FINRA Rule 5270 Disclosure
FINRA Rule 5270 prohibits FINRA member broker-dealers from executing orders to buy or sell certain securities or related financial instruments when the member has material, non-public information (“MNPI”) concerning an imminent block transaction in those securities, related financial instruments, or securities underlying the related financial instruments, prior to the time information concerning the block transaction has been made publicly available or has otherwise become stale or obsolete. FINRA Rule 5270 permits certain exceptions to the foregoing prohibition, including transactions that are undertaken to fulfill or facilitate the execution of a client block order. GTS may rely on exceptions to FINRA Rule 5270 while executing block orders for its clients. In connection with the handling of a client’s block order, GTS may engage in hedging, offsetting, liquidating, facilitating, or positioning transactions (“risk-mitigating transactions”) that may occur at the same time or in advance of this order. Such activities may have an impact on market prices. Beyond these risk-mitigating transactions, GTS will generally refrain from conduct that could disadvantage or harm the execution of client’s orders or that would place GTS financial interests ahead of clients. Unless client informs GTS otherwise in writing (“opt out”), the Firm will conclude that client understands that GTS may engage in risk-mitigating transactions in connection with client orders and the Firm will conclude that client has given its consent to GTS to handle block transactions as described above. Client may choose to opt out by providing written notice to GTS Compliance Department at 545 Madison Ave, 15th floor, New York, NY 10022. Please direct any questions regarding FINRA Rule 5270 to a GTS sales representative.