Introduction This document outlines the changes to our FIX messaging specifications being implemented to support MiFID II/R for equity (and equity-like) and FFO instruments. Much of the material here is based on work performed by the FIX Trading Community s MiFID working groups (notably the Transparency, Transaction Reporting and Order Record Keeping working groups). New Order and Replace Request Messages Summary of changes identified by FIX Trading Community MiFID working groups In this table, fields that will not be supported by BofAML for equity/equity-like or FFO instruments are highlighted in grey. This table also identifies which fields are applicable for equities (including equity-like) or FFO. Data element FIX Standard Details FIX User Defined Details Applies to Short sell indicator Side(54) - existing field from 2.7 New value H -> Sell undisclosed n/a (as FIX Standard details) Order originating from an SI Client identifier New OrderAttributeGrp containing three fields, NoOrderAttributes(2593), OrderAttributeType(2594) and OrderAttributeValue(2595) with values: OrderAttributeType(2594)=5 (Systematic internaliser order) OrderAttributeValue(2595)="Y" Where using an explicit client identifier, use Parties - existing from 4.3 with fields as follows: Where the order is for a single client who is a legal entity: PartyRole(452) = 13 (Order Origination Firm) PartyIDSource(447) = N (LEI) or P (Short code identifier) Where the order is for a single client who is not a legal entity: PartyRole(452) = 13 (Order Origination Firm) PartyIDSource(447) = O (National ID) or P (Short code identifier) Where using the AGGR or PNAL codes (i.e. where the order has been or will be allocated to multiple clients), instead of the above, use New OrderAttributeGrp containing three fields: NoOrderAttributes(2593) OrderAttributeType(2594)=0 (Aggregated order) or 1 (Pending allocations) OrderAttributeValue(2595)="Y" 8015 OrderAttributeTypes - flattened version of OrderAttribute 20013 PartyIDOrderOriginationFirm with reserved values for PartyID as follows: 0 = NONE (No client for this order) 1 = AGGR (An aggregation of multiple client orders) 2 = PNAL (Clients are pending allocation) The AGGR/PNAL codes may alternatively be represented using 8015 OrderAttributeTypes - flattened version of OrderAttribute. & FFO 2017 Bank of America Corporation 1 Proprietary
Data element FIX Standard Details FIX User Defined Details Applies to Commodity deriv risk reduction flag Order destination instruction (i.e. to trade on a TV, SI etc.) New OrderAttributeGrp 8015 OrderAttributeTypes - containing three fields, flattened version of NoOrderAttributes(2593), OrderAttribute OrderAttributeType(2594)=3 (Risk reduction order) OrderAttributeValue(2595)="Y" ExDestinationType(2704) 0 = No trading venue restriction 1 = Can be traded on a trading venue 2 = Can be traded on a Systematic Internaliser (SI) 3 = Can be traded on a trading venue or Systematic Internaliser (SI) As FIX Standard details FFO RFMD vs. order indicator DEA client subdelegated client id BookingType(775) - existing field from 4.4 0 (regular booking) -> order 1 (CFD) or 2 (total return swap) -> RFMD Parties - existing from 4.3 with PartyRole(452) = 3 (Client ID) As FIX Standard details 20003 PartyIDClientID Both DEA client trader id Parties - existing from 4.3 with PartyRole(452) = 11 (Order origination trader) 20011 PartyIDOrderOriginationTrader Both Order instruction to report to an APA (under assisted reporting arrangement) APA to be used for trade reporting New OrderAttributeGrp containing three fields, NoOrderAttributes(2593), OrderAttributeType(2594) and OrderAttributeValue(2595) with values: OrderAttributeType(2594)=6 (All executions for the order are to be reported to an APA) OrderAttributeValue(2595)="Y" Parties - existing from 4.3 with fields as follows: PartyRole(452) = 123 (Publishing intermediary) PartyIDSource(447) = G (MIC) PartyID(448) = the APA's MIC 8015 OrderAttributeTypes - flattened version of OrderAttribute 20123 PartyIDPublishingIntermediary n/a n/a 2017 Bank of America Corporation 2 Proprietary
