Alternative Trading Systems Notice to IRA and ERISA Accounts

Wells Fargo Advisors (WFA), as part of its on-going efforts to provide best execution to its clients, frequently uses electronic communication networks, alternative trading systems, or similar execution systems or trading venues (collectively, “Alternative Trading Systems”) for transactions involving the purchase or sale of securities or other property. This notice is designed to give Individual Retirement Account investors and retirement plan clients information about WFA’s use of such systems as required by the Employee Retirement Income Security Act of 1974 (ERISA).

The Alternative Trading Systems to which WFA directs IRA and ERISA client order flow:

Are subject to applicable Federal regulation and oversight (or to a foreign regulatory entity’s regulation and oversight);
Generally match purchase and sale orders either (1) by rules designed to find the best price available or (2) by not taking into account the identity of the parties involved in the transaction
Executes transactions at prices and WFA receives compensation from such transactions that are at levels that are no greater than the price and compensation levels associated with other arm’s length transaction providers.

WFA may route order flow to affiliate firm, Wells Fargo Securities, LLC (WFS), who may subsequently route certain orders to the below list of Alternative Trading Systems (ATS) or other similar electronic trading venues for matching and price improvement opportunities. WFS may also route certain orders to MEMX, a market operator in which an affiliate of Wells Fargo holds a minority ownership interest.

Citadel Connect
IEX Exchange
Intelligent Cross ATS
Jane Street JX
Level ATS
UBS ATS
Virtu vEQ Link

Below please find a list of Electronic Communication Networks, Alternative Trading Systems or similar Execution or Trading System to which WFA may direct trades:

Equities:

CBOE BZX Equities Exchange
Citadel Securities
Miami Stock Exchange
NASDAQ
National Stock Exchange
NASDAQ International Securities Exchange (ISE)
NASDAQ PHLX
New York Stock Exchange (NYSE)
NYSE American Stock Exchange – formerly NYSE MKT and NYSE Amex NYSE
NYSE ARCA
NYSE Chicago Stock Exchange
OTC Link, LLC
Two Sigma Securities, LLC
Virtu Financial

Options:

BOX Exchange
Chicago Board Options Exchange (CBOE)
CBOE BZX Options Exchange
CBOE C2 Options Exchange
CBOE EDGX Exchange
Citadel Securities
Dash Financial Technologies
Interactive Brokers
ISE
ISE Gemini
ISE Mercury
MIAX Exchange
MIAX Emerald
MIAX Pearl
Morgan Stanley
NASDAQ OMX
NASDAQ OMX BX
NASDAQ OMX PHLX
NYSE Amex Options
NYSE ARCA Options
Susquehanna
Wolverine Execution Services

Fixed Income

Bonds.com
ICE Bondpoint
ICE NYSE Bonds
ICE TMC Bonds
MarketAxess
Tradeweb Direct