Global Execution and Order Placement Disclosure

1. Background

The purpose of this document is to explain BlackRock’s Execution and Order Placement Policy (‘the Policy’), as required under the recast Markets in Financial Instruments Directive 2014/65/EU (MiFID) and Markets in Financial Instruments Regulation EU 600/2014 (MiFIR) (the Directive and Regulation together “MiFID II”) and the UK version of the regulation EU 600/2014, which is part of UK Law by virtue of the European Union (Withdrawal) Act 2018 UK (Onshoring of MiFID II in the UK).

Under such rules, BlackRock is required to take all sufficient steps to obtain the best possible result when executing clients’ orders. This is an obligation referred to as “best execution.”

This Policy sets out how BlackRock complies with its obligation to act in the best interests of its clients when directly executing orders on behalf of clients and additionally when placing orders with entities (such as brokers and dealers) for execution, pursuant to applicable regulation. References in this Policy to the execution of client orders include the execution of clients’ orders, and/or BlackRock’s decisions to execute orders on behalf of its clients.

All terms used in this document are defined in accordance with MiFID II and the Onshoring of MiFID II in the UK. Additionally, a Glossary of key terms can be found in Appendix 1.

2. Scope

This document applies to:

• BlackRock entities regulated by MiFID II and the Onshoring of MiFID II by the United Kingdom which execute client orders, place orders with, or transmit orders to, other entities for execution (listed below).
• BlackRock Investment Management (UK) Limited (“BIM”)
• BlackRock Advisors (UK) Limited (“BAL”)
• BlackRock International Limited (“BIL”)
• BlackRock (Netherlands) B.V. (“BNBV”)
• BlackRock Institutional Trust Company N.A, UK Branch (“BTC”)
• BlackRock Asset Management Deutschland AG (“BAMDE”)
• BlackRock France SAS (“BFS”)
• BlackRock Fund Managers Limited (“BFM”), a UCITS Management Company and Alternative Investment Fund Manager located in the United Kingdom, (only those sections of the policy required by relevant regulation) Orders executed for Professional Clients in relation to financial instruments defined by MiFID II.

3. BlackRock's Trade Execution Model

BlackRock’s trade execution model that involves the centralisation of its trading platform, whereby orders are routed to specialised trading desks. Maintaining a centralized execution model allows BlackRock to create a separation of duties between trading and portfolio management for most trading activity. It also allows BlackRock to seek to optimize trade execution which is beneficial to BlackRock’s clients, through a globally consistent operating model for order communication to facilitate Global Order Routing.

BlackRock’s centralized trading desks are separate from BlackRock’s portfolio management function, with certain exceptions due to the uniqueness of particular investment strategies and financial instruments and are operated by BlackRock regulated entities in each jurisdiction.

Dealing desks outside the European Economic Area (the “EEA”) and the United Kingdom follow similar policies, processes and procedures. However, the counterparties and trading methods used may vary from those used in the EEA and the United Kingdom given country specific practices.

BlackRock may match and cross orders received in opposite directions in the same financial instrument where permitted by applicable laws, regulations, and client agreements, and when BlackRock believes this is in the best interest of both clients. When this occurs, it is done in accordance with BlackRock's Global Crossing Policy and related procedures, which set out provisions and controls designed to manage potential conflicts of interests between clients participating in such cross trades. In the EEA and the United Kingdom, BlackRock typically identifies a crossing opportunity and executes the cross trade on a trading venue which facilitates that type of trade.

4. Order Handling Protocol

BlackRock takes all sufficient steps to obtain the best possible result for its clients. Subject to the best interests of the client and instructions of the portfolio manager (“PM”), BlackRock must handle otherwise comparable orders for client accounts in the order in which they are received to provide fair and expeditious execution of all client orders.

Subject to local regulatory requirements, and consistent with BlackRock’s duty to seek best execution, BlackRock may find it efficient and beneficial to aggregate contemporaneous orders for multiple clients. BlackRock’s Global Investment and Trading Allocation Policy sets out how BlackRock handles the aggregation of client orders and the fair allocation of financial instruments executed as part of an aggregated order over time.

5. Brokers/Counterparties & Execution Venues

In seeking best execution for its clients, BlackRock may use a variety of execution venues and methods including, but not limited to, brokers acting in an agency or principal capacity, block dealing, Request for Quote (“RFQ”) platforms, swap execution facilities, and sponsored access to the order books of major execution venues).

BlackRock will either:

1. Execute an order for a client on an execution venue, or with brokers acting as market makers, liquidity providers or in a principal capacity, or
2. Place orders with brokers for them to execute on the execution venue. 

A current list of Execution Venues and brokers used by BlackRock can be found in Appendix 2. This list is subject to change and may be revised from time to time.

With our clients’ consent and unless there is a regulatory obligation to trade certain financial instruments on Trading Venues, we may execute trades in financial instruments traded on Trading Venues outside such venues. This enables us to access a wider range of sources of liquidity and it is particularly desirable when trading illiquid financial instruments and/or large sizes, where we would likely aim to minimize the risk of information leakage or signalling to the market, to avoid a poor execution outcome. In these cases, we may find it more desirable to trade with a broker acting as a systematic internaliser or in a principal capacity.

Although there are benefits to executing trades outside of a trading venue, it should be noted that there is a risk that a broker will fail to meet its obligations in relation to the transaction (‘Counterparty Risk’). While contractual remedies would be available in these circumstances, protections which may be available when trading on venues (such as buy-in procedures) may not be available. Clients can request additional information from BlackRock about the consequences of transactions being executed outside a Trading Venue.

6. Broker/Counterparty Approval Process

All prospective and existing counterparties require the approval of BlackRock’s Counterparty Risk Group (“CRG”), which operates under BlackRock’s independent risk management function, Risk & Quantitative Analysis Department (“RQA”).

The CRG is independent from the trading and investment functions, and is responsible for developing, implementing and updating, firmwide counterparty credit policies and procedures (collectively the “Counterparty Credit Risk Policy”) that are designed to identify and evaluate counterparty credit risks and establish appropriate practices to manage these risks. All employees responsible for trade execution are required to comply with the Counterparty Credit Risk Policy.

The Global Trading and Investment Teams are required to submit all prospective trading counterparty requests to the CRG for an independence credit assessment. These views are undertaken at the legal entity level and consider the intrinsic credit quality of the trading counterparty, together with the expected transaction activities.

7. Ongoing Monitoring of Brokers/Counterparties

The CRG maintains a list of approved trading counterparties and reviews the list on an on-going basis via a number of sources including but not limited to audited and interim financial reports, rating agency reports and bulletins where available, various databases and news media and, if covered, output from the BlackRock Credit Research Group. All trading counterparties undergo a cyclical formal review and renewal on a 12 to 18-month basis, which is documented in a form established and/or agreed by the Chief Counterparty Credit Officer. Additional interim trading counterparty reviews may be completed in accordance with local regulatory requirements. Periodic updates are presented to the relevant best execution governance forums on counterparty risk matters, as appropriate.

8. Best Execution Obligation and Relevant Factors

BlackRock performs its best execution obligation to take all sufficient steps to obtain consistently over time the best possible results for our clients when executing or placing, or transmitting, client orders by assessing the relative weight and importance of various execution factors and other relevant considerations under the particular circumstances.

A. Execution Factors

BlackRock may consider any one or more of the following execution factors, as relevant:

• price of the relevant financial instrument net of brokers’ commissions, Execution Venues’ fees and other applicable execution costs;
• costs incurred in execution of the transaction;
• speed of execution;
• likelihood of execution and settlement;
• market conditions
• instrument liquidity
• size of the order;
• nature of the order; and
• any other relevant factors.

The relative importance of the execution factors for individual orders varies depending on the characteristics of the order, the financial instrument, the Execution Venues available for execution or placement of that order and the specific market conditions at the time of the trade, such as signals (e.g., indications of interest or axes) about the availability of natural liquidity.

B. Execution Factors and Characteristics of the Order

When generating an order, BlackRock’s PMs specify instructions relating to the strategy they are pursuing on behalf of clients and for the nature of the order that they are generating. For example, their instructions may vary depending on whether the order was driven by cash inflows or outflows or by changes in the PM’s view regarding a particular investment or type of exposure. Such instructions help influence the prioritization of the execution factors by BlackRock’s traders. The instructions of PMs typically fall into one of the following categories:

Forward Benchmarks

These orders target execution at a price specified by reference to a point in time in the future (such as “market on close” for stocks or WMR Benchmark Rate for currencies) when the calculation of the price will take place, often by way of an auction mechanism.

This type of benchmark is widely used by index sponsors for index calculation and it is also generally used by managers when executing orders for passive strategies in order to minimize their tracking error. Trading is typically concentrated around the specified future point in time, unless a trader believes there will be insufficient liquidity in the auction or at the close of the market; in such cases a trader may extend the trading window to execute outside of the auction while still seeking to manage tracking error appropriately.

Market-on-close orders typically prioritize the execution factors of likelihood and speed of execution at the required time.

Explicit Price Benchmarks

These orders (such as limit or stop orders) specify a price point at which (or at a more advantageous price than which) to buy or sell the relevant amount of a financial instrument. An explicit price benchmark can be used by active investment strategies to help mitigate total expenses. It can also be used by passive strategies, which, for similar reasons, may choose to participate in end-of-day auctions subject to a limit.

Explicit price benchmarks orders inherently prioritise price as the primary execution factor for consideration. If the explicit price benchmark can be satisfied for the order, a trader may prioritise additional execution factors that will most likely lead to complete execution of the order based on prevailing market conditions.

Best Efforts Benchmarks

For orders that are made available to trade immediately, with benchmarks such as arrival price, price at the time of execution or market price at the point in time when the PM assigns the order to the trading desk, are used where available and unless otherwise specified.

PMs may assign a higher degree of importance to one factor over another. For example, for orders where fulfilment of the entire trade is of highest importance, the likelihood of execution is prioritized. This is more often the case when executing orders for active strategies when the PM has a particularly strong view (whether as a result of fundamental analysis or strong quantitative signals) and tends to be less price sensitive to achieve fast execution.

Where the trader has full discretion in the execution of the order, all execution factors are considered and prioritization varies depending on prevailing market conditions, with total consideration and likelihood of execution typically having higher importance. 

Contingent Orders

Contingent orders consider the interdependency of two or more financial instruments on one another, such as the roll of futures contracts or the hedging of a credit instrument. In these cases, it is the collective benchmark of the package that drives the execution factors for consideration, rather than the application of the execution factors to the individual financial instruments that form part of the package or contingent order.

Similarly, traders may also need to consider the impact an order imparts on the overall investment outcome. For example, the execution of an order, which is part of larger basket of orders, may result in a particular investment outcome in the absence of the other orders in the basket also being executed. In such a situation, the calibration of execution timing with regard to the other orders that form the larger basket of orders may drive the consideration of execution factors, so as to minimize or eliminate unwanted market exposure. Further, investment objectives and constraints may limit PMs’ and traders’ ability to prioritise the execution factors.

C. Execution Factors and Characteristics of Financial Instruments

The hierarchy of execution factors that is expressed by a particular type of instruction is complemented by consideration of the characteristics of the financial instrument, as well as consideration of the size of the order, the market conditions at the time of execution of the order, and other relevant facts and circumstances, such that the execution strategy employed for a particular order may differ significantly from executions effected in the same class of financial instruments (and even in the same security) but for different trade sizes and/or in different market conditions at the time of execution.

