Alternative Trading Systems (ATSs) have received quite a bit of attention in recent years. From Flash Boys, numerous high-profile SEC cases, to the New York Attorney General, the spotlight has focused squarely on ATSs' disclosures and operations. At Healthy Markets, we believe that meaningful disclosures are crucial for investors and brokers to make informed order routing decisions.

The Healthy Markets ATS Transparency Initiative, which is supported by our ATS Transparency Working Group, is a multi-pronged effort to enhance ATS disclosure practices. Our work includes:

• Creation and distribution of the 2016 ATS Risk Assessment, which provides comprehensive comparisons and analyses of 18 leading ATSs, on issues ranging from conflicts of interest to technology risks. This report will help investors understand how each ATS operates, and what risks they pose.
• Creation and distribution of the ATS Transparency Index™, which provides a unique system to help inform market participants of ATSs' transparency and disclosure practices.
• Development of ATS disclosure best practices and working with individual ATSs to improve disclosure practices.
• Development and publication of unique reports related to key issues impacting ATSs, including the Dark Side of the Pools: What Investors Should Learn from Regulators' Actions.
• Development and publication of the 2017 Healthy Markets ATS Questionnaire to help investors and routing brokers make more informed venue selection decisions.
• Offering suggestions to regulators and the public regarding the regulation of ATSs, including through regulatory comment letters.