Rule 605 and 606 Reporting: Monthly Execution Data, Quarterly Routing

On 30 September 2025 the SEC moved the compliance date for its 2024 amendments to Rule 605 of Regulation NMS to 1 August 2026, the day market centers and larger broker-dealers had to start collecting data for rebuilt monthly execution quality reports. The reports covering August 2026 then had to be public by the end of September 2026. That reset one half of Rule 605 and 606 reporting. Rule 605 publishes monthly statistics on how covered orders in NMS stocks were executed. Rule 606 publishes, each quarter, where a broker-dealer routed its customers’ non-directed held orders in NMS stocks and their non-directed options orders, and what it received or paid at each venue.

Both rules work mainly through public posting. The monthly Rule 605 reports and the quarterly Rule 606(a) report stay on a free, readily accessible website for three years. FINRA Rule 6151 also requires FINRA members to provide their Rule 606(a) reports for central publication, subject to the permitted adoption-by-reference arrangements. Rule 606(b) reports go to individual customers on request.

Related reading: RTRS Reporting: Municipal Trades to the MSRB Within 15 Minutes

The legal basis: Rules 605 and 606 of Regulation NMS and the Rule 600 definitions

Both rules are SEC rules made under the Securities Exchange Act of 1934 and codified in Regulation NMS, 17 CFR 242.600 through 242.614. The Commission adopted them in November 2000 as Rules 11Ac1-5 and 11Ac1-6 (Release No. 34-43590) and redesignated them as Rules 605 and 606 when it adopted Regulation NMS in 2005 (Release No. 34-51808).

• 17 CFR 242.605, “Disclosure of order execution information”, requires market centers, brokers and dealers to make standardized monthly reports of statistical information about their order executions available to the public.
• 17 CFR 242.606, “Disclosure of order routing information”, requires brokers and dealers to publish a quarterly routing report and to answer customer requests for routing and order handling information.
• 17 CFR 242.600(b) supplies the definitions that decide what lands in each file: “covered order” (paragraph (b)(27)), “market center” (paragraph (b)(55)), “directed order” and “non-directed order” (paragraphs (b)(32) and (b)(66)), and the order-size and order-type categories in paragraphs (b)(18) and (b)(19).

The current text of Rule 605 comes from the amendments adopted on 6 March 2024 in Release No. 34-99679 and published at 89 FR 26428 on 15 April 2024. They took effect on 14 June 2024, with the compliance date deferred by Release No. 34-104147 as set out under deadlines. Rule 606 was last amended in 2018 by Release No. 34-84528 (83 FR 58338), and the CFR source note for the section records no later amendment.

The format layer is split between two instruments. Rule 605(a)(3) directs every national securities exchange on which NMS stocks trade and each national securities association to set joint procedures for making the reports available in uniform electronic form. Those procedures are the National Market System Plan Establishing Procedures Under Rule 605 (the Rule 605 NMS Plan), which fixes the file type and field order of the monthly detailed report. The summary report follows a different path: Rule 605(a)(2) itself requires the SEC’s CSV schema and PDF renderer, and the 2024 adopting release states that the Rule 605 NMS Plan will not establish the formats and fields for the summary reports. A team that reads only the Plan therefore has half of its Rule 605 specification.

Who must report under Rules 605 and 606: market centers, the 100,000-account test and every broker-dealer

Rule 605: market centers plus larger broker-dealers

Rule 605(a)(1) applies to every market center, broker or dealer, and Rule 605(a)(7) then narrows the broker-dealer side. A market center is any exchange market maker, OTC market maker, alternative trading system, national securities exchange or national securities association. A broker or dealer that is not a market center is in scope only if it introduces or carries 100,000 or more customer accounts through which transactions are effected for the purchase or sale of NMS stocks, the “customer account threshold”.

Three details in Rule 605(a)(7) shape the answer:

• A broker-dealer that uses an omnibus clearing arrangement is treated as carrying the underlying customer accounts when it counts.
• A broker-dealer that meets the threshold and is also a market center produces separate reports for each function; staff FAQ Question 5 has the integrated firm separate its OTC market-making activity from its broker-dealer activity.
• Once over the threshold, the broker-dealer reports for at least three calendar months (the “Reporting Period”). The Reporting Period starts on the first calendar day of the month after the threshold is met, except on the first occasion, when it starts on the first calendar day four calendar months later. After at least one Reporting Period, a broker-dealer that falls below the threshold need not report for the next calendar month.

