Turn raw 605 and 606 filings into your quarterly Best-Execution Committee Dossier in minutes.
Automatically benchmark your routed venues against non-routed competing market centers across all 24 amended Rule 605 notional and odd-lot tiers. Document committee dispositions and export an RFC 3161 timestamped supervisory record.
The 3-Step Best-Execution Review Workflow
Public 606/605 data → Structured Committee DossierA structured pathway designed to evaluate competing-market execution quality and document committee oversight.
1. Exception Detection
Mix-adjusted benchmark comparing SEC Rule 606(a)(1) routed venues against all competing Rule 605 market centers on identical symbols and notional tiers under methodology exq-3. Identifies specific tiers with net price improvement shortfalls.
2. Modify-or-Justify Dispositions
Review each flagged exception against FINRA Rule 5310.09 supervisory factors. Select structured committee determinations (Modify Routing, Supervisory Watchlist, Clearing Constraint, Tail Latency) and record contemporaneous committee notes.
3. Archived Dossier & Trusted Timestamp
Enter committee attendees and meeting date to generate the 5-section governance dossier. Generating freezes the record in an immutable server archive and obtains an RFC 3161 timestamp token from an independent Timestamp Authority (DigiCert) over the dossier's SHA-256 only. Download the dossier and its token into your SEC Rule 17a-4 / FINRA Rule 4511 books-and-records system.
Going It Alone vs. ExecutionReports.com
The manual DIY approach creates fragile spreadsheets, misses non-routed market centers, and lacks exam-ready cryptographic provenance.
| Dimension | Going It Alone (Manual / In-House DIY) | With ExecutionReports.com |
|---|---|---|
| Data Ingestion & Parsing | Manually locating, downloading, and normalizing inconsistent SEC Rule 606 XML/PDFs and massive monthly Amended Rule 605 flat files across dozens of market centers. | Zero data engineering. 744 broker-dealers and all reporting Rule 605 market centers are pre-ingested, normalized, and validated automatically. |
| Amended Rule 605 Complexity (24 Tiers) | Building custom scripts to cross-tabulate 6 notional buckets × odd-lot, fractional, and round-lot categories across S&P 500 and Non-S&P 500 universes. | Instant mix-adjusted (exq-3) benchmarks across all 24 notional & lot tiers out of the box. |
| Rule 5310.09(b) “Non-Routed” Mandate | Blind spots on venues you don’t route to. Clearing firm packages rarely show whether an external non-routed venue beat your current routing table. | Automatic exception flagging whenever a non-routed competing market center delivers superior net price improvement in your exact order tiers. |
| Committee Governance & Dispositions | Ad-hoc Word docs, scattered emails, and untracked spreadsheets that are difficult to defend during a FINRA exam. | Structured “Modify-or-Justify” workspace with standardized 5310.09 supervisory dispositions and contemporaneous notes. |
| Audit Provenance & Books-and-Records | Brittle spreadsheets with no version control or cryptographic proof of when the review actually occurred. | Immutable SHA-256 source hashes + DigiCert RFC 3161 Trusted Timestamp ready for SEC Rule 17a-4 / FINRA Rule 4511 archive upload. |
Why Legacy Reports Fall Short in FINRA Rule 5310.09 Reviews
Rule 5310.09 requires evaluating execution quality across competing market centers, non-routed venues, and order flow conflicts. Standard single-dealer reports leave critical gaps.
The Clearing Firm Trap: Reliance Without Independent Inquiry
Introducing firms cannot satisfy Rule 5310.09(c) simply by adopting a clearing firm’s 606 report. FINRA requires introducing brokers to conduct their own independent review and evaluate whether competing market centers would provide superior execution for customer orders.
The Non-Routed Mandate: Competing Markets Benchmark
Rule 5310.09(b) obligates broker-dealers to compare currently routed venues against market centers the firm does not route to. With amended Rule 605 establishing 24 notional & odd-lot tiers, comparing execution statistics across external market centers is now essential.
PFOF & Price Shortfall Reconciliation
When order routing generates payment for order flow (PFOF) or exchange rebates, regulatory scrutiny requires reconciling payment amounts against any net price improvement shortfall relative to competing, non-rebate market centers.
Broker-Dealer Firm Review
Generate the 5310 evidence packet for any FINRA-registered firm. Includes routing shares, mix-adjusted venue scorecards, routing-weighted composites, and PFOF conflict estimates.
Market Center Scorecard
Examine an execution venue or exchange across the 24 amended Rule 605 size and lot categories. See peer benchmarks and every broker-dealer routing flow here.
Audit & Examination Provenance Guarantee
Every review packet is engineered to serve as an immutable evidentiary exhibit for your Best-Execution Committee and FINRA examination cycles:
- Competing Markets Evidence: Covers the competing-markets comparison in FINRA Rule 5310.09 from public 605/606 data by benchmarking routed venues against all competing reporters.
