1.3 Victory Star Club & Co., Inc. 2022 4 2023-01-31T16:04:09Z 2022 10 100.00 85.48 3.14 8.49 2.89 Virtu Americas, LLC 47.41 48.63 39.75 39.39 43.12 5259.66 14.0000 708.12 14.0000 633.29 14.0000 61.27 14.0000 Victory Star Club receives remuneration from Virtu/NITE based on a rate per shares executed of 14 cents per 100 shares. Arrangements with NITE are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. CITADEL SECURITIES LLC 46.89 47.11 43.79 44.42 50.93 7664.70 16.0000 1015.79 16.0000 990.76 16.0000 205.85 14.1642 Victory Star Club receives remuneration from Citadel/CDRG based on a rate per shares executed of 16 cents per 100 shares. Arrangements with CDRG are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. 100.00 69.13 8.07 19.96 2.84 Virtu Americas, LLC 46.25 48.24 42.24 40.77 47.64 13151.23 13.2193 5549.81 10.2569 4056.74 12.1210 479.25 11.9121 Victory Star Club receives remuneration from Virtu/NITE based on a rate per shares executed of 14 cents per 100 shares. Arrangements with NITE are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. CITADEL SECURITIES LLC 45.94 46.67 43.04 45.01 42.73 24203.86 15.7020 10384.34 13.9890 6452.33 12.4543 579.86 5.8179 Victory Star Club receives remuneration from Citadel/CDRG based on a rate per shares executed of 16 cents per 100 shares. Arrangements with CDRG are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. 100.00 9.88 8.93 55.52 25.68 CITADEL SECURITIES LLC 41.84 54.51 38.86 42.92 35.69 2688.05 28.9442 14291.56 32.6627 21424.59 39.6092 13806.70 41.4703 Victory Star Club receives remuneration from Citadel/CDRG based on a rate per contracts executed. Arrangements with Citadel/CDRG are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club receives per contract: $0.75 for options that quote in nickel increments; $0.70 for complex orders that quote in nickel increments; $0.25 for options that quote in penny increments; and, $0.35 for complex orders that trade in penny increments. For executions of Index options, CDRG does not pay a fixed rate but will pass through any fess or rebates to Oppenheimer. Global Execution Brokers, LP 27.75 25.28 30.59 27.98 27.22 2076.35 31.2892 23108.52 35.8344 27147.85 37.7053 44080.45 38.6105 Victory Star Club receives remuneration from Global Execution/GEBB based on a rate per contracts executed. Arrangements with GEBB are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club receives per contract: $0.70 for options that quote in nickel increments; $0.75 for complex orders that quote in nickel increments; $0.25 for options that quote in penny increments; and, $0.35 for complex orders that trade in penny increments. For executions of Index options, GEBB does not pay a fixed rate but will pass through any fess or rebates to Oppenheimer. Wolverine Execution Services, LLC 19.45 19.31 22.76 18.93 19.49 1894.65 28.3673 11353.70 34.7431 14022.30 40.4276 43191.30 43.4931 Victory Star Club receives remuneration from Wolverine/WEXX based on a rate per contracts executed. Arrangements with WEXX are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club receives per contract: $0.70 for options that quote in nickel increments; $0.75 for complex orders that quote in nickel increments; $0.25 for options that quote in penny increments; and, $0.35 for complex orders that trade in penny increments. For executions of Index options, Wolverine does not pay a fixed rate but will pass through any fess or rebates to Oppenheimer. Instinet, LLC 9.37 0.00 6.89 9.54 13.46 0.00 0.0000 0.00 0.0000 0.00 0.0000 0.00 0.0000 Instinet charges Victory Star Club $0.015-0.045 per executed contract, with the rate decreasing with increased volume executed. Instinet will pass through to Victory Star Club the Exchange base tier net exchange fees or rebates from Oppenheimer's orders. 2022 11 100.00 85.92 2.86 8.86 2.36 CITADEL SECURITIES LLC 44.17 44.35 44.97 42.55 42.82 6490.81 16.0000 1406.38 16.0000 868.36 16.0000 189.13 11.9450 Victory Star Club receives remuneration from Citadel/CDRG based on a rate per shares executed of 16 cents per 100 shares. Arrangements with CDRG are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. Virtu Americas, LLC 40.16 39.96 38.00 40.68 48.12 4855.35 14.0000 604.23 14.0000 696.07 14.0000 101.10 14.0000 Victory Star Club receives remuneration from Virtu/NITE based on a rate per shares executed of 14 cents per 100 shares. Arrangements with NITE are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. Two Sigma Securities, LLC 8.61 8.55 9.92 10.06 3.81 597.11 15.0000 58.05 15.0000 65.54 15.0000 11.26 15.0000 Victory Star Club receives remuneration from Two Sigma/SOHO based on a rate per shares executed of 15 cents per 100 shares. Arrangements with SOHO are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. StoneX Financial, Inc. 7.00 7.14 7.07 6.67 3.22 1439.33 16.0000 123.94 16.0000 197.13 16.0000 34.24 16.0000 Victory Star Club receives remuneration from StoneX Financial, Inc./INTL based on a rate per shares executed of 16 cents per 100 shares. Arrangements with INTL are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. 