus $0.01). Orders pegged to the midpoint of the NBBO may include dollar offset instructions ("Midpoint Offsets"), further discussed below. When used herein, a "positive" (+) offset refers to a more aggressive price, while a "negative" (-) offset refers to a less aggressive price. For instance, where the NBBO is $20.00 x $20.05, a primary pegged buy order with a positive (+) $0.01 offset will have an effective limit price of $20.01, while a primary pegged sell order with a positive (+) $0.01 offset will have an effective limit price of $20.04). Pegged orders are ranked based on their effective limit price. At no time will a peg instruction, including any offset instruction, violate an order's ultimate limit price. Midpoint Offset instructions must include two values, one value that will be applied when the NBBO spread is an even value (e.g., where the NBBO is $20.00 x $20.10) (the "Even Spread Offset") and a second value that will be applied when the NBBO spread is an odd value (e.g., where the NBBO is $20.00 x $20.05) (the "Odd Spread Offset"). Even Spread Offsets must be expressed in full penny increments. Odd Spread Offsets must be expressed in a half penny increment, not a whole penny increment (that is, $0.005, $0.015, $0.025, etc.). Midpoint Offset instructions may be expressed as positive or negative offsets. An order's Even and Odd Spread Offset instructions must be sequential (that is, an order with an Even Spread Offset of +$0.01 must include Odd Spread Offset instructions of either +$0.005 or +$0.015; no other Odd Spread Offset instructions will be accepted). Midpoint Offset instructions will not cause an order's effective limit price to be marketable relative to the prevailing NBBO. Where a Midpoint Offset instruction would cause an order to be marketable relative to the prevailing NBBO (e.g., for buy orders, equal to or greater than the NBO), the ATS will treat the order's effective limit price as one penny below the NBO (for buy orders) or one penny above the NBB (for sell orders). The ATS will disregard any positive Midpoint Offset instruction when the NBBO is one penny wide. The above adjustments operate on a dynamic basis. For instance, assume a buy order pegged to the midpoint is submitted with an Even Spread Offset instruction of +$0.01 and an Odd Spread Offset instruction of +$0.015. If, upon order receipt, the prevailing NBBO is $20.00 x $20.10, the order's effective limit price would be $20.06 (that is, $20.05, the midpoint of the NBBO, plus a $0.01 Even Spread Offset). If, prior to the order being executed or cancelled, the NBBO updates to $20.00 x $20.03, the order's effective limit price would then be $20.02. If the NBBO further narrows to $20.00 x $20.01, the order's effective limit price would then be $20.005 (that is, the ATS will disregard the order's Midpoint Offset instruction). If the NBBO subsequently widens to $20.00 x $20.05, the order's effective limit price would then be $20.04 (that is, $20.025 plus the $0.015 Odd Spread Offset). Orders are not eligible for routing out to other trading venues. Time in Force (TIF) values are as follows: * Immediate Or Cancel (IOC) - immediately fills for as much volume as possible, the remaining shares are canceled back to the subscriber. * Fill or Kill (FOK) - an IOC order where the entire size must be filled, else the order is canceled. * DAY - available for trading during the regular market session until is canceled or executed (expires at market close). Orders that do not specify a TIF are rejected. Y The minimum order size is one share; the ATS does not offer trading in fractional shares. The maximum order size is 100,000 shares, and the maximal notional for an order is $1,000,000. Y Admiral accepts odd lot orders from subscribers and allows for odd lot executions. Odd lot orders are handled in the same manner as round lot orders and have the same priority treatment. Y Mixed lot orders are treated the same as round lot orders and have the same priority treatment. Y N The Admiral ATS does not accept orders for each security until the primary market for that security has opened. The status of the primary market is provided by Admiral's market data provider. Orders will be accepted regardless of whether the book contains both bids and offers, and are matched based on price time priority. During a stoppage (block) on the primary market, the Admiral ATS does not accept new orders. After a stoppage (as discussed in more detail in Item 20 below) on the primary market for a given security, the Admiral ATS does not accept or match orders in that security until the primary market for the stock has recommenced trading. Existing orders are not cancelled during a pause, but are cancelled during a stoppage. Y The Admiral ATS does not accept new orders until the primary market for the stock has recommenced trading. The system automatically resumes accepting orders after the trading stoppage ends. The Admiral ATS does not cancel existing orders during a pause. For more details see Item 20. Y N The Admiral ATS operates a displayed fully automated electronic limit order book that continuously matches and facilitates the execution of Subscriber buy and sell orders. All subscribers must be registered broker-dealers and correspondents or clients of Vision, all orders received by the Admiral ATS are firm orders. The Admiral ATS utilizes the price-time priority matching algorithm. Conditional orders are not accepted. The Admiral ATS accepts orders between 9:30am and 4:00pm ET on weekdays, except for during partial trading days and during the United States equity market holiday schedule, as followed by the New York Stock Exchange. Y