Rule 605 and Rule 606 Reporting

Clear Street supports the development and implementation of rules and regulatory initiatives that produce more liquid and transparent markets. On November 17, 2000, the Securities and Exchange Commission (“SEC”) adopted two rules to improve public disclosure of execution and routing practives.

Overview

Rules 605 and 606 were adopted to standardize and improve public disclosure of execution and routing practices. Pursuant to the SEC’s execution quality disclosure rule (Rule 605), monthly performance statistics can be obtained directly from the Virtu website. Client specific Rule 605 Execution Statistics can be obtained by accessing our web-based client portal using a password-protected login.

Rule 605

Rule 605 requires “market centers” that trade National Market System securities to make available standardized, monthly reports containing statistical information about “covered order” executions. Rule 605 is intended to promote visibility and competition in order execution quality, particularly with respect to execution price and speed. The rule requires, among other things, that the reports be prepared in an electronic format available for downloading from an Internet website that is free and readily accessible to the public.
The disclosures required by Rule 605 do not encompass all of the factors that may be important to clients in evaluating the order routing practices of a broker-dealer. In addition, any particular market center’s statistics will encompass varying types of orders routed by different broker-dealers on behalf of customers with a wide range of objectives. Accordingly, the statistical information required by Rule 605 alone does not create a reliable basis to address whether any particular broker-dealer obtained the most favorable terms under the circumstances for customer orders.
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Rule 606

Rule 606 requires broker-dealers that route customer orders in equities and option securities to publish quarterly reports that provide a general overview of their routing practices. In this report, the venues to which non-directed customer orders in U.S. exchange-listed equity securities and options were routed for execution must be disclosed, as well as the nature of any relationship the broker-dealer has with each venue.
The purpose of this report is to provide the public with information on how broker-dealers route orders, enable the evaluation of order routing practices, and foster competition among market participants. Upon request, broker-dealers also must disclose to customers the venues to which their individual orders were routed. Each customer may request a written copy of the report be mailed to them at no charge.
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Disclosures and Material Relationships

Clear Street routes orders to market centers, including national securities exchanges, alternative trading systems, electronic communications networks, and broker-dealers that may offer credits for orders that provide liquidity to (remove liquidity from) their books and assess fees for orders that take liquidity from (add liquidity to) their books. In some cases, the credits offered by a market center may exceed the charges assessed, such that a market center may make a payment to Virtu in relation to orders directed to such market center.
“Other Orders” include market opening and closing orders, orders submitted with stop prices, all-or-none orders and Not Held orders. Algorithmic and Smart Order Routing orders are considered Not Held. Additional information about the Rule 606 reports:

Information About the Report

The report is divided into three sections:
  1. New York Stock Exchange listed securities
  2. Nasdaq Stock Exchange listed securities
  3. NYSE MKT and other Exchange listed securities
For each section, this report identifies the top venues to which Clear Street routed orders, setting forth the percentage for each venue. Questions regarding this report should be addressed to:
Clear Street LLC
Compliance Department
55 Broadway, 21st Floor
New York, NY 10006