Order Routing Information Rule 606
The Securities & Exchange Commission (SEC) adopted Rule 606 (formerly SEC 11Ac1-6) of the Securities Exchange Act. Rule 606 requires Woodbury Financial to comply with four primary disclosure elements: 1.) to make publicly available quarterly reports that present a general overview of order routing practices; 2.) to disclose the nature of any relationship it has with venues that it routes client orders; 3.) to furnish clients upon request the venues to which individual orders were sent for execution for the previous six months; and 4.) to provide an annual written notification to clients that this information is available upon request.
With respect to Woodbury Financial’s relationships with trading venues, Woodbury Financial directs all trades in over-the-counter (OTC), listed stock, and options to our clearing firm, Pershing, for execution.
Pershing and its affiliate, Pershing Trading Company, (collectively “Pershing”), receive compensation for directing OTC and equity stock, and listed options order flow, to selected market makers and option specialists. Pershing also directs a percentage of listed equity flow to certain exchanges or specialists and receives compensation in connection with the routing of such orders.
With respect to OTC and listed options transactions, compensation may be in the form of a per share or per contract cash payment or non-cash compensation in the form of reciprocal arrangements whereby, in exchange for having orders directed to them, other broker-dealers will direct certain orders to Pershing. Similar reciprocal arrangements exist with respect to listed equities, whereby other broker- dealers will direct orders to Pershing specialists on the floor of various exchanges in return for receiving orders from Pershing. Additionally, certain exchanges reduce or eliminate execution fees on orders directed to them in dually listed securities.
The designated market makers to whom orders are automatically routed are selected based on the consistently high quality of their executions in one or more market segments and their history of seeking price improvements. Pershing regularly reviews reports for quality of execution purposes.
The source and nature of this compensation, if any, received in connection with this trade will be furnished upon your written request to your broker.
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