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2026Q1
⚠️ 0 Competing-Market Differences Flagged Across 144 Buckets Requiring Rule 5310.09 Disposition
CRD #142271 Review Period: 2026Q1 Filing: Direct 606 filer

VISION FINANCIAL MARKETS LLC (CRD #142271) — SEC Rule 606 Order Routing & FINRA Rule 5310.09 Execution Quality Report

Mix-Adjusted Grade: Unrated

Executive Best Execution & Order Routing Analysis

VISION FINANCIAL MARKETS LLC (CRD #142271) files direct SEC Rule 606 quarterly order routing disclosures as an independent executing broker-dealer. In 2026Q1, the firm's non-directed customer order flow was routed across key market centers, led by Citadel Securities (39.8%), Two Sigma Securities, LLC (28.4%), WOLVERINE EXECUTION SERVICES, LLC (8.0%). Under FINRA Rule 5310, the broker-dealer must evaluate whether routing choices maximize customer price improvement relative to non-routed market destinations.

During 2026Q1, the firm reported $-401,857.57 in total net payment for order flow (PFOF) and execution rebates received across its order routing arrangements. Disclosed net payment rates for market orders averaged -20.95 ¢ and marketable limit orders averaged -14.36 ¢. FINRA Rule 5310.09 requires rigorous surveillance of potential conflicts of interest when order routing decisions coincide with financial remuneration from execution venues.

Our mix-adjusted benchmark analysis flagged 0 material differences across the 144 Amended Rule 605 order size and security buckets where VISION FINANCIAL MARKETS LLC's routed execution trailed competing peer benchmarks by more than 1.0 basis points. Under FINRA Rule 5310.09, broker-dealers must conduct regular and rigorous committee reviews comparing execution quality achieved against competing market centers they do not route to. Each flagged competing-market difference requires documented supervisory disposition and committee review in the firm's permanent compliance records.

SEC Rule 606 Order Routing Summary

Disclosed non-directed customer order routing shares, total PFOF remuneration, and net rates by execution venue.

Execution VenueRoute %Disclosed PFOF (USD)Net Rate (¢/100 sh)
Citadel Securities (CDRG)39.8%$0.00-13.90 ¢
Two Sigma Securities, LLC (SOHO)28.4%$0.00-13.60 ¢
WOLVERINE EXECUTION SERVICES, LLC8.0%$0.00-17.57 ¢
DASH FINANCIAL TECHNOLOGIES LLC4.8%$3,122.005.13 ¢
Lampost Capital3.1%$1,925.635.73 ¢

Flagged Competing-Market Differences (0 Locked Buckets)

Scored execution buckets requiring committee evaluation and supervisory disposition under FINRA Rule 5310.09.

No locked exceptions detected in this review period.

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