Alternative Trading Systems (ATSs) have grown to become integral sources of liquidity for many traders. At the same time, numerous high-profile regulatory enforcement actions, press reports, and best-selling books have raised significant questions regarding 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 is a multi-pronged effort to enhance ATS disclosure practices. Our work includes:

• Creation and distribution of a Member Report summarizing key issues disclosed in each of the leading ATS-N reports.
• 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.
• 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.