Clearly Erroneous Trade Policy

A Clearly Erroneous Trade is when there is an obvious error in any term, such as price, number of shares or other unit of trading defined as an execution at a price, for a quantity of shares, or with a symbol, that is substantially inconsistent with the current trading pattern of the issue. A transaction made in clearly erroneous error and cancelled by both parties or determined by CODA MARKETS to be clearly erroneous will be removed from the Consolidated Tape.

A subscriber that receives an execution on an order that was submitted erroneously to the CODA MARKETS for its own or customer account may request that CODA MARKETS review the transaction. An officer of the ATS or such other employee designee of the ATS shall review the transaction under dispute and determine whether it is clearly erroneous, with a view toward maintaining a fair and orderly market and the protection of investors and the public interest. Such request for review shall be made in writing via email or other electronic means.

Requests for review shall be received by CODA MARKETS within thirty (30) minutes of execution time and shall include information concerning the time of the transaction(s), security symbol(s), number of shares, price(s), side (bought or sold), and factual basis for believing that the trade is clearly erroneous. Upon receipt of a timely filed request these guidelines, the counterparty to the trade, if any, shall be notified by CODA MARKETS as soon as practicable, but generally within thirty (30) minutes. CODA MARKETS may request additional supporting written information to aid in the resolution of the matter. If requested, each party to the transaction shall provide any supporting written information as may be reasonably requested by the CODA MARKETS to aid resolution of the matter within thirty (30) minutes of CODA MARKETS’ request. Either party may request the supporting written information provided by the other party on the matter.

Numerical Guidelines

Under the uniform guidelines, a transaction executed during the pre-market trading session, the core trading session and post-market trading session may be found to be clearly erroneous only if the price of the transaction to buy is greater, or less in the case of a sale, than the Reference Price by an amount that equals or exceeds the Numerical Guidelines for a particular transaction category (as set forth below).

CODA MARKETS will generally use the consolidated last sale as the Reference Price to determine whether a trade is clearly erroneous. The execution time of the transaction under review determines which Numerical Guideline is applied. The chart below outlines the details.

Reference Price: Consolidated Last Sale

Core Trading Session Numerical Guidelines (Subject transaction’s % difference from the Consolidated Last Sale):

Pre-market and Post-market Trading Session Numerical Guidelines (Subject transaction’s % difference from the Consolidated Last Sale):

Greater than $0.00 up to and including $25.00

10%

20%

Greater than $25.00 up to and including $50.00

10%

Greater than $50.00

Multi-Stock Event – Filings involving five or more securities by the same subscriber will be aggregated into a single filing

10%

Multi-Stock Event – Filings involving twenty or more securities whose executions occurred within a period of five minutes or less

30%

Leveraged ETF/ETN Securities

Core Trading Session Numerical Guidelines multiplied by the leverage multiplier (e.g., 2x)

CODA MARKETS may consider additional factors to determine whether an execution is clearly erroneous. These factors include, but are not limited to, system malfunctions or disruptions, volume and volatility for the security, derivative securities products that correspond to greater than 100% in the direction of a tracking index, news released for the security, whether trading in the security was recently halted/resumed, whether the security is an IPO, whether the security was subject to a stock-split, reorganization, or other corporate action, overall market conditions, pre-market and post-market session executions, validity of the consolidated tapes trades and quotes, consideration of primary market indications, and executions inconsistent with the trading pattern in the stock. Each additional factor shall be considered with a view toward maintaining a fair and orderly market, the protection of investors and the public interest. Volatile Market Opens

During a Volatile Market Open, CODA MARKETS may expand the Numerical Guidelines applicable to transactions occurring between 9:30 a.m. and 10:00 a.m. based on the disseminated value of the S & P 500 Futures at 9:15 a.m.:

When the S & P 500 Futures are up or down from 3%, to up to but not including 5% at 9:15 a.m., the Numerical Guidelines are doubled for executions occurring between 9:30 a.m. and 10:00 a.m.
When the S & P 500 Futures are up or down 5% or greater at 9:15 a.m., the Numerical Guidelines are tripled for executions occurring between 9:30 a.m. and 10:00 am.

