REGULATORY NOTICE: Amended SEC Rule 605 (24 Notional & Odd-Lot Tiers) is now live. Rule 606 vs. amended 605 competing-market benchmarks for 744 broker-dealers.
FINRA RULE 5310.09 & AMENDED SEC RULE 605 COMPLIANCE ENGINE • Methodology exq-3

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 Dossier

A structured pathway designed to evaluate competing-market execution quality and document committee oversight.

Step 1 • Diagnosis Public Preview

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.

Step 2 • Governance Workspace UI

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.

Step 3 • Record Server Archive

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.

Rule 5310.09(c) Clearing Reliance

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.

Rule 5310.09(b) Competing Venues

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.

Conflict Factor PFOF Reconciliation

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.

Quick: ROBINHOOD FINANCIAL, LLC (165998) • CHARLES SCHWAB & CO., INC. (5393) • A.G.P. / ALLIANCE GLOBAL PARTNERS (8361)

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.

Popular: CITADEL SECURITIES, LLC (CDRG) • Virtu Americas LLC (NITE) • JANE STREET CAPITAL, LLC (JNST) • Cboe BZX Exchange (BATS)
Compare Two Broker-Dealers: Evaluate route composites and PFOF side-by-side to benchmark peer execution metrics.
Compare Peers →
Supervisory Integrity

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:

FINRA 5310.09(b) Competing Markets Coverage
SHA-256 + DigiCert RFC 3161 Timestamp
Reproducible exq-3 Methodology
  • 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.

Live Regulatory Feeds