Disclosure of Order Routing Practices
Under SEC Rule 606 for the Disclosure of Order Routing Practices, broker-dealers that route customer orders in equity and option securities are required to make publicly available quarterly reports that, among other things, identify the market centers to which they route customer orders for execution. In addition, broker-dealers are required to disclose to customers, on request, the market centers to which their individual orders are routed. Only the most significant market centers – the top ten and any others that received 5% or more of the broker-dealer orders – must be disclosed. The rule requires one report divided into four sections. The sections are based on orders for NYSE listed securities, other exchange listed securities, over-the-counter securities, and options. The disclosure only requires the information to be stated as percentages. In addition, broker-dealers must disclose the nature of the broker-dealer’s relationship with those market centers reported, including the existence of any internalization or payment for order flow arrangements or profit-sharing relationship as it related to the type of securities for that section.
Camelot Investment Advisers, LTD (“Camelot”) primarily deals in securities listed on the NYSE. Camelot routes all security orders to the primary exchange on which each security trades. For securities traded on the NASDAQ Stock Market, Camelot relies on its clearing firm, National Financial Services, LLC, to route the orders for execution. More than 99% of the orders are limit orders. The few remaining orders are market orders.
The following are the statistics for the most recent calendar quarter:
| Securities Listed on the NYSE | |||
| Summary Statistics | |||
| Non-directed orders as a percentage of total customer orders | 100% | ||
| Limit orders as a percentage of non-directed orders | 100% | ||
| Market orders as a percentage of non-directed orders | 0% | ||
| Venues receiving a significant percentage of total non-directed orders | Total Orders | Market Orders | Limit Orders |
| NYSE | 98% | 0% | 100% |
| NYSE ARCA | 2% | 0% | 100% |
| Material aspect of relationship with venue | |||
| ARCA pays subscribers a rebate of up to .0021 per executed share for NYSE orders that add liquidity to the ARCA book. According to the SEC rule, this rebate may be considered payment for order flow. ARCA also charges subscribers up to .003 for trades that remove liquidity from the ARCA book; up to .003 for shares routed out; and odd-lot executions may be charged up to .001 per share. | |||
| Securities Listed on the NYSE AMEX | |||
| Summary Statistics | |||
| Non-directed orders as a percentage of total customer orders | 100% | ||
| Limit orders as a percentage of non-directed orders | 100% | ||
| Market orders as a percentage of non-directed orders | 0% | ||
| Venues receiving a significant percentage of total non-directed orders | Total Orders | Market Orders | Limit Orders |
| NYSE ARCA | |||
| Material aspect of relationship with venue | 1% | 0% | 100% |
| ARCA pays subscribers a rebate of up to .0022 per executed share for NYSE orders that add liquidity to the ARCA book. According to the SEC rule, this rebate may be considered payment for order flow. ARCA also charges subscribers up to .003 for trades that remove liquidity from the ARCA book; up to .0035 for shares routed out; and odd-lot executions may be charged up to .001 per share. |
Route Venues: See Section 2 of National Financial’s order routing practices.
Camelot's Summary of Business Continuity Plan