Listed Financial Instruments

Financial instruments listed on or executed on regulated markets or execution venues that display bids and offers, including both securities and listed derivatives, are typically subject to a high degree of price transparency, which typically limits the need for extensive price discovery. This allows traders to focus more on the execution mechanisms that are available from brokers and whether they can easily facilitate prompt execution while mitigating the impact on the market.

When the order size is considered large relative to the average daily trading volume of the relevant financial instrument, traders will have to manage the risk of signalling to the market the existence of a large trading interest to avoid the potential detrimental impact that this may have on the execution price. Traders may therefore prioritize the use of block trading channels that manage large order sizes.

For illiquid financial instruments (or financial instruments for which liquidity is not concentrated on regulated markets or venues that display bid and offers), the need for price discovery is evaluated against the risk that information leakage might impact the overall execution outcome negatively, which may result in traders requesting quotes from market participants known to offer liquidity in the specific financial instrument to be traded.

Over the Counter (‘OTC’) Financial Instruments

OTC financial instruments that trade in a decentralized market, including both unlisted securities and OTC derivatives, have varying degrees of price transparency. For liquid financial instruments within a reasonable range of tradeable market sizes, traders prioritize trading venues that facilitate price discovery through requests for quotes from multiple market participants. Alternatively, traders may rely on the pricing information contained in alternative pricing sources when selecting a single broker to request a quote for the relevant financial instrument.

For less liquid financial instruments or when the order size is considered large, traders may choose their counterparty based on its perceived ability to reduce the market impact of the execution.

For the execution of trades in illiquid financial instruments, brokers who trade in the same securities or securities with similar characteristics may be prioritized.

For more complex OTC products, where prices are not directly observable (e.g. convertible bonds or option packages), traders use available internal and external data or tools to assess the fairness of price, and the expected cost of trading, as accurately as possible under such circumstances.

D. Application of Execution Factors to Individual Classes of Financial Instruments

Listed Financial Instruments and Contracts for Difference

• Shares & Depositary Receipts
• Exchange Traded Products (Exchange Traded Funds, Exchange Traded Notes and Exchange Traded Commodities) (“ETP”)
• Contracts For Difference
• Securitized Derivatives – Listed Warrants & Certificates

In addition to best execution, all general Portfolio Management (“PM”) instructions and considerations based on the nature of the order apply to trades in listed instruments.

Orders for listed instruments with forward benchmarks are typically executed in the closing auction for markets where such a mechanism exists. If there is not sufficient liquidity in the auction, then trading might also take place earlier or later to mitigate market impact.

For orders with a best-efforts benchmark, BlackRock typically choose an execution method most suitable for balancing price and likelihood of execution. 

Where the size of an order is significant relative to available liquidity in the secondary market, traders may prioritize execution channels which provide supplemental or surrogate sources of liquidity, such as broker capital or primary ETP markets.

Listed Futures and Options

• Interest Rate Derivatives – Listed Futures & Options
• Credit Derivatives – Listed Futures & Options
• Equity Derivatives – Listed Futures & Options
• Commodities Derivatives – Listed Futures & Options

In addition to best execution, all general PM instructions and considerations based on the nature of the order apply to trades in futures and listed options. 

Orders for listed instruments with forward benchmarks are typically executed in the closing auction for markets where such a mechanism exists. If there is not sufficient liquidity in the auction, then trading might also take place earlier or later to mitigate market impact.

For orders with a best-efforts benchmark, BlackRock typically choose an execution method most suitable for balancing price and likelihood of execution. 

Where the size of an order is significant relative to available liquidity in the secondary market, traders may prioritize execution channels which provide supplemental or surrogate sources of liquidity, such as broker capital markets.

For liquid options within a reasonable range of tradeable market sizes, traders will prioritize trading platforms that facilitate price discovery through requests for quotes from multiple market participants.

Debt Instruments

• Bonds
• Structured Finance Instruments

While some debt instruments are listed, they are commonly traded in a decentralized OTC manner.

All general PM instructions and considerations based on the nature of the order apply to trades in debt instruments.

Orders for debt instruments with forward benchmarks typically are executed around the point in time specified by the PM, since there is not an official closing auction in these markets. If sufficient liquidity is not available at that time, then trading might also take place earlier or later to mitigate market impact.

For orders with a best-efforts benchmark, BlackRock applies a variety of execution methods most suitable for balancing price and the impact of order size on transaction costs.

Money Market Instruments

The execution factors and criteria that BlackRock considers for money market instruments reflect the nature of these orders. Similar to the general considerations, the orders are primarily characterized by PM motivation.

For overnight funding transactions, such as time deposits, completion of the order is of highest importance. As such, likelihood of execution is prioritized, with consideration given to the number of available counterparties and capacity.

For orders where completion is at the trader’s discretion, price and the impact of order size on transaction costs are considered. (See Best Efforts Benchmarks)

OTC Derivatives

• OTC Derivatives
• Equity Derivatives
• Credit Derivatives
• Interest Rate Derivatives
• Currency Derivatives
• Commodity Derivatives
• Securitized Derivatives

While most derivative instruments are primarily traded in a decentralized OTC manner, some products may be to traded on a centralised trading venue.

In addition to best execution, all general PM instructions and considerations based on the nature of the order apply to trades in derivative instruments.

Orders for derivative instruments with forward benchmarks are typically executed at a point in time specified by the PM, because there is not an official closing mechanism in these markets. If sufficient liquidity is not available, then trading might also take place earlier or later to mitigate market impact.

For orders with a best-efforts benchmark, BlackRock applies a variety of execution methods suitable for balancing price and the impact of order size on transaction costs. Further, due to the OTC nature of these instruments, there is a varying degree of price transparency, so traders also need to reduce information leakage, signalling and market impact.

Different regulations could mandate that some of these instruments are required to be executed on a centralised traded on venue. Instruments that have a mandatory clearing mandate are centrally cleared with a central counterparty.

Other Structured Financial Instruments
From time to time, BlackRock may decide to enter into bespoke structured transactions. When it does so, it seeks to gather structuring proposals and pricing from one or more brokers, depending on their expertise and subject to BlackRock’s requirement to diversify its counterparty exposure. Typically, such transactions comprise different components and, to satisfy itself on the fairness of the price proposed by the counterparty, BlackRock may request quotes from more than one counterparty before entering into the transaction or, alternatively, may break the transactions down into their individual components and analyse the implied pricing of each component based on historical data.

Securities Finance Transactions

• Securities Lending
• Repurchase Agreements
• Physical & Synthetic Securities Financing

For securities finance transactions including securities lending, repurchase agreements and physical/synthetic financing, the execution factors and criteria that BlackRock considers include the supply and demand characteristics for the securities in question and additional considerations such as:

• current market pricing to lend or finance the specific security
• price discovery will follow a similar process to other OTC markets in that traders will prioritize Trading Venues that facilitate ‘requests for price and capacity’ from multiple market participants
• liquidity of the lending, financing and cash market for the relevant security
• current utilisation/availability of the security and the size of supply or demand relative to the lending or financing market will be considered when determining the likelihood of execution
• overall utilization of a broker’s balance sheet; and
• other factors that may include, but are not limited to:
  
  • collateral type proposed (e.g., cash or non-cash)
  • proposed duration of the securities finance transaction
  • transaction costs levied by providers such as custodians, triparty banks, or broker; and
  • specific or idiosyncratic factors (e.g., a pending corporate action, or expected stability of financing).

9. Broker/Counterparty & Execution Venue Selection

General Considerations

After prioritizing the execution factors based on the characteristics of the order and the financial instruments, if BlackRock has a choice of a number of brokers or Execution Venues that could equally fulfil a given order, it selects the individual broker or Execution Venue by considering further qualitative and quantitative factors. These further factors are often specific to individual financial instruments or classes of financial instruments as the applicable market structure determines the instrument’s liquidity. These additional factors include, but are not limited to:

• trade confirmation and settlement capabilities
• ability to avoid information leakage
• breadth of liquidity access across markets, currencies and products
• execution quality
• operational resilience and responsiveness to errors
• pre- and post-trade execution insights
• personnel coverage of the venue or broker
• product offering and customizations
• research provided, where permitted under applicable regulation
• liquidity sourcing capabilities (such as the ability to source natural liquidity)
• willingness to commit capital
• risk concentration

Further Considerations, by Instrument, in the Selection of Execution Venues

Listed Instruments

Listed financial instruments that trade on an exchange may also be traded electronically. Specific factors for consideration of Execution Venue selection may include:

• types, quality and breadth of brokers’ traded financial instruments and functionalities
• quality of execution measured against benchmark exchange prices
• availability of algorithms and ability to adapt products to BlackRock’s workflows
• access to liquidity

OTC Instruments

Venue considerations for OTC instruments vary depending upon overall liquidity and the manner in which they trade:

• for liquid OTC instruments that trade electronically, consideration is given to the type, quality and breadth of Execution Venues; and
• for instruments that do no trade electronically, consideration is given to venue liquidity, coverage of instruments and sectors and competitive quoting

Securities Finance Transactions

• Global Lending, Liquidity, Financing and Balance Sheet transact only with approved counterparties, up to any applicable credit limit determined by Blackrock’s CRG.
• As securities lending does not involve the execution of orders to trade but rather the allocation of loan requests submitted by brokers, BlackRock agrees and settles a requested trade provided the broker has been approved, the value of the proposed transaction does not exceed the aggregate value of loans permitted, and the other execution factor considerations have been met.

Money Market Instruments
Specific factors for consideration of venue selection may include:

• liquidity and availability of instruments offered by the counterparty
• willingness of counterparties to bid back on paper;
• product availability, as some issuers will limit the size of issuances available for certain maturities.

Availability of venues which may be limited by the issuer in certain instances, such as asset backed commercial paper. Where certain financial instruments are only available directly from the issuer or a small group of brokers, this informs the selection of the Execution Venue.

10. Prohibited Considerations in Selecting Broker/Counterparties & Execution Venues

BlackRock employees are prohibited from considering the following factors when selecting a broker or Execution Venue:

• a counterparty’s placement of, or purchase of, any BlackRock products or BlackRock managed funds;
• any personal relationships, including former employment relationships;
• any personal benefit for any person associated with the employee, including but not limited to members of the employee’s family or household in addition to close associates and significant others;
• any gifts or entertainment received;
• a broker-dealer’s historical initial public offering or new issue allocations to BlackRock;
• a broker-dealer’s willingness to accommodate BlackRock’s trading errors.

11. Services and Benefits Received from Execution Venues

BlackRock from time to time may receive the following services and/or benefits from brokers and Execution Venues:

• information or documentation relating to financial instruments or investment services that is generic in nature or personalized to reflect BlackRock’s circumstances;
• issuer commissioned research coverage;
• participation in conferences, seminars or trading events on the benefits and features of specific financial instruments or investment services;
• hospitality of de minimis value during meetings or those events specified in clause iii above;
• connected research on an issuer in the context of an issuer capital raising;
• research provided for a trial period; and
• such other services and/or benefits that can be considered minor non-monetary benefits under Applicable Law from time to time.

12. Receiving a Specific Client Instruction

In instances where a client has provided a specific order instruction, BlackRock will be deemed to have complied with its best execution obligation for the specific part of the trade to which the instruction relates. However, BlackRock will continue to apply this Policy to those aspects of the order not covered by the specific instruction.