New Order and Replace Request Messages BofAML Implementation Short sell handling (equities ) The FIX Protocol implementation of the Side field (tag 54) maps to the MiFID long/short sell values as follows: MiFID Value Description FIX Value (Side 54) SELL No short sell 2 Sell SESH Short sale with no exemption 5 Sell short SSEX Short sale with exemption 6 Sell short exempt UNDI Information not available H Undisclosed sell We will support the new value 54=H for undisclosed sell but recognise that: Not all clients have a regulatory obligation to provide this (e.g. non-mifid investment firms), and Not all clients may be able to modify their systems to support the new value. We will therefore implement logic to handle the following models and require that clients inform us which model they will be using so we can configure our FIX infrastructure accordingly: Model Client Implementation BofAML Implementation 1 full support Client implements short sell marking logic (or simply doesn t sell short at all) and will send 59=2 for long sells, 59=5 for short sells and 59=6 for exempt short sells. 54=2 SELL 54=5 SESH 54=6 SSEX 54=H UNDI 2 no short sell marking Client does not perform any short sell marking and any sell-like order is to be treated as an undisclosed sell. 54=2 UNDI 54=5 UNDI 54=6 UNDI 54=H UNDI Identification of SI orders (equities ) To ensure correct trade reporting of off-venue trades, we require knowledge of whether an order has been received from a systematic internaliser. We have the ability to store this information at a per client level where the client is: An SI in all equity/equity-like MiFID instruments, An SI in no equity/equity-like MiFID instruments 2017 Bank of America Corporation 3 Proprietary
An SI in some equity/equity-like MiFID instruments (and will flag as such on inbound orders) We will require: All clients to inform us as to which of the above they fall into, and If they fall into the last category, then they are to inform us on each inbound new order/replace request message whether they are an SI in the instrument concerned using either: 2593=1; 2594=5; 2595=Y, or 8015=5 These are equivalent from a FIX perspective (the former being the standard implementation and the latter being a simplification for clients not willing/able to implement repeating groups). Assisted trade reporting BofAML is not planning to support assisted trade reporting for equities/equity-like MiFID instruments (on the grounds that it will be an SI in all such instruments). As such, the following fields as listed in the above table will not be supported by BofAML (they will be simply ignored if they are provided): Order instruction to report to an APA (under assisted reporting arrangement) APA to be used for trade reporting Identification of client and pre-aggregated orders In this section, the term LEI refers to the legal entity identifier for the entity facing BofAML, i.e. an investment manager (not the funds managed by the investment manager). To meet both transaction reporting requirements and the record keeping requirements of trading venues, BofAML must know, for every inbound order: Whether the order is received from a single LEI and, if so, what that LEI is. This can be pre-configured into the BofAML trading infrastructure if there is a one to one mapping between FIX session and client LEI or by pre-agreed mapping from a FIX field. We will also support explicit identification of the LEI using the full FIX structure 453=1; 452=13 (Order Origination Firm); 447=N (LEI); 448 = the LEI value (or user defined equivalent 20013 PartyID (Order originationfirm). For FFO, we will continue to support the GMI account specified in tag 1 and, by default, will use that to map to the appropriate LEI. Whether the order is received as an aggregation across multiple LEIs. This must be flagged to us by setting either: 2954=0; 2594=1; 2595=Y, or 8015=0 These are equivalent from a FIX perspective (the former being the standard implementation and the latter being a simplification for clients not willing/able to implement repeating groups). If we receive both and aggregated order indicator AND an LEI identifier, we will consider the aggregation flag to override the LEI. 2017 Bank of America Corporation 4 Proprietary
Risk Reduction Flag (FFO ) For an order on a Commodity Derivative product, this flag indicates whether the transaction reduces risk in an objectively measurable way in accordance with Article 57 of Directive 2014/65/EU. To indicate an order that reduces risk: OrderAttributeType(2594) = 3 (risk reduction order) OrderAttributeValue(2595) = Y If not specified, BofAML will consider that the order is not risk reducing. Order Destination Instruction ( ) This indicates whether the order is to be traded on a trading venue, on a trading venue or SI, or has no restriction: ExDestinationType(2704)=0 no restriction on where the order is traded ExDestinationType(2704)=1 order can be traded on a trading venue ExDestinationType(2704)=3 order can be traded on a trading venue or SI ExDestination has an additional value 2 (SI ) which we are not planning to support. Note this field will apply in addition to any other order routing constraints (e.g. specific venue targeting or exclusion tags). Note also that we can support this as a standing instruction where clients require. RFMD vs. order