In the U.S. the most significant recent market structure developments include: (1) Tick Size Pilot Plan: KCG and more than 50 other market participants submitted comment letters to the SEC; (2) the SEC adopted new Regulation SCI; and (3) ICE/NYSE and BATS offered a competing slate of market structure reforms. In Europe, ESMA continued to move forward on MiFID II and MiFIR and the European Commission is focusing on the recovery and resolution of CCPs.

FEBRUARY 2015

Market Structure Review

In this Issue:

U.S. Market Structure Initiatives and Developments

KCG’s Tick Size Comment Letter Offers Suggestions for Improvement

2

SEC Adopts Regulation Systems Compliance and Integrity

4

Exchanges Offer Recommendations on Changes to Equity Market Structure

6

FINRA Rulemaking Initiatives on Equity Market Structure

8

Statements by Regulators Regarding Equity Market Structure

9

Europe Market Structure Initiatives and Developments

ESMA Pushes Ahead with MiFID II and MiFIR

10

Delay in European Rules on Interest Rate Swaps (IRS)

12

The Recovery and Resolution of CCPs 13

Market Structure Review Feb 2015 2Back to Table of Contents

KCG’s Tick Size Comment Letter Offers Suggestions for Improvement KCG filed a comment letter with the SEC regarding the Tick Size Plan on December 19, 2014, in which we (1) voiced significant concerns regarding the “trade-at” requirement in Test Group Three of the Proposed Plan and argued it should be eliminated from the pilot and (2) expressed support for the approach taken with respect to Test Groups One and Two of the Proposed Plan.

As background, the SEC issued an order in June 2014 directing FINRA and the U.S. equity exchanges (collectively the “SROs”) to act jointly in developing and filing a plan to implement a tick size pilot program. The SROs jointly filed their Tick Size Plan with the SEC in August 2014. In November 2014 the SEC published the SROs’ Tick Size Plan and requested comment on all aspects of the Plan by December 22, 2014. To date, more than 50 commenters have submitted comment letters regarding the Plan to the SEC. KCG submitted a detailed comment letter with our views, which is summarized below. KCG View: Below are the key points raised by KCG in our December 19, 2014 letter. Our opposition to the trade-at component is in line with the majority of comment letters.

• KCG supports a continual review of market structure, including tick sizes, but disagrees that the ability of small and emerging companies to raise capital will be enhanced by widening the minimum tick size of such companies’ stock.

• It is imperative that the Tick Size Pilot be tightly controlled and subject to rigorous analysis as it could have a profound impact on U.S. equity market structure.

• The Tick Size Pilot will lead to wider spreads for securities in all three Test Groups that will increase transaction costs for retail and institutional investors.

• The Tick Size Pilot should be implemented and analyzed by the Commission instead of the SROs and a cost/benefit analysis should be conducted to ensure that any costs imposed by the Tick Size Pilot are outweighed by any benefits of wider tick sizes to listing companies and other constituencies.

• An optimal structure for the Tick Size Pilot would include one test group (instead of three) containing only a minimum quoting increment of $0.05.

U.S. Market Structure Initiatives and Developments

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Market Structure Review Feb 2015 3Back to Table of Contents

• The trade-at requirement raises numerous significant concerns:

 ⚪ The trade-at requirement is anti-competitive in that it restricts competition and forces wholesale market makers, like KCG and our competitors, to route to exchanges despite the fact that certain clients do not want their orders routed to exchanges.

 ⚪ To be successful, the Pilot should be strictly limited to experimenting with a single variable—wider tick sizes—for small-cap issuers. By introducing other market structure experiments (variables) such as a trade-at requirement within the Pilot the Commission will not be able to determine which caused its success or failure.

 ⚪ The Tick Size Pilot is too important to serve as a battleground for the long-standing industry debate about the merits of a trade-at rule, which certain market participants (primarily exchanges) have been advocating in favor of for years.

 ⚪ The trade-at requirement will harm investors by increasing trading costs for retail and institutional investors, as they will be forced to pay access fees when trading on exchanges while at the same time increasing the likelihood of information leakage.

 ⚪ The routing requirements to comply with the trade-at component dramatically increase complexity of the Tick Size Pilot and increase the operational risks for the entire marketplace.

Next steps for the Tick Size Pilot include: (1) a review by SEC staff of all comment letters received, which to date number more than 50; (2) a vote by SEC Commissioners on whether to implement the Tick Size Plan as initially submitted by the SROs or if it is necessary for the SROs to make revisions to their Plan based on the comments submitted; and (3) when approved, the Tick Size Pilot will be implemented for a period of one year.

