Comment Letters
July 2023
Imperative Execution Supplemental Letter on FINRA Proposal to Add IntelligentCross to Alternative Display Facility (ADF)
February 2023
Imperative Execution Letter on FINRA Proposal to Add IntelligentCross to Alternative Display Facility (ADF)
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June 6, 2022 Weekly Update
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May 23, 2022 Weekly Update
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May 16, 2022 Weekly Update
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May 9, 2022 Weekly Update
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May 2, 2022 Weekly Update
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April 25, 2022 Weekly Update
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April 18, 2022 Weekly Update
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April 11, 2022 Weekly Update
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April 4, 2022 Weekly Update
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Mar 28, 2022
March 28, 2022 Weekly Update
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Mar 21, 2022
March 21, 2022 Weekly Update
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Mar 14, 2022
March 14, 2022 Weekly Update
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Mar 7, 2022
March 7, 2022 Weekly Update
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  • Last week, IntelligentCross had a top 5-week for the platform across many metrics, including daily matched shares and number of unique names ordered.
  • Digging deeper, the data show IntelligentCross provided sizable stability and spread savings during market stress - when urgency matters.
  • For example, while VIX rose over 15% from its 2/25 close, last week IntelligentCross had top-5 weeks for the platform in matches of demi-blocks and larger (starting at 2000 shares) and IOC utilization.
  • We also saw round-lot or larger orders posted on our free displayed market data feed, IQX, priced better than the NBBO on arrival over 10mm times per day.
  • Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.


Feb 28, 2022
February 28, 2022 Weekly Update
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  • IntelligentCross remained in the top 5 for total shares traded in both NMS Tier 1 and 2 names according to the most recent FINRA ATS statistics.
  • Last week was our best week ever for daily matched shares in Midpoint, and our top week for the number of active names ordered across the platform. It was our second best week for the number of times that orders on our displayed IQX feed arrived with prices superior to the NBBO, averaging more than 14 million per day.
  • Median spreads across all names have risen more than 13% since the beginning of the year, increasing the value of savings from intra-spread and midpoint liquidity. IntelligentCross continues to see intra-spread activity grow even during these periods of market stress.
  • Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.


Feb 21, 2022
February 21, 2022 Weekly Update
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  • The most recent FINRA ATS statistics show IntelligentCross is in the top 5 for total shares traded for both NMS Tier 1 and Tier 2 stocks.
  • February is shaping up to be our best month ever for Midpoint daily matched shares. In ASPEN^3, we are seeing over 8mm round-lot or larger orders per day priced better than the NBBO on arrival on our displayed market data feed IQX.
  • Our success in helping our subscribers find intra-spread liquidity has become more important as a means of controlling the implicit costs of trading while the VIX has remained elevated and spreads have widened since Q3-2021.
  • Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Feb 14, 2022
February 14, 2022 Weekly Update
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  • Last week we set new records for market share vs. total consolidated volume, rising above 80bps for the first time ever and averaging over 75bps for the week.
  • Orders displayed on our free market data feed, IQX, continue to drive value for our subscribers. Displayed round-lot orders are priced better than the NBBO over 8.5mm times per day across more than 5700 names.
  • Last week we saw more than 1.2mm trades per day outside of our platform happening at prices worse than what was displayed on ASPEN^3. Roughly 65% of our displayed orders rest at or longer than the median quote duration in a name.
  • Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.
Feb 7, 2022
February 7, 2022 Weekly Update
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- January 2022 was our best month ever for daily matched shares on the platform. This was our 7th month in a row setting new daily records.

- It was also our first month breaking 70bps market share, single counted, versus total consolidated volume.

- Over one-quarter of our customers saw hit-rates of 10% or higher during January across Midpoint and ASPEN. 30% of our subscribers experienced ASPN IOC hit-rates of at least 20%.

- Liquidity continues to be driven by orders displayed on our market data feed IQX, where we saw orders priced better than the NBBO on arrival over 12mm times per day.

- Over 95% of displayed orders priced better than the NBBO were median trade size or larger and almost 80% were round-lots.

- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.