13. Directed Brokerage

From time to time, a client may instruct BlackRock to execute its trades with a particular counterparty or venue or otherwise place limitations on BlackRock’s discretion to determine counterparty, venue or commission. Directed brokerage arrangements are typically documented in a client’s Investment Management Agreement with BlackRock, or a side letter. Subject to applicable regional regulations, such arrangements may involve the receipt of brokerage commissions from the client transactions in exchange for the provision of services directly to the client or the payment of certain expenses on behalf of the client. The execution timing, levels and/or trading costs may be compromised when entering into directed brokerage arrangements.

Alternatively, a client may direct BlackRock to execute a certain proportion of their overall trading to a broker that meets specific criteria set by the client (e.g., an emerging broker). BlackRock traders use their judgment to decide which trades to execute with such directed brokers and balance a client’s directed brokerage requirements with trying to obtain the best overall result for the client.

Implications on Commission Rates.
In directed brokerage arrangements, BlackRock may not be able to freely negotiate commission rates or spreads, obtain volume discounts on aggregated orders or select counterparties on the basis of best price and execution. As a result, directed brokerage transactions may result in higher commissions, greater spreads, or less favourable execution, than would normally be the case if BlackRock were able to choose the broker.

In certain instances where BlackRock is instructed by a client to execute transactions with a specific broker or dealer, BlackRock may “step out” part of an aggregated order in order to have the directed broker or dealer clear and settle that portion of the trade.

14. Monitoring

BlackRock performs multiple types of monitoring to help ensure its order execution arrangements remain suitable for the purpose of seeking to deliver the best client outcomes. Some aspects of monitoring include transaction cost analysis (TCA), senior management oversight in governance committees (Trading Oversight Committees) and compliance and risk monitoring activities. The specific scope and content of monitoring may vary depending on the data that is available, for the relevant asset class, in the market. As new data sources and pricing models become available, they are assessed for potential inclusion in our monitoring.

Transaction Cost Analytics (TCA)

BlackRock utilizes in-house TCA systems, to assess whether trading costs are in line with BlackRock’s expectations.

BlackRock’s TCA platform quantifies the full cost of trading, which includes cost contributions from commissions, spreads, market impact, and the opportunity costs that arise from not executing a trade. The total impact from order handling and routing decisions is captured by these measures. Transactions are evaluated against a range of pre-trade, intra-day, and post-trade benchmarks to holistically assess trading performance against the market context. Trading results can be examined in a TCA tool taking into account a broad array of attributes, such as by counterparty, trader, benchmark, or market, allowing for a focused evaluation of each category.

Governance
BlackRock performs reviews of its trading activity in regular Trading Oversight Committees which review execution quality, the effectiveness of execution arrangements and the effectiveness of this Policy. The Trading Oversight committees are also charged with making enhancements to BlackRock’s execution arrangements and this Policy, where deemed appropriate. The oversight committees are global in nature and cover all asset classes. Trading, Investments, Risk, and Legal & Compliance are represented on each Committee.

Compliance Monitoring
The Global Trade Surveillance and Forensic Testing team, within Legal & Compliance, is responsible for post trade, second line monitoring. The team conducts ongoing, routine, sample based and risk-based tests for adherence to the Policy, currently with a focus on pricing, timeliness of execution and broker selection criteria. Any deficiencies identified are escalated to the relevant Trading Oversight Committee.

In addition, Compliance may undertake reviews from time to time (as deemed necessary) aimed at testing/monitoring best execution related controls effectiveness, design and governance framework.

RQA Oversight

RQA meets regularly with each trading business line to review and examine outlier patterns. The key objectives are to evaluate that Trading decisions over time appear consistent with meeting the firm’s best execution, and ensuring adequate records are kept when point-in-time analysis is undertaken on outlier trades.

15. Periodic Review of the Policy and Order Execution Arrangements

BlackRock is required, under applicable regulations, to review this Policy and its order execution arrangements at least on an annual basis for its adequacy and the effectiveness of implementation. It is also required to review this policy whenever a material change occurs that affects BlackRock’s ability to continue to obtain the best possible result for its clients. 

A material change means a significant event of an internal or external nature, that could materially impact the relevant best execution factors listed in this Policy or the execution venues or entities to which BlackRock transmits client orders for execution, on which BlackRock places significant reliance in meeting its overarching best execution requirement. Any of the following events may, but will not necessarily in all circumstances, amount to such a material change: regulatory changes that materially alter the market structure for certain classes of financial instruments or that otherwise require changes to BlackRock’s arrangements and processes; BlackRock’s observation of a significant and consistent deterioration in the liquidity offered and in the quality of execution achieved on a trading venue or from a broker or dealer.

As part of Global Trading and RQA’s continuous framework for evaluating execution quality and governance, along with oversight processes related to monitoring best execution, on an ongoing basis, BlackRock will consider whether it could consistently obtain better execution results if it were to:

• include additional or different Execution Venues or entities;
• remove any existing Execution Venues or entities;
• assign a different relative importance to the best execution factors;
• or modify any other aspects of this Policy and/or execution arrangements.

The effectiveness of BlackRock’s order execution arrangements is tested and monitored by Global Trading and any identified deficiencies are escalated to the relevant Oversight Committees. As new data sources and pricing models become available, they are assessed for potential inclusion in our monitoring. BlackRock tests both the effectiveness of the execution venues that it selects when executing client orders and the execution quality of the entities where it places orders for clients.

16. Conflicts of Interest

BlackRock’s Global Conflicts of Interest Policy (the “Conflicts Policy”) governs BlackRock’s responsibility to place its clients’ interests first and identify and manage any conflicts of interest inherent to BlackRock’s business. The Conflicts Policy requires that BlackRock employees report any actual or potential conflicts of interest to their supervisor and to Legal & Compliance. Amongst other things the Conflicts Policy also requires employees to act solely in the best interests of clients and avoid or otherwise mitigate conflicts of interest, which may involve curtailing or terminating an activity or seeking client consent.

17. Information Provided to Clients

In accordance with relevant regulatory requirements, BlackRock is required to disclose certain information to clients regarding this Policy, including appropriate information about BlackRock and its services, and in some jurisdictions, additional information about the consequences of executing outside a trading venue and the entities chosen for execution.

In addition, in certain jurisdictions BlackRock has an obligation to publish on a website annual reports on the quality of execution attained for 22 classes of financial instruments (as of 30 April 2022), separating reports for:

1. Trades executed by BlackRock
2. Orders placed by BlackRock with third parties for execution and
3. Trades in securities financing transactions

Additionally, in certain jurisdictions BlackRock will summarize and make public on our website on an annual basis for each class of financial instrument in which we execute orders for, or on behalf of clients, the following information:

• The top five Execution Venues (in terms of trading volumes) where we executed client orders in the preceding year; and the quality of execution obtained; and
• The top five entities (in terms of trading volumes) where we placed, or transmitted, client order for execution; and the quality of execution obtained

---

Appendix 1 – Glossary of Terms 

Bid/Ask Spread	The difference between the market price quotations, for buying and for selling particular securities.
Directed Brokerage	The process whereby a client directs a manager to place trades for his account through a specific broker, in exchange for which the client will receive a rebate of a portion of the total commission in addition to execution services. The arrangement can be managed by a third party, such as an investment consultant, or managed by the client’s investment manager.
Crossing Network	An electronic execution venue that enables the matching of orders directly between buyers and sellers. Commissions are typically lower while market impact and bid/ask spreads are removed altogether. Liquidity is often a constraint to order completion.
Direct Market Access (“DMA”)	Direct access to the market floor by managers who wish to deal anonymously in the market, without the use of execution services provided by a broker.
Electronic Communication Network (“ECNs”)	An electronic system that connects major brokerages and individual traders so that they can trade financial products outside of stock exchanges, directly between themselves. The primary products that are traded on ECNs are stocks and currencies.
Execution Services	Those services related to trade execution that meet the criteria laid down by the FCA for payment out of commission.
Execution Venue	A Regulated Market, a Multilateral Trading Facility (MTF), an organized Trading Facility (OTF), a Systematic Internaliser, or a Market Maker or other Liquidity Provider or an entity that performs a similar function in a third country to the functions performed by any of the foregoing.
Liquidity	The degree to which an asset or security can be bought or sold in the market without affecting the asset's price. Liquidity is characterized by a high level of trading activity. 2) The ability to convert an asset to cash quickly. Investing in illiquid assets is riskier because there might not be a way for you to get your money out of the investment. Examples of assets with good liquidity include blue chip common stock and those assets in the money market. A fund with good liquidity would be characterized by having enough units outstanding to allow large transactions without a substantial change in price.
Market Impact	The effect a market participant has when it buys or sells an asset and the extent to which the buy or sell moves the price against the buyer or seller.
Market Maker	A person who holds himself out on the financial markets on continuous basis as being willing to deal on own account by buying and selling financial instruments against the person’s proprietary capital at prices defined by that person.
Multilateral System	Any system or facility in which multiple third-party buying and selling trading interests in financial instruments are able to interact in the system.
Multilateral Trading Facility (MTF)	A multilateral system, operated by an investment firm or a market operator, which brings together multiple third-party buying and selling interests in financial instruments – in the system and in accordance with non-discretionary rules – in a way that results in a contract in accordance with Title II of MIFID II.
Organized Trading Facility	A multilateral system which is not a regulated market or an MTF and in which multiple third-party buying and selling interests in bonds, structured finance products, emission allowances or derivatives are able to interact in the system in a way that results in a contract in accordance with Title II of MIFID II.
Other Liquidity Provider	A firm that holds themselves out as being willing to deal on own account, and which provides liquidity as part of their normal business activity, whether or not they have formal agreements in place or commit to providing liquidity on a continuous basis
Onshoring of MiFID II	Statutory Instrument No 2018/1403 The Markets in Financial Instruments (Amendment) (EU Exit) Regulations 2018 makes amendments to MiFIR, the tertiary legislation made under MiFID II and the UK legislation which implemented MiFID.
Programme Trades	Trades for a basket of securities placed through a single broker and priced as a portfolio and not by reference to the individual constituents of the basked.
Professional Client	A client who possesses the experience, knowledge and expertise to make its own investment decisions and properly assess the risks that it incurs. A client meeting the criteria laid out in Annex II of MIFID II is considered to be a Professional Client.
Regulated Market	A multilateral system operated and/or managed by a market operator, which brings together or facilitates the bringing together of multiple third-party buying and selling interests in financial instruments – in the system and in accordance with its non-discretionary rules – in a way that results in a contract, in respect of the financial instruments admitted to trading under its rules and/or systems, and which is authorised and functions regularly and in accordance with Title III of MIFID II.
Securities Lending	The process by which securities are transferred to a counterparty, subject to an obligation for return of the equivalent securities at a future date. The lender is remunerated by way of a fee.
Systematic Internaliser	An investment firm which, on an organized, frequent systematic and substantial basis, deals on own account when executing client orders outside a regulated market, an MTF or an OTF without operating a multilateral system.
Trading Venue	A regulated market, an MTF or an OTF. After the Transition Period ends, UK trading venues will become third-country trading venues. Similarly, EEA venues will become third-country venues under UK law.
Volatility	The relative rate at which the price of a security or fund moves up and down. Volatility is found by calculating the annualised standard deviation of daily change in price. If the price of a stock moves up and down rapidly over short time periods, it has high volatility. If the price almost never changes, it has low volatility.

