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 Level ATS 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.

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:

NYSE American – formerly NYSE MKT and NYSE Amex NYSE
BZX Equities
Chicago Stock Exchange
NASDAQ
Virtu

Options:

Dash Financial Technologies
NYSE Amex Options
NYSE Arca Options
CBOE
ISE
ISE Gemini
NASDAQ PHLX

Fixed Income

Bloomberg
MarketAxess
Tradeweb
MuniBrokers
ICE TMC Bonds
ICE Bondpoint
Tradeweb Direct
MTS Markets
ICE NYSE Bonds