Under FINRA Rule 6151, this broker-dealer adopts by reference the 606 routing reports of its clearing firm(s): PERSHING LLC. 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.
SAMUEL A. RAMIREZ & COMPANY, INC. (CRD #6963) — SEC Rule 606 Order Routing & FINRA Rule 5310.09 Execution Quality Report
Executive Best Execution & Order Routing Analysis
SAMUEL A. RAMIREZ & COMPANY, INC. (CRD #6963) operates as an introducing broker-dealer adopting the SEC Rule 606 order routing disclosures of PERSHING LLC. 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 GLOBAL EXECUTION BROKERS, LP. (27.5%), CITADEL SECURITIES LLC (27.3%), JANE STREET CAPITAL, LLC (18.5%).
During 2026Q3, the firm reported $304,378.05 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 10.65 ¢ and marketable limit orders averaged 16.45 ¢. 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 492 of 753 scored routed venue × bucket cells (one routed market center in one of the 144 Amended Rule 605 order size and security buckets) where SAMUEL A. RAMIREZ & COMPANY, 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) |
|---|---|---|---|
| GLOBAL EXECUTION BROKERS, LP. | 27.5% | $33,971.10 | 38.00 ¢ |
| CITADEL SECURITIES LLC (CDRG) | 27.3% | $87,536.33 | 19.19 ¢ |
| JANE STREET CAPITAL, LLC (JNST) | 18.5% | $32,821.25 | 9.87 ¢ |
| WOLVERINE EXECUTION SERV, LLC | 15.9% | $21,859.90 | 37.81 ¢ |
| G1 EXECUTION SERVICES, LLC (ETMM) | 15.9% | $30,014.03 | 9.96 ¢ |
| DASH FINANCIAL OPTION ATS | 13.9% | $19,061.25 | 35.79 ¢ |
| HRT FINANCIAL LP (HRTF) | 11.5% | $19,979.70 | 9.99 ¢ |
| VIRTU AMERICAS LLC (NITE) | 11.4% | $20,626.71 | 9.99 ¢ |
| UBS SECURITIES (UBSS) | 7.0% | $10,437.32 | 9.99 ¢ |
| TWO SIGMA SECURITIES (SOHW) | 6.3% | $10,127.88 | 9.99 ¢ |
| JNOP | 5.4% | $7,596.10 | 31.89 ¢ |
| STONEX FINANCIAL INC. (INTL) | 4.2% | $7,044.71 | 9.98 ¢ |
| DASH FINANCIAL TECH LLC | 3.6% | $1,256.75 | 5.12 ¢ |
| GTS SECURITIES LLC. (GTSM) | 0.6% | $1,609.63 | 10.00 ¢ |
| ICRS | 0.5% | $435.39 | 10.00 ¢ |
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. (484,376 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) | 25.7% | 10.00 ¢ | 1.9 bps | 2.0 bps | 100.0% | -0.0 bps |
| Routed Venue | G1 EXECUTION SERVICES, LLC (ETMM) | 14.5% | 10.00 ¢ | 1.9 bps | 2.0 bps | 100.0% | -0.2 bps |
| Routed Venue | GTS SECURITIES LLC. (GTSM) | 0.0% | 10.00 ¢ | 1.9 bps | 2.0 bps | 7.9% | -0.1 bps |
| Routed Venue | HRT FINANCIAL LP (HRTF) | 13.7% | 10.00 ¢ | 2.1 bps | 2.0 bps | 98.8% | 0.2 bps |
| Routed Venue | STONEX FINANCIAL INC. (INTL) | 4.4% | 10.00 ¢ | 1.4 bps | 1.8 bps | 99.6% | -0.4 bps |
| Routed Venue | JANE STREET CAPITAL, LLC (JNST) | 17.5% | 10.00 ¢ | 1.5 bps | 2.0 bps | 79.0% | -0.4 bps |
| Routed Venue | VIRTU AMERICAS LLC (NITE) | 10.9% | 10.00 ¢ | 1.8 bps | 2.0 bps | 92.3% | -0.2 bps |
| Routed Venue | TWO SIGMA SECURITIES (SOHW) | 5.5% | 10.00 ¢ | 1.8 bps | 2.0 bps | 100.0% | -0.3 bps |
| Routed Venue | UBS SECURITIES (UBSS) | 7.3% | 10.00 ¢ | 1.7 bps | 1.9 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 (62 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.
7-day committee preview for SAMUEL A. RAMIREZ & COMPANY, INC.
Work email only. We email a sign-in link; the preview unlocks this CRD for 7 days. Exports stay watermarked.
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.