100.00 68.76 7.93 20.73 2.59 CITADEL SECURITIES LLC 43.83 43.85 43.11 44.36 41.13 21497.65 15.6425 12618.52 13.2044 6554.52 12.3898 1130.50 12.9602 Victory Star Club receives remuneration from Citadel/CDRG based on a rate per shares executed of 16 cents per 100 shares. Arrangements with CDRG are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. Virtu Americas, LLC 40.14 40.05 40.18 38.90 52.39 15120.95 13.4929 7927.33 11.3462 4689.17 12.1754 689.02 13.8592 Victory Star Club receives remuneration from Virtu/NITE based on a rate per shares executed of 14 cents per 100 shares. Arrangements with NITE are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. StoneX Financial, Inc. 8.66 8.68 9.12 9.20 2.47 3337.80 14.6464 1182.65 14.3218 1134.17 10.6733 48.37 14.5556 Victory Star Club receives remuneration from StoneX Financial, Inc./INTL based on a rate per shares executed of 16 cents per 100 shares. Arrangements with INTL are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. Two Sigma Securities, LLC 7.25 7.41 6.80 7.33 3.67 954.31 14.9064 235.55 14.6922 237.18 14.8126 36.02 13.8466 Victory Star Club receives remuneration from Virtu/NITE based on a rate per shares executed of 14 cents per 100 shares. Arrangements with NITE are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. 100.00 9.02 8.69 54.05 28.24 CITADEL SECURITIES LLC 36.41 48.10 38.99 40.69 23.69 3156.44 30.6035 22662.38 37.5106 22425.31 35.2300 26353.40 40.9119 Victory Star Club receives remuneration from Citadel/CDRG based on a rate per contracts executed. Arrangements with Citadel/CDRG are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club receives per contract: $0.75 for options that quote in nickel increments; $0.70 for complex orders that quote in nickel increments; $0.25 for options that quote in penny increments; and, $0.35 for complex orders that trade in penny increments. For executions of Index options, CDRG does not pay a fixed rate but will pass through any fess or rebates to Oppenheimer. Global Execution Brokers, LP 25.24 27.95 30.42 25.87 21.60 2305.05 27.7049 23775.32 34.6771 22494.43 33.8272 33156.40 37.6914 Victory Star Club receives remuneration from Global Execution/GEBB based on a rate per contracts executed. Arrangements with GEBB are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club receives per contract: $0.70 for options that quote in nickel increments; $0.75 for complex orders that quote in nickel increments; $0.25 for options that quote in penny increments; and, $0.35 for complex orders that trade in penny increments. For executions of Index options, GEBB does not pay a fixed rate but will pass through any fess or rebates to Oppenheimer. Wolverine Execution Services, LLC 20.18 23.08 22.15 19.59 19.76 2617.80 27.1923 14738.75 36.0017 15403.60 38.2394 42874.30 42.3680 Victory Star Club receives remuneration from Wolverine/WEXX based on a rate per contracts executed. Arrangements with WEXX are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club receives per contract: $0.70 for options that quote in nickel increments; $0.75 for complex orders that quote in nickel increments; $0.25 for options that quote in penny increments; and, $0.35 for complex orders that trade in penny increments. For executions of Index options, Wolverine does not pay a fixed rate but will pass through any fess or rebates to Oppenheimer. Instinet, LLC 17.43 0.04 7.50 13.31 33.94 0.00 0.0000 0.00 0.0000 0.00 0.0000 0.00 0.0000 Instinet charges Victory Star Club $0.015-0.045 per executed contract, with the rate decreasing with increased volume executed. Instinet will pass through to Victory Star Club the Exchange base tier net exchange fees or rebates from Oppenheimer's orders. 