Jan 31, 2022
January 31, 2022 Weekly Update
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- January 2022 was our best month ever for daily matched shares on the platform and was our 7th month in a row setting new daily records.
- It was also our first month breaking 70bps market share, single counted, versus total consolidated volume.
- Last week was a new platform record for matched shares for the second week in a row and we matched over 100mm shares twice in the same week for the first time ever.
- Our growth is being driven by increases in larger size match events and orders displayed on our market data feed, IQX.
- For the second week in a row, we reached new highs in shares traded of demi-block or better (starting at 2000 shares), shares traded against displayed orders, and saw over 18mm displayed orders per day priced better than the NBBO on arrival,
- Month to date, displayed orders priced better than the NBBO on arrival have averaged median trade size or larger over 95% of the time and round lot or larger almost 80%.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Jan 24, 2022
January 24, 2022 Weekly Update
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- We continue to deliver for our subscribers, setting new records for share matching and price improvement.
- Last week was a new platform record for matched shares for the second week in a row and we matched over 100mm shares twice in the same week for the first time ever.
- Our growth is being driven by increases in larger size match events and orders displayed on our market data feed, IQX.
- For the second week in a row, we reached new highs in shares traded of demi-block or better (starting at 2000 shares), shares traded against displayed orders, and saw over 18mm displayed orders per day priced better than the NBBO on arrival,
- Month to date, displayed orders priced better than the NBBO on arrival have averaged median trade size or larger over 95% of the time and round lot or larger almost 80%.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Jan 17, 2022
January 17, 2022 Weekly Update
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- Last week, IntelligentCross set a new record for daily matched shares, matching more than 100mm shares single counted for the first time.
- The drivers behind this new record were a second straight week of our most successful matching of demi-blocks or larger (starting at 2000 shares) and continued spread-saving opportunities from orders displayed on our market-data feed, IQX.
- Last week, displayed orders were priced better than the NBBO on arrival over 11mm times per day across 5600 names with a median order-size of 100 shares.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Jan 10, 2022
January 10, 2022 Weekly Update
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- Last week, IntelligentCross set a new record for market-share versus total consolidated volume.
- This was driven by our best week ever for matching demi-blocks or larger (starting at 2000 shares) and by continued spread-saving opportunities from orders displayed on our market-data feed IQX.
- Last week, displayed orders were priced better than the NBBO on arrival over 11mm times per day and were median trade size or larger over 96% of the time.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Jan 3, 2022
January 03, 2022 Weekly Update
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- IntelligentCross opened the first full week of 2022 by offering our deepest number of active names ever. The week also ranked in our top 5 weeks for match quantity in both ASPEN^3 and Midpoint.
- So far, January has been our best month ever for matching larger sizes of demi-blocks or bigger (starting at 2000 shares).
- This growth is driven by the unique displayed liquidity on our free market data feed, IQX. Last week orders displayed on IQX improved the NBBO on arrival over 8mm times a day and were median trade size or larger more than 95% of the time.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Dec 27, 2021
December 27, 2021 Weekly Update
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- IntelligentCross closed 2021 with our best month ever, setting platform records for daily match-quantity and market share vs. the total consolidated volume (TCV).
- We also saw a new record specifically for daily match-quantity from displayed orders on our market data feed, IQX.
- In December, orders displayed on IQX improved the NBBO on arrival over 8mm times a day with a spread savings of around 30%. IQX orders are median trade size or larger over 95% of the time.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Dec 20, 2021
December 20, 2021 Weekly Update
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- As we look back on another successful year, we are so grateful for the continued support of our subscribers, clients, and friends.
- Monthly, from December 2020, to December 23rd 2021: the platform has had a 150% increase in overall daily matched shares, and a 135% increase in total consolidated volume market-share.
- Our growth has elevated us to a FINRA weekly ranking of 5th or 6th for all ATS in NMS Tier 1 stocks since October (https://otctransparency.finra.org/otctransparency/AtsData).
- Most importantly, we have seen a 300% increase in daily matched shares from orders that are displayed on our ASPEN^3 market-data feed, IQX calculated over the same period.
- Displayed orders on ASPEN^3 were priced better than the NBBO on arrival in December over 40% of the time, improving the spread by over 30%.
- Thank you again for your support and we look forward to working with you in 2022. We wish you a happy and healthy New Year.

