EXHIBIT A

TEMPLATE – DRAFT

Template note: This Exhibit A is generated by DataCT’s licensing system at portal.consolidatedtape.com (“DataCT Portal”). Fields shown as «Field» are populated by the system from the Customer record. Each Schedule other than Schedule A-1 (Data Licenses) is generated and versioned independently so that it can be amended and restated through the Portal without re-execution of this Exhibit A; a change to Schedule A-1 (Data Licenses) requires execution of that amended and restated schedule.

This Exhibit A (this “Exhibit”, version «Exhibit.VersionNo») is effective as of «Exhibit.EffectiveDate» (the “Effective Date”) between DataCT LLC, acting as the administrator of the CT Plan under the oversight of CT Plan LLC (the “Administrator”), on behalf of the Authorizing SROs, and «Customer.LegalName» (the “Customer” or “Licensee”, the Distributor under the Agreement). This Exhibit is incorporated into, forms part of, and amends the Distribution Agreement between the Parties (the “Agreement”). As of the Effective Date, this Exhibit replaces any prior Exhibit A to the Agreement.

(a) The Agreement contains the terms governing Access to, and the control, distribution and recordkeeping of, CT Plan Information and is amended by this Exhibit, which sets out the Customer-specific terms and incorporates the Customer’s Data Licenses and associated Declarations, each granting product- or use-case-specific terms.

(b) Each Data License grants rights for Access and Usage of CT Plan Information together with prescribed Reporting and Recordkeeping Obligations. One Unit of Count is designated for each Data License, as recorded in Schedule A-1 (Data Licenses).

(c) This Exhibit adopts the term “CT Plan Information” as defined in the Agreement (referred to in the CT Plan Policies as “CT Data”). The Customer’s receipt, use, Distribution and redistribution of CT Plan Information remains subject in all respects to the Agreement, the applicable Data Licenses, and the Policies.

(d) This Exhibit comprises this main body, which is executed by the Parties and changes only by executed amendment, and the Schedules, which record the Customer-specific inventory (Affiliates, Service Facilitators, Data Licenses, Controls, Non-Display Applications, Derived Data Outputs, Waivers, and Attestations) and are maintained through the Portal without re-execution of this Exhibit.

Capitalized terms not defined in this Exhibit have the meanings assigned in the Agreement, the Policies, or the CT Plan. Where a Data License defines a term differently, the definition in the Data License governs for that license only. As used in this Exhibit:

(a) “Attestation” means a written confirmation recorded in Schedule A-8 and executed in accordance with Section 8 of this Exhibit, confirming the Customer’s understanding of applicable terms, the accuracy and completeness of declarations made (including Non-Display Category and Derived Data declarations), and/or the accuracy of reporting.

(b) “Data License Inventory” means the inventory of the Customer’s Data Licenses maintained on the Portal, as described in Section 6 of this Exhibit.

(c) “Portal” means the DataCT Portal located at portal.consolidatedtape.com, the authenticated web application through which Customer performs market data administration, including licensing, reporting, and compliance activities.

(d) “Waiver” means an approved fee waiver or Exempt Activity fee treatment under Section 4.9 of the Policies for a specific type of permitted usage, as recorded in Schedule A-7 against the related Data License.

The following Customer-specific details are populated from the Customer’s licensing record:

The remaining role designations required by Section 8.5 of the Policies are recorded and maintained in the Customer’s licensing record on the Portal.

This Exhibit A is organized as a single legal reference point for the Customer, comprising this executed main body and the Schedules listed below. Each Schedule is generated by the Portal from the Customer record and is versioned independently, so that an individual Schedule can be amended and restated without restating or re-executing the remainder of this Exhibit A or other Schedules.

(a) Incorporation. Each Schedule forms part of and is incorporated into this Exhibit A. References to Exhibit A (including in the Agreement, the Data Licenses, and the Policies) include each Schedule.