Rule 605(a)(1) also splits some reports by venue. An OTC market maker that runs a trading system in which only that single dealer buys and sells against everyone else entering orders produces a separate report for orders entered in that system, the single-dealer platform report. An alternative trading system prepares its reports separately from its broker-dealer operator.

The customer account threshold is a broker-dealer test only; a market center that never reaches 100,000 accounts still reports in its market-center capacity. The April 2026 exemptive order recalls that a firm may act as an OTC market maker for fractional shares only, and states that, in general, a broker-dealer executing fractional share orders as principal would be acting as an OTC market maker for those orders and would report as a market center, subject to the narrow dividend-reinvestment exemption covered under caveats.

Rule 606: every broker or dealer, with thresholds only on the institutional report

Rule 606(a)(1) begins “Every broker or dealer” and contains no size threshold. The quarterly report covers the broker-dealer’s routing of non-directed orders in NMS stocks submitted on a held basis and of non-directed customer orders in NMS securities that are option contracts. Rule 606(b)(1) and (b)(2) also apply to every broker or dealer: customer-specific routing information on request, and a written notice at least annually that the information is available.

The thresholds sit on Rule 606(b)(3), the order handling report for not held orders:

• Rule 606(b)(4) provides a broker-dealer-level exemption where not held NMS-stock shares are less than five percent of all customer NMS-stock shares over the prior six calendar months, subject to its Compliance Period rules. Falling below the threshold does not end an existing Compliance Period. After that period ends, requested Rule 606(b)(3) reports remain required, subject to Rule 606(b)(5), for orders received during the portion of the Compliance Period still within the six-month reporting look-back. Staff FAQ 10.01 assesses that test at broker-dealer level across all branches, business units and divisions. Reaching five percent starts a “Compliance Period” of at least six calendar months, beginning on the first day of the next month or, on the first occasion, four calendar months later.
• Rule 606(b)(5) excludes, customer by customer, any customer that traded on average less than $1,000,000 of notional value of not held orders in NMS stocks through the broker-dealer each month for the prior six months.

Neither rule has a separate provision for branches or third-country firms. Both attach to the “broker or dealer” and to market centers as defined in Rule 600, and the SEC releases and staff FAQs reviewed for this guide do not address foreign broker-dealers.

What the report contains: detailed and summary 605 files, quarterly 606 tables and customer reports

Rule 605(a)(1): the monthly detailed report

The detailed report covers covered orders in NMS stocks that the reporting entity received for execution, or received in a prior month and that remained open. A covered order can be a market or limit order received during regular trading hours while a national best bid and offer (NBBO) is disseminated and after the primary listing market’s first firm, uncrossed quotations. It can also be a non-marketable limit order, including one submitted with a stop price, received outside regular trading hours, before those quotations or while no NBBO is disseminated. Under both limbs, if the order is executed, the execution must occur during regular trading hours. Unexecuted orders can still be covered orders, and a non-marketable limit order enters its reporting category once it becomes executable. Orders with special handling requests are excluded, including opening or closing price orders, orders to be executed only at their full size, orders submitted on a not held basis, orders for other than regular settlement and orders to be executed at prices unrelated to the market.

Each report is categorized three ways. By security, one category per NMS stock. By order type, ten categories under Rule 600(b)(19): market orders, marketable limit orders, marketable immediate-or-cancel orders, midpoint-or-better limit orders and their immediate-or-cancel version, executable non-marketable limit orders and their immediate-or-cancel version, and three stop-order categories (executable market orders submitted with stop prices, executable stop marketable limit orders and executable stop non-marketable limit orders). By order size, 24 categories under Rule 600(b)(18): eight notional bands from less than $250 to $200,000 or more, each split into less than a share, odd-lot and at least a round lot. Staff FAQ Question 1 puts the file at 55 fields and a maximum of 240 records for each individual security.

