User Manual

Introduction

This section provides information about the OneChronos ATS, its technology, connectivity, surveillance, operations, the OneChronos Expressive Bidding Service and relevant policies as they pertain to trading on or engaging with the OneChronos ATS or related services. OneChronos ATS is operated by OneChronos Markets LLC, a wholly owned subsidiary of OCX Group Inc.

All references to OneChronos refers to OneChronos Markets LLC, the Broker-Dealer and operator, unless expressly stated otherwise. This document is updated from time to time. This version is considered the active User Manual. In the case of any differences in this version and a prior version, this version will supersede.

Capitalized terms if not otherwise defined have the meaning set forth in the Subscriber Agreement and Expressive Bidding Service Terms of Service Agreements between OneChronos and its Subscribers or users.

Participation on the OneChronos ATS

Entry of orders on the OneChronos ATS is limited to Subscribers. Only broker-dealers that are registered with the SEC and are members of FINRA or, if they do not have any public customers, a national securities exchanges, are eligible to become Subscribers. For certain kinds of orders called Expressive Bids, described below, Subscribers are able to enter pre-registered code called Bidder Logic that applies conditionality to the terms of their Limit or Peg orders. While Customers of Subscribers cannot enter orders directly into the OneChronos ATS, they can enter into agreements with OneChronos to submit their own Bidder Logic to the OneChronos ATS.

Trading Operations

OneChronos ATS operates periodic auctions at a rate of approximately 10 auctions per second throughout the trading day (standard trading hours, as further described below). Auctions are initiated by the matching engine at deliberately randomized times within the aforementioned parameters.

Matching Process

Rather than matching orders continuously as they arrive at the matching engine (as with a continuous limit order book) the OneChronos ATS periodically holds auctions designed to seek an optimal matching between buyers and sellers across all eligible orders. These auctions are multi-lateral in that one or more buyers may be matched with one or more sellers in the same security. As part of this mechanism, Subscribers can enter Limit Orders or Midpoint Peg Orders in single securities or, by the use of Expressive Bids, specify execution instructions that span multiple orders in a single security or multiple securities. Expressive Bids allow ATS users to express constraints on one order or a group of related orders to fit their business specific execution and or risk management objectives. For example, an Expressive Bid may enforce an aggregate limit on notional dollars transacted across simultaneous executions in orders for multiple securities, in addition to the price and quantity limits specified on those individual orders. As explained in Part III Item 7 of our ATS-N, Expressive Bids are comprised of “Target Orders” sent via FIX by Subscribers; Bidder Logic (computer code specifying constraints); (any) Bidder Inputs to complement the Bidder Logic as it may apply to a given Target Order, and Market Inputs (i.e. Market Data).

OneChronos uses the technique of mathematical optimization to match and clear buyers’ and sellers’ orders. Optimization generally involves searching through a large number of possible solutions and identifying the best among the solutions encountered; in our case, the best matching arrangements. As a means of comparing the quality of solutions, an “objective function” is defined to maximize (or minimize) a pre-determined goal of the search in our matching process. That search process for the objective is bound by predefined “constraints” which act as boundary limits to the relevant variables: e.g. quantities, prices, and symbols. A simple example of a constraint for our optimization is that clearing prices must be within or at the NBBO spread. Users can similarly supply their own constraints using Expressive Bids. A commercialized periodic auction system conducted using the described approach is called a Smart Market, as is the case with the OneChronos ATS.

The primary objective of the OneChronos optimization (a/k/a, match process) is to determine, match and clear the configuration of eligible buy and sell orders that would maximize the total Aggregate Price Improvement (defined in the following paragraph) achievable by those orders in a given auction. The maximizing objective considers all eligible orders across all securities in that auction. All orders that execute (in part or in full) within the base trading environment clear at a single price per symbol per auction, however, orders directed to specific counterparties (see the section regarding custom groups below) may receive executions at different (i.e. potentially better or worse) prices than orders directed to the base trading environment.

Price Improvement, as referred to, is the difference between an order’s limit price and the auction clearing price for that security. Aggregate Price improvement refers to Price Improvement multiplied by the order quantity potentially filled for all orders across all securities in each auction.

