Disclosure of Order Routing Practices (SEC Rule 606-Formally Rule 11Ac1-6) (Q3 2012)

SEC Rule 606 requires broker/dealers that route orders on behalf of customers to prepare quarterly reports that disclose the identity of the venues to which it routed orders for execution. The reports also will disclose the nature of the broker-dealers relationship with those venues, including the existence of any internalization or payment for order flow arrangements. Additionally, Rule 606 requires broker/dealers to make publicly available for each calendar quarter a report on its routing of non-directed orders in covered securities. The term “make publicly available” requires the Firm to complete three steps — post on a free Internet web site, furnish a written copy on request, and notify customers at least annually that a written copy will be furnished on request. Each quarterly report shall be made publicly available within one month after the end of the quarter addressed in the report.