The columns fall into three groups:

• For every order type: order count, cumulative notional value, shares, shares cancelled before execution, shares executed at the receiving entity (excluding riskless principal executions), shares executed at any other venue, eight time-to-execution buckets from less than 100 microseconds to 5 minutes or more, average realized spread and percentage realized spread at 50 milliseconds, 1 second, 15 seconds, 1 minute and 5 minutes after execution, and the average midpoint.
• For market, marketable and midpoint-or-better orders and executable stop market and stop marketable limit orders: quoted and effective spread measures; shares, amounts and timing for executions with price improvement, at the quote and outside the quote; five columns measured against the best available displayed price; and two size-improvement columns built on the “order size benchmark”: the aggregate displayed size of protected offers at the national best offer for a buy order, or protected bids at the national best bid for a sell order, capped at the size of that order. The benchmark is measured at order receipt, except for midpoint-or-better limit orders, for which it is measured when the order becomes executable.
• For midpoint-or-better orders and executable non-marketable limit orders, including the stop version: the number of orders filled in whole or in part, shares executed regular way at prices that could have filled the order while it was in force (across all venues, and separately on exchanges, each capped at the order size), and the share-weighted average time from executability to execution.

Time is measured from order receipt or, for non-marketable limit orders, midpoint-or-better limit orders and stop orders, from the applicable time the order becomes executable, in increments of a millisecond or finer. The “best available displayed price” is the lower of the national best offer and the disseminated best odd-lot offer for a buy order, and the higher of the national best bid and the disseminated best odd-lot bid for a sell order. It is measured at order receipt, except for midpoint-or-better limit orders, for which it is measured when the order becomes executable. It brings odd-lot quotes into the benchmark and is the reason for the later phase-in described under deadlines.

Rule 605(a)(2): the monthly summary report

The summary report is narrower. It covers only market orders and marketable limit orders, in two sections: NMS stocks in the S&P 500 Index as of the first day of the month, and other NMS stocks. Each section is split by order type and the order-size categories specified in Rule 605(a)(2). The SEC’s Order Execution Summary technical specification provides nine order-size codes: seven individual notional bands below $200,000, one band for orders of $200,000 or more, and one aggregate category combining orders below $200,000. Each monthly summary report contains separate records for the applicable combinations of stock group, order type and order-size category. A combination with no reportable orders need not have a record. Twelve columns follow, covering average order size in shares and notional terms, the average midpoint, the percentages of shares executed at the quote or better and receiving price improvement, net percentage price improvement, percentage effective and quoted spreads and their ratio, percentage realized spreads at 15 seconds and 1 minute, and share-weighted average execution speed in milliseconds.

Rule 606(a)(1): the quarterly held-order and options routing report

The quarterly report is broken down by calendar month and has three sections: NMS stocks in the S&P 500 Index as of the first day of the quarter, other NMS stocks, and NMS securities that are option contracts. Each section contains:

• the percentage of total orders that were non-directed, and the split of non-directed orders between market, marketable limit, non-marketable limit and other orders;
• the ten venues that received the largest number of non-directed orders, plus any venue that received five percent or more, with the percentage of non-directed orders routed to each, overall and by order type;
• for each listed venue, the net aggregate amount of payment for order flow received, payment from any profit-sharing relationship received, transaction fees paid and transaction rebates received, as a total dollar amount and per share, for market, marketable limit, non-marketable limit and other orders;
• a discussion of the material aspects of the relationship with each listed venue, including payment for order flow and profit-sharing terms and terms that may influence routing, such as volume incentives, shortfall disincentives, tiered payment schedules and minimum order flow agreements.

For options, the scope runs through the “customer order” definition, which excludes an options order with a market value of at least $50,000. Staff FAQ 13.03 reads the per-share payment requirement for options as net cents per option contract for one hundred shares.

Rule 606(b): the customer reports

Rule 606(b)(1) is the light report. On request, the broker-dealer discloses the venues to which the customer’s orders were routed in the six months before the request, whether the orders were directed or non-directed, and the time of any resulting transactions. It covers held orders in NMS stocks, options orders, and not held NMS stock orders where no Rule 606(b)(3) report is owed.