Unusual Circumstances

In Unusual Circumstances, CODA MARKETS may use (while attempting to maintain a fair and orderly market, protect investors and public interest) a Reference Price other than the consolidated last sale. Unusual Circumstances can include periods of extreme market volatility, sustained illiquidity, or widespread system issues. Other Reference Prices may include the consolidated inside price, the consolidated opening price, the consolidated prior close, or the consolidated last sale prior to a series of executions.

Joint Market Rulings

In circumstances that involve other markets, CODA MARKETS could potentially use a different Reference Price and/or Numerical Guideline. In these circumstances, the Reference Price would be determined based on a consensus among the exchanges where the transactions occurred.

Reviews Initiated by CODA MARKETS

In its sole discretion, CODA MARKETS reserves the right to initiate a review of a transaction if it determines that circumstances warrant such a review, regardless of whether or not a client request has been submitted. Any affected clients shall be notified accordingly.

ALISA Research Website

General

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Last updated: September 30, 2016

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ALISA Research Website

TERMS OF USE AND PRIVACY POLICY

General

PDQ Enterprises, LLC ("PDQE") provides this Web site and all information contained herein subject to your compliance with the terms and conditions set forth below. Please read the following information carefully before continuing to use this Web site. By using this Web site or any service of this Web site, you signify your acceptance of these terms of use. BY USING THE WEB SITE, YOU AGREE TO THESE TERMS OF USE; IF YOU DO NOT AGREE, DO NOT USE THE WEB SITE. By accessing and using this Web Site or any service of this Web site, you acknowledge, accept and agree to all of our terms, conditions and privacy policies described below, and otherwise contained on or referenced in this Web site (the "Agreement"). If you do not agree to this Agreement, you are not authorized to access and use this Web site. You also acknowledge and agree that we may modify this Agreement at any time, in our sole discretion; that all modifications to this Agreement will be effective immediately upon our posting of the modifications on this Web site; and that you will review this Agreement each time you access this Web site, so that you are aware of and agree to any and all modifications made to this Agreement. You also acknowledge and agree that, unless we specifically indicate otherwise, this Agreement only applies to this Web site and our online activities and does not apply to any of our offline activities. The "Web site" or the "Site" shall mean the [ALISAResearch] Web site available to the general public and located at http://pdq.staging312.com/lpr "Content" means any and all information, statements, materials, articles, research, data, software, links to third party websites, products and services made available on or accessible through the Site.

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BY USING THE SITE, YOU AGREE, TO THE EXTENT PERMITTED BY LAW, TO INDEMNIFY AND HOLD PDQE, ITS AFFILIATES, AND THEIRMANAGERS, MEMBERS, DIRECTORS, OFFICERS, EMPLOYEES, AFFILIATES, AGENTS, CONTRACTORS, AND LICENSORS HARMLESS WITH RESPECT TO ANY CLAIMS ARISING OUT OF YOUR BREACH OF THIS AGREEMENT, YOUR USE OF THE SITE, OR ANY ACTION TAKEN BY PDQE AS PART OF ITS INVESTIGATION OF A SUSPECTED VIOLATION OF THIS AGREEMENT OR AS A RESULT OF ITS FINDING OR DECISION THAT A VIOLATION OF THIS AGREEMENT HAS OCCURRED. THIS MEANS THAT YOU CANNOT SUE OR RECOVER ANY DAMAGES FROM PDQE, ITS AFFILIATES, OR THEIR MANAGERS, MEMBERS, DIRECTORS, OFFICERS, EMPLOYEES, AFFILIATES, AGENTS, CONTRACTORS, AND LICENSORS AS A RESULT OF ITS DECISION TO REMOVE OR REFUSE TO PROCESS ANY INFORMATION OR CONTENT, TO WARN YOU, TO SUSPEND OR TERMINATE YOUR ACCESS TO THE SITE, OR TO TAKE ANY OTHER ACTION DURING THE INVESTIGATION OF A SUSPECTED VIOLATION OR AS A RESULT OF PDQE’S CONCLUSION THAT A VIOLATION OF THIS AGREEMENT HAS OCCURRED. THIS WAIVER AND INDEMNITY PROVISION APPLIES TO ALL VIOLATIONS DESCRIBED IN OR CONTEMPLATED BY THIS AGREEMENT.

