BNY MELLON CAPITAL MARKETS, LLC (CRD #17454) — SEC Rule 606 Order Routing & FINRA Rule 5310.09 Execution Quality Report
Executive Best Execution & Order Routing Analysis
BNY MELLON CAPITAL MARKETS, LLC (CRD #17454) 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 VIRTU AMERICAS LLC (VALR) (80.4%), Pershing LLC (PERX) (77.8%), Goldman Sachs & Co (GSCO) (62.7%). 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 $855.00 in total net payment for order flow (PFOF) and execution rebates received across its order routing arrangements. Disclosed net payment rates for marketable limit orders averaged 30.00 ¢. 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 BNY MELLON CAPITAL 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 Venue | Route % | Disclosed PFOF (USD) | Net Rate (¢/100 sh) |
|---|---|---|---|
| VIRTU AMERICAS LLC (VALR) | 80.4% | $0.00 | 0.00 ¢ |
| Pershing LLC (PERX) | 77.8% | $0.00 | — |
| Goldman Sachs & Co (GSCO) | 62.7% | $0.00 | 0.00 ¢ |
| The Nasdaq Stock Market LLC (NSDQ) | 60.8% | $855.00 | 30.00 ¢ |
| BofA Securities,Inc. (MLCO) | 59.1% | $0.00 | 0.00 ¢ |
| Citadel Securities LLC (CITL) | 32.1% | $0.00 | 0.00 ¢ |
| Morgan Stanley (MSCO) | 30.1% | $0.00 | — |
| Susquehanna International Group, LLP (SUSQ) | 25.1% | $0.00 | 0.00 ¢ |
| DASH Financial Technologies LLC (DFIN) | 21.9% | $0.00 | — |
| Wolverine Execution Svc. (WEXX) | 12.3% | $0.00 | 0.00 ¢ |
| Virtu Americas, LLC (NITE) | 12.2% | $0.00 | — |
| Jane Street Options, LLC (JSOL) | 8.6% | $0.00 | 0.00 ¢ |
| Instinet (INCA) | 6.4% | $0.00 | 0.00 ¢ |
| RBC Capital Markets, LLC (RBCM) | 2.3% | $0.00 | 0.00 ¢ |
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.