Custom Groups: Nexus and Omnimarket Auctions

OneChronos permits a Subscriber, or their client, to establish a private trading environment experience that allows the Subscriber to designate all or some of its orders to interact only with another specified user, or group of specified users (a “Nexus” also referred to in our Form ATS-N as a Custom Group), rather than have those orders exposed to the base trading environment. Upon request of a user, OneChronos will create a Nexus, provide the user a Nexus ID, and add the designated counterparties upon receipt of their written consent. A Subscriber seeking to send orders to a particular Nexus, will include the Nexus ID on the relevant orders.

A user may establish multiple Nexuses and represent its orders across them simultaneously by using an “Omnimarket”, an umbrella encompassing two or more Nexuses to which the user already has access. A Subscriber’s order can ultimately execute in the Nexus(es) within the Omnimarket where the order best satisfies the auctions’ main objective; matching inbound orders in a manner that maximizes the notional price improvement achievable by those orders. The fill from an Omnimarket order can therefore span multiple Nexuses, which can possibly be at distinct fill prices. In the event that multiple Nexus solutions yield equivalent results, the Nexus(es) a Subscriber’s order executes in will be chosen randomly.

Nexus directed functionality may be used with any OneChronos order types, including Limit and Peg Orders, and allows a user to create a Nexus including one counterparty, multiple counterparties, or only its own orders.

While the default behavior for Nexus orders is to limit order interaction to only those users within the specified Nexus, a Subscriber can make any residual quantity not executed in a Nexus eligible for execution in the base trading environment. This is accomplished as a hierarchy, where the order attempts to source liquidity from the Nexus or Omnimarket, then secondarily attempts to source liquidity from the base environment within the same auction cycle. The cycle restarts for the following auction and repeats for each successive auction of the order’s life.

As detailed in Part III Item 11 of our ATS-N, given the difference in available counterparty liquidity within Nexuses, Nexus orders may receive executions at different (i.e. potentially better or worse) prices than orders outside the particular Nexus. Additionally, orders participating in Omnimarkets may be executed at unique prices per Nexus in which it executes. For more specific details, please refer to our form ATS-N, or contact [email protected].

Order Types and Entry

OneChronos permits Subscribers to enter two standard order types — Limit Orders and Midpoint Peg Orders — and the unique to OneChronos order type mentioned above called the Expressive Bid. In the OneChronos match process, Expressive Bids interact with standard orders in addition to other Expressive Bids, and all orders, regardless of their components or complexity, potentially benefit from that interaction. Subscribers are not required to use Expressive Bids; nor are they required to use them to achieve potential execution benefits from trading on OneChronos.

Bidder Logic code is conveyed using the OneChronos Expressive Bidding Service described below and in detail in the Expressive Bidding guide section of this site. All orders are sent to OneChronos by Subscribers, either for their own account or the account of their Customers. The Expressive Bidding Service can be used by Subscribers (for example to complement their principal or agency execution offerings) or by customers of Subscribers (to complement orders they send to their executing broker for potential execution at OneChronos). Bidder Logic registered in the Expressive Bidding Service is not in itself an order and cannot initiate execution. Rather, an order instructed by a Subscriber via FIX constitutes an order, and if one or more Target Orders are related to an assembly of previously registered Bidder Logic code in the Expressive Bidding Service, they form an Expressive Bid for execution at OneChronos.

To use the Expressive Bidding Service a Subscriber is also required to execute a Terms of Service agreement. Customers of Subscribers who endeavor to register their own code to complement the execution of their Target Orders sent to their Broker for execution at OneChronos would execute a separate Customer Terms of Service agreement. Please contact [email protected] for further information or to initiate connectivity discussions.

Standard orders and Target Orders submitted in connection with Expressive Bids are all sent via standard FIX (4.2) protocol. Information relating to connectivity, order instructions and more related messaging instructions are available in our FIX specification.

Subscriber Broker Dealers may use OneChronos as an execution venue and to complement their algorithm and smart routing strategies, and may also offer OneChronos as a direct market access (DMA) destination to their customers.

This summary information is contextual for the reader to gain an overview of the offering and its use. For more specific details please refer to our form ATS-N, as well as the FAQ section of our website located in the lower section of our home page. For a detailed guide on Expressive Bidding, including useable plug & play templates, please see the Expressive Bidding section of this site.