(b) Amendment by Schedule; no re-execution. Each Schedule other than Schedule A-1 (Data Licenses) is maintained through the Portal and may be amended and restated individually in accordance with Section 7, replacing the prior version of that Schedule without restating the remainder of this Exhibit A and without re-execution of this Exhibit A by the Parties. Schedule A-1 (Data Licenses) is amended only via written agreement by the Parties: each addition, modification or removal of a Data License requires execution in accordance with Section 7(c) of this Exhibit. Amendments to this main body likewise require execution of an amended and restated Exhibit A.

(a) Incorporation. Each Data License listed in Schedule A-1 is incorporated into and forms part of this Exhibit and the Agreement. Each Data License grants product- or use-case-specific rights for Access and Usage of CT Plan Information solely as and to the extent described, and in the manner specified, in that Data License and the Policies. The Data License detail for each Data License is accessible at the hyperlink set out in Schedule A-1.

(b) Licensed Rights. Each Data License clearly sets forth the authorized rights granted and the limitations associated with those rights. The Customer accepts responsibility for implementing and maintaining the Controls necessary to ensure that Access, Usage, Distribution, and downstream use of CT Plan Information remain within the scope of the rights granted. Accountability follows the holder of the licensed right and cannot be transferred to any party other than the Licensee.

(c) Reporting and Recordkeeping. Each Data License carries the reporting and recordkeeping obligations prescribed in it and in the Policies. A single Unit of Count is assigned to each reporting obligation. Unless a Data License specifically requires Usage Reporting, Access Reporting is the default reporting method, and the default reporting frequency is monthly per Reporting Period. Reports are submitted, corrected, and reconciled as prescribed by Section 6.5 of the Policies.

(d) Controls. The Controls that support the reporting and recordkeeping obligations under each Data License must be declared and verified through the initial and periodic license reviews. Each Control is registered and assigned a unique identifier (Control ID) and may be applied to one or more Data Licenses; a Control appropriate for one Data License is not automatically suitable for another. A Control that cannot be verified, or is deemed insufficient, must be resubmitted within a specified time period for the associated Data Licenses to remain valid. Where a Control cannot evidence the Access, Usage, netting deduction, or delay it is intended to enforce, the Control is disqualified and must be resolved for the associated Data License to remain valid. The Controls registered in Schedule A-2 constitute the entitlement controls referenced in Paragraph 9(d) of the Agreement.

(e) Non-Display Use and Derived Data. Each Non-Display application (by Category 1, 2 or 3) must be registered in Schedule A-3 through the initial and periodic license reviews. Such registration will include its Category Declaration and a declaration whether the Non-Display Use creates Derived Data, before the application is operated. Each Derived Data output must be registered in Schedule A-4 and covered by an executed Attestation that the output conforms to the definition of Derived Data in Section 4.6 of the Policies. Any output outside the declared and attested bounds remains CT Plan Information subject to the policies and fees applicable to the underlying inputs.

(f) Delayed Data. Where a Data License permits the provision of Delayed Data, the prescribed minimum 15-minute delay must be applied through a verified Delayed Data Control registered in Schedule A-2, and each display and item of promotional material shall conspicuously exhibit a delay statement in the form prescribed by the applicable Data License.

(g) Waivers. No fee waiver or Exempt Activity treatment becomes effective until approved by the Administrator and recorded in Schedule A-7 against the related Data License. A Waiver does not relieve the Customer of licensing, reporting, recordkeeping, or attestation obligations. Waivers are applied only after reporting has been reconciled, and activity outside the terms of the related Data License may void the Waiver.

(a) Shared record. The Data License Inventory on the Portal acts as the shared record of the Data Licenses and Schedules reflected in the Agreements, reconciled to, but never displacing, the signed documents (the Agreement, this Exhibit, and the executed Data Licenses).

(b) Inconsistencies. Inconsistencies between the Data License Inventory and the signed documents (the Agreement, this Exhibit, and the executed Data Licenses) are corrected through the applicable legal and operational change process. Pending correction, the signed documents govern.

