Equities

The following information is intended solely for Institutional Equities clients of the Global Markets Division of HSBC Securities USA, Inc. (HSI)

Order Handling and Execution Quality (Institutional Clients)

HSI will take all reasonable steps to achieve the best possible execution result, taking into account a range of execution factors. When selecting an execution venue(s) best execution may be obtained by taking into account one or more of the following execution factors, in no order of priority:

• The price at which the Order could be executed;
• The costs that will be payable by the Client as a result of the execution of the Order;
• The size and nature of the Order;
• The speed of execution and settlement of the Order;
• The likelihood that the Order will be executed and settled; and
• Any other consideration that is relevant to the execution of the Order.

Price will generally merit a high relative importance when obtaining the best possible result for the Client, but HSI will also take into account the following criteria when determining the relative importance of the execution factors which may result in it affording higher priority to one of the other execution factors:

• The characteristics of the Client;
• The size and any other characteristics of the Order;
• The characteristics of the security that are the subject of the Order; and/or
• The characteristics of the execution venues to which the Order may be directed.

HSI performs a regular review of the execution quality provided by the destinations to which we route undirected Orders in order to assure that Clients receive high quality execution.

SEC Rule 606 Order Disclosure - Institutional (Non-Retail)

The U.S. Securities and Exchange Commission's client disclosure rule, SEC Rule 606, requires all broker-dealers that route orders in equity and options securities to make available quarterly reports that present a general overview of their routing practices. The reports must identify the significant venues to which the client orders were routed for execution during the applicable quarter and disclose the material aspects of the broker dealer's relationship with such venues. Pursuant to SEC Rules 606, HSI’s order routing statistics are available at https://public.s3.com/rule606/hsbc/. In addition, Rule 606(b)(3) requires broker-dealers to provide a customer, upon request, a report on the broker-dealer’s handling of the customer’s NMS stock orders submitted on a not-held basis for the prior six months. Please contact your HSI sales representative for further details.

Payment for Order Flow

HSBC Securities (USA), Inc. routes client and principal orders to national exchanges, alternative trading systems (“ATS”), and other market centers, which may include other broker-dealers. As such, HSBC Securities (USA) Inc. may accept payment in the form of rebates from certain market centers as part of “Maker-Taker” programs and discounts and/or reduction in fees from certain executing brokers, which in some cases may exceed the costs of execution; such cases constitute payment for order flow. However, HSBC Securities (USA) Inc.’s routing decisions are not determined by the receipt of payments, but rather on the basis of the quality of execution offered, taking into consideration various factors including, but not limited to price, transaction costs, liquidity and speed of execution.

SEC Rule 611 (Regulation NMS Order Protection Rule)

Rule 611 of Regulation NMS (“Reg NMS”) (commonly known as the Order Protection Rule) establishes intermarket price protection against trade-throughs for all NMS Stocks by requiring broker-dealers to attempt to access any better priced “protected” quotes on automated trading centers when executing at prices that would trade through those protected quotes. Rule 611 contains a number of exceptions, which are designed to make the rule’s intermarket price protection as efficient as possible. One of those exceptions is referred to as the Intermarket Sweep Order, or ISO exception. An ISO is a limit order for an NMS stock that is identified with an ISO designation when routed to an automated trading center and simultaneously with the routing of that limit order, is accompanied by one or more additional limit orders (also marked as ISOs) that will execute against the protected quotations on those automated trading centers. The ISO designation alerts the receiving automated trading center that the order sender itself is executing against any better priced protected quotations at other automated trading centers.

A broker-dealer is obligated to send ISOs when the price of a transaction between the broker-dealer and a customer, or a transaction between two or more clients, is outside of the current national best bid and offer (“NBBO”) for the NMS stock. In general, HSI will provide customers with the automatic ISO executions priced better than an agreed upon trade price. However, if you prefer to receive one execution at the agreed upon price rather than the fills generated through the ISO route, please notify your HSI sales coverage so that your consent may be documented on an order by order basis.