indicator ( ) This indicates whether the new order single FIX message represents an actual order in the specified instrument, or a request for market data (RFMD) used to obtain a price for a derivative. This distinction needs to be known at the point of message capture as it affects the trading process and associated regulatory reporting. BookingType(775)=0 (regular booking) message is to be treated as an order in the specified instrument BookingType(775)=1 (CFD) message is to be treated as an RFMD BookingType(775)=2 (total return swap) message is to be treated as an RFMD Note also that we can support this as a standing instruction where clients require, and also that clients using different fields (e.g. tag 1) for this purpose will continue to be able to do so. Where clients do use 775, we will treat values 1 and 2 the same way. DEA Identifiers There are two requirements specifically for DEA activity as per RTS 6 article 21: Paragraph 3 requires that we be able to identify traders of DEA clients. We will support this using the full FIX structure 453=1; 452= 11 (Order origination trader); 447=D (Proprietary / Custom code); 448 = the 2017 Bank of America Corporation 5 Proprietary
trader id value (or user defined equivalent 20011 PartyIDOrderOriginationTrader). Paragraph 4 requires that we be able to differentiate clients of DEA clients in the case of sub-delegation. We will support this using the full FIX structure 453=1; 452=3 (Client ID); 447=D (Proprietary / Custom code); 448 = the underlying client id (or user defined equivalent 20003 PartyIDClientID). Note we are not required to know the actual identity of the underlying clients. Execution Report Messages Summary of changes identified by FIX Trading Community MiFID working groups In this table, fields that will not be supported by BofAML for equity/equity-like instruments are highlighted in grey. This table also identifies which fields are applicable for equities (including equity-like) or FFO. Those that are not provided by default but can be supplied on request are highlighted in blue. Data element FIX Standard Details FIX User Defined Details Applies to Execution capacity Execution venue identifier Transaction reporting venue identifier (i.e. XOFF or SI MIC) Trade report indicator0f1 LastCapacity(29) - existing field from 2.7 1 (agent) -> AOTC 2 (cross as agent) -> AOTC 3 (cross as principal) -> MTCH 4 (principal) -> DEAL New value 5 (riskless principal) -> DEAL n/a (as FIX Standard details) Both 30 Last Market As FIX Standard details Both Parties - existing from 4.3 with fields as follows: PartyRole(452) = 73 (Execution venue) PartyIDSource(447) = G (MIC) PartyID(448) = the SI MIC New TradeReportingIndicator field (2524) with values: 0 = Trade has not (yet) been reported 1 = Trade has been reported by a trading venue as an "on-book" trade 2 = Trade has been reported as a "systematic internalizer" seller trade 3 = Trade has been reported as a "systematic internalizer" buyer trade 4 = Trade has been reported as a "nonsystematic internalizer" seller trader 5 = Trade has been reported under a subdelegation arrangement by an investment firm to a reporting facility (e.g. APA) on behalf of another investment firm 20073 PartyIDExecutionVenue n/a (as FIX Standard details) 1 Two other values Trade has or will be reported as a "non-systematic internaliser" buyer trader and Trade has or will be reported by a trading venue as an off-book trade are pending allocation by the FIX technical committee and will be added to this specification as they become available. 2017 Bank of America Corporation 6 Proprietary
Data element FIX Standard Details FIX User Defined Details Applies to Venue transaction identifier RegulatoryTradeIDGrp with 8016 RegulatoryTradeIDType(1906) = 5 (Trading venue transaction identifier) and the value itself in RegulatoryTradeID(1903) TradingVenueRegulatoryTradeID Transaction time TransactTime (60) n/a (as FIX Standard details) "I am an SI" (order Parties - existing from 4.3 20063 recipient) (PartyRoleQualifier from 5.0) with fields as follows: PartyIDSystematicInternaliser SI execution indicator Broker's LEI PartyRole(452) = 63 (Systematic internaliser) PartyIDSource(447) = G (MIC) PartyID(448) = the SI MIC MatchType(574)=9 - existing from 4.3 As FIX Standard details Parties - existing from 4.3 with 20001 PartyIDExecutingFirm Both fields as follows: APA used for trade reporting PartyRole(452) = 1 (Executing firm) PartyIDSource(447) = N (LEI) PartyID(448) = the LEI Parties - existing from 4.3 with fields as follows: 20123 PartyIDPublishingIntermediary n/a PartyRole(452) = 123 (Publishing intermediary) PartyIDSource(447) = G (MIC) PartyID(448) = the APA's MIC Venue flags RFPT ref price