(c) Currency. Customer is required to keep its Data License Inventory current, supported by the Administrator, including prompt notification of any event affecting the accuracy of Section 3 of this Exhibit or of the information recorded in any Schedule.

(a) Schedule updates. A change confined to the information recorded in each Schedule is completed through the Portal workflow. Upon completion, the Portal generates an amended and restated version of the affected Schedule(s) alone, with an incremented Schedule version number recorded in the Schedule version register maintained on the Portal, which replaces the prior version of that Schedule. Not all updates to a Schedule requires re-execution. However, each addition of a new Data License, and each modification or removal of an existing Data License, changes the Data License Inventory and Schedule A-1 (Data Licenses) and requires an amended and restated Schedule A-1 for execution by the Parties. The change is not effective as an amendment of the Schedule A-1 until so executed.

(a) Register. Schedule A-8 records each Attestation executed by or on behalf of the Customer, including periodic compliance attestations required by Section 8.8 of the Policies, Attestations confirming the Customer’s understanding of the terms of this Exhibit and the Data Licenses, Attestations confirming the declarations made in Schedules A-3 and A-4 (including that each registered Derived Data output conforms to the definition of Derived Data in Section 4.6 of the Policies), and Attestations confirming the accuracy of reporting (including any Netting Reports).

(b) Authorized signatories. Each Attestation must be executed by an authorized representative of the Customer with authority to bind the Customer with respect to the matters attested to. An Attestation executed by any other person is not a valid Attestation for the purposes of this Exhibit, the Agreement, or the Policies.

(c) Standing effect. Attestations are a standing input to the Compliance Risk Monitoring Program and a condition of good standing. Material changes affecting a prior Attestation must be disclosed when they occur, rather than only at the next attestation date.

The Customer will complete an initial license review on the Portal within 180 days of the Effective Date of this Exhibit A. During that review, the Customer will complete the details of all Schedules other than Schedule A-1 (Data Licenses), which is completed concurrently with the execution of this Exhibit.

The Policies provide guidance on the implementation of the terms and conditions set out in the Agreement and each Data License but do not themselves assign, grant, or create any rights or obligations; such rights and obligations are established exclusively by the Agreement (including this Exhibit) and the applicable Data License. Where the Policies and the Agreement or a Data License differ, the Agreement or the Data License governs. Where a Data License defines a term differently, the Data License governs for that license.

(a) Each person signing this Exhibit or completing any Schedule on behalf of the Customer represents and warrants that such person has full power and authority to execute and deliver this Exhibit or complete any Schedule on behalf of the Customer and to bind the Customer to the terms and conditions of this Exhibit and each applicable Schedule incorporated herein.

(b) Except as expressly amended by this Exhibit, the Agreement remains in full force and effect. This Exhibit (including Schedules A-1 through A-9), together with the Agreement, Exhibit B, Exhibit C (if any), and the Policies, contains the entire agreement of the Parties with respect to its subject matter.

This Schedule forms part of and is incorporated into Exhibit A to the Agreement; references to Exhibit A include this Schedule. This Schedule is generated by the Portal from the Customer record, is versioned independently (this version «Sch.A-1.VersionNo», effective «Sch.A-1.EffectiveDate»). This Schedule is amended only by an amended and restated Schedule A-1 executed by the Parties.

Data License Schedule

The following Data Licenses are in effect for the Customer as of this Schedule’s effective date. Each Data License ID is hyperlinked to the individual Data License detail on the Portal.

The Reporting, Recordkeeping and Compliance Obligations for each Data License are prescribed in that Data License; related Waivers, if any, are recorded in Schedule A-7. A Terminated Data License remains listed with status “Terminated” for the remainder of the current reporting year and is thereafter retained in the Portal archive for the recordkeeping period.

IN WITNESS WHEREOF, the Parties have caused this Schedule A-1 to the Exhibit A to be executed as of the effective date first written above.