Indications of Interest

Indications of interest (“IOIs”) are expressions of trading interest to buy or sell securities that are sent by broker dealers to their clients. IOI messages typically contain the security name, side, price and volume for which the broker dealer seeks to transact. In addition, IOIs are generally designated into two types: natural – to represent agency interest or interest on a principal basis that is being or was established in connection with the facilitation of a customer order; and non-natural – to represent principal or house interest to trade in a particular direction. HSI uses certain vendors to advertise IOIs. HSI will label an IOI a natural if it is the result of an existing agency basis (i.e. customer order in hand) or interest on a principal basis that is being, or was established in connection with the facilitation of a customer order (e.g., unwinding or hedging client generated activity), including the facilitation of client listed option orders and certain over-the-counter equity derivatives, or the execution of client orders on a riskless principal basis.

Guaranteed Price Orders

HSI is dedicated to seeking best execution of client orders and providing transparency when working client orders or hedging against market risk from facilitating them. We may receive orders for single stocks or a basket of securities whereby we agree that HSI will execute in a principal capacity all or a portion of the order at a guaranteed price. That price may be based on an independent benchmark such as a Volume Weighted Average Price (“VWAP”), Time-Weighted Average Price (“TWAP”) or the official closing price for the security(s) comprising the basket. Prior to the execution of a guaranteed price order, HSI may establish a hedge through single or multiple trades that serve to offset HSI market risk associated with facilitating these transactions. This hedge will usually involve principal trades (possibly throughout the day) in the same security or in a related derivative instrument on the same side of the market as the client order.

HSI makes every reasonable effort to minimise the market impact of its hedging. Nevertheless, such activity may ultimately affect the agreed guaranteed benchmark price.

“Held” and “Not Held” Orders

A “held” order is one in which the client will instruct HSI to immediately submit for executions at the best available market prices, subject to size and limit price constraints. A “not held” order is one in which HSI has been given discretion as to the time and price at which to execute client orders. When handling a “not held” order, HSI uses professional judgment to seek the best possible overall quality of execution under the circumstances in accordance with the order’s instructions. HSI takes into consideration the size and potential market impact of the order and the depth and liquidity of the current market, as well as other relevant factors when exercising trading discretion. Client orders will be handled as “not held” (including all orders sent to an HSI algorithm or smart order router (“SOR”) unless instructed otherwise.

Market Access Rule (SEC Rule 15c3-5)

As required by SEC Rule 15c3-5, HSI has established, documented and maintains a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of the Firm’s market access to an exchange or alternative trading system (“ATS”). HSI subjects all orders to certain financial and regulatory risk management controls prior to submitting the orders to market centers. In the event a client order triggers one of these controls, HSI has the discretion to either reject it or execute it on a delayed basis upon further review of the order.

HSI offers a variety of electronic order execution services, including algorithmic trading strategies (e.g., VWAP trading strategies) and SOR technology. As part of these electronic order execution services a client order may be broken down into smaller orders which are routed to one or more execution venues. In addition, one or more of these electronic order execution services may also be used in the execution of a client order where the expertise of an HSI professional is utilized.

By submitting electronic orders to HSI, in both US and foreign listed equity securities, clients acknowledge that they are proficient and competent in utilizing the electronic services provided by HSI to access US and foreign equities markets. Clients also agree that orders routed through HSI are properly monitored and at all times be made in accordance with the applicable rules and customs of any Exchange, and of any regulatory and self-regulatory organization (foreign or domestic). Clients should notify HSI of any further sub-delegation of the electronic services being provided by HSI and will be responsible for conducting the same assessment on their sub-delegate(s). Furthermore, HSI maintains the right to suspend and/or terminate immediately client access to the electronic services provided by HSI to access all equities markets, as deemed necessary for HSI (and its affiliates) to fulfil its regulatory requirements in the respective jurisdictions.

