SEC RULE 606

SEC Disclosure

SEC-Required Report on Routing of Customer Orders
For the Quarter Ended September 2018

First Manhattan Co. (FMC) has prepared this report pursuant to the U.S. Securities and Exchange Commission rule requiring all brokerage firms to make publicly available quarterly reports on their order routing practices. The report provides information on the routing of "non-directed orders"- any order that the customer has not specifically instructed to be routed to a particular venue for execution. For these non-directed orders, FMC has selected the execution venue on behalf of its customers.

The report is divided into four sections: one for securities listed on the New York Stock Exchange, one for securities listed on the American Stock Exchange and all other National Exchanges, one for securities listed on The Nasdaq Stock Market, and one for exchange-listed options. For each section, this report identifies the venues most often selected by FMC, sets forth the percentage of various types of orders routed to the venues, and discusses the material aspects of FMC's relationship with the venues.

Securities Listed on New York Stock Exchange  

Summary Statistics:
Non-directed orders as percentage of total customer orders 100%
Market orders as percentage of total non-directed orders
Limit orders as percentage of total non-directed orders
Other orders as percentage of total non-directed orders (market - non held) 100%
 
Venues Receiving Significant Percentage of Total Non-Directed Orders:
1. Pershing LLC 40%
2. Instinet          27%
3. ARCA              27%
4. Virtu Americas LLC (DTTX) (NITE)  4%
5. Canaccord Genuity Inc                   2%

Information Concerning Significant Venues:
1. Pershing LLC
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 0%
    Other orders as percentage of total other orders 40%
    Material Aspects of Relationship with Venue:  * Please see below

2. Instinet
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 0%
    Other orders as percentage of total other orders 27%
    Material Aspects of Relationship with Venue:  * Please see below

3. ARCA
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 0%
    Other orders as percentage of total other orders 27%
    Material Aspects of Relationship with Venue:  * Please see below

4. Virtu Americas LLC (DTTX) (NITE)
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 0%
    Other orders as percentage of total other orders 4%
    Material Aspects of Relationship with Venue: * Please see below  

5. Canaccord Genuity Inc
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 0%
    Other orders as percentage of total other orders 2%
    Material Aspects of Relationship with Venue: * Please see below

Securities Listed on American Stock Exchange AND ALL OTHER NATIONAL EXCHANGES

Summary Statistics:
Non-directed orders as percentage of total customer orders 100%
Market orders as percentage of total non-directed orders 0%
Limit orders as percentage of total non-directed orders 0%
Other orders as percentage of total non-directed orders 100%

Venues Receiving Significant Percentage of Total Non-Directed Orders:
1. ARCA    45%
2. Instinet 34%
3. Pershing LLC  19%
4. Virtu Americas LLC (DTTX)  2%

Information Concerning Significant Venues:
1. ARCA
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 0%
    Other orders as percentage of total other orders 45%
   Material Aspects of Relationship with Venue:  * Please see below

2. Instinet
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 0%
    Other orders as percentage of total other orders 34%
    Material Aspects of Relationship with Venue:  * Please see below

3. Pershing LLC  
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders  0%
    Limit orders as percentage of total limit orders  0%
    Other orders as percentage of total other orders  19%
    Material Aspects of Relationship with Venue:  * Please see below   

4. Virtu Americas LLC (DTTX)
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders  0%
    Limit orders as percentage of total limit orders  0%
    Other orders as percentage of total other orders  2%
    Material Aspects of Relationship with Venue:  * Please see below  

   

Securities Listed on the Nasdaq Stock Market

Summary Statistics:
Non-directed orders as percentage of total customer orders 100%
Market orders as percentage of total non-directed orders 0%
Limit orders as percentage of total non-directed orders 0%
Other orders as percentage of total non-directed orders 100%

Venues Receiving Significant Percentage of Total Non-Directed Orders:
1. Instinet 63%
2. Pershing LLC  25%
3. ARCA 8%
4. Virtu Americas LLC (DTTX) 4%
     
Information Concerning Significant Venues:
1. Instinet
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 0%
    Other orders as percentage of total other orders 63%
    Material Aspects of Relationship with Venue: * Please see below
We pay Nasdaq Execution Services, LLC a sliding scale fee based on the volume of shares traded each month. The venue chosen for all Nasdaq trades is based on our assessment of the availability of best execution.

2. Pershing LLC
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 0%
    Other orders as percentage of total other orders 25%
    Material Aspects of Relationship with Venue:  * Please see below

3. ARCA
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 0%
    Other orders as percentage of total other orders 8%
    Material Aspects of Relationship with Venue: * Please see below

4. Virtu Americas LLC (DTTX)
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 0%
    Other orders as percentage of total other orders 4%
    Material Aspects of Relationship with Venue:  * Please see below

* FMC, in its effort to seek best execution, routes client orders to national securities exchanges, alternative trading systems and other venues and market centers (collectively "market centers"). Certain markets centers, such as many exchanges, provide rebates or charge fees based upon whether routed orders contribute liquidity to, or extract liquidity from, the market center (the "Payments"). The amounts of such fees and rebates vary, and rebates may or may not exceed the fees paid by FMC to a market center during any given time period.

The amount of the Payments are calculated solely by the market centers in accordance with their respective standard rate schedules. FMC has not negotiated with the market centers with respect to the rates utilized to calculate the Payments, nor has it taken into account the rebates that it would receive from or the fees that it would be charged by a market center in making order routing determinations for its clients' accounts.

Exchange-Listed Options 

Summary Statistics:   
Non-directed orders as percentage of total customer orders 100%
Market orders as percentage of total non-directed orders 3%
Limit orders as percentage of total non-directed orders 97%
Other orders as percentage of total non-directed orders
 
Venues Receiving Significant Percentage of Total Non-Directed Orders:

1. BATS Exchange 28%
2. NASDAQ 14%
3. Philadelphia Stock Exchange 11%
4. Virtu Americas LLC 8%
5. Citadel Derivatives Group 8%
6. Two Sigma Securities 8%
7. UBS Securities 6%
8. NYSE ARCA 6%
9. CBOE Exchange 6%
10. G1 Execution Services, LLC 3%
11. Boston Option Exchange 2%

Information Concerning Significant Venues:
1. BATS Exchange
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 28%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue: See below
     
2. NASDAQ
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 14%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue: See below
     
3. Philadelphia Stock Exchange   
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 11%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

4. Virtu Americas LLC
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 8%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

5. Citadel Derivatives Group
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 8%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

6. Two Sigma Securities
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 8%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

7. UBS Securities
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 6%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

8. NYSE ARCA
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 6%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

9. CBOE Exchange
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders 100%
    Limit orders as percentage of total limit orders 6%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

10. G1 Execution Services, LLC
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 3%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

11. Boston Option Exchange
     Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 2%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

Venues Receiving Significant Percentage of Total Non-Directed Orders:

FMC routes all option orders through its clearing broker, Pershing LLC, who determines the appropriate venue to execute the order.