 

Appendix 2 – Execution Venues and Brokers (as of 1 July 2023)

This list is subject to change and may vary from time to time. Arrangements may vary depending on contractual arrangements with clients.

EQUITIES - Shares & Depositary Receipts

ABG SUNDAL COLLIER ASA
ARDEN PARTNERS PLC
AXIS CAPITAL LTD
B. RILEY SECURITIES, INC.
BANCO SANTANDER (BRASIL) S.A.
BANCO SANTANDER CHILE S.A.
BANK OF AMERICA CORP
BANK OF MONTREAL
BARCLAYS CAPITAL INC.
BARCLAYS CAPITAL SECURITIES LTD
BARCLAYS PLC
BARRENJOEY MARKETS PTY LIMITED
BELL POTTER SECURITIES LIMITED
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
BRADESCO SECURITIES INC
BTG PACTUAL US CAPITAL, LLC
BTIG LIMITED
BTIG, LLC
CABRERA CAPITAL MARKETS LLC
CANACCORD GENUITY (AUSTRALIA) LTD
CANACCORD GENUITY CORP.
CANACCORD GENUITY GROUP INC
CANACCORD GENUITY LIMITED
CANACCORD GENUITY LLC
CANADIAN IMPERIAL BANK OF COMMERCE
CANTOR FITZGERALD & COMPANY
CANTOR FITZGERALD EUROPE
CANTOR FITZGERALD L.P.
CARNEGIE INVESTMENT BANK AB
CASA DE BOLSA CREDIT SUISSE MEXICO
CASA DE BOLSA FINAMEX SAB DE CV
CASA DE BOLSA SANTANDER SA
CASTLEOAK SECURITIES, L.P.
CENKOS SECURITIES PLC
CGS-CIMB SECURITIES (SINGAPORE) PTE
CHINA INTL CAPITAL CORPORATION
CIBC WORLD MARKETS CORP.
CITADEL SECURITIES LLC
CITIBANAMEX CASA DE BOLSA SA DE CV CASA 
DE BOLSA INTEGRANTE DEL GRUPO FINANCIERO
CITIC SECURITIES COMPANY LIMITED
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS JAPAN INC
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP GLOBAL MARKETS TAIWAN 
SECURITIES CO LTD
CITIGROUP INC
CLSA LIMITED
CORMARK SECURITIES
COWEN & COMPANY LLC
COWEN EXECUTION SERVICES LIMITED
COWEN INC
CRAIGS INVESTMENT PARTNERS LTD
CREDIT SUISSE AG, TAIPEI SECURITIES
CREDIT SUISSE GROUP AG
CREDIT SUISSE INTERNATIONAL
CREDIT SUISSE SECURITIES (USA) LLC
DAIWA CAPITAL MARKETS EUROPE LTD
DANSKE BANK A/S
DBS GROUP HOLDINGS LTD
DESJARDINS SECURITIES INC
DNB BANK ASA
DREXEL HAMILTON LLC
EDELWEISS SECURITIES LIMITED
EFG HERMES HOLDINGS SAE
EUROZ HARTLEYS GROUP LTD
EUROZ HARTLEYS LTD
EVANS AND PARTNERS PTY LTD
EVERCORE GROUP LLC
EXANE S.A.
FIDELITY CAPITAL MARKETS, DIV. OF NFSC
FINANCIAL BROKERAGE GROUP S.A.E.
FINNCAP LTD
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS GROUP INC/THE
GOLDMAN SACHS INTERNATIONAL
GOODBODY STOCKBROKERS
GREAT PACIFIC SECURITIES
GUZMAN & COMPANY
HAITONG INTERNATIONAL SECURITIES CO LTD
HONGKONG AND SHANGHAI BANKING 
CORPORATION LTD
HSBC BANK PLC
HSBC HOLDINGS PLC
HSBC SECURITIES (TAIWAN) CO., LTD.
HSBC SECURITIES (USA) INC
ICAP SECURITIES LIMITED
ICICI SECURITIES LIMITED
IIFL SECURITIES LIMITED
INSTINET EUROPE LIMITED
INSTINET LLC
INVESTEC BANK PLC
INVESTEC PLC
ITAU BBA USA SECURITIES, INC.
J & E DAVY
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES (TAIWAN) LTD.
JANE STREET CAPITAL, LLC
JANE STREET EXECUTION SERVICES, LLC
JANNEY MONTGOMERY SCOTT LLC
JARDEN SECURITIES LTD
JEFFERIES FINANCIAL GROUP INC
JEFFERIES INTERNATIONAL LIMITED
JEFFERIES LLC
JOH. BERENBERG, GOSSLER & CO. KG
JONESTRADING INSTITUTIONAL SERVICES
JP MORGAN CASA DE BOLSA SA DE CV JP 
MORGAN GRUPO FINANCIERO
JP MORGAN SECURITIES PLC
JPMORGAN CHASE & CO
KBC SECURITIES NV
KEPLER CHEUVREUX S.A.
KEYBANC CAPITAL MARKETS INC.
KOREA INVESTMENT & SECURITIES CO LTD
KOTAK MAH BK
KOTAK SECURITIES LIMITED
LIBERUM CAPITAL LIMITED
LIQUIDNET ASIA LTD
LIQUIDNET EUROPE LIMITED
LIQUIDNET INC
LOOP CAPITAL MARKETS LLC
LUMINEX TRADING & ANALYTICS LLC
MACQUARIE CAPITAL (EUROPE) LIMITED
MACQUARIE CAPITAL (USA) INC.
MACQUARIE GROUP LTD
MERRILL LYNCH INTERNATIONAL
MERRILL LYNCH MEXICO SA DE CV CASA 
DE BOLSA
MERRILL LYNCH SECURITIES (TAIWAN) LTD
MIB SECURITIES (HONG KONG) LIMITED
MIRAE ASSET SECURITIES CO LTD.
MISCHLER FINANCIAL GROUP, INC.
MITSUBISHI UFJ MORGAN STANLEY SECURITIES CO LTD
MITSUBISHI UFJ FINANCIAL GROUP
MIZUHO FINANCIAL GROUP INC
MIZUHO INTERNATIONAL PLC
MIZUHO SECURITIES USA LLC
MKM PARTNERS LLC
MOELIS AUSTRALIA SECURITIES P/L
MORGAN STANLEY
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
MORGAN STANLEY INDIA COMPANY PRIVATE LIMITED
MORGAN STANLEY MEXICO CASA DE BOLSA
MORGAN STANLEY TAIWAN LIMITED
MORGANS FINANCIAL LTD
MOTILAL OSWAL FINANCIAL SERVICES LTD
NATIONAL BANK FINANCIAL INC.
NOMURA HOLDINGS INC
NOMURA SECURITIES COMPANY LIMITED
NOMURA SECURITIES INTERNATIONAL INC
NORDEA BANK ABP
NORTHERN TRUST SECURITIES LLP
NPLUS1 SINGER CAPITAL MARKETS LIMITED
NUMIS CORPORATION PLC
NUMIS SECURITIES LTD
ODDO BHF SCA
OPPENHEIMER & CO. INC.
ORD MINNETT LIMITED
PANMURE GORDON (UK) LIMITED
PEEL HUNT LLP
PENSERRA SECURITIES LLC
PETRA CAPITAL PTY LTD
PIPER SANDLER & CO.
PIPER SANDLER COMPANIES
RAYMOND JAMES & ASSOCIATES INC
RAYMOND JAMES FINANCIAL INC.
RAYMOND JAMES LTD.
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
REDBURN (EUROPE) LIMITED
ROBERT W BAIRD & CO INC
ROYAL BANK OF CANADA
SAMSUNG SECURITIES CO., LTD
SAMUEL A. RAMIREZ & CO., INC
SANFORD C BERNSTEIN & CO LLC
SANFORD C. BERNSTEIN LIMITED
SANTANDER INVESTMENT SECURITIES INC
SANTANDER US CAPITAL MARKETS LLC
SCOTIA CAPITAL (USA), INC
SG AMERICAS SECURITIES LLC
SG SECURITIES (HK) LIMITED
SHAW AND PARTNERS LIMITED 
SHORE CAPITAL STOCKBROKERS LIMITED
SIEBERT WILLIAMS SHANK & CO. LLC
SKANDINAVISKA ENSKILDA BANKEN AB
SMBC NIKKO SECURITIES INC.
SOCIETE GENERALE
STANDARD BANK OF SOUTH AFRICA LTD
STATE STREET GLOBAL MARKETS 
INTERNATIONAL LTD
STERN BROTHERS & CO.
STIFEL FINL CORP
STIFEL NICOLAUS AND CO INC
STIFEL NICOLAUS EUROPE LIMITED
STRATEGAS SECURITIES, LLC.
STUART FRANKEL & CO. INC.
SUMITOMO MITSUI FIN GRP INC
SUSQUEHANNA FINANCIAL GROUP LLLP
SVB LEERINK LLC
TAYLOR COLLISON LIMITED
TD SECURITIES INC
TOURMALINE PARTNERS, LLC
TRADEWEB MARKETS LLC
TRUIST SECURITIES, INC.
UBS AG
UBS GROUP AG
UBS SECURITIES LLC
UBS SECURITIES PTE LTD, TAIPEI BRANCH
VAN LANSCHOT KEMPEN N.V.
VIRTU AMERICAS LLC
VIRTU EUROPE TRADING LIMITED
VIRTU ITG HONG KONG LIMITED
VIRTU ITG CANADA CORP
WELLS FARGO & COMPANY
WELLS FARGO SECURITIES LLC
WILLIAM BLAIR & COMPANY LLC
WILSONS ADVISORY AND STOCKBROKING 
LIMITED
WINTERFLOOD SECURITIES LIMITED
XP INVESTMENTS US, LLC
YUANTA SECURITIES CO., LTD.
ZEUS CAPITAL LIMITED
ZKB SECURITIES UK LTD