OTC Equity Securities

Investing and/or trading in OTC stocks can pose considerable financial risk. These securities typically represent low-priced shares of new or small companies and foreign equity issues that do not qualify for trading on the Listed exchanges (ie., NYSE, NASDAQ, etc.) and may exhibit high price volatility and erratic trading volume. In general, HSI does not accept orders in certain OTC equity securities which are categorized by The OTC Markets Group (www.otcmarkets.com) as (1) OTC Pink – Limited Information; (2) OTC Pink – No Information; (3) Grey Market; (4) Caveat Emptor or (5) Crypto/Blockchain. Should a client order be submitted an order in a security that falls within any of the above categories, it may be rejected.

Low-Priced Securities (Penny and Sub Penny Stocks)

The term “penny stock” generally refers to low-priced (below $5), speculative securities of very small companies. While penny stocks generally are quoted over the counter, such as on the OTC Bulletin Board or in the Pink Sheets, they may also trade on securities exchanges, including foreign securities exchanges. In addition, penny stocks include the securities of certain private companies with no active trading market.

Investing in low-priced securities is speculative and involves considerable risk. Low-priced securities often exhibit high price volatility and erratic market movements. Often, when investors buy or sell these securities, they significantly affect the quoted price. In some cases, the liquidation of a position in a low priced security may not be possible within a reasonable period of time and is subject to additional fees.

It may be difficult to properly value an investment in a low-priced security. Reliable information regarding issuers of low-priced securities, their prospects, or the risks associated with investing in such securities may not be available. Certain issuers of low-priced securities have no obligation to provide information to investors. Some issuers register securities with the Securities and Exchange Commission (SEC) and may provide regular reports to investors. Others however may not be required to maintain such registration or provide such reports. Securities may continue to be traded if issuers are delinquent in their reporting obligation to the SEC or other federal or state regulatory agencies.

Penny stocks have not been approved or disapproved by the Securities and Exchange Commission (SEC). The SEC has not passed upon the fairness, the merits, the accuracy or adequacy of the information contained in any prospectus or any other information provided by an issuer or a broker or a dealer of penny stocks.

Trading low-priced securities is subject to significant risks, increasing regulatory requirements and oversight, and additional fees.

Anti-Fraud/Manipulation

HSI clients must not engage in any activity prohibited by the anti-fraud statutes and regulations including, but not limited to, wash sales, “naked” short selling, illegal pre-arranged trading, marking the close/open, non bona fide trading, spoofing or layering. HSI monitors the trading activity that is effected through the firm and will take the appropriate action should any activity be deemed suspicious. HSI reserves the right, in its sole discretion, to reject, refuse to accept, execute or cancel any Order in accordance with the terms of the HSI Client Agreement.

Restricted Securities

Clients seeking to sell a security deemed to be “restricted” due to the acquisition of such security in an unregistered, private sale or from an affiliate of the issuer, such security must be sold pursuant to Rule 144 of the Securities Exchange Act of 1933, as amended, or another applicable exemption from registration. Clients must contact the appropriate HSI salesperson prior to submitting the order to ensure HSI is able to process the sale in accordance with the applicable regulatory requirements and any restrictions imposed by the transfer agent.

FINRA Rule 5270

FINRA Rule 5270 generally prohibits a broker-dealer from trading for its own account while in possession of information regarding an imminent customer block order. In the normal course, HSI accepts and facilitates customer block orders, including single stock orders, baskets of securities and derivatives. HSI may trade principally at prices that would satisfy a customer block order where such transactions are unrelated (e.g. due to appropriate information barriers as detailed in the “no knowledge” exception to FINRA Rule 5320 detailed below) to the customer block order. Under certain circumstances, HSI may also engage in bona fide hedging or positioning activity to reduce the market risk associated with the facilitation of a customer block order. Such trading activity may coincidentally impact the execution price of the customer block order. HSI, however, will use reasonable efforts to avoid or minimise any such impact and to obtain the best possible execution for the client block order.

FINRA Rule 5320

Rule 5320 generally prohibits a member firm that accepts and holds a customer order from trading for its own account at terms that would satisfy the client order, unless the member immediately thereafter executes the client order at the same or better price than it traded for its own account. Described below, are certain exceptions to the Rule and an explanation of how HSI will handle those exceptions. Please note that consistent with existing regulatory guidance, ‘not held’ orders are outside the scope of the Rule.