Learn more:

>> KCG’s full comment letter

>> All comment letters submitted to the SEC

>> KCG Market Commentary “Who Gets the Short End of the ‘Tick?”

>> KCG Market Commentary “Today’s Spreads Make More Sense than Nickels”

>> SEC notice soliciting comments on SROs’ proposed Tick Size Pilot Plan

>> Tick Size Plan filed by the SROs

>> Press release for the Tick Size Plan filed by the SROs

>> SEC’s order directing the SROs to submit a Tick Size Pilot Plan

Market Structure Review Feb 2015 4Back to Table of Contents

SEC Adopts Regulation Systems Compliance and IntegrityOn November 19, 2014, the Commission adopted new Regulation Systems Compliance and Integrity (“Reg SCI”), which is designed to establish uniform requirements relating to the automated systems of self-regulatory organizations and market utilities. The new rule set requires “SCI Entities” (exchanges, FINRA, registered clearing agencies, plan processors, and certain high volume ATSs) to comply with capacity, integrity, security and testing requirements for their automated systems that support their regulated activities. Significantly, at this time Reg SCI does not apply to other market participants, such as market makers like KCG who internalize order flow, although there was debate among regulators about expanding the scope of the rule to do so. The SEC received more than 50 comment letters in response to Reg SCI, including a comment letter from KCG in which we advocated against expanding Reg SCI to cover broker-dealers.

Reg SCI formalizes, strengthens, and makes mandatory the decades-old voluntary guidelines previously followed by exchanges, clearing agencies, the MSRB, and FINRA and also applies these expanded requirements to certain ATSs with significant volume. In general, Regulation SCI requires SCI Entities to (1) establish policies and procedures reasonably designed to help ensure that their systems are robust, secure, and compliant; (2) file with the SEC notices and reports about the occurrence of certain adverse system events or material changes to such systems; and (3) require SRO members and ATS participants to participate in routine, industry-wide testing of their systems.

Although new Reg SCI does not apply to broker-dealers, SEC Chair Mary Jo White stated that she had directed SEC staff to prepare recommendations for the Commission’s consideration as to whether an SCI-like framework should be developed for other key market participants that are not included in the current definition of SCI entity, such as broker-dealers. If the SEC ultimately seeks to apply some or all of the requirements of Reg SCI to entities not already covered by the rule, it will issue a proposing release discussing such a proposal and seeking public comment on the issue. KCG will advocate against expansion of Reg SCI to include broker-dealers. Continues on the next page.

Market Structure Review Feb 2015 5Back to Table of Contents

KCG View: We are strongly opposed to expansion of Reg SCI to cover additional entities, including broker-dealers. Below is a summary of reasons we oppose expansion of Reg SCI’s scope.

• Regulation SCI was specifically intended to supersede and enhance the voluntary ARP inspections program for exchanges, which the GAO found to be a significant limitation and recommended mandatory compliance with ARP guidelines.

• Regulation SCI should be targeted to services offered by only one or a few entities (so called market utilities) and these “single points of failure” should be subject to heightened regulatory requirements. For example, opening and closing auctions, trading halt coordination, IPO auctions, and market data consolidators are functions on which all participants rely and for which there is no commercial alternative. Given their position in our market structure, market utilities should be subject to unique and greater levels of oversight and surveillance.

• Unlike market utilities, broker-dealers perform functions that do not have a systemic impact on the operation of the national market system and, regardless of broker-dealer market share, they can be routed around if problems occur.

• Unlike exchanges, broker-dealers are already subject to extensive regulation designed to achieve many of the same goals as Regulation SCI, including SEC Rule 15c3-5, best execution obligations, WSP requirements, FINRA Rule 4530, BCP rules, and CCO reports.

• Unlike exchanges that are shielded from liability for even egregious conduct, broker-dealers do not benefit from absolute legal immunity.

• Most commenters who responded to the SEC’s request for comment on the issue of expansion opposed extending Regulation SCI to broker-dealers and other entities. Indeed, certain exchanges either took no view on the matter or opposed inclusion of broker-dealers and other entities under the new rule set. Among exchanges, only NYSE Euronext supported an expansion of scope to cover broker-dealers and, as evidenced by an ICE representative in a follow-up email to SEC Commissioner Aguilar on September 22, 2014, this is based on competitive reasons: “…it is important to us to compete on a level playing field and these regulations ultimately need to protect that concept.”

