A cell is one routed market center in one of the 144 Amended Rule 605 buckets; it counts once however many factors trail.
PHILLIP CAPITAL INC. (CRD #173869) — SEC Rule 606 Order Routing & FINRA Rule 5310.09 Execution Quality Report
Executive Best Execution & Order Routing Analysis
PHILLIP CAPITAL INC. (CRD #173869) files direct SEC Rule 606 quarterly order routing disclosures as an independent executing broker-dealer. In 2026Q3, the firm's non-directed customer order flow was routed across key market centers, led by no primary routing venues disclosed. Under FINRA Rule 5310, the broker-dealer must evaluate whether routing choices maximize customer price improvement relative to non-routed market destinations.
During 2026Q3, the firm disclosed $0.00 in total net payment for order flow (PFOF) across market and marketable limit orders. While zero disclosed remuneration mitigates direct rebate conflicts, FINRA Rule 5310.09 nevertheless mandates regular and rigorous quarterly evaluation of whether routed order execution achieves best execution against alternative market centers.
Our mix-adjusted benchmark analysis flagged 0 of 0 scored routed venue × bucket cells (one routed market center in one of the 144 Amended Rule 605 order size and security buckets) where PHILLIP CAPITAL INC.'s routed execution trailed competing peer benchmarks on at least one factor. 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 Venue | Route % | Disclosed PFOF (USD) | Net Rate (¢/100 sh) |
|---|
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.
Complete Your FINRA Rule 5310.09 Best Execution Review
Unlock all 144 order size and security tiers, reveal competing market center metrics, record supervisory dispositions, and export signed committee minutes.
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Standing Review Limitations:
- A venue's Rule 605 statistics describe all flow it handled, not this firm's orders.
- 606 route shares are per order, not per share, and list only the top 10 venues plus any venue with at least 5% of non-directed orders.
- FINRA Rule 5310.09 also requires the firm's own order-level review of its executions.
- This report is not legal or compliance advice.
- Net price improvement is in basis points of executed notional (quote midpoint × shares). The PFOF comparison converts the difference to ¢/100 sh at the venue's average executed price; it is an estimate.