Rule 606(b)(3) is the institutional report: for a customer that places not held orders in NMS stocks, a report on the handling of those orders for the prior six months by calendar month, including all child orders, in separate directed and non-directed sections. Each section shows totals (shares sent by the customer, shares executed as principal, orders exposed through an actionable indication of interest and the venues of that exposure) and, per venue, four column blocks: order routing (shares routed, shares routed marked immediate-or-cancel, shares further routable, average order size), order execution (shares executed, fill rate, average fill size, average net execution fee or rebate in cents per 100 shares to four decimal places, midpoint executions, and executions on the favorable and unfavorable side of the spread), orders that provided liquidity, and orders that removed liquidity.

Rule 605 and 606 reporting deadlines: monthly, quarterly and on request

The recurring deadlines sit in the rule text:

The amended Rule 605 added four fixed dates:

• 1 August 2026: compliance date. The extension release says that from that day reporting entities “must begin to collect the information needed to prepare” the amended reports; publication of the first month came later.
• End of September 2026: the August 2026 detailed and summary reports are due.
• 1 November 2026: statistics measured against the best available displayed price become required (staff FAQ Question 39).
• End of December 2026: the November 2026 reports, the first to carry those statistics, are due.

For Rule 606, “within one month after the end of the quarter” gives a fixed calendar. The quarter ending 31 March is due by 30 April, the June quarter by 31 July, the September quarter by 31 October and the December quarter by 31 January. FINRA Regulatory Notice 24-05 applied that reading to the first Rule 6151 cycle, setting 31 July 2024 for the second quarter of 2024. The SEC’s 2025 extension release reads Rule 605(a)(6) the same way for the first monthly reports under the amended rule.

The best-available-displayed-price columns run on their own clock: six months after the odd-lot information needed to calculate them becomes available under an effective NMS plan. As the extension release records, the SEC’s September 2024 tick size and access fee release (Release No. 34-101070) set the first business day of May 2026 for the exclusive securities information processors to disseminate that information, and the extension left the six-month gap untouched, which produced November 2026. Staff FAQ Question 39 adds that firms may not fill the columns earlier with the NBBO as a stand-in; voluntary early reporting has to use the odd-lot data.

The rule text does not address a deadline that falls on a weekend or holiday, and this guide does not assume a roll-forward.

Submission and format: Plan files, the OES CSV, the order handling XML and FINRA Rule 6151

The rule text routes every Rule 605 report and every Rule 606(a) report to a public website, and FINRA Rule 6151 separately applies to FINRA members, including its permitted adoption-by-reference arrangements. Neither rule has an SEC filing step, which sets them apart from the EDGAR submissions covered in our EDGAR Filer Manual guide.

Rule 605 detailed report: pipe-delimited files and a Designated Participant

Staff FAQ Question 1 summarizes the Plan’s requirements: the monthly detailed report is an electronic data file in standard, pipe-delimited ASCII format, made available for downloading without charge from an internet site (the Download Site). Each reporting entity arranges with a Plan participant, its Designated Participant, which assigns it a reporter identification code and maintains a “Link Site” listing hyperlinks to each entity’s Download Site.

FINRA is one of the Designated Participants. Its Information Notice of 17 June 2026 replaced the old PDF authorization form with an electronic Designated Participant Authorization Form on the FINRA Gateway, required for every member that selects FINRA, including firms that had filed the PDF version before. The notice ties the timing to the amended rule and the amended Plan taking effect on the compliance date, and sets these conventions:

• The reporter identification code (RIC) is exactly four alphabetic characters, with no numerals or special characters.
• Each reporting function needs its own form and its own RIC, so an integrated firm reporting as an OTC market maker and as a broker-dealer holds two.
• The RIC is independent of the firm’s MPID, and a market center that already produced Rule 605 reports may reuse its four-character Market Center ID.
• The form captures the URL of the firm’s Rule 605 reports and its reporter type, with “Single Dealer Trading System” and “Broker-Dealer” among the options.

