Under FINRA Rule 6151, this broker-dealer adopts by reference the 606 routing reports of its clearing firm(s): APEX CLEARING CORPORATION. Under FINRA Rule 5310.09(c), introducing broker-dealers must independently examine execution quality and compare clearing firm routing against competing market centers.
A cell is one routed market center in one of the 144 Amended Rule 605 buckets; it counts once however many factors trail.
UPHOLD SECURITIES INC. (CRD #34071) — SEC Rule 606 Order Routing & FINRA Rule 5310.09 Execution Quality Report
Executive Best Execution & Order Routing Analysis
UPHOLD SECURITIES INC. (CRD #34071) operates as an introducing broker-dealer adopting the SEC Rule 606 order routing disclosures of APEX CLEARING CORPORATION. Under FINRA Rule 5310.09(c), introducing firms that rely on clearing firm routing arrangements remain obligated to independently examine execution quality and compare results against competing market centers. In 2026Q3, non-directed customer order flow was routed primarily to Virtu Americas, LLC (48.3%), CITADEL SECURITIES LLC (25.3%), Instinet, LLC (20.9%).
During 2026Q3, the firm reported $15,394,805.67 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 22.38 ¢ and marketable limit orders averaged 24.91 ¢. 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 226 of 364 scored routed venue × bucket cells (one routed market center in one of the 144 Amended Rule 605 order size and security buckets) where UPHOLD SECURITIES 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) |
|---|---|---|---|
| Virtu Americas, LLC (NITE) | 48.3% | $1,985,973.18 | 18.08 ¢ |
| CITADEL SECURITIES LLC (CDRG) | 25.3% | $3,503,707.59 | 21.32 ¢ |
| Instinet, LLC (ICBX) | 20.9% | $0.00 | 0.00 ¢ |
| Dash/IMC Financial Markets | 18.9% | $2,122,090.60 | 28.81 ¢ |
| Wolverine Execution Services, LLC | 16.3% | $1,396,223.57 | 34.08 ¢ |
| Jane Street Capital (JNST) | 13.2% | $3,457,270.26 | 23.58 ¢ |
| Global Execution Brokers LP | 8.9% | $1,491,098.61 | 30.00 ¢ |
| Matrix Executions, LLC | 6.3% | $792,697.56 | 14.17 ¢ |
| Hudson River Trading (HRT) (HRTF) | 5.1% | $645,744.30 | 14.82 ¢ |
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) | 27.1% | 20.00 ¢ | 1.9 bps | 2.0 bps | 100.0% | -0.0 bps |
| Routed Venue | Hudson River Trading (HRT) (HRTF) | 5.1% | 12.55 ¢ | 2.1 bps | 2.0 bps | 98.8% | 0.2 bps |
| Routed Venue | Jane Street Capital (JNST) | 7.7% | 20.00 ¢ | 1.5 bps | 2.0 bps | 79.0% | -0.4 bps |
| Routed Venue | Virtu Americas, LLC (NITE) | 59.1% | 17.95 ¢ | 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 (61 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
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.