SEC Rule 606 Reporting

Easily and effectively comply with the 2019 SEC 606 order routing disclosure regulations.

The Securities and Exchange Commission (“SEC”) announced updates to Rule 606 in an effort to ensure that broker-dealers are acting in the best interest of their clients. These enhancements pertain to rebates, fees and order routing related to Best Execution mandates. 

Effective January 1, 2020, all broker-dealers who handle order flow are expected to be compliant with this mandate.

The S3 Solution

Since the release of this disclosure, S3 has been proactively developing automated 606 reporting solutions. Our team of industry experts actively monitors and communicates with the SEC to ensure that these reports are in compliance.

S3 Product Features


  • Utilizes Recursive Routing Analysis (RRA) offering the least amount of information leakage whilst remaining in compliance
  • Ability to drill down to a granular level of analytical detail to verify data
  • Generates reports that are in compliance with 606 requirements
  • Easily produces 606 reports with the click of one button

Get Started Today

Our client support team is ready to assist. Please contact us today to get started.

 Key SEC Updates

 Report 606(a)(1)

  • In depth information regarding venues, orders and executions
  • Held NMS Equity and Option orders greater than $50,000 must be disclosed
  • Marketability of security at route time
  • Detailed fee and rebate disclosure
  • Required to be in XML and PDF Format

 Report 606(b)(1)

  • Upon request, XML and PDF reports for held, exempt not-held and options orders
  • Detailed order execution data, including execution venue and time for any customer order

 Report 606(b)(3)

  • Upon request, XML and PDF reports for not-held orders must be provided within 7 days
  • Includes Information on:
    • Actionable Indications of Interest (IOIs) including venues that received the IOI
    • Order Routing, including size and further routable instructions
    • Order Execution, including volumes, fees, rebates, spread position
    • Liquidity, including whether liquidity was provided or removed, fees and rebates associated with time or execution