DEBT INSTRUMENTS – Bonds

ABN AMRO BANK NV
ACADEMY SECURITIES INC
ADVISORS ASSET MANAGEMENT, INC.
AGRICULTURAL BANK OF CHINA LIMITED
ALAMO CAPITAL
AMERICAN VETERANS GROUP PBC
AMHERST PIERPONT SECURITIES LLC
ANZ GROUP HOLDINGS LTD
ANZ SECURITIES INC.
AUREL BGC
AUSTRALIA AND NEW ZEALAND BANKING GROUP LTD
B. RILEY SECURITIES, INC.
BANCO BILBAO VIZCAYA ARGENTARIA SA
BANCO BRADESCO S.A.
BANCO HSBC S.A.
BANCO JP MORGAN SA INSTITUCION DE BANCA 
MULTIPLE JP MORGAN GRUPO FINANCIERO
BANCO NACIONAL DE MEXICO SA
BANCO SANTANDER (BRASIL) S.A.
BANCO SANTANDER DE NEGOCIOS COLOMBIA SA
BANCO SANTANDER MEXICO SA INSTITUCION DE 
BANCA MULTIPLE
BANCO SANTANDER SA
BANCOLOMBIA S.A.
BANCROFT CAPITAL LLC
BANK HAPOALIM B.M.
BANK OF AMERICA CORP
BANK OF AMERICA NATIONAL ASSOCIATION 
SHANGHAI BRANCH
BANK OF CHINA (HONG KONG) LIMITED
BANK OF COMMUNICATIONS CO., LTD
BANK OF MONTREAL
BANK OF NOVA SCOTIA
BARCLAYS BANK MEXICO SA
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BARCLAYS CAPITAL SECURITIES LTD
BARCLAYS PLC
BARCLAYS SECURITIES JAPAN LIMITED
BARRENJOEY MARKETS PTY LIMITED
BAYERISCHE LANDESBANKEN
BBVA MEXICO, S.A.
BBVA SECURITIES INC.
BC ZIEGLER & CO.
BCP SECURITIES, INC
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BMO NESBITT BURNS INC
BNP PARIBAS
BNP PARIBAS (CHINA) LIMITED
BNP PARIBAS SECURITIES CORPORATION
BNP PARIBAS SECURITIES JAPAN LTD
BNY MELLON CAPITAL MARKETS LLC
BOCI SECURITIES LIMITED
BOFA SECURITIES INC.
BOFA SECURITIES JAPAN CO., LTD
BOKF, NA
BPCE SA
BRADESCO SECURITIES INC
BREAN CAPITAL, LLC
BROWNSTONE INVESTMENT GROUP, LLC
BTG PACTUAL US CAPITAL, LLC
BTIG LIMITED
BTIG, LLC
C.L. KING & ASSOCIATES, INC
CABRERA CAPITAL MARKETS LLC
CAIXABANK, SA
CANACCORD GENUITY LIMITED
CANADIAN IMPERIAL BANK OF COMMERCE
CANTOR FITZGERALD & COMPANY
CANTOR FITZGERALD EUROPE
CASA DE BOLSA FINAMEX SAB DE CV
CASGRAIN & COMPANY (USA) LIMITED
CASTLEOAK SECURITIES, L.P.
CHINA CITIC BANK INTERNATIONAL LTD
CHINA CONSTRUCTION BANK CORPORATION
CHINA INTERNATIONAL CAPITAL CO. HK
CHINA INTL CAPITAL CORPORATION
CHINA MERCHANTS SECURITIES CO., LTD
CIBC WORLD MARKETS CORP.
CIBC WORLD MARKETS INC
CIMB BANK BERHAD
CITADEL SECURITIES (EUROPE) LIMITED
CITADEL SECURITIES INSTITUTIONAL LLC
CITIBANK (CHINA) COMPANY LIMITED
CITIBANK COLOMBIA S.A.
CITIC SECURITIES COMPANY LIMITED
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS JAPAN INC
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
CITIZENS CAPITAL MARKETS INC
CLSA AMERICAS, LLC
CMB INTERNATIONAL GLOBAL MARKETS LTD
CMB INTERNATIONAL SECURITIES LTD
COMMERZ MARKETS LLC
COMMERZBANK AG
COMMONWEALTH BANK OF AUSTRALIA
COOPERATIEVE RABOBANK U.A.
COWEN & COMPANY LLC
CREDICORP CAPITAL COLOMBIA SA
CREDICORP CAPITAL, LLC
CREDIT AGRICOLE CORPORATE AND INVESTMENT
BANK SA
CREDIT AGRICOLE SECURITIES (USA) INC
CREDIT INDUSTRIEL ET COMMERCIAL
CREDIT SUISSE AG
CREDIT SUISSE AG NY BRANCH
CREDIT SUISSE INTERNATIONAL
CREDIT SUISSE SECURITIES (USA) LLC
CSI GLOBAL MARKETS LIMITED
DA DAVIDSON & COMPANY
DAIWA CAPITAL MARKETS AMERICA INC.
DAIWA CAPITAL MARKETS EUROPE LTD
DAIWA SECURITIES CAPITAL MARKETS 
KOREA CO LTD
DAIWA SECURITIES CO LTD
DAIWA SECURITIES GROUP INC
DANSKE BANK A/S
DAVENPORT & COMPANY LLC
DBS BANK LTD (SINGAPORE BRANCH)
DESJARDINS SECURITIES INC
DESJARDINS SECURITIES INTERNATIONAL
DEUTSCHE BANK (CHINA) CO., LTD
DEUTSCHE BANK AG
DEUTSCHE BANK SECURITIES INC.
DEUTSCHE CAPITAL MARKETS AUSTRALIA
DEUTSCHE SECURITIES INC.
DNB BANK ASA
DREXEL HAMILTON LLC
DZ BANK AG DEUTSCHE ZENTRAL 
GENOSSENSCHAFTSBANK FRANKFURT AM MAIN
ERSTE GROUP BANK AG
FHN FINANCIAL SECURITIES CORP.
FIDELITY CAPITAL MARKETS, DIV. OF NFSC
FIFTH THIRD SECURITIES, INC..
FIRST ABU DHABI BANK PJSC
FIRST HORIZON BANK, N.A.
FIRST TRYON SECURITIES, LLC
FIRSTRAND BANK LIMITED
FLEXTRADER
FLOW TRADERS B.V.
FLOW TRADERS U.S. INSTITUTIONAL 
TRADING LLC
FMSBONDS, INC.
GMP SECURITIES LP
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS GROUP INC/THE
GOLDMAN SACHS INTERNATIONAL
GOLDMAN SACHS JAPAN CO. LTD.
GOLDMAN SACHS MEXICO CASA DE BOLSA 
SA DE CV
GOODBODY STOCKBROKERS
GREAT PACIFIC SECURITIES
GUOTAI JUNAN SECURITIES (HONG KONG)
GUOTAI JUNAN SECURITIES CO., LTD
HAITONG INTERNATIONAL SECURITIES CO LTD
HARTFIELD, TITUS & DONNELLY, LLC
HERBERT J SIMS & CO., INC
HILLTOP SECURITIES INC.
HONGKONG AND SHANGHAI BANKING 
CORPORATION LTD
HSBC BANK (CHINA) COMPANY LIMITED
HSBC BANK PLC
HSBC HOLDINGS PLC
HSBC MEXICO SA INSTITUCION DE BANCA 
MULTIPLE GRUPO FINANCIERO HSBC
HSBC SECURITIES (USA) INC
HUATAI SECURITIES CO LTD
HUNTINGTON SECURITIES, INC.
ICBC STANDARD BANK PLC.
ICICI BANK LIMITED
IMPERIAL CAPITAL (INTERNATIONAL) LLP
IMPERIAL CAPITAL LLC
INDUSTRIAL & COMMERCIAL BANK OF 
CHINA FINANCIAL SERVICES LLC
INDUSTRIAL AND COMMERCIAL BANK OF 
CHINA LTD
ING BANK NV
ING FINANCIAL MARKETS LLC
INSPEREX LLC
INTESA SANPAOLO IMI SECURITIES CORP
INTESA SANPAOLO SPA
ITAU BBA USA SECURITIES, INC.
J & E DAVY
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
J.V.B. FINANCIAL GROUP, LLC
JANE STREET EXECUTION SERVICES, LLC
JANE STREET FINANCIAL LIMITED
JANNEY MONTGOMERY SCOTT LLC
JEFFERIES FINANCIAL GROUP INC
JEFFERIES INTERNATIONAL LIMITED
JEFFERIES LLC
JPMORGAN CHASE & CO
JPMORGAN CHASE BANK (CHINA) COMPANY
JPMORGAN SECURITIES JAPAN CO LTD
KBC BANK N.V.
KEPLER CHEUVREUX S.A.
KEYBANC CAPITAL MARKETS INC.
KOTAK MAHINDRA (UK) LIMITED
LANDESBANK BADEN-WUERTTEMBERG
LANDESBANK HESSEN THUERINGEN 
GIROZENTRALE
LARRAIN VIAL SA CORREDORA DE BOLSA
LAURENTIAN BANK SECURITIES INC.
LIQUIDNET EUROPE LIMITED
LIQUIDNET INC
LLOYDS BANK CORPORATE MARKETS
LLOYDS SECURITIES INC
LOOP CAPITAL MARKETS LLC
MARKETAXESS CAPITAL LIMITED
MARKETAXESS CORPORATION 
MARKETAXESS EUROPE LTD
MERRILL LYNCH INTERNATIONAL
MESIROW FINANCIAL INC
MIDDLEGATE SECURITIES LTD.
MILLENNIUM ADVISORS, LLC
MILLENNIUM EUROPE LIMITED
MIRAE ASSET SECURITIES CO LTD.
MISCHLER FINANCIAL GROUP, INC.
MITSUBISHI UFJ MORGAN STANLEY 
SECURITIES CO LTD
MITSUBISHI UFJ FINANCIAL GROUP
MIZUHO FINANCIAL GROUP INC
MIZUHO INTERNATIONAL PLC
MIZUHO SECURITIES ASIA LIMITED
MIZUHO SECURITIES CO., LTD
MIZUHO SECURITIES USA LLC
MORGAN STANLEY
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
MORGAN STANLEY MEXICO CASA DE BOLSA
MORGAN STANLEY MUFG SECURITIES CO.
MTS BONDVISION
MUFG SECURITIES AMERICAS INC
MUFG SECURITIES EMEA PLC
MULTI-BANK SECURITIES, INC
NATIONAL AUSTRALIA BANK LIMITED
NATIONAL BANK FINANCIAL INC.
NATIONAL BANK OF CANADA
NATIONAL BANK OF CANADA FINANCIAL INC
NATIXIS S.A.
NATWEST GROUP PLC
NATWEST MARKETS PLC
NATWEST MARKETS SECURITIES INC
NEDBANK LIMITED
NOMURA HOLDINGS INC
NOMURA INTERNATIONAL PLC
NOMURA SECURITIES COMPANY LIMITED
NOMURA SECURITIES INTERNATIONAL INC
NORDDEUTSCHE LANDESBANK
NORDEA BANK ABP
NYKREDIT BANK A/S
ODDO BHF SCA
ODEON CAPITAL GROUP LLC
OKASAN SECURITIES CO LTD
OLD MISSION MARKETS LLC
OP CORPORATE BANK PLC
OPPENHEIMER & CO. INC.
ORIENT SECURITIES COMPANY LIMITED
OVERSEA-CHINESE BANKING CORPORATION
PENSERRA SECURITIES LLC
PERFORMANCE TRUST CAPITAL PARTNERS
LLC
PING AN BANK CO LTD
PING AN SECURITIES COMPANY LTD
PIPER SANDLER & CO.
PIPER SANDLER COMPANIES
PNC CAPITAL MARKETS INC
PNC FINANCIAL SERVICES GROUP INC (THE)
R. SEELAUS & CO., LLC.
R.W. PRESSPRICH & CO
RAYMOND JAMES & ASSOCIATES INC
RAYMOND JAMES LTD.
RBC CAPITAL MARKETS, LLC.
RBC DOMINION SECURITIES INC.
RBC EUROPE LTD
ROBERT W BAIRD & CO INC
ROYAL BANK OF CANADA
RUE LA BOETIE SAS
SAMSUNG SECURITIES CO., LTD
SAMUEL A. RAMIREZ & CO., INC
SANTANDER INVESTMENT SECURITIES INC
SC LOWY FINANCIAL (HK) LIMITED
SCOTIA CAPITAL (USA), INC
SCOTIA CAPITAL INC
SCOTIABANK EUROPE PLC
SCOTIABANK INVERLAT SA
SEAPORT GLOBAL SECURITIES LLC
SECUREVEST FINANCIAL GROUP INC.
SG AMERICAS SECURITIES LLC
SHANXI SECURITIES CO LTD
SHINKIN SECURITIES CO., LTD
SIEBERT WILLIAMS SHANK & CO. LLC
SKANDINAVISKA ENSKILDA BANKEN AB
SMBC NIKKO CAPITAL MARKETS LTD
SMBC NIKKO SECURITIES AMERICA, INC.
SMBC NIKKO SECURITIES INC.
SOCIETE GENERALE
STANDARD CHARTERED BANK
STANDARD CHARTERED BANK (CHINA) LTD
STANDARD CHARTERED PLC
STATE STREET GLOBAL MARKETS, LLC
STERN BROTHERS & CO.
STIFEL FINL CORP
STIFEL NICOLAUS AND CO INC
STIFEL NICOLAUS EUROPE LIMITED
STONEX FINANCIAL INC
STONEX FINANCIAL LTD
SUMRIDGE PARTNERS, LLC
SUSQUEHANNA FINANCIAL GROUP LLLP
SUSQUEHANNA INTERNATIONAL SECURITIES 
LIMITED
SVENSKA HANDELSBANKEN AB
SWBC INVESTMENT SERVICES, LLC
SWEDBANK
TD SECURITIES (USA) LLC
TD SECURITIES AUTOMATED TRADING LLC
TD SECURITIES INC
THE SEAPORT GROUP EUROPE LLP
TIGRESS FINANCIAL PARTNERS LLC
TMC BONDS L.L.C.
TOKAI TOKYO SECURITIES CO LTD
TORONTO-DOMINION BANK/THE
TRADEWEB DIRECT LLC
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
TRUIST SECURITIES, INC.
TRUMID
U.S. BANCORP INVESTMENTS, INC.
UBS AG
UBS FINANCIAL SERVICES INC
UBS GROUP AG
UBS SECURITIES CO., LIMITED
UBS SECURITIES LLC
UMB BANK, N.A.
UNICREDIT BANK AG
UNICREDIT SPA
VIRTU AMERICAS LLC
WELLS FARGO & COMPANY
WELLS FARGO BANK NA
WELLS FARGO SECURITIES INTERNATIONAL 
LTD
WELLS FARGO SECURITIES LLC
WESTPAC BANKING CORP ABN
XP INVESTMENTS US, LLC
YIELDBROKER
ZUERCHER KANTONALBANK

