SEC RULE 606

SEC Disclosure

SEC-Required Report on Routing of Customer Orders
For the Quarter Ended June 2019

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
Market orders as percentage of total non-directed orders    34%
Limit orders as percentage of total non-directed orders       66%
Other orders as percentage of total non-directed orders (market - non held) 
 
Venues Receiving Significant Percentage of Total Non-Directed Orders:
1. Pershing LLC 77%
2. Instinet          7%
3. Citigroup Global Market  6%
4. Morgan Stanley & Co LLC  6%
5. RBC Capital Markets  2%
6. Jones Trading   2%

Information Concerning Significant Venues:
1. Pershing LLC
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 96%
    Limit orders as percentage of total limit orders 72%
    Other orders as percentage of total other orders   0%
    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 9%
    Other orders as percentage of total other orders  0%
    Material Aspects of Relationship with Venue:  * Please see below

3. Citigroup Global Market
    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:  * Please see below

4. Morgan Stanley & Co LLC
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 7%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue: * Please see below  

5. RBC Capital Markets
    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: * Please see below  

6. Jones Trading 
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 2%
    Limit orders as percentage of total limit orders 2%
    Other orders as percentage of total other orders 0%
    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 0%
Market orders as percentage of total non-directed orders 51%
Limit orders as percentage of total non-directed orders 49%
Other orders as percentage of total non-directed orders 0%

Venues Receiving Significant Percentage of Total Non-Directed Orders:
1. Pershing LLC    73%
2. Instinet    16%
3. Morgan Stanley & Co LLC  5%
4. RBC Capital Markets       4%
5. Citigroup Global Markets   2%

Information Concerning Significant Venues:
1. Pershing
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 99%
    Limit orders as percentage of total limit orders 45%
    Other orders as percentage of total other orders 0%
   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 32%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  * Please see below

3. Morgan Stanley & Co LLC  
    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:  * Please see below   

4. RBC Capital Markets
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders  0%
    Limit orders as percentage of total limit orders  9%
    Other orders as percentage of total other orders  0%
    Material Aspects of Relationship with Venue:  * Please see below  

5. Citigroup Global Markets
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders  1%
    Limit orders as percentage of total limit orders  3%
    Other orders as percentage of total other orders  0%
    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 0%
Market orders as percentage of total non-directed orders 20%
Limit orders as percentage of total non-directed orders 80%
Other orders as percentage of total non-directed orders 0%

Venues Receiving Significant Percentage of Total Non-Directed Orders:
1. Pershing LLC   77%
2. Instinet   7%
3. Citigroup Global Markets   6%
4. Morgan Stanley & Co LLC  6%
5. RBC Capital Markets     2%
6. Jones Trading  2%
     
Information Concerning Significant Venues:
1. Pershing LLC
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 96%
    Limit orders as percentage of total limit orders 72%
    Other orders as percentage of total other orders 0%
    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. Instinet
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 9%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  * Please see below

3. Citigroup Global Markets
    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: * Please see below

4. Morgan Stanley & Co LLC
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 7%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue: * Please see below

5. RBC Capital Markets 
    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:  * Please see below

6. Jones Trading
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 2%
    Limit orders as percentage of total limit orders 2%
    Other orders as percentage of total other orders 0%
    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.

The chart below sets forth the amount of the (1) rebates per share that FMC receives from the market centers for contributing to liquidity via routed orders and (2) charges paid by FMC to the market centers for extracting liquidity via routed orders.

NASDAQ

Add Liquidity: Priced Under $1: $0 per share
                           Standard Tape A or B Security:  $.002 per share
                           Standard Tape C Security: $.0015 per share

Remove Liquidity: Priced Under $1: $.003 per share
                                   Standard:  $.003 per share


NYSE/ARCA

Add Liquidity: Standard Tape A And C: $.002 per share
                                           Tape B: $.0 per share

Remove Liquidity: Standard Tape A and C: $.003 per share
                                                  Tape B: $.0 per share

Exchange-Listed Options 

Summary Statistics:   
Non-directed orders as percentage of total customer orders 100%
Market orders as percentage of total non-directed orders 11%
Limit orders as percentage of total non-directed orders 89%
Other orders as percentage of total non-directed orders
 
Venues Receiving Significant Percentage of Total Non-Directed Orders:

1. CBOE BZX Exchange 37%
2. CBOE Options Exchange  20%
3. NASDAQ 15%
4. NYSE ARCA 11%
5. Philadelphia Stock Exchange 10%
6. MIAX PEARL OPTION Exchange   7%

Information Concerning Significant Venues:
1. CBOE BZX Exchange
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 11%
    Limit orders as percentage of total limit orders 40%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue: See below
     
2. CBOE OPTIONS EXCHANGE
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 78%
    Limit orders as percentage of total limit orders 13%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue: See below
     
3. NASDAQ   
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 17%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

4. 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 12%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

5. Philadelphia Stock Exchange
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders 11%
    Limit orders as percentage of total limit orders 10%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

6. MIAX PEARL 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 8%
    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.