This Schedule forms part of and is incorporated into Exhibit A to the Agreement; references to Exhibit A include this Schedule. This Schedule is generated by the Portal from the Customer record, is versioned independently (this version «Sch.A-2.VersionNo», effective «Sch.A-2.EffectiveDate»), and may be amended and restated individually through the Portal workflow in accordance with Section 7 of Exhibit A without re-execution of Exhibit A.

This Schedule constitutes the Controls Registry. It lists and describes each Data Access Control, each Data Usage Control (including each Netting Control), and each Delayed Data Control, each with the unique Control ID assigned by the Administrator. The Controls registered in this Schedule constitute the entitlement controls referenced in Paragraph 9(d) of the Agreement.

Part A — Data Access Controls

Part B — Data Usage Controls (including Netting Controls)

Part C — Delayed Data Controls

One row per Control; generated from the Customer’s licensing record on the Portal. Each Control is registered once and may be applied to one or more Data Licenses; a Control appropriate for one Data License is not automatically suitable for another. Verification of a Delayed Data Control includes demonstration that the declared delay is genuinely enforced, including measurement against synchronized timestamps. Where any netted deduction cannot be reproduced from the underlying Netting Control records, the deduction is excluded and the accounting resolves to the conservative default.

This Schedule forms part of and is incorporated into Exhibit A to the Agreement; references to Exhibit A include this Schedule. This Schedule is generated by the Portal from the Customer record, is versioned independently (this version «Sch.A-3.VersionNo», effective «Sch.A-3.EffectiveDate»), and may be amended and restated individually through the Portal workflow in accordance with Section 7 of Exhibit A without re-execution of Exhibit A.

This Schedule registers each Non-Display application used with CT Data, together with the associated Category Declaration (Category 1, 2 or 3) and the declaration whether the Non-Display Use creates Derived Data. Non-Display applications must be registered in this Schedule, declared, and approved in accordance with the Policies (Sections 4.5, 4.6 and 8.3).

One row per Non-Display application; generated for all Non-Display Use declarations in the Customer’s licensing record on the Portal. Each distinct Category 1 (Electronic Trading) system is registered and reported separately; where an application operates in more than one category, each category is declared and licensed separately. Where the Derived Data Creation declaration is “Yes”, each associated output is registered in Schedule A-4.

This Schedule forms part of and is incorporated into Exhibit A to the Agreement; references to Exhibit A include this Schedule. This Schedule is generated by the Portal from the Customer record, is versioned independently (this version «Sch.A-4.VersionNo», effective «Sch.A-4.EffectiveDate»), and may be amended and restated individually through the Portal workflow in accordance with Section 7 of Exhibit A without re-execution of Exhibit A.

This Schedule registers each output associated with Non-Display Use where Derived Data is created, together with the Attestation that each output conforms to the definition of Derived Data in the Policies (Section 4.6) — namely that (1) the output cannot be reverse engineered to recreate the CT Data, and (2) the output cannot be used to create other data recognizable as a substitute for CT Data. Derived data output may require an executed conformity Attestation and inclusion in this Schedule as determined by the Administrator.

One row per Derived Data output; generated from the Derived Data Registry entries in the Customer’s licensing record. Qualification attaches to the declared Derived Data Product, not to the system that produces it. An approved Declaration covers only outputs conforming to the declared product type; any output outside the declared and attested bounds remains CT Data subject to the policies and fees applicable to the underlying inputs. Qualified Derived Data Products may be eligible for the fee treatment recorded in Schedule A-7; the underlying Derived Data Creation remains fee-liable as Non-Display Use.

This Schedule forms part of and is incorporated into Exhibit A to the Agreement; references to Exhibit A include this Schedule. This Schedule is generated by the Portal from the Customer record, is versioned independently (this version «Sch.A-5.VersionNo», effective «Sch.A-5.EffectiveDate»), and may be amended and restated individually through the Portal workflow in accordance with Section 7 of Exhibit A without re-execution of Exhibit A.

This Schedule identifies every Affiliate whose access, use, reporting or payment is intended to be covered under the Customer’s Agreement. An Affiliate is covered only if, and for so long as, it is identified in this Schedule with an approval status of “Approved”.