Learn more:

>> SEC release adopting Regulation SCI

>> SEC release proposing new Regulation SCI

>> KCG’s comment letter on Regulation SCI

Market Structure Review Feb 2015 6Back to Table of Contents

Exchanges Offer Recommendations on Changes to Equity Market Structure In December 2014, news reports surfaced about a so-called “grand bargain” to overhaul market structure promoted by ICE/NYSE, in which exchanges would dramatically cut trading fees if banks agreed to support a trade-at requirement designed to force more order flow to exchanges. BATS responded to ICE’s grand bargain with an open letter to the industry setting forth its own approach for market structure reforms and also formally filed a petition for rulemaking on market structure reform with the SEC. The SEC has published the BATS petition and comments letters can be submitted to the SEC via email at rule-comments@sec.gov and should reference the BATS Petition 4-680. In its letter, BATS opposed ICE’s proposal and argued that although ICE’s grand bargain would likely benefit exchanges it would ultimately harm end investors by widening spreads and providing them with fewer and inferior execution choices. KCG also issued a statement opposing and criticizing ICE’s grand bargain as an elephant-gun approach motivated by a select handful of market participants.

In their proposals, both ICE and BATS outlined specific positions on several key market structure issues currently being debated by the industry, including the merits of a trade-at rule, maker-taker pricing, access fee reductions, and imposition of trading center thresholds.

• Trade-at: ICE supports trade-at in conjunction with a reduced fee cap and BATS opposes trade-at.

• Maker-taker: ICE supports a ban on maker-taker pricing and BATS opposes any ban on maker-taker pricing.

• Access fees: Both ICE and BATS support a reduction in access fees.

• Trading center thresholds: Both ICE and BATS support setting a 1% minimum market share for a market center to be granted quote protection.

Although NASDAQ has not issued a similarly broad set of suggestions for market structure reform, it has proposed to reduce access fees (and rebates) for 14 symbols (7 NASDAQ-listed and 7 NYSE-listed) for a four-month period that began on February 2, 2015. As noted by several observers, including SIFMA in a comment letter filed with the SEC, the limited scope and length of NASDAQ’s

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Market Structure Review Feb 2015 7Back to Table of Contents

pilot will likely decrease its effectiveness and produce insufficient data from which to draw broader implications concerning the impact of reduced access fees. KCG View: The ongoing debate about key market structure issues, particularly around trade-at and reduction of access fees, will continue to intensify throughout 2015. KCG agrees that current market structure needs to be reviewed. Specifically, we believe (1) the obligations associated with market making need to be modernized to reflect today’s electronic marketplace; (2) trade-at restrictions are an anti-competitive and would ultimately harm investors (particularly retail) by limiting their opportunities for price improvement and would only add greater complexity to our market; (3) pricing structures such as maker-taker generally should be driven by market forces; (4) access fees should be reduced to a de minimis level as current access fees are too high, distort price discovery, and cause unnecessary complexity; and (5) it would beneficial to set appropriate trading center thresholds for quote protection.

With respect to NASDAQ’s access fee cap pilot, KCG supports SIFMA’s view that “NASDAQ’s proposal will not contribute meaningful data to any larger market structure questions at hand.” Specifically, SIFMA’s view is that the scope of NASDAQ’s proposal is extremely limited—it will apply only to transactions in those securities on NASDAQ. In addition, the length of the pilot is only four months and it only applies to a total of 14 symbols. KCG supports a reduction in access fees and believes any pilot designed to examine the impact of reduced access fees must be carried out across all exchanges for a meaningful period of time and with a much larger sampling of symbols than NASDAQ’s pilot.

Learn more:

>> Discussion of ICE’s grand compromise

>> BATS open letter to the industry

>> BATS Petition for Rulemaking

>> NASDAQ’s proposal lowering access fees for a select group of securities

>> SIFMA’s Comment Letter on NASDAQ’s proposal

Market Structure Review Feb 2015 8Back to Table of Contents

FINRA Rulemaking Initiatives on Equity Market Structure FINRA recently proposed several rulemakings relating to equity market structure and automated trading activities, which are part of FINRA’s response to SEC Chair White’s call to action on market structure issues. Among others, FINRA has issued Regulatory Notices requesting comment on the following proposals: (1) identify OTC equity trades reported more than two seconds after execution as “out of sequence” and not last sale eligible (Regulatory Notice 14-46); (2) expanding its ATS transparency initiative to publish OTC equity volume executed outside ATSs (Regulatory Notice 14-48); and (3) requiring reporting of additional order information by ATSs in OATS (Regulatory Notice 14-51). FINRA has extended the comment period to February 20, 2015.

