Electronic Trading Order Handling and Routing Disclosure

This Electronic Trading Order Handling and Routing Disclosure is intended to provide further information with respect to how the electronic trading desk at BTIG, LLC (“BTIG”) handles and routes electronic orders.  While this disclosure is intended to describe certain aspects of BTIG’s electronic order handling and routing practices, it may not address how all orders are handled.  Customers are encouraged to contact their BTIG sales representative if they have any questions.

BTIG’s algorithms and order handling and routing systems are designed to access internal and/or external sources of liquidity in order to satisfy BTIG’s best execution obligation to its customers.  With respect to its order handling and routing, customers should be aware of the following:

• Upon receipt of a client’s instruction, BTIG’s routing logic will select trading venues by considering certain factors including, but not limited to, whether a specific algorithm has been selected by the client, the urgency of the execution of the order, a venue’s market share and historical fill ratios, historical markouts, the availability of quotes from available liquidity venues and venue fees and rebates.
• BTIG, including through its algorithmic trading strategies, accesses liquidity through both US exchanges and non-exchange liquidity providers including various alternative trading systems and external liquidity providers such as single-dealer platforms, electronic liquidity providers, floor brokers, and inter-dealer brokers.
• BTIG has direct connections to most exchanges and alternative trading systems. BTIG may also use sponsored access lines and various third-party service bureaus and brokers to access trading venues and counterparties.
• BTIG has bilateral arrangements with selected alternative trading system counterparties in which certain BTIG orders will only trade with those counterparties. Customers may request that their orders not be routed to any non-exchange trading venue or counterparty.
• BTIG may execute a customer order by matching the order internally rather than sending the order to an exchange. This is known as internalization and involves crossing the customer order with a principal order or another customer’s order. For example, because BTIG’s internal trading desks also use BTIG algorithms, certain orders from those desks may be principal orders and it is possible that a customer order may cross with the principal order.  Customers may opt out of internalization by contacting their BTIG sales representative.
• BTIG reserves the right to reject or cancel an order at any time and/or unilaterally disable a customer’s access to any non-exchange venue in its sole discretion.
• BTIG uses a combination of direct and Securities Information Processor (“SIP”) market data feeds for routing purposes.
• For options trading, BTIG transmits orders to third-party brokers for execution.
• BTIG routinely reviews order and execution data for business purposes, including performance analysis and calibration of its algorithms
• BTIG “advertises” client electronic trading volume by default. Customers may opt out by contacting their BTIG sales representative.
• While most exchange and alternative trading system rates and fees are published and standard, for both equity and options trading venues and counterparties, BTIG may from time to time negotiate rates.
• Algorithm child orders may incur a venue transaction cost, execute at no cost or receive a rebate and order routing decisions may take into account venue transactions costs. Depending on the fee arrangements agreed upon between the customer and BTIG, a customer may be responsible for some or all transaction costs.
• BTIG does not receive payment for order flow from market makers to which BTIG routes its customer orders in equity securities. When BTIG routes an equity or options order that provides liquidity on an equity or options exchange, BTIG may receive a fee rebate for providing the liquidity, in accordance with the exchange’s published fee schedule approved by the SEC.