Market Operations

The OneChronos auction lifecycle consists of the following five steps, which occur in sequence and are repeated throughout the ATS’s trading hours:

Initialization Time: an auction Cutoff Time is randomly chosen following the completion of the prior auction lifecycle, drawn at random within a range of 20 milliseconds to 200 milliseconds from the previous auction;
Auction Network Buffer: this allows sufficient time for orders and market data to arrive, including data from the furthest PoP from the matching engine. The length of the Buffer can vary based on expected transmission times, but would typically be on the order of tens of milliseconds;
Match Optimization: the ATS evaluates Expressive Bids and runs the trade matching process, which determines prices and share allocations across all symbols;
Post Auction Network Buffer: upon completion of the Match Optimization process, the matching engine broadcasts auction results to all Points of Presence (“PoP”). Each PoP waits until a pre-determined time (which always precedes the following auction’s Cutoff) to distribute execution reports, thereby providing a synchronized dissemination of such data externally. As with the Auction Network Buffer, the length of the Post Auction Network Buffer can vary based on expected transmission times, but would typically be on the order of tens of milliseconds;
Data Dissemination: at the conclusion of the Post Auction Network Buffer period, the PoPs communicate auction results in the form of execution reports to external parties, including Subscribers, the ATS’s direct clearing provider, and the Trade Reporting Facility.

Orders entered into the ATS are “firm.” The ATS does not support modification of resting orders, but Subscribers can cancel and replace resting orders. Cancellation requests received and timestamped before the Cutoff Time (i.e. during the Initialization Time) have immediate effect. Cancellation requests received after the Cutoff Time but before the completion of the auction cycle do not have effect until the following cycle (and therefore the order may still participate in the auction notwithstanding the cancellation request).

OneChronos ATS supports the following order types:

Limit Order
Midpoint Peg Order
Expressive Bid: an order type that allows Subscribers or other External Users entering Bidder Logic to specify execution instructions spanning one or more individual Limit Orders, including Midpoint Peg Orders. Any Limit Order or collection of Limit Orders referencing Bidder Logic receives treatment as an Expressive Bid.

Currently, OneChronos operates one PoP at Equinix NY5 in Secaucus, NJ.

The ATS operates Monday through Friday according to the standard market hours schedule below, with the exception of the following holidays: New Years Day, Martin Luther King Jr. Day, Presidents’ Day, Good Friday, Memorial Day, Juneteenth, Independence Day, Labor Day, Thanksgiving Day, and Christmas Day.

Standard Market Hours (US Eastern time):

8:00am: begin accepting FIX connections / sessions;
9:15am: begin accepting orders;
9:30am: begin executing orders (i.e. first call auction will take place at or after 9:30am);
4:00pm: stop executing orders (i.e. final call auction will take place at or before 4:00pm)*;
5:00pm: all FIX sessions disconnected.

* The ATS stops executing orders at 1:00pm instead of 4:00pm on: the day prior to observed Christmas Day, the day prior to observed Independence Day, and the day after Thanksgiving Day. FIX sessions are disconnected at 2:00pm instead of 5:00pm on these days.

OneChronos ATS supports Time-in-force instructions of: Day, Immediate or Cancel, Fill or Kill, Good ‘Til Date (with an expire time not to exceed the end of the current trading session).

Each Subscriber must either be self-clearing or have a clearing arrangement with a clearing firm acceptable to OneChronos, for purposes of settling the Subscriber’s transactions executed on the ATS. OneChronos has engaged Instinet, LLC. (Instinet) (clearing number 0067), as a broker-dealer clearing agent to facilitate the clearing and settlement process. Instinet will submit trades matched on the ATS for clearing to the National Securities Clearing Corporation (“NSCC”), to be settled regular way. OneChronos acts as a dual-agent in this process. OneChronos is not a counterparty to transactions that are matched on the ATS. Solely for operational purposes, Instinet will submit a transaction executed on the OneChronos System to NSCC as a pair of matched transactions (each with the same transaction ID) in which the OneChronos ATS Market Participant ID (which is “CGXS”) is used to designate OneChronos as the contra-side buying broker to the seller and the contra-side selling broker to the buyer, consistent with its role as dual agent. Clearing and settlement of transactions is subject to applicable rules of NSCC and the Depository Trust Corporation. As part of the onboarding process, a Subscriber acknowledges the arrangement for submitting transactions through Instinet via electronic filing of its acceptance using NSCC Form 9-B.

With regards to order routing, the ATS does not route orders externally. Being all trades are executed at or within the NBBO spread, the ATS also does not make use of inter-market sweep orders (ISOs).

Further detail on order types including inputs to and examples of Expressive Bids are available in our Form ATS-N. Further detail relating to execution instructions or cancellation and replacement are available in our FIX specification.