KCG View: Although the comment periods for these initiatives are still open and there will be separate opportunities to submit comments with the SEC on these proposals, KCG does intend to file comment letters with FINRA on these proposals.

• FINRA’s proposal in Regulatory Notice 14-46 to interpret the “as soon as practicable” trade reporting requirement to require members to disseminate trade information to other market participants no sooner than executed trade information is reported to FINRA is unclear. FINRA should clarify that members will be in compliance if trade information is contemporaneously output to market participants and FINRA regardless of when the information is ultimately received.

• FINRA’s proposal in Regulatory Notice 14-51 to require reporting of “additional order information” by ATSs, including all events and order attributes that would change the ATS’s system quantity, will generate an enormous amount of new OATS records and will not provide FINRA with the information it is seeking. There are, however, alternative approaches—such as the incorporation of special handling codes into OATS—that should allow FINRA to obtain additional order information without imposing significant costs on the industry.

Learn more:

>> FINRA regulatory notices

Market Structure Review Feb 2015 9Back to Table of Contents

Statements by Regulators Regarding Equity Market StructureSeveral regulators provided recent statements confirming their focus on market structure. For additional insight into the minds of these regulators, we have summarized their views below and provided links to the full text of their remarks.

SEC Chair White SEC Chair Mary Jo White explained that while work remains to be done, the SEC has made significant progress on a number of market structure issues, including: (1) adoption of Reg SCI; (2) publishing for comment the Tick Size Pilot Plan; (3) requesting exchanges conduct an analysis of order types and SIP feeds; and (4) bringing a number of significant enforcement actions for violations of market integrity rules.

Learn more:

>> Chair Mary Jo White’s December 23, 2014 letter to Senators Johnson and Crapo regarding the SEC’s progress in its review of equity market structure

Commissioner Gallagher Commissioner Daniel Gallagher stressed the need for the SEC to see past issues concerning high frequency trading and equities markets and begin to focus its attention on the fixed income markets. He specifically cited the need to facilitate bond market liquidity by working with the industry to create workable, market-based solutions.

Learn more:

>> Commissioner Gallagher’s October 24, 2014 remarks at the Los Angeles County Bar Association

Market Structure Review Feb 2015 10Back to Table of Contents

Europe Market Structure Initiatives and Developments

ESMA Pushes Ahead with MiFID II and MiFIRThe European Securities Markets Authority (ESMA) is pushing ahead on implementing technical rules under the revised Market in Financial Instruments Directive II (MiFID II) and Regulation (MiFIR).

The technical work on MiFID II/MiFIR (Level 1 legislation) secondary legislation is currently continuing at ESMA and the European Commission (Level 2 legislation). These implementing rules will contain the detailed technical requirements for many of the rules laid down in MiFID II/MiFIR.

The European Commission will have to develop definitions of high frequency trading (HFT), algorithmic trading, Direct Electronic Access (DEA), and systematic internalizer (SI). On December 19 the European Commission received technical advice (TA) from ESMA on these topics. ESMA advised the European Commission to align the regime of pre- and post-trade transparency for SIs with the regime for trading venues for non-equity instruments. ESMA also placed the responsibility on an SI to make sure its quotes are made public through a regulated market or MTF, a reporting service or a proprietary arrangement that must meet certain minimum criteria. These quotes must be made public to all market participants wanting to have access, in both a human- and machine-readable way.

In parallel to this process, ESMA is drafting a complementary set of implementing rules for which it sought the input from stakeholders in June and July 2014. In December 2014, ESMA released its draft rules for stakeholders to comment on by March 3, 2015. ESMA clarified its policy approach on several microstructural issues. ESMA is in favor of full unbundling of co-location services so that participants can choose which services they are willing to pay for. Investment firms obliged to enter into market making agreements will have to post quotes for at least 50% of the number of trading hours of a trading venue and will be incentivized to provide this liquidity accordingly. Trading venues will have to disclose the conditions of these market-making schemes. All trading venues allowing HFT and algorithmic trading must have an Order to Trade Ratio (OTR) in place, which they will be entrusted to set following indications by ESMA. Trading venues will be required to provide full transparency on the structure of their fees as well as benefits

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Market Structure Review Feb 2015 11Back to Table of Contents

and rebates and must base all these elements on objective and non-discriminatory criteria. ESMA will have to deliver these rules to the European Commission for endorsement by July 2015. These final rules cover a very large array of topics affecting financial markets, such as transparency issues, best-execution and investor protection, trading venue requirements, trading obligations, open-access for clearing, third country firms, and issues around commodity derivatives and position limits.