DEBT INSTRUMENTS – Money Market Instruments

ACADEMY SECURITIES INC
AGRICULTURAL BANK OF CHINA LIMITED
AUSTRALIA AND NEW ZEALAND BANKING 
GROUP LTD
BANCO BILBAO VIZCAYA ARGENTARIA SA
BANCO JP MORGAN SA INSTITUCION DE BANCA
MULTIPLE JP MORGAN GRUPO FINANCIERO
BANCO NACIONAL DE MEXICO SA
BANCO SANTANDER MEXICO SA INSTITUCION 
DE BANCA MULTIPLE
BANCO SANTANDER SA
BANK OF COMMUNICATIONS CO., LTD
BANK OF MONTREAL
BANK OF NOVA SCOTIA
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BBVA MEXICO, S.A.
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BMO NESBITT BURNS INC
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BNP PARIBAS SECURITIES JAPAN LTD
BNY MELLON CAPITAL MARKETS LLC
BOFA SECURITIES INC.
BOFA SECURITIES JAPAN CO., LTD
CABRERA CAPITAL MARKETS LLC
CANADIAN IMPERIAL BANK OF COMMERCE
CASA DE BOLSA FINAMEX SAB DE CV
CHINA INTL CAPITAL CORPORATION
CIBC WORLD MARKETS CORP.
CITADEL SECURITIES (EUROPE) LIMITED
CITADEL SECURITIES INSTITUTIONAL LLC
CITIC SECURITIES COMPANY LIMITED
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS JAPAN INC
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
COMMERZBANK AG
COOPERATIEVE RABOBANK U.A.
CREDIT AGRICOLE CORPORATE AND INVESTMENT 
BANK SA
CREDIT SUISSE AG NY BRANCH
CREDIT SUISSE SECURITIES (USA) LLC
DAIWA CAPITAL MARKETS AMERICA INC.
DAIWA CAPITAL MARKETS EUROPE LTD
DAIWA SECURITIES CO LTD
DAIWA SECURITIES GROUP INC
DANSKE BANK A/S
DBS BANK LTD (SINGAPORE BRANCH)
DESJARDINS SECURITIES INC
DESJARDINS SECURITIES INTERNATIONAL
DEUTSCHE BANK AG
DEUTSCHE BANK SECURITIES INC.
DEUTSCHE SECURITIES INC.
DZ BANK AG DEUTSCHE ZENTRAL 
GENOSSENSCHAFTSBANK FRANKFURT AM MAIN
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
GOLDMAN SACHS JAPAN CO. LTD.
GOLDMAN SACHS MEXICO CASA DE BOLSA 
SA DE CV
HSBC BANK PLC
HSBC MEXICO SA INSTITUCION DE BANCA 
MULTIPLE GRUPO FINANCIERO HSBC
HSBC SECURITIES (USA) INC
HUATAI SECURITIES CO LTD
INTESA SANPAOLO SPA
J.P. MORGAN SECURITIES LLC
JEFFERIES INTERNATIONAL LIMITED
JEFFERIES LLC
JP MORGAN SECURITIES PLC
JPMORGAN CHASE & CO
JPMORGAN SECURITIES JAPAN CO LTD
KBC BANK N.V.
LANDESBANK BADEN-WUERTTEMBERG
MARKETAXESS CORPORATION 
MERRILL LYNCH INTERNATIONAL
MISCHLER FINANCIAL GROUP, INC.
MITSUBISHI UFJ MORGAN STANLEY 
SECURITIES CO LTD
MITSUBISHI UFJ FINANCIAL GROUP
MIZUHO INTERNATIONAL PLC
MIZUHO SECURITIES CO., LTD
MIZUHO SECURITIES USA LLC
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
MORGAN STANLEY MUFG SECURITIES CO.
MTS BONDVISION
MUFG SECURITIES AMERICAS INC
MUFG SECURITIES EMEA PLC
NATIONAL AUSTRALIA BANK LIMITED
NATIONAL BANK FINANCIAL INC.
NATIXIS S.A.
NATWEST MARKETS PLC
NATWEST MARKETS SECURITIES INC
NOMURA HOLDINGS INC
NOMURA INTERNATIONAL PLC
NOMURA SECURITIES COMPANY LIMITED
NOMURA SECURITIES INTERNATIONAL INC
NORDEA BANK ABP
OKASAN SECURITIES CO LTD
ORIENT SECURITIES COMPANY LIMITED
OVERSEA-CHINESE BANKING CORPORATION
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
SCOTIA CAPITAL (USA), INC
SCOTIA CAPITAL INC
SCOTIABANK EUROPE PLC
SCOTIABANK INVERLAT SA
SIEBERT WILLIAMS SHANK & CO. LLC
SMBC NIKKO CAPITAL MARKETS LTD
SMBC NIKKO SECURITIES INC.
SOCIETE GENERALE (NY BRANCH)
STANDARD CHARTERED BANK (CHINA) LTD
SUMITOMO MITSUI BANKING CORP (SYDNEY 
BRANCH)
SUMITOMO MITSUI FIN GRP INC
SWEDBANK
TD SECURITIES (USA) LLC
TD SECURITIES INC
TIGRESS FINANCIAL PARTNERS LLC
TORONTO DOMINION BANK (LONDON BRANCH)
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
UBS GROUP AG
UBS SECURITIES LLC
UNICREDIT BANK AG
WELLS FARGO SECURITIES INTERNATIONAL LTD
WELLS FARGO SECURITIES LLC
WESTPAC BANKING CORP ABN
YIELDBROKER

INTEREST RATE DERIVATIVES – Futures & Options admitted to trading on a trading venue

BARCLAYS BANK PLC
BARCLAYS CAPITAL INC
BLOOMBERG TRADEBOOK LLC
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CREDIT SUISSE INTERNATIONAL
CREDIT SUISSE SECURITIES (USA) LLC
DEUTSCHE BANK AG
DEUTSCHE BANK SECURITIES INC.
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
HSBC BANK PLC
HSBC SECURITIES (USA) INC
J.P. MORGAN SECURITIES LLC
JP MORGAN SECURITIES PLC
MERRILL LYNCH INTERNATIONAL
MIZUHO SECURITIES USA LLC
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
NOMURA INTERNATIONAL PLC
PRISM FINANCIAL PRODUCTS LLP
R.J. O'BRIEN & ASSOCIATES LLC
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
SIGMA BROKING LTD
SOCIETE GENERALE CAPITAL CANADA INC
SOCIETE GENERALE INTERNATIONAL LTD
UBS AG
UBS SECURITIES LLC
WELLS FARGO SECURITIES LLC

INTEREST RATE DERIVATIVES – Swaps, forwards & other interest rates derivatives

BANCO BILBAO VIZCAYA ARGENTARIA SA
BANCO SANTANDER SA
BANK OF AMERICA CORP
BANK OF MONTREAL
BANK OF NOVA SCOTIA
BARCLAYS PLC
BLOOMBERG TRADEBOOK LLC
BNP PARIBAS SA
CANADIAN IMPERIAL BANK OF COMMERCE
CITADEL SECURITIES SWAP DEALER LLC
CITIGROUP INC
CREDIT SUISSE GROUP AG
CSHC EUROPE LLC
DANSKE BANK A/S
DEUTSCHE BANK AG
DNB BANK ASA
GOLDMAN SACHS GROUP INC/THE
HSBC HOLDINGS PLC
ING GROEP NV
JEFFERIES FINANCIAL GROUP INC
JPMORGAN CHASE & CO
LLOYDS BANKING GROUP PLC
MIZUHO FINANCIAL GROUP INC
MORGAN STANLEY
NATWEST GROUP PLC
NOMURA HOLDINGS INC
NORDEA BANK ABP
ROYAL BANK OF CANADA
ROYAL BANK OF SCOTLAND PLC
RUE LA BOETIE SAS
SKANDINAVISKA ENSKILDA BANKEN AB
SOCIETE GENERALE SA
STANDARD CHARTERED PLC
TORONTO-DOMINION BANK/THE
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
UBS GROUP AG
UNICREDIT SPA
WELLS FARGO & COMPANY
WESTPAC BANKING CORP

COMMODITIES DERIVATIVES – Futures & Options admitted to trading on a trading venue

BARCLAYS CAPITAL INC
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
CITIGROUP GLOBAL MARKETS INC
CITIGROUP GLOBAL MARKETS LIMITED
CREDIT SUISSE INTERNATIONAL
CREDIT SUISSE SECURITIES (USA) LLC
DEUTSCHE BANK SECURITIES INC.
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
J.P. MORGAN SECURITIES LLC
JP MORGAN SECURITIES PLC
MAREX FINANCIAL LIMITED
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
RBC CAPITAL MARKETS, LLC.
SG AMERICAS SECURITIES, LLC
SOCIETE GENERALE CAPITAL CANADA INC
SOCIETE GENERALE INTERNATIONAL LTD
UBS SECURITIES LLC
WELLS FARGO SECURITIES LLC

