SEC RULE 606

SEC Disclosure

SEC-Required Report on Routing of Customer Orders
For the Quarter Ended March 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. Archipelago Stock Exchange 42%
2. Virtu Americas LLC (DTTX) (NITE) 18%
3. Nasdaq Execution Services LLC (NSDQ) 11%
4. ARCA 10%
5. Instinet 9%
6. Pershing LLC 9%
7. Canaccord Genuity Inc 1%

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 42%
    Material Aspects of Relationship with Venue:

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 18%
    Material Aspects of Relationship with Venue:

3. 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 11%
    Material Aspects of Relationship with Venue:

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:  

5. 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 9%
    Material Aspects of Relationship with Venue:  

6. 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 9%
    Material Aspects of Relationship with Venue:  

7. 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 1%
    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. Nasdaq Execution Services, LLC  32%
2. ARCA 32%
3. Virtu Americas LLC (DTTX)  15%
4. Instinet 11%
5. Archipelago Stock Exchange  9%
6. Canaccord Genuity Inc 1%

Information Concerning Significant Venues:
1. 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 32%
    Material Aspects of Relationship with Venue:

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 32%
    Material Aspects of Relationship with Venue:

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:   

4. 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  11% 
    Material Aspects of Relationship with Venue:   

5. 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  9% 
    Material Aspects of Relationship with Venue:   

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  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  34%
2. Instinet  27%
3. Virtu Americas LLC (DTTX)  25%
4. ARCA  6%
5. Pershing LLC  4%
6. Archipelago Stock Exchange (ARCX)  3%
7. 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 34%
    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. 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:

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 25%
    Material Aspects of Relationship with Venue:

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 6%
    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 4%
    Material Aspects of Relationship with Venue:

6. 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 3%
    Material Aspects of Relationship with Venue:

7. 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 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 42%
2. G1 Execution Services, LLC 25%
3. UBS Securities 9%
4. Philadelphia Stock Exchange 6%
5. NYSE 4%
6. MIAX Options Exchange 4%
7. Boston Options Exchange 4% 
8. NASDAQ 3% 
9. Virtu Americas LLC 2%
10. Citadel Derivatives Group 1%

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 42%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue: See below
     
2. 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 25%
    Other orders as percentage of total other orders 0%
    Material Aspects of Relationship with Venue: See below
     
3. 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  9% 
    Other orders as percentage of total other orders  0% 
    Material Aspects of Relationship with Venue:  See below 
     
4. 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  6% 
    Other orders as percentage of total other orders  0% 
    Material Aspects of Relationship with Venue:  See below

5. 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 
     
6. MIAX 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  4% 
    Other orders as percentage of total other orders  0% 
    Material Aspects of Relationship with Venue:  See below 

7. 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  4% 
    Other orders as percentage of total other orders  0% 
    Material Aspects of Relationship with Venue:  See below 

8. NASDAQ   
    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

9. 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  2% 
    Other orders as percentage of total other orders  0% 
    Material Aspects of Relationship with Venue:  See below

10. 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  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.