• Large Orders and Institutional Account Exceptions

  Large orders (orders of 10,000 or more shares with a total value of $100,000 or more) and/or orders by “institutional accounts” as (as defined under FINRA Rule 4512(c) are exempted from the requirements of Rule 5320. HSI will generally work such orders in accordance with customer instructions. While working such orders, HSI may trade for its own account while handling a client order without providing price protection. HSI may be notified in the event consent is not granted to HSI trading while handling orders by providing HSI with written notice to “opt-in” to Rule 5320 protections. Otherwise, the client, will be deemed to have consented to the HSI’s trading for its own account on the same side of the market at a price that would satisfy the customer order. Client election to “opt-in” may be applied to all orders or individual orders on an order-by-order basis.

• No-Knowledge’ Exception

  HSI maintains Rule 5320 internal controls known as information barriers between its trading units. The information barriers are designed to prevent one trading unit from having knowledge of customer orders held by a different trading unit. With these barriers in place, one trading unit may hold a client order, while another trading unit, executes an order for an HSI account that would satisfy the client order.

• “Not Held” Orders

  HSI may trade in the security for its own account prior to the completion of a customer “not held” order, in which the clients have given HSI discretion as to the time and price at which to execute orders.

If there are any questions about this disclosure, wish to discuss it further, or object to the manner in which we are handling client Orders, please contact the appropriate HSI sales representative.

Stop Orders and Stop Limit Orders

• Stop prices are not guaranteed execution prices. A "stop order" becomes a "market order" when the "stop price" is reached and broker dealers are required to execute a market order fully and promptly at the current market price. Therefore, the price at which a stop order ultimately is executed may be very different from the client's "stop price”. Accordingly, while the client may receive a prompt execution of a stop order that becomes a market order, during volatile market conditions, the execution may be at a significantly different price from the stop price if the market is moving rapidly.
• Stop orders may be triggered by a short-lived, dramatic price change. Clients are reminded that, during periods of volatile market conditions, the price of a stock can move significantly in a short period of time and trigger an execution of a stop order (and the stock may later resume trading at its prior price level). Clients should understand that if their stop order is triggered under these circumstances, they may sell at an undesirable price even though the price of the stock may stabilise during the same trading day.
• Sell stop orders may exacerbate price declines during times of extreme volatility. The activation of sell stop orders may add downward price pressure on a security. If triggered during a precipitous price decline, a sell stop order also is more likely to result in an execution well below the stop price.
• Placing a "limit price" on a stop order may help manage some of these risks. A stop order with a "limit price" (a "stop limit" order) becomes a "limit order" when the stock reaches the "stop price." A "limit order" is an order to buy or sell a security for an amount no worse than a specific price (i.e., the "limit price"). By using a stop limit order instead of a regular stop order, the customer will receive additional certainty with respect to the price received. However, clients also should be aware that, because broker dealers cannot sell for a price that is lower (or buy for a price that is higher) than the limit price selected by the client, there is the possibility that the order will not be executed at all. Clients are encouraged to use limit orders in cases where they prioritise achieving a desired target price more than getting an immediate execution irrespective of price.

Short Selling (SEC Regulation SHO)

• Order Marking: When placing orders with HSI, clients are required to correctly mark all sale orders as either “long” or “short”. For any orders marked as “long”, you are representing to HSI that you are “net long” in the security pursuant to Rule 200.
• Locate Requirement: HSI may not accept a short sale order in a US equity security unless there is reasonable grounds to believe that the security can be borrowed to make delivery on settlement date (i.e. “locate”). Clients must provide HSI with a valid locate and clearly indicate the source of the locate. A locate is not a confirmation or guarantee that HSI has borrowed or will be able to borrow the security to make delivery on settlement date.
• Buy-Ins: HSI may be required to effect a mandatory market buy-in of a short or long sale transaction which resulted in a fail to deliver on settlement date. Should HSI execute a buy-in on a client short or long sale transaction, the client trading activity in the subject security executed through HSI on that trade date must end the day either net flat or net long. Any such fail to deliver may result in a restriction on the clients ability to effect short sales in such security. HSI reserves the right to pass through any fees or expense incurred in connection with any such buy-in.

