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.
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.
- Utilizes Recursive Routing Analysis (RRA) to reduce information leakage while remaining in compliance with look-through requirements
- Mitigates unnecessary information leakage by offering the least data possible whilst remaining in compliance with reporting guidelines
- Allows the introducing broker to produce the required look-through data without viewing the details beyond the required data (when counterparties utilize S3 606 Reporting)
Ensures that an introducing broker’s customer ID is not seen by the executing broker
- 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
Our client support team is ready to assist. Please contact us today to get started.
Key SEC Updates
- In depth information regarding venues, orders and executions
- Held NMS Equity and Option orders less 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
- Firms must begin collecting data January 1, 2020
- 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
- Firms must begin collecting data October 1, 2019
- 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
- Firms must begin collecting first route data January 1, 2020, and second route data June 1, 2020