Dec 13, 2021
December 13, 2021 Weekly Update
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- IntelligentCross would like to wish everyone happy holidays and an enjoyable, healthy long weekend with friends and family.
- Last week was our best ever. We set new single day records for total matched shares and market-share versus the total consolidated volume.
- We also had our best week for daily matched shares against orders displayed on our free market-data feed, IQX, where over 95% of our orders are median trade size or larger.
- Our unique displayed liquidity continues to provide spread saving value to our subscribers. Last week displayed orders were better than the NBBO on arrival over 44% of the time with spread savings of 29%.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Dec 6, 2021
December 06, 2021 Weekly Update
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- IntelligentCross would like to wish everyone happy holidays and an enjoyable and healthy long weekend with friends and family.
- Last week was our best ever. We set new single day records for total matched shares and market share of the total consolidated volume.
- We also had our best week for daily matched shares against orders displayed on our free market-data feed, IQX, where over 95% of our orders are median trade size or larger.
- Our unique displayed liquidity continues to provide spread savings value to our subscribers. Last week displayed orders were better than the NBBO on arrival 45% of the time with spread savings of over 30%.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Nov 29, 2021
November 29, 2021 Weekly Update
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- IntelligentCross opened the first full week of December with our best market-share vs total consolidated volume day ever: we were just over 70bps.
- We also had our best week for daily matched shares against orders displayed on our free market-data feed, IQX.
- Our unique displayed liquidity continues to provide spread savings value to our subscribers. Last week displayed orders were better than the NBBO on arrival 43% of the time with spread savings of 30%.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Nov 22, 2021
November 22, 2021 Weekly Update
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- Last week, IntelligentCross saw a new record day for matched shares on the platform and has been above 60bps of total consolidated volume for a record 4 weeks in a row.
- 49% of orders displayed on our market data feed, IQX, were priced better than the NBBO last week and over 96% were median trade size or larger.
- This unique liquidity has helped us set 3 straight weeks of records for matched shares of demi-block or larger (e.g., beginning at 2000 shares or $100k).
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Nov 15, 2021
November 15, 2021 Weekly Update
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- We would like to wish everyone a very happy and relaxing Thanksgiving, and a joyous start to the holiday season.
- In the spirit of the holiday, we thank all our subscribers and supporters as we remain at our platform best 5th for total shares traded of NMS Tier 1 stocks in FINRA ATS weekly rankings (https://otctransparency.finra.org/otctransparency/AtsData).
- Unique liquidity continues to be the driver. Last week was our best week ever for demi-block trades or larger (starting at 2000 shares or $100k), while orders displayed on our ASPEN^3 market-data feed IQX were priced better than the NBBO over 40% of the time.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Nov 8, 2021
November 08, 2021 Weekly Update
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- Last week IntelligentCross had its highest market-share day ever vs the total consolidated volume. This was supported by the platform's best week for demi-block or larger trades (starting at 2000 shares or $100k).
- Market-share growth has propelled us into the top 5 for total shares traded of NMS Tier 1 stocks in FINRA ATS rankings for 2 of the last 4 weeks (https://otctransparency.finra.org/otctransparency/AtsData).
- Orders displayed on our ASPEN^3 market-data feed, IQX, continue to provide unique liquidity for subscribers. Last week we saw displayed orders in over 5900 names daily. These displayed orders were priced better than the NBBO over 7.8mm times per day on arrival.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.

Nov 1, 2021
November 01, 2021 Weekly Update
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- Last week was IntelligentCross' best week ever. We achieved new records in platform market share vs. the total consolidated volume and in daily matched shares.
- Part of our growth is coming from an increase in larger size transactions. Last week was the platform's second-best week for trades considered demi-blocks or larger (i.e., above 2000 shares or $100k).
- Overall, ASPEN^3 continues to be the driver, setting a record for average daily shares matched for the 9th week in a row.
- This is due to our unique displayed liquidity. Last week, orders displayed on our IQX market data feed were median trade or larger 95% of the time and priced better than the NBBO 40% of the time on arrival for a spread savings of 30%.
- Please contact the desk for more information on getting IQX - it's available directly or through Exegy, MayStreet, Redline, and ACTIV.