SEC Large Trader Designation (Rule 13h-1)

A Large Trader is defined as an entity having discretionary control over transactions in NMS securities equal to or exceeding (1) 2 million shares or $20 million during any calendar day or (2) $20 million shares or $200 million during any calendar month. Clients are required to provide HSI with their Large Trader Identification Number (“LTID”) and identify any related accounts. HSI is required to assign an LTID to any client that does not have a LTID but is required under the rule.

Transactions in Listed Options

For clients that purchase or sell options listed on U.S. options exchanges, the review the Characteristics and Risks of Standardized Options disclosure published by The Options Clearing Corporation (OCC) is recommended. Clients may obtain a copy of the options disclosure document by visiting the OCC website at http://www.theocc.com/about/publications/character-risks.jsp

Order Origin Codes

The rules of various options exchanges require that HSI properly designate orders as originating from certain market participants including: Clients, broker-dealers, market-makers or “Professionals” (i.e., orders of any customer who places more than 390 orders in listed options per day on average during a calendar month). Accordingly, HSI will categorize client orders as “Professional” if either the activity through HSI meets the threshold for “Professional” designation or if the client affirmatively self designates its Professional status in writing to HSI.

Option Position Limits

FINRA and the options exchanges have established limits on the maximum number of options covering the same security that may be held by a client, including any entities acting in concert. Accordingly, HSI will monitor and report client options positions to the OCC and may be required to liquidate any positions in excess of applicable position limits.

International Securities Exchange’s (ISE) Solicited Order Mechanism

When handling an order of 500 or more options contracts on behalf a client, HSI may solicit other parties to execute against the order and may thereafter execute the order using the International Securities Exchange’s (ISE) Solicited Order Mechanism. This functionality provides a single-price execution only, so that an entire order may receive a better price after being exposed to the Exchange’s participants, but will not receive partial price improvement. For further details on the operation of this Mechanism, please refer to ISE Rule 716, which is available at www.ise.com under ‘Membership, Rules, and Fees – Regulatory-ISE Rules’.

Tied Hedge Procedures

When handling an option order of 500 contracts or more, HSI may buy or sell, security futures or futures positions, following receipt of the option order but prior to announcing the option order to the trading crowd. The option order may thereafter be executed using the tied hedge procedures of the exchange (e.g. the Chicago Board Options Exchange or the NASDAQ OMX PHLX) on which the order is executed. These procedures permit the option order and hedging position to be presented for execution as a net-priced package subject to certain requirements. For further details on the operation of the procedures, please refer to the exchange rules for tied orders including Chicago Board Options Exchange Rule 6.74.10, which is available at www.cboe.org/Legal.

CBOE Extended Trading Hours

Under CBOE Rule 6.1A(j), HSI may not accept an order from a customer for execution during Extended Trading Hours (ETH) without disclosing the potential risks involved in such extended-hours trading, such as:

1. Risk of Lower Liquidity: Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders and quotes that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity during ETH as compared to Regular Trading Hours (RTH), including fewer Market-Makers quoting during ETH. As a result, the order may only be partially executed or not at all.
2. Risk of Higher Volatility: Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility during ETH as compared to RTH. As a result, a client order may only be partially executed or not at all, or may receive an inferior price during ETH as compared to RTH.
3. Risk of Changing Prices: The prices of securities traded during ETH may not reflect the prices either at the end of RTH or upon the opening of RTH the next business day. As a result, you may receive an inferior price during ETH as compared to RTH.
4. Risk of News Announcements: Normally, issuers make news announcements that may affect the price of their securities after RTH. Similarly, important financial information is frequently announced outside of RTH. These announcements may occur during ETH, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
5. Risk of Wider Spreads: The spread refers to the difference between the price for which you can buy a security and the price for which you can sell it. Lower liquidity and higher volatility during ETH may result in wider than normal spreads for a particular security.
6. Risk of Lack of Calculation or Dissemination of Underlying Index Value or Intraday Indicative Value (IIV) and Lack of Regular Trading in Securities Underlying Indexes: For certain products, an updated underlying index or portfolio value or IIV will not be calculated or publicly disseminated during ETH. Since the underlying index or portfolio value and IIV are not calculated or widely disseminated during ETH, an investor who is unable to calculate implied values for certain products during ETH may be at a disadvantage to market professionals. Additionally, securities underlying the indexes or portfolios will not be regularly trading as they are during RTH, or may not be trading at all. This may cause prices during ETH to not reflect the prices of those securities when they open for trading

