SEC RULE 606

SEC Disclosure

SEC-Required Report on Routing of Customer Orders
For the Quarter Ended June 2017

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. Archipelago Stock Exchange 76%
2. Nasdaq Execution Services LLC (NSDQ) 13%
3. Knight Capital Americas LLC (DTTX) 6%
4. Pershing LLC 5%

Information Concerning Significant Venues:
1. Archipelago 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 0%
    Other orders as percentage of total other orders 76%
    Material Aspects of Relationship with Venue:

2. Nasdaq Execution Services LLC (NSDQ)
    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 13%
    Material Aspects of Relationship with Venue:

3. Knight Capital 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 6%
    Material Aspects of Relationship with Venue:

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 5%
    Material Aspects of Relationship with Venue:  

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. Archipelago Stock Exchange (ARCX)  61%
2. Nasdaq Execution Services, LLC (NSDQ)  26%
3. Knight Capital Americas LLC (DTTX)  10%
4. Knight Capital Americas LLC (NITE)  2%
5. Pershing LLC 1%

Information Concerning Significant Venues:
1. Archipelago Stock Exchange (ARCX)
    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 61%
    Material Aspects of Relationship with Venue:

2. Nasdaq Execution Services, LLC (NSDQ) 
    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:

3. Knight Capital 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  10% 
    Material Aspects of Relationship with Venue:   

4. Knight Capital Americas LLC (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  2% 
    Material Aspects of Relationship with Venue:   

5. 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  1% 
    Material Aspects of Relationship with Venue: 
   

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. Nasdaq Execution Services, LLC  61%
2. Archipelago Stock Exchange (ARCX)  32%
3. Knight Capital Americas LLC (DTTX)  6%
4. Morgan Stanley & Co LLC  1%
     
Information Concerning Significant Venues:
1. Nasdaq 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 0%
    Other orders as percentage of total other orders 61%
    Material Aspects of Relationship with Venue:
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. Archipelago 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 0%
    Other orders as percentage of total other orders 32%
    Material Aspects of Relationship with Venue:

3. Knight Capital 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 0%
    Other orders as percentage of total other orders 6%
    Material Aspects of Relationship with Venue:

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 0%
    Other orders as percentage of total other orders 1%
    Material Aspects of Relationship with Venue:

Exchange-Listed Options   

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 100%
Other orders as percentage of total non-directed orders

Venues Receiving Significant Percentage of Total Non-Directed Orders:
1. BATS Exchange 31%
2. NASDAQ 19%
3. Knight Direct LLC 10%
4. Citadel Derivatives Group 9%
5. Philadelphia Stock Exchange 9%
6. UBS Securities 8%
7. G1 Execution Services, LLC 7% 
8. NYSE 4% 
9. Boston Options Exchange 2%
10. International Securities 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 31%
    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 19%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue: See below
     
3. Knight Direct LLC   
    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 
     
4. 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  9% 
    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  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:  See below 
     
6. 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  8% 
    Other orders as percentage of total other orders  0% 
    Material Aspects of Relationship with Venue:  See below 

7. 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  7% 
    Other orders as percentage of total other orders  0% 
    Material Aspects of Relationship with Venue:  See below 

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

9. Boston Options 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

10. International Securities Exchange   
    Types of Orders Routed to Venues:   
    Market orders as percentage of total market orders  0% 
    Limit orders as percentage of total limit orders  1% 
    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.