waiver flag NLIQ NT flag OILQ NT flag New TrdRegPublicationGrp 0 (Pre-trade transparency waiver) TrdRegPublicationReason(2670) = 3 (No public price preceding order as public reference price was used for matching orders) New TrdRegPublicationGrp 0 (Pre-trade transparency waiver) TrdRegPublicationReason(2670) = 0 (No preceding order in book as transaction price set within average spread of a liquid instrument) New TrdRegPublicationGrp 0 (Pre-trade transparency waiver) TrdRegPublicationReason(2670) = 1 (No preceding order in book as transaction price depends on system-set reference price for an illiquid Instrument) 8013 TrdRegPublicationReasons 8013 TrdRegPublicationReasons 8013 TrdRegPublicationReasons 2017 Bank of America Corporation 7 Proprietary
Data element FIX Standard Details FIX User Defined Details Applies to PRIC NT flag LRGS large in scale flag OM waiver flag OTC trade flags New TrdRegPublicationGrp 0 (Pre-trade transparency waiver) TrdRegPublicationReason(2670) = 2 (No preceding order in book as transaction price is subject to conditions other than current market price) New TrdRegPublicationGrp 0 (Pre-trade transparency waiver) TrdRegPublicationReason(2670) = 9 (No public price and/or size quoted as transaction size is large in scale) 8013 TrdRegPublicationReasons 8013 TrdRegPublicationReasons Both New TrdRegPublicationGrp 8013 TrdRegPublicationReasons 0 (Pre-trade transparency waiver) TrdRegPublicationReason(2670) = 10 (No public price and/or size quoted due to order being held in a trading venue's order management facility) BENC flag SecondaryTrdType(855) - existing field from 4.4, being added to execution reports 64 -> Benchmark n/a (as FIX Standard details) SDIV flag TradePriceConditionGrp - 8014 TradePriceConditions - existing from 4.4, being added to execution flattened version of reports TradePriceCondition(1839) = 13 (Special TradePriceConditions dividend) TNCP flag TradePriceConditionGrp - 8014 TradePriceConditions - existing from 4.4, being added to execution flattened version of reports TradePriceConditions TradePriceCondition(1839) = 16 (Trade exempted from trading obligation) ACTX flag TrdSubType(829) - existing field from 4.4, n/a (as FIX Standard details) being added to execution reports 37 -> Crossed trade RPRI SI flag TradePriceConditionGrp - 8014 TradePriceConditions - existing from 4.4, being added to execution flattened version of reports TradePriceCondition(1839) = 14 (Price TradePriceConditions improvement) ILQD SI flag (as per RTS 1) New TrdRegPublicationGrp 0 (Pre-trade transparency TrdRegPublicationReason(2670) = 4 (No public price quoted as order size is above standard market size") 8013 TrdRegPublicationReasons 2017 Bank of America Corporation 8 Proprietary
Data element FIX Standard Details FIX User Defined Details Applies to SIZE SI flag (as per RTS 1) LRGS deferral flag SIZE deferral flag (as per RTS 2) ILQD deferral flag (as per RTS 2) New TrdRegPublicationGrp 0 (Pre-trade transparency TrdRegPublicationReason(2670) = 5 (No public price quoted as order is above standard market size) New TrdRegPublicationGrp 1 (Post-trade deferral) TrdRegPublicationReason(2670) = 6 (Deferral due to "Large in scale") New TrdRegPublicationGrp 1 (Post-trade deferral) TrdRegPublicationReason(2670) = 8 (Deferral due to "Size specific") New TrdRegPublicationGrp 1 (Post-trade deferral) TrdRegPublicationReason(2670) = 7 (Deferral due to "Illiquid instrument") 8013 TrdRegPublicationReasons 8013 TrdRegPublicationReasons 8013 TrdRegPublicationReasons FFO 8013 TrdRegPublicationReasons FFO Note this table (specifically the list of trade flags) has been filtered for relevance to equity/equity-like MiFID instruments. Further flags are available for non-equity instruments. Execution Report Messages BofAML Implementation Venue identifiers FIX tag 30 will be used for the venue of execution and will be populated on all execution report messages representing actual executions (as opposed to order state changes). We will provide a segment level MIC where available (i.e. as provided to us by the execution venue), or operator MIC otherwise. Where we use a broker to access an execution venue, tag 30 will contain the identifier from the end execution venue, not the intermediary broker. Where trading in DEAL capacity we are required to notify our clients of the transaction reporting venue which is used in field 36 of clients market-side transaction reports. This will be represented, by default, using the FIX user defined field 20073 PartyIDExecutionVenue (though we will be able to use the full Party structure on request): NoPartyIds 453=1 PartyID 448=XOFF or an SI MIC PartyIDSource 447=G (MIC) PartyIDRole 452=73 (execution venue) In line with FIX guidelines, this field (or ) will be supplied on execution report messages denoting a client execution for transaction reporting purposes. 2017 Bank of America Corporation 9 Proprietary