FINRA Extended Trading Hours

HSI may accept client orders outside of regular U.S. trading hours (9:30am – 4pm EST). Such customer orders will be handled based on specific order instructions, including but not limited to, limit price and timeframe to which the order is eligible for execution (e.g., regular/extended trading hours). Unless otherwise stated within the order instructions, all orders received prior to 9:30am EST will be handled and eligible for execution in the regular trading hours session on that business day.

Pursuant to both FINRA and NASDAQ rules, HSI is required to provide the following disclosures regarding risk associated with customer trading in the Pre-Market and Post-Market Sessions:

1. Risk of Lower Liquidity: Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular market hours. As a result, the order may only be partially executed or not at all.
2. Risk of Higher Volatility: Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular market hours. As a result, a client order may only be partially executed or not at all, or the client may receive an inferior price in extended hours trading than would have been received during regular markets hours.
3. Risk of Changing Prices: The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular market hours, or upon the opening of the next morning. As a result, a client may receive an inferior price in extended hours trading than would have been received during regular market hours.
4. Risk of Unlinked Markets: Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, a client may receive an inferior price in one extended hours trading system than would have been received in another extended hours trading system.
5. Risk of News Announcements: Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended hours trading, these announcements may occur during trading and, if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
6. Risk of Wider Spreads: The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.
7. Risk of Lack of Calculation or Dissemination of Underlying Index Value or Intraday Indicative Value (IIV): For certain Derivative Securities Products, an updated underlying index value or IIV may not be calculated or publicly disseminated in extended trading hours. Since the underlying index value and IIV are not calculated or widely disseminated during the pre-market and post-market sessions, an investor who is unable to calculate implied values for certain Derivative Securities Products in those sessions may be at a disadvantage to market professionals.

Telephone Recording Disclosure

As part of HSI’s compliance with applicable laws and regulations, certain telephone lines in the sales and trading departments will be recorded. Please note that these recordings may be made with or without the use of a spoken warning, tone, or similar notification.

FINRA Rule 2267 Investor Education and Protection

BrokerCheck provides investors with the ability to research the professional backgrounds, business practices, and conduct of FINRA-registered broker-dealers, investment advisers and registered representatives. In connection with this programme, investors may call the BrokerCheck Hotline at (800) 289-9999, and visit the FINRA website at http://brokercheck.finra.org/Search/Search. An investor brochure that includes information describing the FINRA BrokerCheck Programme is available from either of these sources.

FINRA Rule 2266 SIPC Information

HSI is a member of SIPC. Clients may obtain information about SIPC, including the SIPC brochure, by contacting SIPC at www.sipc.org or (202) 371-8300.

Net Transactions

HSI may execute orders received from its institutional clients on a net basis. A net transaction is a principal transaction whereby HSI, after having received an order to buy (sell) an equity security, purchases (sells) the security at one price and then sells to (buys from) you at a different price. These transactions are executed by HSI on a principal basis at a price that may be different than the price reported to you on the confirmation. The trade price reflected on the confirmation will be the net price of the trade which may include commissions added to the purchase price or subtracted from the sale price.

Net Trades are not eligible for an exemption under the Order Protection Rule. The net price that is reported to the appropriate Trade Reporting Facility (TRF) and disseminated to the public is the price of the trade. If necessary, HSI will route inter-market sweep orders (“ISOs”) to execute against protected quotations to comply with the Order Protection Rule. Unless explicitly agreed to prior to execution, any fills from these ISOs will not be passed along to the client, but instead will be for HSI’s principal account.