All implementing measures will apply from January 3, 2017 when MiFID II/MiFIR becomes fully applicable. KCG submitted a response in July 2014 and is currently preparing a response to the current consultation by ESMA. KCG View: MiFID II and MiFIR are designed to bring transparency and predictability to the financial markets, which will impact the way trading venues and market participants do business and may result in some trading shifting from non-displayed venues to displayed venues.

As the ESMA consultation continues and we work on our draft answer—either through industry associations or directly under our name—here is a glimpse of our first thoughts on some of the topics:

• We agree that DEA providers have a responsibility to have robust and resilient pre-trade controls. However, these requirements should be carefully calibrated to avoid duplication of efforts and unnecessary burden on investment firms who will be required to have similar requirements directly and in their capacity as a DEA provider;

• We welcome that market makers will be acknowledged for the services they provide to the market and the important role they play for enabling investors to transfer risk efficiently. However, the requirements imposed on market makers should not be too onerous that it jeopardizes prudent risk management practices;

• We agree that co-location should be provided in a fair, objective, transparent, and non-discriminatory manner and support the ban of cliff edge pricing structures because they are anti-competitive and reward trading volume quantity over quality;

• The impact of the proposed tick size regime is currently unknown and, therefore, we think that ESMA should include a provision that would allow national competent authorities to intervene and temporarily derogate from the new tick size tables in case of “degradation of market microstructure” with a notification requirement to ESMA.

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Market Structure Review Feb 2015 12Back to Table of Contents

Learn more:

>> ESMA discussion paper and consultation paper on implementing rule on MiFID II/MiFIR—May 22, 2014

>> Responses of KCG to the ESMA consultation of May 2014— consultation paper (Best-Execution & SI)

>> Responses of KCG to the ESMA consultation of May 2014—discussion paper (Investor Protection and pre- and post-trade transparency)

>> ESMA technical advice to the European Commission— December 19, 2014

>> ESMA consultation paper on implementing rule on MiFID II/MiFIR— December 19, 2014

>> Directive 2014/65/EU of the European Parliament and of the Council of May 15, 2014 on markets in financial instruments (MiFID II)

>> Regulation (EU) No 600/2014 of the European Parliament and of the Council of May 15, 2014 on markets in financial instruments (MiFIR)

Delay in European Rules on Interest Rate Swaps (IRS) The European Securities Markets Authority (ESMA) on October 1, 2014 sent to the European Commission its final report on draft implementing rules under the European Market Infrastructure Regulation (EMIR) specifying which type of interest rate swaps (IRS) must be centrally cleared through a CCP.

On December 18, 2014 the European Commission sent ESMA its amendments to the draft implementing rules. The amendments of the Commission relate to the postponement of the frontloading requirement and clarify the classification of counterparties subject to the clearing obligation.

The issue of frontloading relates to the pricing of OTC derivatives transactions that will become subject to the clearing obligation at a later stage. The future obligation is affecting the pricing of derivatives currently concluded as these may have to become centrally cleared before the end of their maturity.

ESMA published a feedback statement on February 4, 2014 on the Consultation on the Clearing Obligation for Non-Deliverable Forwards under EMIR.

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Market Structure Review Feb 2015 13Back to Table of Contents

The feedback statement summarizes the comments received to the consultation and concludes that based on the feedback received, ESMA is not proposing a clearing obligation on the NDF classes at this stage. ESMA believes that more time is needed to address appropriately the main concerns raised in the responses.

“ESMA takes note of the comments received and summarised above, in particular the ones related to the timing for the entry into force of a potential clearing obligation on nondeliverable forward classes, and its link with the CCPs (in EU or third-countries) available to clear NDF, the experience of counterparties with NDF clearing, and the importance of international consistency in the implementation schedule of the clearing obligation. In this respect, ESMA considers that the criteria for the determination of the clearing obligation should be further assessed considering the global nature of the FX market.”

It is, however, noted that the decision is without prejudice to the possibility for ESMA to propose a clearing obligation on the NDF classes (by the submission of a final report to the European Commission including a draft RTS) at a later point in time to take into account further market developments.