Rule 605 summary report: the Order Execution Summary CSV

The SEC publishes the Order Execution Summary (OES) Data Report technical specification, CSV schema, PDF renderer and sample report on its Technical Specifications and Schemas page. Implementations must use the applicable current versions rather than relying on an earlier specification or draft. The specification provides the following requirements:

• The file is standard comma-delimited ASCII, optionally compressed with Zip or Gzip.
• The uncompressed file is named with the reporter identification code assigned under the Plan followed by a six-digit year-and-month code and “.csv”; compressed files take “.zip” or “.gz”.
• The first record holds the field names and is required even when no data rows follow; each record ends with a carriage return line feed.
• Exhibit A fixes 18 columns: the Designated Participant code (FINRA is “T”), the reporting entity code, the report month as YYYYMM, an S&P 500 flag (Y or N), an order size code (0, 250, 1000, 5000, 10000, 20000, 50000, 199999 for all sizes under $200,000, and 200000 for $200,000 or more), an order type code (M or ML) and the twelve statistics.
• Decimal fields carry up to six decimal places, rounded half up at the sixth.
• Reports for each month sit at a single page on an internet site that is free of charge and readily accessible to the public.

Rule 605(a)(2) ties the summary report to the SEC’s CSV schema and associated PDF renderer, and the adopting release explains that the renderer provides the same data in a human-readable PDF. The OES specification does not describe a correction or resubmission procedure for a posted file.

Rule 606: the order routing and handling XML and its renderer

Rule 606(a)(1), (b)(1) and (b)(3) each require the most recent versions of the SEC’s XML schema and associated PDF renderer. The SEC’s Order Routing and Handling Data Technical Specification, dated 21 May 2024, defines that schema as the most recent XML 1.0 schema posted on the SEC website, and the schema package on the Technical Specifications and Schemas page carries the file name oh-20240520.zip. The specification defines three XML reports: the Held Order Routing Public Report under Rule 606(a), whose root element is “heldOrderRoutingPublicReport”, the Held/Exempt Not-Held Order Routing Customer Report under Rule 606(b)(1), and the Not-Held Order Handling Customer Report under Rule 606(b)(3).

The broker-dealer publishes each quarterly report at a permanent, readily accessible URL linking to the current quarter’s schema-valid XML file, the PDF the SEC’s Report Renderer produces from it and any optional formats, plus the same links for three years of earlier reports, up to 11 additional sets. The Report Renderer, a JavaScript program that can run privately in a browser, validates a file and converts it to PDF. Units follow suffixes in element names:

• “Pct”: a percentage between 0 and 100 to two decimal places, left as an empty string where the denominator would be zero.
• “Cph”: cents per hundred shares, positive or negative, to four decimal places.
• “Usd”: US dollars, positive or negative.
• “Msec”: milliseconds rounded to the nearest whole number.
• The “netPmtPaidRecv” elements: amounts received by the broker-dealer as positive, less amounts paid.

Rule 606(a)(1)(iii) asks for payment amounts “per share”, while the schema element carries them in cents per hundred shares, a conversion that has to happen before the XML is written. For the Rule 606(b)(3) fee and rebate column, staff FAQ 5.02 sets the sign convention: a net fee is negative and a net rebate positive.

FINRA Rule 6151: the central copy of Rule 606(a) reports

FINRA Rule 6151, effective from 30 June 2024, requires members to submit their Rule 606(a) reports to FINRA for centralised publication within the applicable quarterly reporting deadline. FINRA’s Rule 6151 Order Routing Information Filing Guide (version 7, 12 December 2025, the current version checked) requires both XML and PDF files. Members may submit through FINRA Gateway or the fileX machine-to-machine channel, using the SEC Rule 606 NMS Reporting entitlement. Filenames must identify the firm’s CRD number, Rule 606 NMS reporting, the year and quarter, and the file extension; a firm submitting multiple reports for a quarter adds a “_CNTXT-” context label, as the FINRA guide describes. A correction replaces the corresponding report for the same firm and reporting period. Where the firm submits multiple reports for that period, the replacement filename must retain the same context label as the report being corrected.

Validation: what the SEC schema, the renderer and FINRA check

The clearest rejection point in the chain is FINRA’s Rule 6151 intake: FINRA’s guidance states that if the XML file does not conform to the SEC specification, it will be rejected. The 606 technical specification lists what XML Schema validation flags:

• missing or misplaced elements;
• negative values where a positive value is required;
• values outside the expected range;
• insufficient decimal digits of precision;
• a list of months that repeats a month.