Execution capacity We will use tag 29 (LastCapacity) to communicate the capacity in which we are working an order. This will be provided on all execution report messages and will not change during the life of an order. Our usage of this field is in line with FIX Protocol guidelines as follows: Value & Description Explanatory Guidance 1 (agent) An execution on a public market or from an external party (e.g. broker) conducted on an agency basis. For MiFID II, this will be used to represent AOTC capacity. 2 (cross as agent) An execution between two clients of the executing firm, taking place within the firm, and conducted on an agency basis. For MiFID II, this will be used to represent AOTC capacity. 3 (cross as principal) An execution on a public market or from an external party (e.g. broker) conducted on a matched principal basis in line with the MiFID definition of MTCH capacity. 4 (principal) An execution where the executing firm is committing capital (e.g. a risk fill or change in price on fills obtained from markets or external parties). Where the FIX execution message is being used to communicate an indicative price and quantity (for example when being used by the executing firm to write a swap), regardless of the source of liquidity. For MiFID II, this will be used to represent DEAL capacity. 5 (riskless principal) An execution on a public market or from an external party (e.g. broker) conducted on a riskless principal basis. For MiFID II, this will be used to represent DEAL capacity. Waiver and OTC flags We will support a number of the MiFID OTC trade flags and venue waiver flags (where made available to us by trading venues), using the FIX User Defined fields 8013 and 8014 where relevant. It should be noted that an execution may carry multiple flags, in which case 8013 and/or 8014 will contain multiple values, delimited by spaces: Flag BofAML Implementation Equity/equity-like-Specific OTC Flags Trade reported on a deferred basis (LRGS) 8013 contains 6 SI trade in illiquid instrument (ILQD) 8013 contains 4 SI trade above standard market size (SIZE) 8013 contains 5 Non price forming trade (TNCP) 8014 contains 16 Special dividend trade (SDIV) 8014 contains 13 Benchmark price trade (BENC) 855 = 64 Agency cross trade (ACTX) Not supported by BofAML 2017 Bank of America Corporation 10 Proprietary
Flag SI trade with price improvement (RPRI) BofAML Implementation Not supported by BofAML Equity/equity-like-Specific Venue Waiver Flags Reference price waiver (RFPT) 8013 contains 3 Execution arising from order using a large in scale waiver 8013 contains 9 Execution arising from order using an order mgt system waiver 8013 contains 10 FFO-Specific Flags Above specific size (SIZE) 8013 contains 8 Illiquid instrument (ILQD) 8013 contains 7 It should be noted that the venue waiver flags are provided for informational purposes (i.e. are not required fields for MiFID II compliance) except for DEA clients, where these are required for record keeping purposes. These flags will be provided on execution report messages representing actual executions from trading venues (as opposed to order state changes). Trade reporting fields (equities ) We will provide an indicator (field 2524) on execution reports to indicate whether the trade has been reported and, if so, why: Value Description 0 Trade has not (yet) been reported 1 Trade has or will be reported by a trading venue as an "on-book" trade 2 Trade has or will be reported as a "systematic internalizer" seller trade 3 Trade has or will be reported as a "systematic internalizer" buyer trade 4 Trade has or will be reported as a "non-systematic internalizer" seller trader 5 Trade has or will be reported under a sub-delegation arrangement by an investment firm to a reporting facility (e.g. APA) on behalf of another investment firm. Tbd1 Tbd2 Trade has or will be reported as a "non-systematic internaliser" buyer trader Trade has or will be reported by a trading venue as an off-book trade Values marked in italics will not be provided by BofAML for equity/equity-like MiFID instruments as: 2017 Bank of America Corporation 11 Proprietary
