SPX trading is presently under development not available commercially.
Contact us to learn more about SPX, spectrum trading opportunities and to participate in a field trial.

Information presented below is excerpted from Key Bridge public filings with the US government and indicates present expectations. Service features may change. No offer for service is made or implied.

Spectrum trading in the 3.5 GHz band

In the 3.5 GHz band a secondary market facility is established and operated as a trusted CBRS infrastructure component that communicates directly with one or more SASs via bilateral peering arrangements.

Illustration 1: SAS to Exchange peering enables a liquid spectrum trading marketplace.

The Exchange supports concurrent spectrum trading with any number of other authorized SASs through separate, independent bilateral peering sessions on a non-discriminatory basis.

Anatomy of a Spectrum Trade

As described in sections §96.32, §1.9020 and §1.9046 of the Commission’s rules, a PAL licensee may engage in spectrum manager leasing transactions (a “spectrum trade”) with any other properly validated entity. A spectrum trade implements a de facto leasing arrangement for a portion of a PAL’s spectrum, time duration and geographic area outside of the PAL Protection Area.

In practice a spectrum trade is a multiple step transaction implemented by and between the Exchange and SAS Infrastructure that implements, executes and perfects the transfer and assignment of spectrum license rights between trading parties. A high level process diagram illustrating this concept as envisioned for CBRS is shown in Illustration 2.

Illustration 2: Anatomy of a multiple part spectrum trading transaction.

A spectrum trade begins when two parties, a lessor (seller) and a lessee (buyer), agree to conduct a leasing arrangement facilitated through the Exchange. The spectrum trade transaction starts as the Exchange first validates the requesting parties’ certification status and also confirms that the trade, if completed, will not violate a spectrum aggregation limit. Prima facie valid trades are then submitted for automated review and confirmation to the SAS.

Upon receipt of a trade confirmation request the SAS also confirms the requesting parties’ certification status and the proposed trade’s compliance with spectrum aggregation limits. The SAS then conducts a geospatial analysis to verify that the area to be leased is within the lessor’s PAL Service Area and is outside the PAL Protection Area. Upon successful validation the SAS affirms to the Exchange that the prospective trade is acceptable, after which the Exchange completes the trade transaction and issues a trade completion notification to the SAS and a trade completion verification is forwarded to the parties. The parties may also directly query the SAS to receive a transaction status.

By this methodology the Exchange and SAS confirm to each other and to the licensee and lessee that a spectrum trade has been received, verified, accepted and completed.

Lessee Registration and Validation

Key Bridge SAS and Exchange will implement formal know your customer (“KYC”) processes in compliance with the certification requirements described in 47 CFR §1.9046(b). User registration status will be shared between the SAS and Exchange and either entity may conduct CBRS lessee registration and validation. This concept is shown in Illustration 3.

Illustration 3: CBRS users may initiate registration with a SAS or the Exchange.

Which infrastructure component (SAS or Exchange) performs the lessee validation function is determined by the lessee and how the lessee initially engages with the CBRS ecosystem.

The Key Bridge SAS and Exchange will acquire and store a copy of the FCC provided database of Priority Access Licensees, as defined in §96.3. Entities in the PAL database will be automatically validated as certified users when registering with the SAS and the Exchange.

The Key Bridge SAS and Exchange customer enrollment processes will also support the registration and certification of unlicensed parties through the Universal Licensing System and FCC Form 608.

Spectrum Aggregation Limits

Priority Access Licenses in the SAS and also in the Exchange are always associated with a currently registered and validated lessee. Both the SAS and the Exchange will take care to ensure that no controlling party’s licensed holdings exceed the spectrum aggregation limits identified in §96.66(3) of the Commission’s rules.

Key Bridge will also take care to ensure that any violation of this requirement, be it inadvertent, purposeful, or due to error or omission, will be quickly and automatically corrected and reported to the Commission upon discovery. Corrections may be through the invalidation or reversal (i.e. unwinding) of a spectrum trade or other administrative process.


A completed spectrum trade on the Exchange will generate an automated trade completion notification from the Exchange to the SAS. The electronic notification message will contain, at minimum, the information fields identified in §1.9046(c).

Upon receipt and acceptance the Key Bridge SAS will record the notification in a local transaction database. Once daily the SAS will generate a lease notification transaction report from its transaction database and submit the daily transaction report to the Commission via a Commission-provided automated and machine accessible API.

Illustration 4: The SAS will provide a daily transaction report of all leasing activity.

It may be useful for the Exchange to also submit transaction reports or summaries to the Commission. The Exchange will support this capability.

Lessee and Lessor Rights and Responsibilities

The Key Bridge SAS and SPX will treat CBSDs operated by a lessee the same as similarly situated CBSDs operated by the lessor.

During the period of a lease and within the geographic area of a lease the SAS will extend Priority Access Licensee protections after a leasing notification is accepted (i.e. received, verified and processed) by the SAS Infrastructure. This treatment will be extended for CBSDs operating within a leased geographic area and for the specified time period. If no time period is indicated then protections will be afforded immediately upon leasing notification acceptance and extended until either the original PAL expires or a subsequent notification of early termination is received by the SAS Infrastructure. Furthermore, during the period of a lease and within the geographic area of a lease the SAS Infrastructure will treat lessee operated CBSDs the same as a similarly situated lessor operated CBSD for frequency assignment and interference mitigation purposes.

Information Retention

The SAS and Exchange will retain all necessary and pertinent spectrum trade information for 60 months.

Learn more about spectrum trading

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