2022 12 100.00 86.75 2.64 7.91 2.70 CITADEL SECURITIES LLC 45.13 45.05 44.05 43.03 54.88 9470.56 16.0000 1593.44 16.0000 1063.43 16.0000 366.70 12.3983 Victory Star Club receives remuneration from Citadel/CDRG based on a rate per shares executed of 16 cents per 100 shares. Arrangements with CDRG are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. Virtu Americas, LLC 39.73 39.79 40.42 39.09 39.06 6484.39 14.0000 851.27 14.0000 687.63 14.0000 198.54 14.0000 Victory Star Club receives remuneration from Virtu/NITE based on a rate per shares executed of 14 cents per 100 shares. Arrangements with NITE are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. Two Sigma Securities, LLC 8.29 8.28 7.70 9.83 4.58 776.07 15.0000 47.84 15.0000 54.77 15.0000 12.19 15.0000 Victory Star Club receives remuneration from Two Sigma/SOHO based on a rate per shares executed of 15 cents per 100 shares. Arrangements with SOHO are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. StoneX Financial, Inc. 6.84 6.88 7.70 7.98 1.39 1909.09 16.0000 227.71 16.0000 218.46 16.0000 23.50 16.0000 Victory Star Club receives remuneration from StoneX Financial, Inc./INTL based on a rate per shares executed of 16 cents per 100 shares. Arrangements with INTL are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. 100.00 74.30 7.08 16.38 2.23 CITADEL SECURITIES LLC 44.27 44.46 43.79 43.49 45.10 27588.53 15.3984 10038.92 11.9550 7692.88 11.8396 923.17 11.4555 Victory Star Club receives remuneration from Citadel/CDRG based on a rate per shares executed of 16 cents per 100 shares. Arrangements with CDRG are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. Virtu Americas, LLC 38.92 38.69 38.74 39.21 45.28 19763.80 13.1728 7349.24 11.4763 5215.74 12.1970 803.88 13.9962 Victory Star Club receives remuneration from Virtu/NITE based on a rate per shares executed of 14 cents per 100 shares. Arrangements with NITE are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. StoneX Financial, Inc. 8.81 8.66 9.83 9.81 3.50 4464.82 15.2905 1251.28 6.1434 1068.06 10.2348 95.06 16.0000 Victory Star Club receives remuneration from StoneX Financial, Inc./INTL based on a rate per shares executed of 16 cents per 100 shares. Arrangements with INTL are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. Two Sigma Securities, LLC 7.87 8.17 6.59 7.31 5.94 1288.58 14.7540 264.28 14.7511 231.67 14.8040 22.82 15.0000 Victory Star Club receives remuneration from Virtu/NITE based on a rate per shares executed of 14 cents per 100 shares. Arrangements with NITE are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club does not receive payment for odd lot orders or for stocks priced under $1.00. 100.00 11.38 9.23 56.14 23.25 CITADEL SECURITIES LLC 39.45 48.71 37.78 41.84 29.81 3141.51 29.6229 14106.09 32.1572 18513.31 36.8909 9029.62 41.8716 Victory Star Club receives remuneration from Citadel/CDRG based on a rate per contracts executed. Arrangements with Citadel/CDRG are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club receives per contract: $0.75 for options that quote in nickel increments; $0.70 for complex orders that quote in nickel increments; $0.25 for options that quote in penny increments; and, $0.35 for complex orders that trade in penny increments. For executions of Index options, CDRG does not pay a fixed rate but will pass through any fess or rebates to Oppenheimer. Global Execution Brokers, LP 25.62 28.81 28.90 25.49 23.06 2574.60 28.4455 16930.04 31.9236 18788.50 38.0565 29744.55 39.0646 Victory Star Club receives remuneration from Global Execution/GEBB based on a rate per contracts executed. Arrangements with GEBB are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club receives per contract: $0.70 for options that quote in nickel increments; $0.75 for complex orders that quote in nickel increments; $0.25 for options that quote in penny increments; and, $0.35 for complex orders that trade in penny increments. For executions of Index options, GEBB does not pay a fixed rate but will pass through any fess or rebates to Oppenheimer. Wolverine Execution Services, LLC 20.31 21.93 24.83 20.00 18.48 2605.60 28.7182 13647.55 39.0958 14814.75 43.4297 39093.95 43.4624 Victory Star Club receives remuneration from Wolverine/WEXX based on a rate per contracts executed. Arrangements with WEXX are not based upon order flow, volume minimums / maximums, decreased execution quality for increased payment, or the characteristics and categories of the order flow (i.e. order types). In addition, such arrangements do not include incentive or disincentive benchmarks. Victory Star Club receives per contract: $0.70 for options that quote in nickel increments; $0.75 for complex orders that quote in nickel increments; $0.25 for options that quote in penny increments; and, $0.35 for complex orders that trade in penny increments. For executions of Index options, Wolverine does not pay a fixed rate but will pass through any fess or rebates to Oppenheimer. Instinet, LLC 14.12 0.00 7.85 12.33 27.85 0.00 0.0000 0.00 0.0000 0.00 0.0000 0.00 0.0000 Instinet charges Victory Star Club $0.015-0.045 per executed contract, with the rate decreasing with increased volume executed. Instinet will pass through to Victory Star Club the Exchange base tier net exchange fees or rebates from Oppenheimer's orders.