Copyright

The works of authorship contained in this Site, including but not limited to all design, text and images, are owned, except as otherwise expressly stated, by PDQE, and may not be copied, reproduced, transmitted, displayed, performed, distributed, rented, sublicensed, altered, stored for subsequent use or otherwise used in whole or in part in any manner without the prior written consent of PDQE, except to the extent that such use constitutes fair use under the Copyright Act of 1976, as amended, and except for one temporary copy in a single computer’s memory and one unaltered permanent copy to be used by the viewer for personal and non-commercial use only, with an attached copy of this page containing PDQE’s Terms and Conditions of Use and Privacy Policy.

Unless you have a written agreement in effect with PDQE which states otherwise, you may only provide a hypertext link to the Site on another website provided that (a) the link must be a text-only link clearly marked [ALISA Research Site] or http://pdq.staging312.com/iframe-outer-page/.com, (b) the link must point to the URL http://pdq.staging312.com/iframe-outer-page/.comand not to other pages within the Site, (c) the appearance, position and other aspects of the link may not be such as to damage or dilute the goodwill associated with PDQE’s name and trademarks, (d) the appearance, position and other aspects of the link may not create the false appearance that an entity is associated with or sponsored by PDQE, (e) the link, when activated by a user, must display the Site full-screen and not within a frame on the linked website, and (f) PDQE reserves the right to revoke its consent to the link at any time in its sole discretion.You may not display any Content in any way that creates a misimpression or likelihood of confusion that such Content is from any source other than PDQE.

PDQE respects the intellectual property of others. If you believe that your work has been copied in a way that constitutes copyright infringement or are aware of any infringing material placed by any third party on this Web site, please contact us at webinquiries@pdqenteprises.com. In your notification, please provide us with the following information:
- An electronic or physical signature of the person authorized to act on behalf of the copyright owner;
- A description of the copyrighted work that you claim has been infringed;
- A description of where on our site the material is located;
- Your address, telephone number and email address;
- A statement by you that you have a good faith belief that the use is not authorized by the copyright owner, its agent or the law; and
- A statement by you, made under penalty of perjury, that the information in your notice is accurate and that you’re the copyright owner or authorized to act on behalf of the copyright owner.
Trademarks and Service Marks

PDQE owns registered and common-law trademarks, service marks, domain names and trade dress protected by trademark laws in the United States and other countries. Other names, whether or not appearing in large print, italics or with the trademark/service mark symbol are trademarks and service marks of PDQE, its subsidiaries, related companies or third party content providers, unless otherwise noted. The use or misuse of these trademarks/service marks or any other content or materials, except as permitted herein, is expressly prohibited and may be in violation of copyright law, trademark law and/or other relevant laws. Please be advised that PDQE actively and aggressively enforces its intellectual property rights to the fullest extent of the law. PDQEand its affiliates’ marks, names, logos and trade dress include, but are not limited to, the following: “PDQ”, “PDQ Enterprises”, “ALISA”, “PDQ ATS”, “CODA”, “CODA Markets”.

Third Party Materials

Certain Content available via the Web site may include materials from third parties. PDQE may provide links to third-party websites as a convenience to you. You agree that PDQE is not responsible for examining or evaluating the content or accuracy and PDQE does not warrant and will not have any liability or responsibility for any third-party materials or websites, or for any other materials, products, or services of third parties. You agree that you will not use any third-party materials in a manner that would infringe or violate the rights of any other party and that PDQE is not in any way responsible for any such use by you.

Laws and Applicable Jurisdiction

You acknowledge and agree that your access to and use of this Site is subject to all applicable international, federal, state and local laws and regulations. The terms, conditions and policies contained in this Agreement will be governed by and construed in accordance with the laws of the State of New York, without regard to any principles of conflicts of law. You acknowledge and agree that any legal action, whether at law or in equity, arising out of or relating to this Agreement will be filed only in the state or federal courts located in New York City; that you irrevocably consent and submit to the exclusive personal jurisdiction of those courts for the purpose of litigating any such action; and that you will irrevocably waive any jurisdictional, venue or inconvenient forum objections to such court.

Privacy Notice

The Site does not require you to provide personal, nonpublic information. We only collect personal, nonpublic information that you knowingly and willingly supply to us. Site users may choose to complete a contact form, which may request information such as name, address, telephone number, e-mail address, etc. Users may also use this form to share comments relating to our Web site or our business in general. The information provided through this form will be used either to improve the content of our Web site or to direct a member of our sales department to contact the user. None of the information provided in the contact form will be sold or transferred to any third party. We will not share your information with third parties unless required by law. We store your information securely and only for the purpose of providing services you have requested from us or as otherwise described herein.

