SEC Rule 606 (Formerly known as Rule 11Ac1-6 under the Securities Exchange Act of 1934) requires all broker-dealers that route customer orders in equity and option securities to make publicly available quarterly reports that disclose the venues to which it routes "non-directed" orders in covered securities. Approximately 80% of Lek Securities' orders are routed to an exchange or ECN as selected by the customer.  However, when an order is routed to Lek Securities' order desk or worked using an algorithm, the decision where to send the customer's order is made by the firm.

It is Lek Securities' policy to select the exchange, ECN or market maker, which is expected, because of the displayed quote, or otherwise, to provide the customer with the best possible execution.  Based on this policy, in the Fourth Quarter of 2018 Lek Securities routed customer orders as specified in the below table:


AMEX and Regional Exchanges
(Percentage non-directed orders 7.395%)

LimitOrder
(Percentage of non-directed orders 95.233%)

Market Center
Percentage
Nyse Arca 58.708%
Nasdaq 26.727%
Coda Markets 5.607%
OTC LINK ECN 3.708%
Bats Trading 2.010%
Alternative Execution Group 1.189%
Maxim Group 1.034%
IEX Market 0.404%
American Stock Exchange 0.277%
ClearPool Dark 0.163%

Market Orders
(Percentage of non-directed orders 4.632%)

Market Center
Percentage
Coda Markets 40.901%
Nasdaq 31.557%
Nyse Arca 12.858%
Celadon Financial Group 7.680%
Bats Trading 2.514%
Alternative Execution Group 2.164%
Maxim Group 1.701%
ClearPool Dark 0.588%
ACTBOOK 0.013%
American Stock Exchange 0.013%

Other Orders
(Percentage of non-directed orders 0.135%)

Market Center
Percentage
Direct Edge (Edgx) 86.266%
Direct Edge (Edga) 11.159%
American Stock Exchange 0.858%
Bats Trading 0.858%
OTC LINK ECN 0.429%
Alternative Execution Group 0.429%

NASDAQ Listed Securities
(Percentage non-directed orders 17.351%)

LimitOrder
(Percentage of non-directed orders 88.755%)

Market Center
Percentage
Nasdaq 69.891%
Nyse Arca 27.351%
Coda Markets 2.325%
IEX Market 0.206%
Credit Suisse AES Algorithms Alias 0.112%
Bats Trading 0.081%
BATS-Y 0.019%
ClearPool Dark 0.006%
Direct Edge (Edgx) 0.003%
Direct Edge (Edga) 0.003%

Market Orders
(Percentage of non-directed orders 11.067%)

Market Center
Percentage
Nasdaq 50.137%
Coda Markets 49.603%
Nyse Arca 0.214%
Bats Trading 0.024%
Maxim Group 0.014%
Alternative Execution Group 0.004%
ClearPool Dark 0.003%
IEX Market 0.001%
New York Stock Exchange 0.001%

Other Orders
(Percentage of non-directed orders 0.177%)

Market Center
Percentage
Direct Edge (Edgx) 99.546%
Direct Edge (Edga) 0.454%

NYSE Listed Securities
(Percentage non-directed orders 15.906%)

LimitOrder
(Percentage of non-directed orders 91.985%)

Market Center
Percentage
Nasdaq 65.515%
Nyse Arca 31.077%
Coda Markets 1.844%
IEX Market 0.760%
Bats Trading 0.316%
New York Stock Exchange 0.252%
Credit Suisse AES Algorithms Alias 0.181%
ClearPool Dark 0.026%
BATS-Y 0.015%
Direct Edge (Edgx) 0.011%

Market Orders
(Percentage of non-directed orders 7.847%)

Market Center
Percentage
Coda Markets 52.542%
Nasdaq 46.153%
New York Stock Exchange 1.059%
Nyse Arca 0.149%
Bats Trading 0.057%
Maxim Group 0.024%
ClearPool Dark 0.007%
IEX Market 0.003%
Alternative Execution Group 0.003%
Direct Edge (Edgx) 0.001%

Other Orders
(Percentage of non-directed orders 0.169%)

Market Center
Percentage
Direct Edge (Edgx) 99.558%
Direct Edge (Edga) 0.316%
Nasdaq 0.063%
Convergex 0.063%

Option Contracts
(Percentage non-directed orders 11.250%)

LimitOrder
(Percentage of non-directed orders 93.510%)

Market Center
Percentage
Volant Smart Route 99.137%
Chicago Board Options Exchange 0.190%
Convergex 0.174%
Bats Trading 0.135%
Nyse Amex Options 0.101%
International Securities Exchange, LLC 0.097%
Maxim Group 0.043%
American Stock Exchange 0.031%
Nasdaq Options Market 0.031%
Arca Options Exchange 0.027%

Market Orders
(Percentage of non-directed orders 5.020%)

Market Center
Percentage
Volant Smart Route 99.207%
Arca Options Exchange 0.649%
Maxim Group 0.072%
Convergex 0.072%

Other Orders
(Percentage of non-directed orders 1.469%)

Market Center
Percentage
Volant Smart Route 53.941%
Convergex 34.975%
Maxim Group 9.852%
Chicago Board Options Exchange 0.739%
Arca Options Exchange 0.493%

Material Aspects of Relationship with Route Venues

Lek Securities has arrangements with certain market makers that allows customers to avoid paying an exchange fee when removing liquidity. These routes are advertised to the customer as “free” routes. When a customer selects a route that is advertised as free, Lek Securities may receive a payment if the order was routed to one the following counter parties: ConvergEx, PDQ/Coda Markets, Credit Suisse AES Algorithms, Volant Trading, Speedroute and Maxim Group. The amount of the payment will vary depending on the agreement with the respective venue. Specifics will be furnished upon request.