Learn more:

>> ESMA final report on implementing rules on the clearing obligation of IRS—October 1, 2014

>> Regulation (EU) No 648/2012 of the European Parliament and of the Council of July 4, 2012 on OTC derivatives, central counterparties and trade repositories (EMIR)

>> ESMA opinion on the modified implementing rules on the clearing obli-gation of IRS—January 29, 2015

>> ESMA statement on the Clearing Obligation for Non-Deliverable Forwards—February 2, 2015

The Recovery and Resolution of CCPsOn December 16, 2014, the European Commission unveiled its working program for 2015. One of the most important issues it hopes to address in 2015 is the resolution and recovery of financial market infrastructures such as CCPs.

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Market Structure Review Feb 2015 14Back to Table of Contents

Following the adoption of the European Market Infrastructure Regulation (EMIR) in 2012 and the mandatory central clearing of a majority of OTC derivatives, the issue is whether as a result of mandatory clearing systemic risk has been concentrated in CCPs. In October 2014, the International Organization of Securities Commissions (IOSCO) and the Financial Stability Board (FSB) published their final reports on the recovery and resolution of Financial Markets Infrastructures (FMI). The European Commission will now publish a legislative proposal in the course of 2015 to implement these recommendations in European law.

Several important CCPs (LCH.Clearnet, CME) as well as clearing (JP Morgan) and users of CCPs (Blackrock, Pimco) have already issued position papers on this issue.

KCG View: The need for CCPs to carry out recovery and resolution planning will give the opportunity for collaboration with its members, including KCG, who to a large extent need to carry out the same exercise of considering what measures would ensure survival. KCG relies on CCPs to clear its businesses and so structured recovery planning will be beneficial as it ensures the continued functioning of the major European markets with little disruption.

Learn more:

>> European Commission 2015 Work Program

>> Regulation (EU) No 648/2012 of the European Parliament and of the Council of July 4, 2012 on OTC derivatives, central counterparties and trade repositories (EMIR)

>> IOSCO Report on Recovery of financial market infrastructures— October 2014

>> FSB—Key Attributes of Effective Resolution Regimes for Financial Institutions—October 2014

>> LCH.Clearnet—CCP Risk management, recovery & resolution— November 2014

>> CME—Balancing CCP and Member Contributions with Exposures

>> JP Morgan Chase & Co—What is the Resolution Plan for CCPs?— September 2014

>> Blackrock—Central clearing counterparties and too big to fail— April 2014

>> Pimco—Setting Global Standards for Central Clearinghouses— October 2014

Market Structure Review Feb 2015 15kcg.com

This material is not research and is not intended as such. It has been produced by personnel employed within the Trading Strategy Department and/or by Sales and Trading personnel of KCG Americas LLC (“KCGA”) or KCG Europe Limited (“KCGEL”). This material is intended only for clients of KCG Holdings, Inc. and its subsidiaries (collectively “KCG”). It is not intended for further dissemination in its present form or any other and may not be further disseminated beyond the initial recipient without express consent from KCG. This material is not intended to constitute an offer, or solicitation of an offer, to purchase or sell any security or financial instruments or to participate in any investment strategy. The securities and strategies referenced in this material are not intended as recommendations and may not be suitable for you. KCGA believes that the information contained herein is accurate but does not warrant that is accurate, complete or up to date. The views expressed herein are based on assumptions. Any of those assumptions may be incorrect. KCG does not guarantee the performance or success of any opinion or idea expressed in the information. KCG assumes no liability to anyone as a result of the use of this material. This material provides the observations and views of the persons who prepared the material. These observations and views may be different from, or inconsistent with, the views of KCG or other Departments or persons within KCG. The observations and views expressed in this material may change at any time without notice. KCGA makes markets and trades for its own account and may hold positions in any of the securities of the issuers referred to herein or in related financial instruments. The persons who prepared this material may also advise our trading desks.

In the US, products and services are offered by KCGA, member FINRA/SIPC. In Europe, products and services are offered by KCG Europe Limited (“KCGEL”) which is authorized and regulated by the FCA. KCGA and KCGEL are affiliates and are indirect subsidiaries of KCG. For additional information about KCG (NYSE: Euronext: KCG) please visit www.kcg.com

© 2015 KCG Holdings, Inc. All rights reserved.

If you have questions or would like further information on any of the subjects covered in this review, please contact your KCG account manager.