Order Routing Decision
To: All New and Current Clients
From: Jay Battista, Head of Trading
Re: Payment for Order Flow
In compliance with SEC rule 11Ac1-3 and 11Ac1-6, BlueFin Research Partners, Inc. is required to disclose the following information regarding Payment for Order Flow, Order Routing Decisions, and Execution Practices.
The Firm receives no remuneration for directing orders in Over-the-Counter (OTC) securities to particular OTC market makers for execution. All OTC orders taken by the firm and executed through OTC market makers are held to “best price” practices and are exposed to price improvement opportunities.
BlueFin Research Partners, Inc., is required to make publicly available electronic reports that include uniform statistical measures of execution quality, payment for order flow data and the venues to which customer orders are routed to all market centers. Market Centers are defined as “any exchange market maker, alternative trading system, national securities exchange, or national securities association.” This information is available from our Website, www.bluefinresearch.com, or in writing upon request. These execution reports will become available 30 days after quarter end. Upon customer request, we will also disclose where an individual order was routed.
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