Order Routing Information and Practices

The U.S. Securities and Exchange Commission’s (“SEC”) client disclosure rule, SEC rule 606 requires a broker-dealer that routes orders on behalf of customers, to prepare quarterly reports (“606″ Reports”) that disclose the identity of the venues to which it routed orders for execution. Broker dealers are required to disclose, on customer request, where they routed a customer’s individual orders for execution.

The quarterly information is available free of charge on our web site at www.btig.com/disclosures/sec-rule-606/.  Unless BTIG’s customer specifically requests that its order be routed to a particular market center, BTIG selects execution venues based on the size of the order, the trading characteristics of each security, speed of execution, likelihood of price improvement, availability of efficient automated transaction processing, guaranteed automatic execution level, and other qualitative factors.  Broker-dealers must disclose the nature of the broker-dealer’s relationship with those market centers reported, including the existence of any internalization or payment for order flow arrangements or profit-sharing relationship as it related to the type of securities for that section.

In seeking to obtain best execution for a client’s order, BTIG may execute the order as principal (in such cases BTIG could sustain profits or losses as a result of executing internally) or may route the order to an affiliated or nonaffiliated broker-dealer, alternative trading system or exchange for execution. When it routes an equity or options order (including for a BTIG customer) that provides liquidity on an equity or options exchange, pursuant to the exchange’s fee schedule, BTIG receives a fee rebate for such liquidity provision.  Similarly, for certain transactions in listed options, options liquidity providers provide payment to BTIG (including payments reflecting rebates these liquidity providers may receive) in connection with the options transaction those liquidity providers handle for BTIG.  BTIG does not take into account the fact or amount of any such fee rebate when determining where to route a customer order, although for certain transactions BTIG may seek pricing only from liquidity providers that provide such payments.

Beginning January 2020, The Firm is required to publish quarterly statistics regarding its customer agency order routing practices. The purpose of the report is to provide the public with information on how broker-dealers route their customers’ orders including payment for order flow, fees, rebates, and economic incentives, to enable customers (and others) to evaluate order routing practices. The Rule was adopted by the SEC to enhance market transparency and foster competition among market participants.

This information is available on the internet and in hard copy for those who do not have access to the internet. The report is published by the end of the month following the calendar quarter reported. In addition to quarterly reports, certain information under the Rule about the routing of individual customer orders is available to customers, upon request, for the prior six months’ trading activity. This includes directed or non-directed orders and the transaction time, separated for NMS held orders, NMS not held orders and options on NMS securities. In addition, upon request of a customer who places a not held order the Firm must provide a standardized set of individualized disclosures. Request can be made to [email protected] or via your Registered Representative.