A cell is one routed market center in one of the 144 Amended Rule 605 buckets; it counts once however many factors trail.
WEBULL FINANCIAL LLC (CRD #289063) — SEC Rule 606 Order Routing & FINRA Rule 5310.09 Execution Quality Report
Executive Best Execution & Order Routing Analysis
WEBULL FINANCIAL LLC (CRD #289063) 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 CITADEL SECURITIES LLC (31.7%), Dash/IMC Financial Markets (30.2%), Virtu Americas, LLC (20.6%). 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 reported $114,229,124.56 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 65.03 ¢ and marketable limit orders averaged 37.01 ¢. 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 345 of 478 scored routed venue × bucket cells (one routed market center in one of the 144 Amended Rule 605 order size and security buckets) where WEBULL FINANCIAL LLC'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) |
|---|---|---|---|
| CITADEL SECURITIES LLC (CDRG) | 31.7% | $37,210,097.76 | 90.11 ¢ |
| Dash/IMC Financial Markets | 30.2% | $25,898,979.83 | 30.27 ¢ |
| Virtu Americas, LLC (NITE) | 20.6% | $9,604,723.35 | 58.47 ¢ |
| Hudson River Trading (HRT) (HRTF) | 19.5% | $9,226,365.40 | 59.43 ¢ |
| Jane Street Capital (JNST) | 16.6% | $24,457,783.31 | 46.02 ¢ |
| Global Execution Brokers LP | 10.5% | $8,607,306.46 | 29.92 ¢ |
| Cboe EDGX Exchange, Inc. (EDGK) | 10.0% | $0.00 | -6.19 ¢ |
| MEMX LLC (MEMX) | 6.6% | $0.00 | 7.37 ¢ |
| Wolverine Execution Services, LLC | 5.1% | $69,961.68 | 1.95 ¢ |
S&P 500 (proxy) × Market • $1k–$5k (Round Lot)
Full execution metrics for routed flow against the mix-adjusted peer benchmark and competing market centers. (356,214 covered orders in tier)
| Role | Market Center | Routing Share (606) | PFOF Rate (¢/100) | NPI (bps) | Peer Bench (bps) | Fill Rate | Shortfall vs Bench |
|---|---|---|---|---|---|---|---|
| Routed Venue | CITADEL SECURITIES LLC (CDRG) | 34.9% | 306.89 ¢ | 1.9 bps | 2.0 bps | 100.0% | -0.0 bps |
| Routed Venue | Hudson River Trading (HRT) (HRTF) | 11.8% | 155.49 ¢ | 2.1 bps | 2.0 bps | 98.8% | 0.2 bps |
| Routed Venue | Jane Street Capital (JNST) | 20.5% | 176.01 ¢ | 1.5 bps | 2.0 bps | 79.0% | -0.4 bps |
| Routed Venue | Virtu Americas, LLC (NITE) | 17.6% | 159.87 ¢ | 1.8 bps | 2.0 bps | 92.3% | -0.2 bps |
| Benchmark | Mix-Adjusted Peer Benchmark | — | — | 2.0 bps | 2.0 bps | 94.7% | — |
| Competing Venue | Competing venue A | — | — | 3.5 bps | 2.0 bps | — | — |
| Competing Venue | Competing venue B | — | — | 1.8 bps | 2.0 bps | — | — |
Flagged Competing-Market Differences (84 Locked Buckets)
Scored execution buckets requiring committee evaluation and supervisory disposition under FINRA Rule 5310.09.
Complete Your FINRA Rule 5310.09 Best Execution Review
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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.