SEC RULE 606

SEC Disclosure

SEC-Required Report on Routing of Customer Orders
For the Quarter Ended December 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 56%
2. Instinet          30%
3. ARCA              11%
4. Canaccord Genuity Inc  2%
5. Virtu Americas LLC (DTTX) (NITE) 1%

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 56%
    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 30%
    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 11%
    Material Aspects of Relationship with Venue:  * Please see below

4. 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  

5. 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 1%
    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    40%
2. Pershing LLC 35%
3. ARCA  23%
4. Virtu Americas LLC (DTTX)  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 40%
   Material Aspects of Relationship with Venue:  * Please see below

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 35%
    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  23%
    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 47%
2. Pershing LLC  38%
3. ARCA 12%
4. Morgan Stanley & Co LLC  2%
5. Virtu Americas LLC (DTTX) 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 47%
    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 38%
    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 12%
    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 0%
    Other orders as percentage of total other orders 2%
    Material Aspects of Relationship with Venue: * Please see below

5. 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 1%
    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 2%
Limit orders as percentage of total non-directed orders 98%
Other orders as percentage of total non-directed orders
 
Venues Receiving Significant Percentage of Total Non-Directed Orders:

1. CBOE BZX Exchange 52%
2. NASDAQ 22%
3. NYSE ARCA 11%
4. Boston Option Exchange 9%
5. Philadelphia Stock Exchange 6%


Information Concerning Significant Venues:
1. CBOE BZX Exchange
    Types of Orders Routed to Venues:
    Market orders as percentage of total market orders 0%
    Limit orders as percentage of total limit orders 52%
    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 22%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue: See below
     
3. 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 11%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue:  See below

4. 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 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 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
 

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.