CREDIT DERIVATIVES – other credit derivatives

BANK OF AMERICA CORP
BANK OF AMERICA NA
BARCLAYS BANK PLC
BARCLAYS PLC
BLOOMBERG TRADEBOOK LLC
BNP PARIBAS SA
CITIBANK NA
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
CREDIT SUISSE GROUP AG
CREDIT SUISSE INTERNATIONAL
DEUTSCHE BANK AG
GOLDMAN SACHS BANK USA
GOLDMAN SACHS GROUP INC/THE
GOLDMAN SACHS INTERNATIONAL
HSBC HOLDINGS PLC
J.P. MORGAN SECURITIES PLC
JEFFERIES FINANCIAL GROUP INC
JP MORGAN CHASE BANK
JPMORGAN CHASE & CO
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY
MORGAN STANLEY
MORGAN STANLEY & CO INTERNATIONAL PLC
ROYAL BANK OF CANADA
SOCIETE GENERALE SA
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
WELLS FARGO & COMPANY

CURRENCY DERIVATIVES – Futures & Options admitted to trading on a trading venue

BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BOFA SECURITIES INC.
CITIGROUP GLOBAL MARKETS INC.
DEUTSCHE BANK SECURITIES INC.
FLEXTRADER
GOLDMAN SACHS & CO. LLC
J.P. MORGAN SECURITIES LLC
JP MORGAN CHASE BANK
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO LLC
RBC CAPITAL MARKETS, LLC.
UBS SECURITIES LLC

CURRENCY DERIVATIVES – Swaps, forwards & other currency derivatives

360T
AEGON N.V. (GROUP TREASURY)
AUSTRALIA AND NEW ZEALAND BANKING 
GROUP LTD
BANCO SANTANDER SA
BANK OF AMERICA NA
BANK OF MONTREAL
BANK OF NEW YORK MELLON
BANQUE PICTET ET CIE SA
BARCLAYS BANK IRELAND PLC
BARCLAYS BANK PLC
BNP PARIBAS
BOFA SECURITIES EUROPE SA
BROWN BROTHERS HARRIMAN & CO
CANADIAN IMPERIAL BANK OF COMMERCE
CITIBANK NA
CITIBANK EUROPE PLC
CITIGROUP GLOBAL MARKETS LIMITED
COINBASE
COINBASE, INC.
COMMONWEALTH BANK OF AUSTRALIA
COOPERATIEVE RABOBANK U.A.
CREDIT AGRICOLE CORPORATE AND 
INVESTMENT BANK SA
CREDIT SUISSE
CREDIT SUISSE INTERNATIONAL
DANSKE BANK A/S
DEUTSCHE BANK AG
DEUTSCHE SECURITIES INC.
FLEXTRADER
FX ALLIANCE LLC
FX CONNECT
GOLDMAN SACHS BANK EUROPE, SE
GOLDMAN SACHS BANK USA
GOLDMAN SACHS INTERNATIONAL
GOLDMAN SACHS JAPAN CO. LTD.
HONGKONG AND SHANGHAI BANKING 
CORPORATION LTD
HSBC BANK PLC
HSBC BANK USA, NA
HSBC CONTINENTAL EUROPE SA
INTEGRAL
JP MORGAN CHASE BANK
J.P. MORGAN AG
J.P. MORGAN SECURITIES PLC
LLOYDS BANK CORPORATE MARKETS
MERRILL LYNCH INTERNATIONAL
MITSUBISHI UFJ TRUST AND BANKING CO
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY CAPITAL SERVICES LLC
MORGAN STANLEY EUROPE SE
MORGAN STANLEY MUFG SECURITIES CO.
MUFG BANK, LTD
NATIONAL AUSTRALIA BANK LIMITED
NATWEST MARKETS NV
NATWEST MARKETS PLC
NOMURA INTERNATIONAL PLC
ROYAL BANK OF CANADA
SKANDINAVISKA ENSKILDA BANKEN AB
SOCIETE GENERALE
STANDARD CHARTERED BANK
STATE STREET BANK AND TRUST COMPANY
THE NORTHERN TRUST COMPANY
TORONTO-DOMINION BANK/THE
UBS AG
UBS EUROPE SE
WESTPAC BANKING CORP

STRUCTURED FINANCE INSTRUMENTS

ACADEMY SECURITIES INC
AMHERST PIERPONT SECURITIES LLC
BANCO SANTANDER SA
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BGC BROKERS LP
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BMO NESBITT BURNS INC
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BNY MELLON CAPITAL MARKETS LLC
BOFA SECURITIES INC.
BOKF, NA
BREAN CAPITAL, LLC
BRED BANQUE POPULAIRE
BROWNSTONE INVESTMENT GROUP, LLC
BTIG, LLC
CABRERA CAPITAL MARKETS LLC
CANTOR FITZGERALD & COMPANY
CIBC WORLD MARKETS CORP.
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
COOPERATIEVE RABOBANK UA
CREDIT AGRICOLE CORPORATE AND 
INVESTMENT BANK SA
CREDIT SUISSE AG NY BRANCH
CREDIT SUISSE INTERNATIONAL
CREDIT SUISSE SECURITIES (USA) LLC
DAIWA CAPITAL MARKETS AMERICA INC.
DEUTSCHE BANK AG
DEUTSCHE BANK SECURITIES INC.
DZ BANK AG DEUTSCHE ZENTRAL 
GENOSSENSCHAFTSBANK FRANKFURT 
AM MAIN
FHN FINANCIAL SECURITIES CORP.
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
GUGGENHEIM SECURITIES, LLC
HILLTOP SECURITIES INC.
HSBC BANK PLC
INTESA SANPAOLO SPA
J.P. MORGAN SECURITIES LLC
JANE STREET EXECUTION SERVICES, LLC
JANE STREET FINANCIAL LIMITED
JANNEY MONTGOMERY SCOTT LLC
JEFFERIES INTERNATIONAL LIMITED
JP MORGAN SECURITIES PLC
KEYBANC CAPITAL MARKETS INC.
LAURENTIAN BANK SECURITIES INC.
LIQUIDNET EUROPE LIMITED
LIQUIDNET INC
LLOYDS BANK CORPORATE MARKETS
LOOP CAPITAL MARKETS LLC
MARKETAXESS CAPITAL LIMITED
MARKETAXESS CORPORATION 
MARKETAXESS EUROPE LTD
MERRILL LYNCH INTERNATIONAL
MILLENNIUM ADVISORS, LLC
MISCHLER FINANCIAL GROUP, INC.
MIZUHO SECURITIES CO., LTD
MIZUHO SECURITIES USA LLC
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
MUFG SECURITIES AMERICAS INC
NATIONAL AUSTRALIA BANK LTD
NATIONAL BANK FINANCIAL INC.
NATIXIS S.A.
NATIXIS SECURITIES AMERICAS LLC
NOMURA INTERNATIONAL PLC
NOMURA SECURITIES COMPANY LIMITED
NOMURA SECURITIES INTERNATIONAL INC
ODEON CAPITAL GROUP LLC
OPPENHEIMER & CO. INC.
PERFORMANCE TRUST CAPITAL PARTNERS LLC
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
ROBERT W BAIRD & CO INC
SCOTIA CAPITAL (USA), INC
SCOTIA CAPITAL INC
SEAPORT GLOBAL SECURITIES LLC
SMBC NIKKO CAPITAL MARKETS LTD
SMBC NIKKO SECURITIES AMERICA, INC.
SOCIETE GENERALE (NY BRANCH)
STANDARD CHARTERED BANK
STEPHENS INC
STIFEL NICOLAUS AND CO INC
STONEX FINANCIAL INC
SUSQUEHANNA INTERNATIONAL SECURITIES 
LIMITED
TD SECURITIES (USA) LLC
TD SECURITIES INC
THE SEAPORT GROUP EUROPE LLP
TRADEWEB DIRECT LLC
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
TRUIST SECURITIES, INC.
UBS AG
UBS SECURITIES LLC
WELLS FARGO SECURITIES INTERNATIONAL 
LTD
WELLS FARGO SECURITIES LLC

EQUITY DERIVATIVES – Futures & Options admitted to trading on a trading venue

BANK OF AMERICA NA
BANK OF MONTREAL
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
CIBC WORLD MARKETS CORP.
CITIBANK NA
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
COWEN & COMPANY LLC
CREDIT SUISSE INTERNATIONAL
CREDIT SUISSE SECURITIES (USA) LLC
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
HSBC BANK PLC
HSBC SECURITIES (USA) INC
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
JANE STREET EXECUTION SERVICES, LLC
JEFFERIES LLC
JP MORGAN CHASE BANK
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
NOMURA SECURITIES INTERNATIONAL INC
OPPENHEIMER & CO. INC.
OPTIVER V.O.F.
RBC CAPITAL MARKETS, LLC.
RFQ HUB
ROYAL BANK OF CANADA
SANFORD C BERNSTEIN & CO LLC
SOCIETE GENERALE
SUSQUEHANNA FINANCIAL GROUP LLLP
TD SECURITIES INC
TRADEWEB MARKETS LLC
UBS AG
UBS SECURITIES LLC
WELLS FARGO SECURITIES LLC

EQUITY DERIVATIVES – Swap & other equity derivatives

BANK OF AMERICA NA
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BARCLAYS CAPITAL SECURITIES LTD
BNP PARIBAS SA
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
CITIBANK NA
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
HSBC BANK PLC
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
JP MORGAN CHASE BANK
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
RFQ HUB
SG AMERICAS SECURITIES, LLC
UBS AG
UBS SECURITIES LLC

SECURITIZED DERIVATIVES – Warrants & Certificate Derivatives

BARCLAYS CAPITAL INC.
BARCLAYS CAPITAL SECURITIES LTD
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
BTG PACTUAL US CAPITAL, LLC
CANTOR FITZGERALD EUROPE
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
CLSA LIMITED
COWEN & COMPANY LLC
CREDIT SUISSE INTERNATIONAL
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
HAITONG INTERNATIONAL SECURITIES CO LTD
HONGKONG AND SHANGHAI BANKING 
CORPORATION LTD
HSBC BANK PLC
HSBC SECURITIES (USA) INC
INSTINET LLC
J.P. MORGAN SECURITIES LLC
JEFFERIES INTERNATIONAL LIMITED
JEFFERIES LLC
JP MORGAN SECURITIES PLC
LOOP CAPITAL MARKETS LLC
MACQUARIE CAPITAL (USA) INC.
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
SG SECURITIES (HK) LIMITED
SOCIETE GENERALE PARIS
STIFEL NICOLAUS EUROPE LIMITED
UBS AG
UBS SECURITIES LLC
VIRTU EUROPE TRADING LIMITED