- Public Data Boundaries: Public Rule 605 reports cover all flow handled by a market center, not exclusively the reviewing firm’s orders. Rule 606 reports disclose top-10 and ≥5% venues only.
- Reproducible & Versioned: Every number cites its source URL, raw file SHA-256 hash, methodology version (exq-3), and immutable benchmark build ID.
- Internal Review Still Required: Covers the competing-markets comparison in FINRA Rule 5310.09 from public 605/606 data. Your own order-level review is still required. This analysis does not constitute legal or compliance advice.
Live Engine Benchmarks (2026 Q2 / Amended 605)
Empirical execution statistics and order routing data normalized under methodology exq-3.
| Firm Name | CRD | Rule 606 Filing | Action |
|---|---|---|---|
| ROBINHOOD FINANCIAL, LLC | 165998 | Direct 606 filer | View Review → |
| CHARLES SCHWAB & CO., INC. | 5393 | Direct 606 filer | View Review → |
| A.G.P. / ALLIANCE GLOBAL PARTNERS | 8361 | Adopts clearing firm report | View Review → |
| CITIGROUP GLOBAL MARKETS INC. | 7059 | Direct 606 filer | View Review → |
| WELLS FARGO CLEARING SERVICES, LLC | 19616 | Direct 606 filer | View Review → |
Top Net Price Improvement by Order Tier (Amended 605 • Month 202608)
Leading market centers by net price improvement (bps of executed notional) under methodology exq-3.
| Market Universe | Order Class | Notional × Lot Tier | Top Market Center | Net Price Improvement (bps) | Fill Rate | Action |
|---|---|---|---|---|---|---|
| S&P 500 (proxy) | Market | $250–$999 • Odd Lot | Cboe EDGX Exchange (EDGK) | +67.0 bps | 94.7% | Scorecard → |
| S&P 500 (proxy) | Market | $1k–$5k • Odd Lot | Cboe EDGX Exchange (EDGK) | +43.3 bps | 93.4% | Scorecard → |
| S&P 500 (proxy) | Market | <$250 • Odd Lot | New York Stock Exchange (NXNYS) | +8.9 bps | 89.4% | Scorecard → |
| S&P 500 (proxy) | Market | $1k–$5k • Fractional | FIDELITY BROKERAGE SERVICES LLC (FIBS) | +7.3 bps | 56.3% | Scorecard → |
| S&P 500 (proxy) | Marketable Limit | $5k–$10k • Odd Lot | XTX Execution Services LLC (XTXE) | +6.9 bps | 61.2% | Scorecard → |
| S&P 500 (proxy) | Marketable Limit | $1k–$5k • Odd Lot | XTX Execution Services LLC (XTXE) | +6.9 bps | 68.6% | Scorecard → |
| S&P 500 (proxy) | Marketable Limit | $1k–$5k • Fractional | NATIONAL FINANCIAL SERVICES LLC (NFSF) | +6.0 bps | 59.1% | Scorecard → |
| S&P 500 (proxy) | Market | $250–$999 • Fractional | MORGAN STANLEY (MSFR) | +5.8 bps | 100.0% | Scorecard → |
Largest Recipients of Net Payment for Order Flow (SEC Rule 606 • 2026Q3 • NMS Stocks)
Sum of net payments received (PFOF and exchange rebates) disclosed in 315 broker-dealer Rule 606(a)(1) reports. Options excluded. Rates above 500¢ per 100 shares ($0.05/sh) are treated as unit errors and excluded (12 rows). Affiliated introducing and clearing firms may both report the same orders, so totals can double count.
| Execution Venue | 605 ID | Total | S&P 500 | Non-S&P 500 | Market | Marketable Limit | Non-Marketable Limit | Other | Scorecard |
|---|---|---|---|---|---|---|---|---|---|
| CITADEL SECURITIES, LLC | CDRG | $189.58M | $32.36M | $157.23M | $68.16M | $44.21M | $41.76M | $35.45M | CDRG Scorecard → |
| Virtu Americas LLC | NITE | $126.94M | $30.37M | $96.57M | $44.93M | $25.24M | $22.93M | $33.85M | NITE Scorecard → |
| HRT Financial LP | HRTF | $75.61M | $14.18M | $61.43M | $33.68M | $11.09M | $23.58M | $7.26M | HRTF Scorecard → |
| JANE STREET CAPITAL, LLC | JNST | $69.62M | $12.80M | $56.82M | $26.44M | $16.02M | $22.87M | $4.29M | JNST Scorecard → |
| TWO SIGMA SECURITIES, LLC | SOHW | $28.06M | $2.62M | $25.44M | $13.51M | $2.91M | $9.33M | $2.30M | SOHW Scorecard → |