Months without activity carry a trap of their own. For a venue or customer month with no orders routed or executed, the year and month still appear, numeric elements stay in the file as empty elements such as “<ndoMarketPct/>”, and placeholders such as “N/A” or “NA” are invalid.

For Rule 605, the SEC and FINRA materials reviewed for this guide describe no central intake that accepts or rejects the monthly files: each entity posts them to its Download Site, listed on its Designated Participant’s Link Site. FINRA Rule 6152, approved by the SEC on 25 June 2025 (Release No. 34-103325), adds a central copy for FINRA members: once effective, it requires each member that must publish Rule 605 reports to provide them to FINRA, in the manner FINRA prescribes, within the same time and in the same format. FINRA stated that it would announce the effective date in a Regulatory Notice and that the date would be no earlier than the compliance date for the amended Rule 605 and no later than 12 months after publication of the Regulatory Notice announcing the SEC’s approval of the rule. The checks are therefore the specification’s own. The OES specification marks each statistic as either “should not be negative” (order sizes, average midpoint, percentages executed at the quote or better and price-improved, percentage quoted spread, execution speed) or “may be positive or negative” (net percentage price improvement, percentage effective spread, the effective-over-quoted ratio and both realized spreads). The specification’s footnote on empty fields gives this example: where a reporting entity received orders in a category but executed no shares, it provides values only for the Designated Participant and reporting entity codes, the S&P 500 flag, the order type, the size category and the two average order size fields, and leaves the other fields empty. Exhibit A also defines the RptDate column as a valid date in YYYYMM format, so the report month stays populated in every record. A combination with no orders at all needs no record.

The Rule 605 identifiers have their own validation. On FINRA’s Gateway form, a proposed RIC fails validation if it is already in use, contains invalid characters or has the wrong length, and the OES specification limits the Designated Participant field to listed codes.

Caveats and interactions: best execution, exemptions, not held flow and Rule 607

The statistics are no best execution verdict

Rule 605 says so in its own text: the statistics are based on broad assumptions about order execution and routing, do not cover every factor relevant to evaluating a broker-dealer’s routing, and “alone” do not create a reliable basis to address whether a particular broker-dealer failed to obtain the most favorable terms reasonably available for customer orders. The 2024 adopting release repeats the Commission’s earlier statement that Rules 605 and 606 do not change the legal standards governing a broker-dealer’s duty of best execution, and that any conclusion on compliance with that duty would require a more in-depth analysis of routing practices than the disclosures provide.

Not held flow sits outside Rule 605

Orders submitted on a not held basis are special handling orders and drop out of the “covered order” definition, so a broker-dealer’s handling of not held parent orders falls outside its Rule 605 statistics. The 2024 adopting release notes that most institutional parent orders are handled on a not held basis and that, since 2018, Rule 606(b)(3) is where their execution quality appears, on request. Directed orders follow a split rule in staff FAQ Question 12: the broker-dealer that receives a directed order treats it as special handling and leaves it out, while the venue it is routed to does not treat it as special handling merely because the original order was directed.

Riskless principal

Rule 605(a)(1) counts shares executed at the receiving entity “excluding shares that the market center, broker, or dealer executes on a riskless principal basis”. On the Rule 606(b)(3) side, staff FAQ 9.01 answers no to including riskless principal transactions in the shares executed as principal, and gives treating such orders like agency orders in the report as one method.

Exemptions under the April 2026 order and the staff FAQs

Release No. 34-105136, dated 1 April 2026, granted, modified and rescinded Rule 605 exemptions for the amended rule:

• Fractional shares: a customer-facing broker-dealer that executes customers’ fractional-share orders only to let them exit positions created by a dividend reinvestment program or a stock dividend with a fractional component need not produce a separate market-center report on that basis. Any other OTC market-making activity removes the relief, and the broker-dealer report still applies if the firm meets the customer account threshold.
• Trading halts: marketable orders received during an announced halt are excluded, as are orders received (or, if non-marketable, that became executable) less than five minutes before the halt and still outstanding when it starts; non-marketable orders received during the halt may be included if they become executable after trading resumes.
• Crossed markets: an order that would require reference to an NBBO crossed for 30 seconds or more is excluded entirely; a crossing shorter than that is bridged by the next uncrossed NBBO.
• Inactively traded securities: an NMS stock that did not average more than five reported transactions per trading day in each of the preceding six months is exempt, now explicitly for broker-dealers as well as market centers, and reporting entities may include it voluntarily.
• Manually received orders: the 2001 temporary exemption was rescinded.

