Market Data Fees Effective April 1, 2022

Today, MEMX unveiled proposed fees for our real-time market data products.

We’ve provided real-time data at no cost since our launch in September of 2020. We did so because we believe that it is incumbent upon us to deliver meaningful value to our Members before we charge fees for products and services. Our market share is consistently over 4% and our quote performance is on par with, or outperforming many other US exchanges. MEMX is now the 6th largest trading venue for US equities and is the 5th largest exchange by NBBO quote market share. We believe that by any measure, MEMX is delivering value to our exchange members and other market participants.

The development of our data fee structure was guided by our desire to provide transparency on projected revenue, costs and margins to better assess that our market data fees meet the requirements of fairness and reasonableness. We established our proprietary data fees by determining our total costs to produce and disseminate both proprietary and SIP market data and also the market data revenue earned from the SIP.

Our new fee schedule provides an apples-to-apples comparison with our competitors, to provide our members a perspective on how competitive our pricing is, and to represent our view of data pricing that is both fair and reasonable. From the outset, MEMX has emphasized the importance of operational efficiency and technological scale to keep our costs low. Our hope is that with time and increased competition, all market participants will ultimately save money under a more rational and fair data pricing structure.

We intend to adopt a simple fee structure with both low user fees and very limited differentiation between professional and non-professional categories. By eliminating the financial distinction between professional and non-professional investors in many of our market data offerings, we seek to reduce frictions for retail brokers that stream pricing information to investors. Similarly, by charging user fees of 1 cent for both Top of Book and Last Sale data, we are further democratizing data consumption and reducing unnecessary complexity.

For our members consuming full depth of book, MEMX’s professional and non- professional monthly user fees are at least 25% lower than other exchanges with comparable market share and quote quality. Additionally, for those members who are using our data for non- display trading or an internal matching platform, MEMX pricing is at least 20% lower than products offered by exchanges with similar market share and quote quality.

We are announcing our proposed fee schedule now in order to provide participants with ample time to implement any changes. Subject to filing with the SEC, we plan to begin charging for our market data on April 1, 2022. If you are interested in viewing our proposed market data fees, you can do so at

Please let us know if you have any questions, thank you.

-The MemberX Team