Access and Connectivity

Only Subscribers can access the OneChronos ATS to instruct orders. A Subscriber must execute a Subscriber Agreement and in order to do so must represent and warrant that it (i) is duly registered under the Securities Exchange Act of 1934 with the SEC as a broker-dealer; (ii) is a member of the FINRA or (only if it does not have customers) an exchange that is registered with the SEC as a national securities exchange; (iii) is registered and/or qualified in those states and other jurisdictions where its business requires such registration and/or qualification; and (iv) has the necessary right, power and authority to execute and deliver an Agreement such as the Subscriber Agreement and to perform its obligations thereunder.

OneChronos allows Subscribers to connect directly to the ATS via cross-connect or via extranet, through one or more of the ATS’s PoP. The currently maintained PoP is located at Equinix NY5. Connectivity options include 1 gigabit or 10 gigabit single-mode optical fiber (SMF). Orders may only be submitted electronically. The ATS does not accept telephone orders.

For specific detail relating to connectivity please see our FIX specification. Please contact [email protected] for further information or to initiate connectivity discussions.

Market Quality and Risk Controls

Before each auction, the ATS carries out a series of pre-match market quality and risk checks. These consist of testing for locked and crossed markets, verifying that Subscriber configured risk checks pass, and flagging “clearly erroneous” orders (see following section) as ineligible for the auction. For Subscriber controlled risk checks, the following parameters are configurable within bounds that have been established by OneChronos:

total notional value maximums per order
total quantity maximums per order
symbol restrictions
short sale restrictions
self-trade prevention (by MPID and/or FIX session)

As an additional risk control, orders with Subscriber-supplied prices 10% or more aggressive than the NBBO are not eligible for participation. Subscribers cannot configure this price band, and the ATS automatically rejects orders exceeding this price band at the time of submission. Moreover, the ATS may also enforce share quantity and notional value constraints according to maximums put in place by Instinet, our clearing provider.

Technology, Security and Resiliency

The OneChronos ATS system is designed to support multiple, globally dispersed PoPs through which Subscribers can be connected to the OneChronos ATS. Each point of presence uses high precision time synchronization, and timestamps orders on the network level as they are received. Timestamped data is transmitted to the ATS central matching engine. In an effort to promote fairness, the timestamp on each order rather than its arrival time at the matching engine is used to determine that order’s eligibility for an auction. See our Form ATS-N Part 3 Item 11 for more information on the distributed order entry system. At this time, OneChronos maintains a single Point of Presence in the Equinix NY5 datacenter, located at 800 Secaucus Road, Secaucus, New Jersey 07094.

With regards to security and resiliency please see our form ATS-N Part II Item 7 for detail on OneChronos controls relating to: Centralized identity management, Authentication, Authorization, Encryption, Physical security, change management, monitoring, third part risk assessment, access to and use of confidential information, as well as monitoring of employee activity. Further to physical security, the data center itself provides a high level of security and availability through redundant and reliable environmental control systems. In addition, data center personnel are available 24/7 to maintain and service the system.

The matching engine is designed to efficiently scale even as order volume and order complexity grows. In addition to OneChronos maintaining sufficient server capacity for projected growth, the mechanism is designed in a way that uses advances in computer science, probabilistic search and artificial intelligence reinforcement learning techniques, the combination of which are deliberate and critical to support scale and intelligent distribution of computational resources.

Business Continuity Plan

OneChronos recognizes the importance of system and process resilience in operating an ATS and the potential for unforeseen events to interrupt normal operation. Accordingly, the firm maintains a Business Continuity Plan (“BCP”) defining how we will respond to events that significantly disrupt our business. Our BCP Disclosure Statement can be found here.

Expressive Bidding Service

The ATS offers an Expressive Bidding Service for Subscribers and/or their Customers to register customized constraints to complement their or their Customers’ orders sent to OneChronos for execution by Subscribers. Constraints are expressed using the programming languages supported by OneChronos, and are communicated to the Expressive Bidding Service via API. Technical documentation and examples of Expressive Bids are available in the Expressive Bidding Guide.

Access

Access to the Expressive Bidding Service is only available upon execution by a Subscriber of a Terms of Service agreement and completing the onboarding steps as described in the Expressive Bidding Service onboarding process. The Terms of Service Agreement is in addition to and separate from the Subscriber Agreement that a Subscriber must execute in order to access and connect to the ATS.

