Rule 606 Disclosure Information

Wilson-Davis & Co., Inc.
SEC-Required Report on Routing of Customer Orders

SEC Rule 606 requires all broker-dealers that route non-directed customer orders in equity securities on a held basis and non-directed customer orders in option securities to make publicly available quarterly reports (broken out for S&P 500 stocks, other NMS stocks, and options) that, among other things, identify for each category the following:

  • The percentage of total customer orders that were non-directed orders and the percentages of total non-directed orders that were market orders, limit orders, or other orders.
  • The identity of the venues to which a significant percentage of total non-directed orders were routed for execution.
  • The percentage of total non-directed orders routed to the venue, and the percentages of total non-directed market orders, non-directed marketable limit orders, non- directed non-marketable limit orders, and non-directed other orders that were routed to the venue.
  • For each applicable venue, the amount of payment for order flow received, transaction fees paid, and transaction rebates received, both as a dollar amount and on a per-share basis.
  • Terms of the material aspects of the broker-dealer’s relationship with each venue identified above, including a description of any arrangement for payment for order flow and any profit-sharing relationship.

Consistent with SEC guidance, WDCO provides this information for venues to which it routes 5% or more of order flow. Additionally, upon written request, WDCO will provide you with details regarding the destination to which your orders (for up to six months preceding your request) were routed for execution. WDCO will also provide you, upon request, with information regarding the handling of any “not held” orders you might place with WDCO, consistent with the requirements of Rule 606(b)(3). WDCO does not receive Payment for Order Flow from any venues. WDCO routes over 95% of it’s routable customer orders itself. To access WDCO’s public order-routing reports for these trades please visit SunGard Trading Systems Best Execution Analysis.  A small percentage of WDCO customers are introduced on a fully disclosed to Hilltop Securities Inc. for clearing.  WDCO transmits these equity and option customer orders to Hilltop and relies on Hilltop Securities to route the orders.  These orders amount to approximately less than 5% of WDCO’s routable orders.  WDCO relies and on Hilltop’s 606 reports and disclosures for these orders and incorporates them by reference.  They are available here: Hilltop Securities Trading Agency .