Best Execution Order Routing

In November 2000, the Securities and Exchange Commission (SEC) adopted SEC 606 which generally requires broker-dealers that route customer orders in covered securities to make publicly available quarterly reports that disclose venues to which they route non-directed orders. It also requires broker-dealers to disclose the nature of any relationship they have with those venues, including any payment for order flow arrangements. In addition, broker-dealers must disclose to customers, on request, the venues to which their individual orders were routed.