Customers of Subscribers may enter into a “Customer” Terms of Service agreement. Completion of a Customer Terms of Service agreement enables a Customer to participate directly in the Expressive Bidding Service. Though this enables them to enter their own Bidder Logic code directly into the OneChronos System, any orders they enter in connection with the code must be submitted through their Subscriber BD.

Please contact [email protected] for further information or to initiate onboarding to the Expressive Bidding Service.

Usage

Once an assembly of code is registered via the Service’s API, the user is provided an alphanumeric reference ID which they would apply to a designated FIX tag on an individual or multiple Target Orders sent to OneChronos for potential execution. That FIX tag ID and value is what creates a relationship between a given order or set of orders and a pre-registered assembly of code. The code must be submitted to the OneChronos Expressive Bidding Service at least one business day before it may be used in connection with any Target Orders. See the Expressive Bidding section of the FIX specification for more information.

Bidder Logic registered in The Service is not in itself an order and cannot initiate execution. Rather, an order instructed by a Subscriber via FIX constitutes an order, and if related to an assembly of pre-registered code in The Service, forms an Expressive Bid for execution at OneChronos.

Code communicated for the purpose of programming constraints for Expressive Bids must be submitted in OCaml or ReasonML; OneChronos maintains a library of syntax functions and list operations for either language to simplify code operations and computations. A complete guide is available in the Expressive Bidding Guide section of our website.

The Service provides tools for analyzing and testing properties of Bidder Logic such as the execution instructions that result from the application of specific simulated Bidder Inputs and Market Inputs to the Bidder Logic. The Service also provides Bidder Logic templates, interactive and static tutorial content, and assistance in developing software code regarding bid construction. Further information relating to the Expressive Bidding Service as well as adaptable code templates can also be found at the Expressive Bidding Guide section of our website.

Policies and Procedures

Acceptable Use Policy

Use of the OneChronos ATS and the Expressive Bidding Service are subject to this Acceptable Use Policy. Users (Subscribers or customers of a Subscriber, in the case of non-Subscribers intending to register Bidder Logic with the Expressive Bidding Service) agree not, and not to allow third parties, to use the ATS or Expressive Bidding Service:

to violate, or encourage the violation of, the legal rights of others;
to engage in, promote, or encourage fraudulent, manipulative or other illegal activity;
if such usage is prohibited under United States law, including laws related to embargoes and sanctions;
for any unlawful, invasive, infringing, defamatory, or fraudulent purpose;
to interfere with the use of the ATS or Expressive Bidding Service, or the equipment used to provide the Services, by Customers, or other authorized users;
to disable, interfere with, or circumvent any aspect of the Services. Users are also bound by the terms of their executed Agreements with OneChronos, including but certainly not limited to disclosing Confidential Information for reasons not permissible in that Agreement, or uploading source code or other information that contains or embodies any malware or destructive feature.

Clearly Erroneous Trade Policy

A “clearly erroneous” transaction is an execution of an order that was entered in error (e.g., in terms of price, quantity or symbol) and at a price substantially away from, or inconsistent with, the prevailing market for that security at the time of execution. OneChronos reserves the right, to be exercised at its discretion, to cancel transactions that it determines to be the result of clearly erroneous orders placed by a client or the result of inaccurate market data. Please refer to the FINRA Rule 11890 Series for additional information concerning clearly erroneous transactions and filings. In addition, if the SEC, an SRO, or other applicable regulatory body determines that an executed trade is clearly erroneous or must otherwise be cancelled, OneChronos will be required to cancel the trade and will not be able to honor the executed price, any price guarantee or other terms associated with such trade.

Surveillance

The ATS uses a combination of proprietary and commercial software that monitors: a) trading system status, utilization, connectivity, and message rates; b) anomalies in trading data (orders, executions, reports, market data); and c) centrally aggregated system and application log data for anomalous events and unauthorized access to critical systems and systems containing Confidential Trading Information.

OneChronos has developed automated tools for monitoring orders entered and trades executed by subscribers to its ATS. These tools are intended to assure routine compliance with SEC and FINRA trading regulations, and also to identify significant volume or price changes in securities, or unusual or unexplained patterns of activity. Trade reviews based on these reports are generally conducted on a weekly basis by the Firm’s OSJ Branch Manager, with oversight by the CCO or his designee. In addition, OneChronos produces daily and monthly reports to Subscribers of activity conducted for their account. A Series 24 Supervisor or the CCO, or his designee, will review these accounts for significant changes, including changes in volume and strategy, as well as for unusual or unexplained patterns of activity. In cases where exception reports highlight potential exceptions that exceed threshold parameters on those reports, or information disclosed in a monthly account report cannot be satisfactorily explained, a surveillance review will be initiated.