The Admiral ATS maintains a universe of NMS stocks eligible for trading. The ATS may add or remove securities from this eligible universe. Admiral will maintain a list of currently traded stocks on its website (www.admiral.trade). In addition, the ATS communicates changes to the eligible universe to subscribers by email and FIX. In addition, subscribers may at any time request a list of all securities being traded on the ATS, via email or FIX. The Admiral ATS utilizes the price-time priority matching algorithm. In this algorithm, all orders at the same price level are filled according to time priority; the first order at a price level is the first order matched. A reduction in an order's size does not affect the order's original time priority. Changes that increase an order's size cause the order to lose priority to existing orders at the same price and result in a new time priority. A change in an order's price, however, results in a new time priority being assigned to the order. Orders are time-stamped to the microsecond by the ATS upon receipt, as are order modifications and cancellations. If an order is partially filled, the remainder of the order retains its priority. Amendments to partially filled orders follow the same priority rules as amendments to regular orders. The Admiral ATS provides neither price improvement functionalities nor price protection mechanisms. Consistent with Rule 612 of Regulation NMS, the minimum price increment for orders received by the ATS is $.01. Orders received by the ATS with price increments smaller than the preceding are rejected. All orders entered during the operating hours reside only on the Admiral ATS order book; the Admiral ATS does not route out orders. A buy order priced at or above the best offer, or sell order priced at or below the best bid, therefore result in executions, not locked or crossed markets. All orders are protected from matching outside of price bounds given by the NBBO. During any short sale restricted period under Rule 201 of Regulation SHO, the Admiral ATS will not execute (or "print") any short sale order at a price equal to or below the then-current national best bid (NBB). Short sale orders received at or below the NBB will be rejected or repriced (as applicable) in accordance with the price test restriction so that they are neither executed nor displayed at a non-compliant price. As discussed in Item 19c, Admiral will offer liquidity provider discounts on a trade-by-trade basis, based on two-sided quoting criteria. If a Subscriber believes a transaction to be clearly erroneous, they must notify Admiral within 30 minutes of the execution. Admiral will then assess the claim and generally make a determination within 30 minutes of receiving the claim. The claimant shall be promptly notified of the determination. In case Admiral deems the trade to be erroneous, Admiral will attempt to place the subscriber in the position they would have been in had the error not occurred. Actions taken may include, among others, canceling and busting the trade entirely, reducing quantities, and executing an offsetting trade on the subscriber's behalf. Y N N N N N The Admiral ATS immediately displays, via FIX messaging, to all subscribers (and only subscribers) the best bid and offer prices currently posted on the Admiral ATS, for each NMS security. These communications happen through a direct FIX connection between Admiral and the subscriber (i.e., not through Vision). These are displayed until the corresponding orders are either canceled or executed. In addition, the sizes of the best bids and offers are also displayed to subscribers. Subscribers cannot opt out of having their bid or offer prices displayed, if they are top of the book. Subscribers are permitted to disseminate the Admiral ATS top of book data to other parties. If there are no bid and/or offer prices for a particular security, no bid and/or offer price will be displayed. During a trade stoppage, no prices will be displayed. Under no circumstance are the identities of subscribers posting the best prices be disseminated. Y N N Y N Admiral does not charge a subscription, onboarding, or connectivity or message traffic fee (or any other fee that is not transaction-based) for use of the ATS services. Admiral does not provide market data to subscribers ("market data" refers to publicly disseminated equity market data and not data from the Admiral ATS.). Admiral does not charge subscribers any display fees (see Item 15). Fees are on a per-share basis, with $0.005 per share for taking liquidity and $0 for making liquidity. Admiral may, on a limited-time basis, reduce the standard $0.005-per-share taker fee by up to 50 percent (i.e., as low as $0.0025 per share). These discounts are offered only for promotional, volume-based, or liquidity-enhancement purposes, and run for a predefined period. Not applicable. Admiral defines liquidity provision using a criterion imposed on a subscriber's quotes in a given security at the time of a match. In other words, there are no continuous quoting obligations, and any subscriber could be labeled a liquidity provider (or not) for a specific trade it enters into. The responsibility for monitoring and tracking this is Admiral's. Specifically, a subscriber gets a "liquidity provider" (LP) discount on fees based on his quoting and trading activities. If, at the time the order is matched, the subscriber was maintaining a two sided quote and a different subscriber hit the bid or took the offer, the subscriber gets the LP rebate. This rebate is set at $0.0005 per share. The two sided quote must be such, that the offer price is equal to or less