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2026Q22026Q1
Preview Report: 2026Q2 Routing × 2026Q3 Benchmarks

Preview, not a Rule 5310 review quarter. Routing and PFOF come from 2026Q2 (606, latest month in that quarter); execution quality comes from 2026Q3 amended 605 benchmarks. Route shares from one period are applied to benchmarks from another.

⚠️ 137 Competing-Market Differences Flagged Across 144 Buckets Requiring Rule 5310.09 Disposition
CRD #36500 Review Period: 2026Q2 Filing: Direct 606 filer

PICTET OVERSEAS INC. (CRD #36500) — SEC Rule 606 Order Routing & FINRA Rule 5310.09 Execution Quality Report

Mix-Adjusted Grade: F
Flagged Disparities by Category:
Other Equities × Market: 2 flagged Other Equities × Marketable Limit: 28 flagged Other Equities × nonmarketable_limit: 42 flagged S&P 500 Proxy × Market: 2 flagged S&P 500 Proxy × Marketable Limit: 27 flagged S&P 500 Proxy × nonmarketable_limit: 36 flagged

Executive Best Execution & Order Routing Analysis

PICTET OVERSEAS INC. (CRD #36500) files direct SEC Rule 606 quarterly order routing disclosures as an independent executing broker-dealer. In 2026Q2, the firm's non-directed customer order flow was routed across key market centers, led by Instinet, LLC (43.2%), CBOE EDGX Exchange (33.2%), Nasdaq Stock Market (22.9%). Under FINRA Rule 5310, the broker-dealer must evaluate whether routing choices maximize customer price improvement relative to non-routed market destinations.

During 2026Q2, the firm reported $3,068.00 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 79.59 ¢ and marketable limit orders averaged 160.61 ¢. 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 137 material differences across the 144 Amended Rule 605 order size and security buckets where PICTET OVERSEAS INC.'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)
Instinet, LLC43.2%$240.001185.30 ¢
CBOE EDGX Exchange (EDGK)33.2%$1,072.0017.60 ¢
Nasdaq Stock Market22.9%$292.0015.51 ¢
Clearpool Execution Services, LLC17.8%$999.0025.26 ¢
DASH Financial Technologies, LLC12.2%$82.005.52 ¢
IEX Investors'Exchange LLC (IEXG)10.4%$369.0026.16 ¢
Jane Street Capital9.4%$0.000.00 ¢
Flow Traders4.3%$0.000.00 ¢
CBOE BZX Exchange (BATS)3.6%$14.007.44 ¢
Virtu Financial, Inc (VIRT)1.4%$0.000.00 ¢
StoneX Financial Inc (INTL)0.2%$0.000.00 ¢
MCAP LLC (MCAP)0.2%$0.000.00 ¢
Sample Unlocked Bucket

S&P 500 Proxy × Market • $1k–$5k (ROUND)

Full execution metrics for routed flow against the mix-adjusted peer benchmark and competing market centers. (10,481 covered orders in tier)

RoleMarket CenterRouting Share (606)PFOF Rate (¢/100)NPI (bps)Peer Bench (bps)Fill RateShortfall vs Bench
Routed VenueStoneX Financial Inc (INTL)0.2%0.00 ¢1.4 bps1.8 bps99.6%-0.4 bps
BenchmarkMix-Adjusted Peer Benchmark——1.8 bps1.8 bps94.4%—

Flagged Competing-Market Differences (137 Locked Buckets)

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

CategorySize TierRule 5310.09 Status & Competing Markets
Other Equities × nonmarketable_limit$10k–$20k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit<$250 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$5k–$10k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit<$250 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$250–$999 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$1k–$5k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit<$250 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit<$250 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$250–$999 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$1k–$5k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$250–$999 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$5k–$10k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$10k–$20k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$1k–$5k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$250–$999 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$250–$999 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$5k–$10k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$20k–$50k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$20k–$50k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$250–$999 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$10k–$20k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$5k–$10k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$1k–$5k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$250–$999 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$50k–$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$250–$999 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$10k–$20k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$50k–$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$1k–$5k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$20k–$50k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$50k–$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$5k–$10k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit≥$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$1k–$5k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$250–$999 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$10k–$20k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$10k–$20k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$250–$999 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$5k–$10k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$5k–$10k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$50k–$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$250–$999 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit≥$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$5k–$10k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$20k–$50k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$1k–$5k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$20k–$50k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit≥$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit≥$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$10k–$20k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$10k–$20k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$50k–$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$10k–$20k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$5k–$10k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$20k–$50k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit≥$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$1k–$5k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$50k–$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$20k–$50k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$50k–$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit≥$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$20k–$50k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit≥$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$5k–$10k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$1k–$5k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$20k–$50k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$250–$999 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit≥$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$10k–$20k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$10k–$20k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$10k–$20k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$1k–$5k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$5k–$10k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$1k–$5k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$250–$999 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit≥$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$250–$999 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$20k–$50k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$20k–$50k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Market<$250 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$20k–$50k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$5k–$10k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$1k–$5k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit≥$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$5k–$10k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$50k–$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$1k–$5k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$10k–$20k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$50k–$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$10k–$20k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$5k–$10k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$10k–$20k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$5k–$10k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$10k–$20k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$20k–$50k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$5k–$10k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$20k–$50k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$20k–$50k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$20k–$50k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$1k–$5k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$10k–$20k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$1k–$5k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$1k–$5k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit$50k–$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$10k–$20k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$10k–$20k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Marketable Limit≥$200k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$5k–$10k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$5k–$10k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$1k–$5k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$50k–$200k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$250–$999 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$1k–$5k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$1k–$5k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$1k–$5k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$20k–$50k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit$5k–$10k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$250–$999 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$20k–$50k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$250–$999 • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Marketable Limit$50k–$200k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$1k–$5k • ROUND🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × nonmarketable_limit<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit$20k–$50k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Market$50k–$200k • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × nonmarketable_limit<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
Other Equities × Market<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification
S&P 500 Proxy × Market<$250 • ODD🔒 Locked — Unlock Workspace to View Competing Venues & Record Committee Justification

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