Build your quarterly FINRA Rule 5310.09 best-execution dossier from public 606 and 605 data.
Benchmark SEC Rule 606(a)(1) routing disclosures against non-routed competing market centers across all 24 amended Rule 605 notional and odd-lot tiers. Document committee dispositions and generate supervisory review records.
Why Legacy Reports Fall Short in FINRA Rule 5310.09 Reviews
Rule 5310.09 requires evaluating execution quality across competing market centers, non-routed venues, and order flow conflicts. Standard single-dealer reports leave critical gaps.
The Clearing Firm Trap: Reliance Without Independent Inquiry
Introducing firms cannot satisfy Rule 5310.09(c) simply by adopting a clearing firm’s 606 report. FINRA requires introducing brokers to conduct their own independent review and evaluate whether competing market centers would provide superior execution for customer orders.
The Non-Routed Mandate: Competing Markets Benchmark
Rule 5310.09(b) obligates broker-dealers to compare currently routed venues against market centers the firm does not route to. With amended Rule 605 establishing 24 notional & odd-lot tiers, comparing execution statistics across external market centers is now essential.
PFOF & Price Shortfall Reconciliation
When order routing generates payment for order flow (PFOF) or exchange rebates, regulatory scrutiny requires reconciling payment amounts against any net price improvement shortfall relative to competing, non-rebate market centers.
The 3-Step Best-Execution Review Workflow
Public 606/605 data → Structured Committee DossierA structured pathway designed to evaluate competing-market execution quality and document committee oversight.
1. Exception Detection
Mix-adjusted benchmark comparing SEC Rule 606(a)(1) routed venues against all competing Rule 605 market centers on identical symbols and notional tiers under methodology exq-2. Identifies specific tiers with net price improvement shortfalls.
2. Modify-or-Justify Dispositions
Review each flagged exception against FINRA Rule 5310.09 supervisory factors. Select structured committee determinations (Modify Routing, Supervisory Watchlist, Clearing Constraint, Tail Latency) and record contemporaneous committee notes.
3. Dossier Print & Content Hash
Enter committee attendees and meeting date to assemble the formal 5-section governance dossier. Clean print layout plus client-side SHA-256 content hash of the review record for internal supervisory files.
Broker-Dealer Firm Review
Generate the 5310 evidence packet for any FINRA-registered firm. Includes routing shares, mix-adjusted venue scorecards, routing-weighted composites, and PFOF conflict estimates.
Market Center Scorecard
Examine an execution venue or exchange across the 24 amended Rule 605 size and lot categories. See peer benchmarks and every broker-dealer routing flow here.
Scope, Provenance, and Limitations
Every review packet is designed to serve as an evidentiary exhibit for a firm’s Best Execution Committee or regulatory examination:
- Competing Markets Evidence: Covers the competing-markets comparison in FINRA Rule 5310.09 from public 605/606 data by benchmarking routed venues against all competing reporters.
- Public Data Boundaries: Public Rule 605 reports cover all flow handled by a market center, not exclusively the reviewing firm’s orders. Rule 606 reports disclose top-10 and ≥5% venues only.
- Reproducible & Versioned: Every number cites its source URL, raw file SHA-256 hash, methodology version (exq-2), and immutable benchmark build ID.
- Internal Review Still Required: Covers the competing-markets comparison in FINRA Rule 5310.09 from public 605/606 data. Your own order-level review is still required. This analysis does not constitute legal or compliance advice.
Sample Broker-Dealer 5310 Reviews
| Firm Name | CRD | Rule 606 Filing | Action |
|---|---|---|---|
| ROBINHOOD FINANCIAL, LLC | 165998 | Direct 606 filer | View Review → |
| CHARLES SCHWAB & CO., INC. | 5393 | Direct 606 filer | View Review → |
| A.G.P. / ALLIANCE GLOBAL PARTNERS | 8361 | Adopts clearing firm report | View Review → |
| CITIGROUP GLOBAL MARKETS INC. | 7059 | Direct 606 filer | View Review → |
| WELLS FARGO CLEARING SERVICES, LLC | 19616 | Direct 606 filer | View Review → |
Top Retail Wholesalers by PFOF Received (SEC Rule 606 • 2026Q3)
Aggregated net PFOF payments and average rates across filed broker-dealer routing reports.
| Execution Venue | MIC | Total Net PFOF ($) | Market Order PFOF ($) | Limit Order PFOF ($) | Scorecard |
|---|---|---|---|---|---|
| GTS SECURITIES LLC | — | $276.70 | $167.81 | $108.89 | Unmapped MM |
| Virtu Americas, LLC | — | $249.90 | $181.59 | $68.31 | NITE Scorecard → |
| CITADEL SECURITIES LLC | — | $168.26 | $126.95 | $41.31 | CDRG Scorecard → |
| Hudson River Trading (HRT) | — | $151.28 | $125.08 | $26.20 | HRTF Scorecard → |
| Jane Street Capital | — | $102.09 | $72.42 | $29.67 | JNST Scorecard → |
Top Net Price Improvement by Order Tier (Amended 605 • Month 202608)
Leading market centers by net price improvement (bps of executed notional) under methodology exq-2.
| Market Universe | Order Class | Notional × Lot Tier | Top Market Center | Net Price Improvement (bps) | Fill Rate | Action |
|---|---|---|---|---|---|---|
| sp500_proxy | market | $250–$999 • ODD | Cboe EDGX Exchange (EDGK) | +67.0 bps | 94.7% | Scorecard → |
| sp500_proxy | market | $1k–$5k • ODD | Cboe EDGX Exchange (EDGK) | +43.3 bps | 93.4% | Scorecard → |
| sp500_proxy | market | <$250 • ODD | XNYS (XNYS) | +8.9 bps | 89.4% | Scorecard → |
| sp500_proxy | market | $1k–$5k • FRACT | FIDELITY BROKERAGE SERVICES LLC (FIBS) | +7.3 bps | 56.3% | Scorecard → |
| sp500_proxy | marketable_limit | $5k–$10k • ODD | XTX Execution Services LLC (XTXE) | +6.9 bps | 61.2% | Scorecard → |
| sp500_proxy | marketable_limit | $1k–$5k • ODD | XTX Execution Services LLC (XTXE) | +6.9 bps | 68.6% | Scorecard → |
| sp500_proxy | marketable_limit | $1k–$5k • FRACT | NATIONAL FINANCIAL SERVICES LLC (NFSF) | +6.0 bps | 59.1% | Scorecard → |
| sp500_proxy | market | ≥$200k • ROUND | TLQNT (TLQNT) | +5.7 bps | 100.0% | Scorecard → |