SECURITIZED DERIVATIVES – Other Securitized Derivatives

 N/A

CREDIT DERIVATIVES – Futures & Options admitted to trading on a trading venue

BANK OF AMERICA CORP
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC
BARCLAYS CAPITAL SECURITIES LTD
BARCLAYS PLC
BLOOMBERG TRADEBOOK LLC
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
CITIGROUP GLOBAL MARKETS INC
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
CREDIT SUISSE INTERNATIONAL
CREDIT SUISSE SECURITIES (USA) LLC
DEUTSCHE BANK AG
DEUTSCHE BANK SECURITIES INC.
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS GROUP INC/THE
GOLDMAN SACHS INTERNATIONAL
HONGKONG AND SHANGHAI BANKING 
CORPORATION LTD
HSBC BANK PLC
HSBC SECURITIES (USA) INC
J.P. MORGAN SECURITIES LLC
JEFFERIES LLC
JP MORGAN SECURITIES PLC
MERRILL LYNCH INTERNATIONAL
MIZUHO SECURITIES USA LLC
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
MORGAN STANLEY MUFG SECURITIES CO.
NATWEST MARKETS SECURITIES INC
NOMURA INTERNATIONAL PLC
NOMURA SECURITIES INTERNATIONAL INC
PRISM FINANCIAL PRODUCTS LLP
R.J. O'BRIEN & ASSOCIATES LLC
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
RFQ HUB
ROYAL BANK OF CANADA
SG AMERICAS SECURITIES, LLC
SIGMA BROKING LTD
SOCIETE GENERALE CAPITAL CANADA INC
SOCIETE GENERALE INTERNATIONAL LTD
TRADEWEB MARKETS LLC
UBS AG
UBS SECURITIES LLC
WELLS FARGO SECURITIES LLC

COMMODITIES DERIVATIVES – Other commodities derivatives

BANK OF MONTREAL
BARCLAYS CAPITAL INC
BNP PARIBAS SA
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
CANADIAN IMPERIAL BANK OF COMMERCE
CITIBANK NA
CITIGROUP GLOBAL MARKETS INC
CITIGROUP GLOBAL MARKETS LIMITED
CREDIT SUISSE
CREDIT SUISSE SECURITIES (USA) LLC
DEUTSCHE BANK SECURITIES INC.
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
J.P. MORGAN SECURITIES LLC
JP MORGAN CHASE BANK
JP MORGAN SECURITIES PLC
MACQUARIE BANK LIMITED
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
NOMURA SECURITIES INTERNATIONAL INC
RBC CAPITAL MARKETS, LLC.
SG AMERICAS SECURITIES, LLC
SOCIETE GENERALE
SOCIETE GENERALE CAPITAL CANADA INC
UBS AG
UBS SECURITIES LLC
WELLS FARGO SECURITIES LLC

CONTRACTS FOR DIFFERENCE

ABG SUNDAL COLLIER ASA
ARDEN PARTNERS PLC
BANK OF AMERICA CORP
BARCLAYS CAPITAL INC.
BARCLAYS CAPITAL SECURITIES LTD
BARCLAYS PLC
BLOOMBERG TRADEBOOK LLC
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
BTIG LIMITED
CABRERA CAPITAL MARKETS LLC
CANACCORD GENUITY LIMITED
CANTOR FITZGERALD EUROPE
CARNEGIE INVESTMENT BANK AB
CENKOS SECURITIES PLC
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
CLSA LIMITED
COWEN EXECUTION SERVICES LIMITED
CREDIT SUISSE INTERNATIONAL
DAIWA CAPITAL MARKETS EUROPE LTD
DANSKE BANK A/S
DNB BANK ASA
EXANE S.A.
FINNCAP LTD
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS GROUP INC/THE
GOLDMAN SACHS INTERNATIONAL
GOODBODY STOCKBROKERS
HAITONG INTERNATIONAL SECURITIES CO LTD
HONGKONG AND SHANGHAI BANKING 
CORPORATION LTD
HSBC BANK PLC
HSBC HOLDINGS PLC
HSBC SECURITIES (USA) INC
INSTINET EUROPE LIMITED
INSTINET LLC
INVESTEC BANK PLC
J & E DAVY
J.P. MORGAN SECURITIES LLC
JANE STREET FINANCIAL LIMITED
JEFFERIES FINANCIAL GROUP INC
JEFFERIES INTERNATIONAL LIMITED
JOH. BERENBERG, GOSSLER & CO. KG
JP MORGAN SECURITIES PLC
JPMORGAN CHASE & CO
KEEFE BRUYETTE AND WOODS INC
KEPLER CHEUVREUX S.A.
LIBERUM CAPITAL LIMITED
LIQUIDNET EUROPE LIMITED
MACQUARIE CAPITAL (EUROPE) LIMITED
MACQUARIE CAPITAL (USA) INC.
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
NOMURA INTERNATIONAL PLC
NORDEA BANK ABP
NORTHERN TRUST SECURITIES LLP
NPLUS1 SINGER CAPITAL MARKETS LIMITED
NUMIS SECURITIES LTD
ODDO BHF SCA
PANMURE GORDON (UK) LIMITED
PEEL HUNT LLP
RBC EUROPE LTD
REDBURN (EUROPE) LIMITED
SG SECURITIES (HK) LIMITED
SHORE CAPITAL STOCKBROKERS LIMITED
SKANDINAVISKA ENSKILDA BANKEN AB
SOCIETE GENERALE
STIFEL NICOLAUS EUROPE LIMITED
SVENSKA HANDELSBANKEN AB
TRADEWEB EUROPE LIMITED
UBS AG
UBS GROUP AG
UBS SECURITIES LLC
VIRTU EUROPE TRADING LIMITED
WINTERFLOOD SECURITIES LIMITED
ZEUS CAPITAL LIMITED

EXCHANGE TRADED PRODUCTS

BARCLAYS CAPITAL INC.
BARCLAYS CAPITAL SECURITIES LTD
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BNP PARIBAS
BNP PARIBAS SECURITIES (ASIA) LIMITED
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
BTG PACTUAL US CAPITAL, LLC
BTIG, LLC
CABRERA CAPITAL MARKETS LLC
CANTOR FITZGERALD & COMPANY
CASA DE BOLSA CREDIT SUISSE MEXICO
CASA DE BOLSA FINAMEX SAB DE CV
CASA DE BOLSA SANTANDER SA
CASTLEOAK SECURITIES, L.P.
CHINA INTL CAPITAL CORPORATION
CIBC WORLD MARKETS CORP.
CITADEL SECURITIES LLC
CITIBANAMEX CASA DE BOLSA SA DE CV CASA DE BOLSA INTEGRANTE DEL GRUPO FINANCIERO
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CLSA LIMITED
COWEN & COMPANY LLC
CREDIT SUISSE INTERNATIONAL
CREDIT SUISSE SECURITIES (USA) LLC
DEUTSCHE BANK AG
DRW EUROPE B.V.
EVERCORE GROUP LLC
FLEXTRADER
FLOW TRADERS B.V.
FLOW TRADERS HONG KONG LTD
FLOW TRADERS U.S. INSTITUTIONAL TRADING LLC
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
GREAT PACIFIC SECURITIES
GUZMAN & COMPANY
HONGKONG AND SHANGHAI BANKING 
CORPORATION LTD
HSBC BANK PLC
HSBC SECURITIES (USA) INC
INSTINET LLC
J.P. MORGAN SECURITIES LLC
JANE STREET EXECUTION SERVICES, LLC
JANE STREET FINANCIAL LIMITED
JANNEY MONTGOMERY SCOTT LLC
JEFFERIES INTERNATIONAL LIMITED
JEFFERIES LLC
JONESTRADING INSTITUTIONAL SERVICES
JP MORGAN CASA DE BOLSA SA DE CV JP 
MORGAN GRUPO FINANCIERO
JP MORGAN SECURITIES PLC
JPMORGAN SECURITIES JAPAN CO LTD
KEPLER CHEUVREUX S.A.
LOOP CAPITAL MARKETS LLC
MERRILL LYNCH INTERNATIONAL
MERRILL LYNCH MEXICO SA DE CV CASA DE BOLSA
MISCHLER FINANCIAL GROUP, INC.
MITSUBISHI UFJ MORGAN STANLEY SECURITIES CO LTD
MKM PARTNERS LLC
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
MORGAN STANLEY MEXICO CASA DE BOLSA
NATIONAL BANK FINANCIAL INC.
OPTIVER V.O.F.
PENSERRA SECURITIES LLC
PIPER SANDLER & CO.
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
RFQ HUB
SCOTIA CAPITAL (USA), INC
SEI INVESTMENTS DISTRIBUTION CO
SG SECURITIES (HK) LIMITED
SIEBERT WILLIAMS SHANK & CO. LLC
SMBC NIKKO SECURITIES INC.
SOCIETE GENERALE PARIS
STERN BROTHERS & CO.
STRATEGAS SECURITIES, LLC.
SUSQUEHANNA FINANCIAL GROUP LLLP
TD SECURITIES INC
TOURMALINE PARTNERS, LLC
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
UBS AG
UBS SECURITIES LLC
VIRTU AMERICAS LLC
VIRTU EUROPE TRADING LIMITED
WELLS FARGO SECURITIES LLC

EMISSION ALLOWANCES

N/A

OTHER INSTRUMENTS

BANK OF NOVA SCOTIA
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BNP PARIBAS SA
BNP PARIBAS SECURITIES CORPORATION
CITIBANK NA
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CITIZENS BANK, NATIONAL ASSOCIATION
CITIZENS CAPITAL MARKETS INC
CREDIT SUISSE SECURITIES (USA) LLC
DEUTSCHE BANK SECURITIES INC.
DEUTSCHE BANK TRUST COMPANY AMERICA
GOLDMAN SACHS INTERNATIONAL
HSBC BANK PLC
HSBC SECURITIES (USA) INC
J.P. MORGAN SECURITIES PLC
JEFFERIES LEVERAGED CREDIT PRODUCTS
JEFFERIES LLC
JP MORGAN CHASE BANK
MARKETAXESS CORPORATION 
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
NATIXIS S.A.
NATIXIS SECURITIES AMERICAS LLC
NOMURA CORPORATE FUNDING AMERICAS LLC
NOMURA SECURITIES INTERNATIONAL INC
RBC CAPITAL MARKETS, LLC.
ROYAL BANK OF CANADA
SCOTIA CAPITAL (USA), INC
TD SECURITIES (USA) LLC
TRUIST BANK
TRUIST SECURITIES, INC.
U.S. BANCORP INVESTMENTS, INC.
UBS AG
UBS SECURITIES LLC
WELLS FARGO BANK NA
WELLS FARGO SECURITIES LLC

SECURITIES FINANCING TRANSACTIONS

BANK OF MONTREAL
BANK OF NOVA SCOTIA
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BMO CAPITAL MARKETS CORP.
BNP PARIBAS
BOFA SECURITIES EUROPE SA
BOFA SECURITIES INC.
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CREDIT AGRICOLE CIB (NEW YORK)
CREDIT AGRICOLE CORPORATE AND 
INVESTMENT BANK SA
CREDIT SUISSE AG NY BRANCH
GLMX
GOLDMAN SACHS & CO. LLC
HSBC BANK PLC
HSBC SECURITIES (USA) INC
ING BANK NV
J.P. MORGAN SECURITIES LLC
JP MORGAN SECURITIES PLC
LLOYDS BANK PLC
MERRILL LYNCH INTERNATIONAL
MIZUHO SECURITIES USA LLC
MUFG SECURITIES EMEA PLC
NATIONAL AUSTRALIA BANK LIMITED
NATIXIS S.A.
NOMURA SECURITIES INTERNATIONAL INC
ROYAL BANK OF CANADA (NEW YORK BRANCH)
SANTANDER UK PLC
SCOTIABANK EUROPE PLC
SOCIETE GENERALE
TD SECURITIES (USA) LLC
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
WELLS FARGO SECURITIES LLC