Dear Colleague,

As of July 29, 2020, asset managers could begin requesting reports on the handling of not-held orders given to broker dealers. Under Rule 606(b)(3), reports for not-held orders must be provided within 7 days and the required information includes:

  • Order Routing, including size and further routable instructions
  • Order Execution, including volumes, fees, rebates, spread position
  • Liquidity, including whether liquidity was provided or removed, fees and rebates associated with time or execution
  • Actionable Indications of Interest (IOIs), including venues that received the IOI

How asset managers will incorporate Rule 606(b)(3) Reports into their best-execution policies and procedures is a topic of conversation between and among various market participants. Please join us as we discuss Rule 606(b)(3) and address some of the common questions asset managers and their brokers are asking.

Jeff Estella


Justin Schack
Managing Director & Partner

  Thursday, September 3, 2020
4:30 p.m. - 5:00 p.m. ET
Dial In 1.888.788.0099
Meeting ID# 398 151 1983

Zoom Link will be sent on Sept. 3rd

Plus STA Updates on
Form 13F & October Market Structure Virtual Conference
About Jeff Estella
In 2019, Jeff Estella established Estella LLC to provide both independent consulting
and advisory to the financial services community, leveraging his personal
experience and industry expertise. Previously, Jeff spent 20 years at MFS Investment
Management and held the roles of Director of Trading Analytics & Investment
Operations, Director of Global Equity Trading, and Senior Equity Trader.
About Justin Schack
Justin Schack heads Rosenblatt’s Market Structure Analysis group, which provides
asset managers, exchange groups, proprietary trading firms, regulators and
other clients with in-depth intelligence on global market structure and the
exchange industry. Prior to joining Rosenblatt in February 2008, Justin spent
14 years as a financial and public-affairs journalist.
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