TABB Forum published op-ed authored by S3 CEO Mark Davies.
13 September 2019
While fulfilling SEC Rule 606 obligations may seem straightforward, it actually is very complicated, considering all the parties involved. S3 CEO Mark Davies breaks down the complex web of data management required to comply with the regulations, as well as the unintended consequences.
How difficult will it be to fulfill SEC Rule 606 obligations? On the surface it may seem straightforward. Unfortunately, it actually is very complex, considering all the parties involved. A typical agency brokerage will now have to provide its institutional clients with a 606(b)(3) report that outlines the routes that its orders follow, including fees and rebates associated with those orders for many downstream firms, likely incorporating information from venues the brokerage is unfamiliar with.