Trade Execution Quality Statement and SEC Rule 606 and 607


Disclosure of Payment for Order flow and Order Routing Information

The Securities and Exchange Commission (“SEC”) requires that all broker/dealers disclose their policies regarding the receipt of payment for order flow, the nature of their order routing policies for orders subject to payment for order flow and the degree to which these orders can receive price improvement.

Order Routing

Pursuant to SEC Rule 606, Fenix Securities is required to make publicly available a quarterly report with regard to its routing of non-directed orders. SEC Rule 606(b) requires a broker-dealer to disclose to its customers, upon request, “the identity of the venue to which the customer’s orders were routed for execution in the six months prior to the request, whether the orders were directed orders or non-directed orders, and the time of the transactions, if any, that resulted from such orders.”

In accordance with SEC Rule 606 under the Securities Exchange Act of 1934, Fenix Securities discloses on a quarterly basis its execution quality and order routing information on its Web site at

Fenix Securities may refuse to accept any of your instructions and may process your instructions in any manner it believes commercially reasonable. Fenix Securities has absolute discretion in routing trade orders as long as it makes a reasonable and good faith effort to obtain best execution. For orders executed electronically via the Internet, online order entry systems or by facsimile (collectively, “Electronic Orders”), Fenix Securities’s liability is limited to direct damages caused solely by its gross negligence or willful misconduct; provided, however, Fenix Securities is not responsible for loss or damages (including without limitation, loss of profits or use, and direct, indirect, incidental, punitive, special or consequential damages), arising from (a) any failure or malfunction of an Electronic Order entry system or inability to enter or cancel Electronic Orders, or (b) any fault in delivery, delay, interruption, inaccuracy or termination affecting all or part of any Electronic Order system or any supporting facility, regardless of whether a claim arises in contract, tort or otherwise. Unless otherwise specified, your instructions are not valid beyond the trading session entered. The name of the other party, time of execution and remuneration can be furnished on request.

Payment for Order Flow

Pursuant to SEC Rule 607, Fenix Securities is required to disclose its payment for order flow practices. Fenix Securities may, from time to time, receive payment for order flow. Order flow payment is compensation received as an incentive to direct (i) securities trades to exchanges that provide rebates to post certain orders and (ii) option trades to option market makers or option exchanges that provide rebates for certain option orders. Fenix Securities sends certain equity orders to executing broker-dealers, and may send them to exchanges or electronic communication networks, during normal business hours and during extended trading sessions. Some of those market centers provide payments to Fenix Securities, or charge access fees depending upon the characteristics of the order and any subsequent execution. This compensation is received in a number of ways, including direct cash payment. In certain instances, reduced transaction fees may be provide. Details of these payments and fees may be obtained by making a written request to Fenix Securities.