Regulatory · SEC
Alternative trading system — under disclosed operator conduct.
Certain orbital-resource instruments — specifically tokenised spectrum-right leases and hosted-payload secondary interests — are offered, ordered and matched through Wavestar's SEC-registered broker-dealer subsidiary operating as an Alternative Trading System under Rule 300 of Regulation ATS. Form ATS-N publicly discloses our operator conduct, subscriber population, and order-handling practices.
- Filing
- Form ATS-N
- Status
- Drafting
- Next deadline
- Initial filing · Mo. 9
- Public docket
- sec.gov / ATS-N search
What this authorises
A regulated venue for the securities-like instruments we clear.
Reg ATS operation establishes the disclosed market-structure rules for spectrum-right and hosted-payload secondary trades. Commodity-side contracts route to the separate CFTC-regulated track.
- 01
Spectrum-rights secondary market
ATS matching of tokenised spectrum-hour instruments whose economic exposure is a right to use ITU-coordinated frequency. Treated as securities for market-structure purposes; cleared through the DCO leg once live. - 02
Hosted-payload secondary interests
Transfers of hosted-payload commitments between ITU/FCC-licensed operators, packaged as transferable investment contracts. ATS disclosure ensures consistent handling across subscribers. - 03
Subscriber fair-access terms
Published subscriber criteria, priority rules, and order-handling logic. No preferential access; no undisclosed discretion in order routing. Changes to any of these filed as an ATS-N amendment before effect. - 04
Surveillance and audit trails
Full order-book reconstruction from the transparency log. Time-synchronised event stream, immutable per-subscriber audit trail, and deterministic replay. Ready for SEC examination on request. - 05
Best-execution cooperation
ATS-N transparency supports subscribers' best-execution obligations. We publish tier statistics, fill quality, and latency at the disclosed granularity needed by broker-dealer subscribers. - 06
Operator-conflict disclosure
Wavestar's clearing, settlement and data businesses are disclosed as potential conflicts. Affiliated-order handling, information-barrier posture, and proprietary-trading prohibitions are documented and attested.
Filing timeline
Eighteen months from broker-dealer formation to operating ATS.
- Months 3 – 6Planned
Broker-dealer formation
Wavestar Securities LLC formed as the registered broker-dealer subsidiary. FINRA membership application filed via the NMA process; principals and supervisory structure designated. - Month 7Planned
FINRA NMA interview
Membership interview with FINRA district office. Operational readiness demonstrated — surveillance, books-and-records, WSPs, disaster recovery. - Month 9Planned
Form ATS-N initial filing
Initial ATS-N filed with the SEC Division of Trading and Markets. Public sections posted same-day; private sections submitted under EDGAR confidential treatment where applicable. - Month 11Planned
SEC public comment window closes
Twenty-business-day public comment window under Rule 304(a). We respond to material comments through an ATS-N amendment rather than out-of-band changes. - Month 14Planned
SEC effectiveness order
After resolution of staff comments, ATS-N becomes effective. Operating mode flipped from pre-filing dark to publicly-disclosed operation. - Month 15Planned
First ATS trades cleared
Initial cohort of broker-dealer subscribers onboarded. First spectrum-right secondary trades matched, printed and cleared. Daily surveillance cycle begins. - Month 18Planned
Steady-state subscriber enrolment
Fifteen-plus institutional broker-dealer subscribers onboarded. Monthly order-handling statistics published; annual ATS-N amendment for any material change.
Ongoing obligations
Disclosure is continuous. Not episodic.
Public documents
The ATS-N file, side-by-side with its amendments.
SEC filings register
- Form ATS-N — Initial
Target filing: month 9. Full public sections posted same-day.
- Form ATS-N — Amendments
Every material change versioned. Effective-date table maintained.
- Broker-Dealer Form BD
BD registration and principal / control affiliate disclosures.
- FINRA Membership Agreement
Permitted activities, geographic scope, and supervisory structure.
- Monthly order-handling statistics
Fill rates, tier statistics, order-type mix — at the disclosed granularity.
- Written Supervisory Procedures
Full text available to regulators; public summary published.
Moving along the arc
ATS is the venue. DCO is the clearing leg.
Where ATS-N establishes Wavestar as a disclosed market-structure operator, CFTC Form 7-R establishes the central-counterparty clearing leg for derivatives contracts. Both tracks run in parallel.