SEC Rule 606 – Order routing

(formerly SEC Rule 11Ac1-6)

Disclosure of order routing practices

Pershing LLC order routing information

• You will be directed to enter our Firm Name; please do so as follows:
  Winslow Evans & Crocker Inc (no commas, no periods)

SSC MarketLink order routing information

Although the firm does not receive direct payments for order flow, Winslow does receive a reduction in execution expenses for certain order routing. In addition, the firm may receive liquidity credits for some of its equity trading activity. The credits are considered payment for order flow even though it may not necessarily offset Winslow’s aggregate payments for removing liquidity. In this regard, in any given month, the “credits” received by Winslow from a given market center may exceed the “debits” charged to Winslow for such period. Therefore, such excess credits paid to Winslow may constitute, according to regulatory interpretation, payment for order flow. The Firm also incurs additional execution expense for other order routing decisions. The Firm’s only consideration in determining the execution venue for any individual order is to obtain the best execution for the customer, based on all the information available to the firm, at the time the order is received. Certain Regional Exchanges may execute more than 5% of our order flow. This is the result of further routing by an executing firm, not a result of direct routing by Winslow.