than the NBO and the buy price equal to or greater than the NBB. A liquidity provider discount is applied only to the executed shares that were matched. So for instance, if a subscriber was offering to buy 20 shares, but offering to sell 10, and his buy order of 20 was matched, he gets a liquidity provider discount for 10 shares, not 20. The Admiral ATS generally offers trading for all NMS stocks listed on a national securities exchange Admiral may, in its sole discretion, stop trading certain symbols from time to time for, among other reasons, the purpose of remaining below the volume thresholds for (i) classification as an "SCI Entity" under Regulation SCI and (ii) certain regulatory requirements as set forth in Rules 301(b)(3) and (5) of Regulation ATS. Admiral can systematically pause or block trading in one or more NMS Stocks or the entire ATS due to regulatory compliance reasons or technical issues specific to Admiral. Regulatory conditions that trigger an automatic pause include: (1) a regulatory trading halt (e.g., a halt due to volatility or news pending) or pause in trading at the primary listing exchange (e.g., market-wide circuit breaker); and (2) stock quoting in a Limit Up / Limit Down straddle state. All orders matched before the start of a stoppage will be executed and settled. Information regarding regulatory halts and pauses on the primary listing exchanges reach Admiral via the SIP feed. When a pause is initiated no new orders are accepted. By default, the System will auto-resume all orders after the pause ends, but a Subscriber will be able to manually cancel any order upon occurrence of the pause. A block initiated by Admiral support personnel would occur if a technical issue cannot be completely resolved in a timely manner as determined by the COO or CCO. When a block is initiated, all open orders are cancelled and no new orders are accepted. Admiral support personnel may also initiate a pause or block in trading due to (a) slowness or disruption in market data; (b) a disruption FIX connectivity; or (c) a disruption in connectivity to Admiral's primary and backup Trade Reporting Facilities. Admiral support personnel monitor and resolve technical conditions in real time and exercise discretion over whether to initiate a pause or block based on their assessment of the severity of the issue. For example, a temporary disruption in FIX connectivity would likely result in a pause, while a sustained FIX connectivity outage would result in a block. Admiral blocks trading in a stock on the Admiral ATS if the ATS has executed 5% or more of market volume in the stock for three of the preceding five calendar months or 1% of the average daily volume of all NMS stocks. Each month, prior to the commencement of trading on the 1st day of the month for three of the preceding five calendar months, Admiral's COO reviews a report of all stocks where the Admiral ATS has traded 5% or more of market volume in the stock for three of the preceding five months and implement a block on trading those stocks for the current calendar month. Admiral pauses trading on a security between its ex-dividend date and record date. Any resting orders that are set to expire between the ex-dividend and record date are cancelled at the time the pause begins. The occurrence of a trading pause or block will be communicated to subscribers via FIX messaging. Any orders sent during a pause or block will be rejected, with the reason for the rejection communicated in the return message (ExecutionReport). Y Admiral reports its transactions immediately upon execution to the FINRA/Nasdaq Carteret Trade Reporting Facility ("Carteret TRF"). In the event that the Carteret TRF is unavailable, Admiral reports its transactions to the FINRA/Nasdaq Chicago TRF ("Chicago TRF"). All trade reports will indicate that trade was under cash settlement (".C"). Y Admiral's clearing broker is Vision. Upon the match of a buy and sell order (i.e., the execution of a trade) on the Admiral ATS, Admiral electronically transmits the details of the transaction to Vision, and sends trade confirmations to the parties to the trade. As discussed in Part III, Item 7, Subscribers are responsible for ensuring that orders sent to the Admiral ATS can settle on T+0. A subscriber sending orders that cannot settle on T+0 is financially liable to Admiral and Vision for the costs of remediation (e.g. loss in value of position or borrowing costs) and this could also result in a temporary or permanent expulsion from the Admiral ATS. All settlement occurs after the Admiral ATS closes. As a reminder, the Admiral ATS follows the New York Stock Exchange hours of operation. For trades that can settle T+0, Vision will transfer the securities and cash internally on its own books and records, without utilizing the usual central clearing infrastructure (e.g., NSCC/DTC). Trades that cannot settle T+0 will settle the regular way, i.e., T+1. In such cases, clearance and settlement will utilize the usual central clearing infrastructure (e.g., NSCC/DTC). If necessary, Vision will buy-in or sell-out a position, and the debit position with Vision of the subscriber that failed to deliver funds or securities will be increased accordingly. Following a trade, each subscriber broker receives a trade confirmation report from Vision. Vision (and each subscriber) maintains the trade records for compliance and customer statement purposes. Y The ATS receives NBBO data from the Nasdaq SIP feed. Admiral's market data provider is Options Technology. The data is used to ensure that executions do not happen at prices outside the NBBO bounds, as discussed in Part III, Item 11c. Y N N N