We are not planning to support assisted trade reporting in these products (which rules out value 5), and We will be an SI in all these products (which rules out value Tbd1). This flag will be provided on execution report messages representing actual executions (as opposed to order state changes). Given BofAML will not be supporting assisted trade reporting in equity/equity-like MiFID instruments, the APA used for trade reporting field will not be supported. SI Indicators (equities ) Given BofAML will be an SI in all equity/equity-like MiFID instruments, the I am an SI indicator is somewhat unnecessary. Hence BofAML will not be providing this by default, though should clients require this, we can add this as a customisation to a FIX connection. BofAML will also not be providing the SI execution indicator by default (given it can be inferred directly from tag 30) but, as above, can be added as a customisation on request. Broker LEI BofAML will not be providing the Broker LEI by default but it can be added as a customisation on request in either standard or user defined form. Transaction Time BofAML will provide a Transaction Time (tag 60) as standard. For DEA activity, we will provide this from the trading venue directly to the level of granularity as specified by the venue. This may be up to microsecond granularity. Trading Venue Transaction Identifier This will be provided for DEA activity (in addition to the existing tag 17 execution id, which is generated internally) and is a pass-through of the transaction id supplied by the trading venue. This will be represented, by default, using the FIX user defined field 8016 TradingVenueRegulatoryTradeID (though we will be able to use the full RegulatoryTradeIDGrp structure on request): NoRegulatoryTradeIDs (1907) =1 RegulatoryTradeIDType(1905) = 5 (Trading venue transaction identifier) RegulatoryTradeID(1903) = the actual value Contacts If you would like further information or you have any related enquiries, please contact your BofAML Sales Representative or the Market Structure Desk (emeamarketstructure@baml.com +44 20 7996 3179) 2017 Bank of America Corporation 12 Proprietary
Execution Sales E-mail +44 20 7996 9935 DMA Desk E-mail +44 20 7996 6044 Execution Consulting E-mail +44 20 7995 6382 Market Structure E-mail +44 20 7995 3179 Americas Trading +1.212.449.6090 Europe Trading +44.207.996.4521 Japan Trading +813.6225.8398 Asia Trading +852.2161.7550 BofAML Instinct X Bank of America Merrill Lynch ( BofAML ) operates Instinct X, an Alternative Trading System ( ATS ) in the US and as a Broker Crossing Network ( BCN ) in other geographies. BofAML seeks to operate its ATS/BCNs in accordance with applicable regulations, and in accordance with reasonable expectations of fairness. However, potential execution counterparties in BofAML s ATS/BCNs and in external venues may have trading objectives and/or expectations that may be adverse to your own, and so execution outcomes may vary. BofAML makes no guarantee as to the performance that can be achieved through the use of its ATSs or BCNs. Within its own ATSs and BCNs, BofAML may offer a variety of crossing services that support a segmentation and/or tiering model to enhance Client choice regarding the nature of potential counterparties with whom they may execute. Where it does so, BofAML will use reasonable efforts to adhere to your expressed preferences regarding the use of different crossing services, to assign Clients to the appropriate segment and to maintain those assignments, and to adhere to your expressed preferences regarding interaction with participants in such segments. While BofAML will use reasonable efforts in this context, it makes no guarantee as to accuracy or consistency of the composition of any segmentation assignment, which may be based in part on BofAML s understanding of information supplied by others. BofAML Routing and Order Handling In the absence of instructions to the contrary, or depending upon your expressed preferences, the particular BofAML routing strategy or algorithm that you may elect to employ, or that is employed on your behalf, and as part of BofAML s services seeking the most efficient and effective experience for Client orders, your orders may be given an opportunity to interact with any resident non-displayed orders in one of BofAML s own ATSs or BCNs, which may include BofAML principal trading interest (which may include BofAML internal liquidity provision in relation to BofAML s own BCNs), prior to being exposed to external venues. External venues may include but not be limited to public exchange markets, multi-lateral trading facilities, other ATSs or BCNs, or broker dealers, (such routing appropriate to each BofAML region) consistent with your instructions or BofAML s routing logic as applicable. While BofAML maintains relationships and connectivity to a variety of such venues as part of its routing processes, BofAML does not represent that it has access to all such venues that potentially may be available at any given point in time. To the extent that this document references performance times, such information is