OneChronos maintains Written Supervisory Procedures (“WSPs”), which, in addition to other supervisory practices, further details surveillance of trading activity as well as the trading activity and information access of OneChronos employees. In addition, the OneChronos WSPs detail compliant practices with regards to monitoring and, as necessary, reporting Suspicious Activity.

Errors & Corrections

OneChronos maintains Written Supervisory Procedures that include procedures for handling execution errors. Execution errors may be the result, for example, of an ATS system failure, an error on the part of an ATS Subscriber, or an error in data (e.g. NBBO) provided to the ATS and used in executing a trade. In any of these cases, ATS personnel contact all Subscribers party to the transaction or transactions affected by the error and determine the appropriate course of action. If all Subscribers party to the trade wish to keep the trade in place and applicable FINRA, SEC, and SRO rules allow, no action is taken and the trade is processed. If one or more of the Subscribers wishes to break or correct a trade, the Operator may accordingly cancel or issue corrections for erroneous trades. If OneChronos determines a transaction to be a bona fide error, the Operator may in its sole discretion accept erroneous legs of a transaction into an error account maintained with the Operator’s clearing provider. The Operator promptly trades out of any positions it takes into the error account via execution services offered by its clearing provider. The CCO reviews all activity in the Operator’s error account on a monthly basis to ensure that the account maintains a zero balance and that the account is only used for bona fide errors.

OneChronos may also suspend trading temporarily if it detects certain error conditions that materially impact its ability to match trades. These error conditions include: loss or material degradation of communication between the matching engine and one or more PoPs; matching engine system errors; loss or material degradation of communication between market data sources and the matching engine; loss of connectivity with the Trade Reporting Facility.

Privacy Policy

When you visit sites, including the Expressive Bidding Service, operated by OneChronos, you consent to our use and processing of your information as set forth herein. This Privacy Policy covers OneChronos treatment of personal information that OneChronos gathers when you use or visit the Site and that our business partners share with OneChronos.

Confidentiality

Subscriber and OneChronos each may receive or have access to non-public information of the other Party in connection with the Subscriber Agreement and the Services provided relating to it. Such non-public information is deemed “Confidential Information” of the Party to which it belongs. Subscribers and OneChronos shall hold in strict confidence the Confidential Information of the other Party, using the same degree of care that each uses to protect its own information of a similar type, but in no event less than a commercially reasonable degree of care. A receiving Party shall not disclose Confidential Information of the other Party for any purpose not expressly permitted under the relevant Subscriber Agreement. Please see the Subscriber Agreement for complete information relating to Confidential Information and for the specific conditions by which the Subscriber or OneChronos may disclose the other’s Confidential Information.

With regards to Confidential Trading Information, a type of Confidential Information, OneChronos defines such information as: orders and order handling instructions, executions, clearing reports, non-tape TRF reports, risk configurations, and Bidder Logic. The commingling of data that would otherwise not be considered confidential, for example, raw FIX messages appearing in application performance logs, with Confidential Trading Information is also treated as Confidential Trading Information. Individuals with access to a system that stores or processes Confidential Trading Information are considered to have access to that information.

OneChronos’ activities as a broker-dealer are limited to operation of its ATS. Employees operating the ATS may have access to Confidential Trading Information. A Series 24 registered supervisor (“ATS Supervisor”) ensures the ATS restricts access to Confidential Trading Information to employees who are operating the ATS, those whose roles require access to such information for performing their duties, or those responsible for compliance with Reg ATS and other applicable rules, as further described in our Form ATS-N Part II Item 7(c).

OneChronos personnel with access to Confidential Trading Information are only authorized to use such information as required by their job functions. They cannot disseminate such information to anyone not authorized to receive that information. OneChronos requires all employees, including those with authorized access to Confidential Trading Information, to undergo annual compliance training that includes instruction and attestation relating to the protection of Confidential Trading Information. In addition, OneChronos maintains Written Supervisory Procedures that govern the use of Confidential Trading Information. For further information relating to Confidential Trading Information please see our Form ATS-N Part II Item 7.