One table per Affiliate; generated for all Affiliates recorded in the Customer’s licensing record on the Portal. Where reporting or billing responsibility rests with the Affiliate, the associated Unit(s) of Count and reporting obligations are recorded against the relevant Data License in Schedules A-1 and A-8.

This Schedule forms part of and is incorporated into Exhibit A to the Agreement; references to Exhibit A include this Schedule. This Schedule is generated by the Portal from the Customer record, is versioned independently (this version «Sch.A-6.VersionNo», effective «Sch.A-6.EffectiveDate»), and may be amended and restated individually through the Portal workflow in accordance with Section 7 of Exhibit A without re-execution of Exhibit A.

This Schedule records each Service Facilitator approved to support the Customer, its relationship to the Customer, and confirmation that the required Administrator approval and the written agreement between the Customer and the Service Facilitator required by the Policies are in place. Identification in this Schedule does not grant the Service Facilitator any independent right to receive, access, use or distribute CT Data.

One table per Service Facilitator; generated for all Service Facilitators recorded in the Customer’s licensing record on the Portal. Service Facilitators include any third-party hosted AI Service used by the Customer in accordance with Section 4.10 of the Policies.

This Schedule forms part of and is incorporated into Exhibit A to the Agreement; references to Exhibit A include this Schedule. This Schedule is generated by the Portal from the Customer record, is versioned independently (this version «Sch.A-7.VersionNo», effective «Sch.A-7.EffectiveDate»), and may be amended and restated individually through the Portal workflow in accordance with Section 7 of Exhibit A without re-execution of Exhibit A.

This Schedule records each fee waiver and Exempt Activity fee treatment approved for the Customer for a specific type of permitted usage under Section 4.9 of the Policies, together with the ID of each Data License to which the Waiver relates. Licensing, reporting, recordkeeping and attestation obligations remain required for every waived or exempt activity; waivers are applied only after reporting has been reconciled.

One row per Waiver; generated from the Customer’s licensing record on the Portal. Waiver / Exempt Activity types follow Section 4.9 of the Policies and include: Development use; Administrative and Operational use; Disaster Recovery; System Migration; Service Facilitator access; Consolidated Volume Only services; Academic Use (fee waiver under an Academic Use license); Professional User Netting (Section 6.7 of the Policies); and Delayed Data Redistribution. Activity outside the terms of the related Data License may void the Waiver and cause the activity to become fee-liable.

This Schedule forms part of and is incorporated into Exhibit A to the Agreement; references to Exhibit A include this Schedule. This Schedule is generated by the Portal from the Customer record, is versioned independently (this version «Sch.A-8.VersionNo», effective «Sch.A-8.EffectiveDate»), and may be amended and restated individually through the Portal workflow in accordance with Section 7 of Exhibit A without re-execution of Exhibit A.

This Schedule records each Attestation executed by or on behalf of the Customer confirming the Customer’s understanding of applicable terms, the declarations made, and the accuracy of reporting. Each Attestation must be executed by an authorized representative of the Customer (Section 8 of this Exhibit).

One row per Attestation; generated from the Customer’s licensing record on the Portal. Attestations include the periodic compliance attestations required by Section 8.8 of the Policies (no less than annually), the Derived Data conformity attestations referenced in Schedule A-4, and any additional attestations prescribed by a Data License, a Compliance Review, or the Compliance Risk Monitoring Program. Material changes affecting a prior Attestation must be disclosed when they occur.

This Schedule forms part of and is incorporated into Exhibit A to the Agreement; references to Exhibit A include this Schedule. This Schedule is generated by the Portal from the Customer record, is versioned independently (this version «Sch.A-9.VersionNo», effective «Sch.A-9.EffectiveDate»), and may be amended and restated individually through the Portal workflow in accordance with Section 7 of Exhibit A without re-execution of Exhibit A.

This Schedule records various points of contact for the Customer. Customer shall ensure that the below contact information remains up-to-date.