SEC Rule 606
Under SEC Rule 606, broker-dealers that route orders on behalf of customers are required to prepare quarterly reports that disclose the following information.
- The percentage of total customer orders that were non-directed orders, and the percentages of total non-directed orders that were market orders, limit orders, or other orders
- The identity of the venues to which a significant percentage of total non-directed orders were routed for execution
- The percentage of total non-directed orders routed to the venue, and the percentages of total non-directed market orders, non-directed limit orders, and non-directed other orders that were routed to the venue
- Terms of the material aspects of the broker-dealer’s relationship with each venue identified above, including a description of any arrangement for payment for order flow and any profit-sharing relationship
The reports are to be made public for each calendar quarter and published no later than one month after the end of the quarter. Another piece of this rule requires annual public notification that the detail is available.
Pursuant to the rule, customers can request details, from their investment representative, on the identity of the venue to which the customer’s orders were routed for execution in the six months prior to the request, whether the orders were directed, at the customer’s request, to a specific venue for execution and the time of the executions, if any, that resulted from those orders. Customers also may request up to six months of this information in hard copy through a representative on all orders for a specific time period and/or on individual securities.
Market centers include exchange market makers (e.g. specialist), OTC market makers, alternative trading systems, national securities exchanges (e.g. New York Stock Exchange, Inc.), or national securities associations. (e.g. FINRA)
We have made every attempt to prepare these statistics in compliance with the SEC’s rules, however these statistics have not been audited and may contain errors. The SEC has made it clear that investors should take into account a number of factors in evaluating the quality of their order executions and in making order routing decisions. These include the size of the order, whether the dealer commits its capital to enhance liquidity for the customer, market conditions, customer objectives, technological capabilities, and other services provided by the dealer. Accordingly, any decision about whether to establish a relationship with Keel Point should not be based solely on these statistics, but on an evaluation of Keel Point’s full range of provided services.
Our most recent Quarterly Report is linked below.