indicative and attempts to illustrate the performance speed and latency generally associated with certain systems, order/message paths, and linkages. Actual performance may be different and, in some cases, materially slower than indicated. Additional Disclaimers and Information Bank of America Merrill Lynch is the marketing name for the global banking and global markets businesses of Bank of America Corporation. Lending, derivatives, and other commercial banking activities are performed globally by banking affiliates of Bank of America Corporation, including Bank of America, N.A., member FDIC. Securities, strategic advisory, and other investment banking activities are performed globally by investment banking affiliates of Bank of America Corporation ( Investment Banking Affiliates ), including, in the United States, Banc of America Securities LLC and Merrill Lynch, Pierce, Fenner & Smith Incorporated, which are both registered broker dealers and members of FINRA and SIPC, and, in other jurisdictions, locally registered entities. 2017 Bank of America Corporation 13 Proprietary
Investment products offered by Investment Banking Affiliates: Are Not FDIC Insured * May Lose Value * Are Not Bank Guaranteed. The material contained herein is for our clients for informational purposes, and does not constitute an offer to buy or sell or a solicitation of an offer to buy or sell any security or other financial instrument. Bank of America Merrill Lynch makes no representation, warranty or guarantee, express or implied, concerning this document and its contents, including whether the information (which may include information and statistics obtained from third party sources) is accurate, complete or current. The information in this document is provided as is, is subject to change at any time, and Bank of America Merrill Lynch has no duty to provide you with notice of such changes. Where the information relates to legislative initiatives, it represents a non-exhaustive summary of BofAML s current understanding of the legislation and the proposed timeframes as at the date of this publication, which is subject to change pending further clarification of the rules through the legislative rule making and implementation processes in the relevant jurisdiction. The information in this document is not intended to constitute nor should it be construed as advice of any kind, whether in relation to legal, compliance, accounting, regulatory matters or otherwise. You should discuss with your professional legal, accounting or other adviser how it may affect you. Where this communication constitutes a financial promotion/marketing communication it is issued and approved for distribution in the UK by Merrill Lynch International to, and directed at, (a) persons who have professional experience in matters relating to investments falling within Article 19(1) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (the Order ) or (b) high net worth entities, and other persons to whom it may otherwise lawfully be communicated, falling within Article 49(1) of the Order (all such persons together being referred to as relevant persons ). This communication must not be acted on or relied on by persons who are not relevant persons. Any investment or investment activity to which this communication relates is available to relevant persons and will be engaged in with relevant persons. The UK compensation scheme and rules for the protection of retail clients do not apply to the services provided or products sold by non-uk regulated affiliates. This information is not a publication of BofA Merrill Lynch Global Research, although a BofA Merrill Lynch Global Research report may be referenced as a link or as an attachment hereto. Any summary of BofA Merrill Lynch Global Research is qualified in its entirety by the views of BofA Merrill Lynch Global Research and the specific disclaimers associated with that report. BOFAML and any affiliate may trade for its own accounts in any of the securities of issuers mentioned herein or in related investments, or other products, and may also from time to time perform or solicit investment banking or other services for, or from, any entity mentioned herein. Bank of America and its affiliates do not operate as a banking entity in all jurisdictions. Some products and services may not be available in all jurisdictions or to all clients. Where products are not regulated by the Financial Conduct Authority, this will be made clear. Instinct and Trader Instinct are trademarks of Bank of America Corporation in the U.S. and other countries. 2017 Bank of America Corporation. All rights reserved. http://www.bankofamerica.com. 2017 Bank of America Corporation 14 Proprietary