Rule 606: Material Aspects

Disclosure of Material Aspects of Venue Relationships Pursuant to SEC Rule 606(a), EarlyBirdCapital, Inc. ("EBC") publishes routing statistics for its customers’ orders in U.S. exchange-listed equity securities which it sends to various execution venues or intermediary broker-dealers.

The SEC’s final adopting release, along with the text of Rule 606, can be found at:

The SEC’s Frequently Asked Questions about Rule 606 can be found at:

This report provides information regarding the routing destinations EBC utilizes for non-directed customer orders submitted on a held basis. This report identifies the routing destinations selected by EBC, the percentage of various types of orders routed to the venues, and if applicable, discusses the material aspects of EBC's relationship with the venues.

Below are the top five venues with which EBC routes the largest number of total non-directed orders for execution as well as any venue with 5% or more of the non-directed orders for execution—

  • Citadel Securities, LLC
  • Virtu Americas, LLC
  • UBS Securities, LLC
  • Wedbush Securities

EBC does not receive any payment for order flow from the venues listed but does receive execution fees and/or rebates at certain exchanges and execution venues such as Virtu Americas. Additionally, NYSE and NASDAQ operate within pricing tiers for public exchange pricing and offer fee/rebates per public exchange pricing disclosures.

Primarily, EBC routes orders in Rule 606 reportable securities, other than options as discussed separately below, to intermediary broker-dealers that may not be the ultimate execution venue of such orders. Orders routed to these intermediary broker-dealers are generally internalized or further routed to execution venues.

EBC does not receive any remuneration for the held orders routed to these intermediary broker-dealers, including any execution venue fees or rebates that may be paid by an executing venue. However, the intermediary broker-dealer may receive remuneration from executing venues through maker-taker pricing or other applicable execution venue fees or rebates, which are generally similar regardless of which cost-plus intermediary broker-dealer EBC selects for a particular customer order.

EBC does not select the execution venues to which the intermediary broker-dealers route Rule 606 reportable securities for execution. As a result, these routing broker-dealers are better positioned to prepare a quarterly report that reflects any execution venue specific maker-taker arrangements or other execution venue fees or rebates.

Options: EarlyBirdCapital does not execute options on behalf of customers.