We may collect and retain data on the general usage of the Site. Like most Web sites, the site maintains logs that when analyzed show IP addresses of our users, date and time and pages viewed. These reports do not contain personally identifiable information. We do not log, record, obtain or retain the information and data that you enter into this Site or into the tools and calculators on the Site such as securities symbols, order size, and other transaction-specific data.

Cookies are also used in our site. Cookies are small text files that are placed in a site user’s computer that contain no personal information about the user, but enable us to determine whether the site user has viewed the site previously. If you have any questions about our Privacy Notice, please contact us at webinquiries@pdqenterprises.com.

You acknowledge and agree that any communication between you and PDQE via this Site is not encrypted.

This Web site is not intended or designed to attract individuals under the age of 18. We do not knowingly collect personal information from or about any person under the age of 18. If you are under 18 years old and wish to ask a question or use this Site in any way which requires you to submit your personal information, please get your parent or guardian to do so on your behalf.

Restrictions on Use

The information provided on this Web site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject PDQE or its affiliates to any registration requirement within such jurisdiction or country. You may not use this Web site for any illegal purpose or in any manner inconsistent with the Agreement. You agree not to use, transfer, dispose, or distribute any Content in any manner that could compete with PDQE’s business.

You may not attempt to gain unauthorized access to any portion or feature of the Web site, or any other systems or networks connected to the Web site or to any PDQE server, or to any of the services offered on or through the Web site, by hacking, password “mining” or any other illegitimate means.

You may not probe, scan or test the vulnerability of the Web site or any network connected to the Web site, nor breach the security or authentication measures on the Web site or any network connected to the Web site. You may not reverse look-up, trace or seek to trace any information on any other user of or visitor to the Web site, to its source, or exploit the Web site or any service or information made available or offered by or through the Web site, in any way where the purpose is to reveal any information, including but not limited to personal identification or information, other than your own information, as provided for by the Web site.

You agree that you will not take any action that imposes an unreasonable or disproportionately large load on the infrastructure of the Web site or PDQE’s systems or networks, or any systems or networks connected to the Web site or to PDQE.

You agree not to use any device, software or routine to interfere or attempt to interfere with the proper working of the Web site or any transaction being conducted on the Web site, or with any other person’s use of the Web site.

You may not forge headers or otherwise manipulate identifiers in order to disguise the origin of any message or transmittal you send to PDQE on or through the Web site or any service offered on or through the Web site. You may not pretend that you are, or that you represent, someone else, or impersonate any other individual or entity.

Your Account

As a user of the Web site, you may establish an account ("Account"). You should not reveal your Account information to anyone else. You are solely responsible for maintaining the confidentiality and security of your Account and for all activities that occur on or through your Account, and you agree to immediately notify PDQE of any security breach of your Account. PDQE shall not be responsible for any losses arising out of the unauthorized use of your Account.You agree to provide accurate and complete information when you register with, and as you use, the Web site ("Registration Data"), and you agree to update your Registration Data to keep it accurate and complete. You agree that PDQE may store and use the Registration Data you provide for use in maintaining your Account.You may not use anyone else’s Registration Data at any time without the express permission and consent of the holder of that Registration Data.

Termination

PDQE, at its sole discretion, at any time, for any reason or no reason and without notice to you may: (i) terminate this Agreement and/or your access to the Site, and/or (ii) terminate the license to any software; and/or (iii) preclude access to the Site (or any part thereof). PDQE reserves the right to modify, suspend, or discontinue the Site or any associated services (or any part or content thereof) at any time with or without notice to you, and PDQE will not be liable to you or to any third party should it exercise such rights.

Miscellaneous

The failure of PDQE to exercise or enforce any right or provision of this Agreement shall not constitute a waiver of such right or provision. Any clause of this Agreement declared invalid shall be deemed severable and shall not affect the validity or enforceability of the remainder. The terms of this Agreement may only be amended in a writing signed by PDQE.The Agreement constitutes the entire agreement between user and PDQE relating to the use of this Site. Users may also be subject to additional terms and conditions that may apply when users use affiliate services, third-party content or third-party software.

For More Information

If you have questions about any of the information provided herein, please contact us at webinquiries@pdqenterprises.com.

Last updated: September 30, 2016
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