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 92% 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 First Quarter of 2018 Lek Securities routed customer orders as specified in the below table:


AMEX and Regional Exchanges
(Percentage non-directed orders 23.317%)

Limit Orders
(Percentage of non-directed orders 94.192%)

Market Center
Percentage
Nasdaq 67.352%
Nyse Arca 23.602%
Coda Markets 6.265%
Bats Trading 2.045%
American Stock Exchange 0.218%
IEX Market 0.214%
American Stock Exchange 0.127%
Direct Edge Ecn (Edgx) 0.129%
Credit Suisse AES Algorithms Alias 0.083%
Direct Edge Ecn (Byx) 0.062%

Market Orders
(Percentage of non-directed orders 4.640%)

Market Center
Percentage
Coda Markets 50.125%
Nasdaq 31.586%
Nyse Arca 14.488%
Alternative Execution Group 1.681%
Bats Trading 1.141%
Biltmore International 0.326%
American Stock Exchange 0.289%
Celadon Financial Group 0.276%
Credit Suisse AES Algorithms Alias 0.038%
Direct Edge Ecn (Edgx) 0.013%

Other Orders
(Percentage of non-directed orders 1.168%)

Market Center
Percentage
Alternative Execution Group 77.977%
Celadon Financial Group 8.719%
Nyse Arca 4.933%
Direct Edge Ecn (Edgx) 4.684%
Direct Edge Ecn (Edga) 1.844%
Biltmore International 1.844%

NASDAQ Listed Securities

(Percentage non-directed orders 8.298%)

Limit Orders
(Percentage of non-directed orders 69.158%)

Market Center
Percentage
Nasdaq 67.525%
Nyse Arca 24.914%
Coda Markets 7.299%
Bats Trading 0.063%
Direct Edge Ecn (Edga) 0.045%
Credit Suisse AES Algorithms Alias 0.043%
IEX Market 0.040%
Direct Edge Ecn (Byx) 0.035%
Direct Edge Ecn (Edgx) 0.027%
ClearPool Dark 0.004%

Market Orders
(Percentage of non-directed orders 30.471%)

Market Center
Percentage
Nasdaq 52.604%
Coda Markets 47.220%
Nyse Arca 0.166%
Credit Suisse AES Algorithms Alias 0.003%
Alternative Execution Group 0.003%
Biltmore International 0.002%
Direct Edge Ecn (Edgx) 0.001%

Other Orders
(Percentage of non-directed orders 0.371%)

Market Center
Percentage
Direct Edge Ecn (Edgx) 82.153%
Nyse Arca 14.443%
Alternative Execution Group 3.306%
Direct Edge Ecn (Edga) 0.368%

NYSE Listed Securities

(Percentage non-directed orders 4.862%)

Limit Orders
(Percentage of non-directed orders 62.857%)

Market Center
Percentage
Nasdaq 64.842%
Nyse Arca 23.195%
Coda Markets 8.466%
New York Stock Exchange, Inc. 1.446%
Bats Trading 0.726%
Direct Edge Ecn (Edga) 0.491%
IEX Market 0.287%
Direct Edge Ecn (Byx) 0.169%
Credit Suisse AES Algorithms Alias 0.139%
Credit Suisse AES Algorithms 0.129%

Market Orders
(Percentage of non-directed orders 36.745%)

Market Center
Percentage
Nasdaq 54.651%
Coda Markets 43.046%
New York Stock Exchange 2.204%
Nyse Arca 0.085%
Alternative Execution Group 0.005%
Credit Suisse AES Algorithms Alias 0.002%
Direct Edge Ecn (Byx) 0.002%
Bats Trading 0.002%
Celadon Financial Group 0.001%
Direct Edge Ecn (Edga) 0.001%

Other Orders
(Percentage of non-directed orders 0.398%)

Market Center
Percentage
Direct Edge Ecn (Edgx) 74.633%
Convergex 12.341%
Nyse Arca 12.145%
Alternative Execution Group 0.490%
Direct Edge Ecn (Edga) 0.196%
Chicago Board Options Exchange 0.098%
Celadon Financial Group 0.098%

Option Contracts

(Percentage non-directed orders 5.573%)

Limit Orders
(Percentage of non-directed orders 96.797%)

Market Center
Percentage
Volant Smart Route 88.601%
Chicago Board Of Trade 6.252%
International Securities Exchange, LLC 2.174%
Chicago Board Options Exchange 1.076%
Convergex 0.979%
Bats Trading 0.784%
Nyse Amex Options 0.097%
Philadelphia Options Exchange 0.037%

Market Orders
(Percentage of non-directed orders 1.056%)

Market Center
Percentage
Volant Scrape Route 100%

Other Orders
(Percentage of non-directed orders 2.148%)

Market Center
Percentage
Convergex 89.226%
Volant Smart Route 4.040%
Chicago Board Options Exchange 3.367%
International Securities Exchange, LLC 2.020%
Maxim Group 1.347%

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 and Maxim Group. The amount of the payment will vary depending on the agreement with the respective venue. Specifics will be furnished upon request.