SEC RULE 606

SEC Disclosure

SEC-Required Report on Routing of Customer Orders
For the Quarter Ended June 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 26%
2. Virtu Americas LLC (DTTX) (NITE) 25%
3. Instinet 24%
4. ARCA 21%
5. Morgan Stanley & Co LLC 2%
6. 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 26%
    Material Aspects of Relationship with Venue:  * Please see below

2. 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 25%
    Material Aspects of Relationship with Venue:  * Please see below

3. 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 24%
    Material Aspects of Relationship with Venue:  * Please see below

4. 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 21%
    Material Aspects of Relationship with Venue:  * Please see below  

5. 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 0% 
    Other orders as percentage of total other orders 2%
    Material Aspects of Relationship with Venue:  * Please see below  

6. 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. Instinet 49%
2. ARCA 23%
3. Virtu Americas LLC (DTTX)  15%
4. Pershing LLC 11%
5. B. Riley FBR, Inc 1%
6. Morgan Stanely & Co LLC 1%

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 49%
    Material Aspects of Relationship with Venue:  * Please see below

2. 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 23%
    Material Aspects of Relationship with Venue:  * Please see below

3. 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  15% 
    Material Aspects of Relationship with Venue:  * Please see below   

4. 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  11% 
    Material Aspects of Relationship with Venue:  * Please see below   

5. B. Riley FBR, 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  1% 
    Material Aspects of Relationship with Venue:  * Please see below   

6. 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  0% 
    Other orders as percentage of total other orders  1% 
    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 58%
2. Virtu Americas LLC (DTTX)  18
3. Pershing LLC  12%
4. ARCA 10%
5. Morgan Stanley & Co LLC  2%
     
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 58%
    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. 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 18%
    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 12%
    Material Aspects of Relationship with Venue:  * Please see below

4. 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 10%
    Material Aspects of Relationship with Venue:  * Please see below

5. 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 0%
    Other orders as percentage of total other orders 2%
    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 0%
Limit orders as percentage of total non-directed orders 100%
Other orders as percentage of total non-directed orders

Venues Receiving Significant Percentage of Total Non-Directed Orders:
1. BATS Exchange 76%
2. NASDAQ 14%
3. Philadelphia Stock Exchange 10%
 

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 76%
    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  10% 
    Other orders as percentage of total other orders  0% 
    Material Aspects of Relationship with Venue:  See below 
     
 

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