Two further exemptions come from elsewhere. The 2024 adopting release kept the Spread Width Exemption for orders received when the consolidated best bid and offer reflects a spread exceeding $1 plus 5% of its midpoint. Staff FAQ Question 8 describes a small market center exemption: a market center that reported fewer than 200 transactions per trading day on average over the preceding six months in covered securities, but only if more than 90% of them were in securities outside the Nasdaq-100 and the S&P 500. The FAQ frames that exemption in market-center terms; the April 2026 order, which expressly covered broker-dealers in the inactively traded securities and crossed-market exemptions, does not mention it.

Rule 607 and the payment for order flow trail

Rule 607 requires a broker-dealer acting as agent to tell customers in writing, at account opening and annually, its policies on payment for order flow and on routing orders that are the subject of such payments. The Rule 607 statement describes the policy; the Rule 606(a) report shows each quarter’s venue figures and the material terms of the arrangements. Options routing appears only in Rule 606, since Rule 605 covers NMS stocks.

Changes to Rules 605 and 606: 2018 routing amendments to the November 2026 odd-lot phase

• 2 November 2018: Rule 606 amendments (Release No. 34-84528, 83 FR 58338) amend the Rule 606(a) quarterly report, add the Rule 606(b)(3) not held order handling report, and amend Rule 605 to keep reports public for three years.
• 2 August 2023: SEC approves FINRA Rule 6151 (Release No. 34-98047); the rule takes effect on 30 June 2024.
• 6 March 2024: Rule 605 amendments adopted (Release No. 34-99679, 89 FR 26428, 15 April 2024), effective 14 June 2024, bringing in larger broker-dealers, single-dealer platforms and the summary report.
• 25 June 2025: SEC approves FINRA Rule 6152 (Release No. 34-103325), a central FINRA copy of members’ Rule 605 reports, with the effective date to be announced in a FINRA Regulatory Notice.
• 10 September 2025: amendment to the Rule 605 NMS Plan approved by Release No. 34-103939. The detailed-report procedures are contained in the amended Plan; the summary report uses the SEC’s separately published CSV schema and associated PDF renderer.
• 30 September 2025: compliance date extended from 14 December 2025 to 1 August 2026 (Release No. 34-104147, 90 FR 47552, 2 October 2025).
• 1 April 2026: exemptive order Release No. 34-105136 and new Rule 605 staff FAQs, effective on the compliance date, superseding Staff Legal Bulletins No. 12 and No. 12R and the February 2013 Rule 605 FAQs.
• 11 June 2026: SEC proposes rescinding Rules 611 and 610(e) (Release No. 34-105655, comments due 17 August 2026); the proposal would also redefine the Rule 605 order size benchmark by reference to bids and offers disseminated under an effective NMS plan in place of protected bids and offers. It has not been adopted.
• 17 June 2026: FINRA’s electronic Designated Participant Authorization Form goes live ahead of the amended rule and the amended Rule 605 NMS Plan taking effect together.
• 23 September 2026: the SEC’s Technical Specifications and Schemas page lists an update to the OES technical specification and the accompanying schema, renderer and sample-report package.
• 1 November 2026: the best-available-displayed-price phase begins.

The CFR text of Rule 606 carries no amendment after 2018; the changes on that side are FINRA’s central copy and schema maintenance, most recently a May 2024 correction of the specification’s schema appendix. The 2026 staff FAQs also withdrew several legacy answers, among them the earlier guidance on phase-in of reporting and on rounding of statistics, so procedures that still cite Staff Legal Bulletin No. 12R point to guidance the staff has superseded.

Frequently Asked Questions

Our clearing firm routes every order we introduce. Can we rely on its Rule 606(a) report?

FINRA’s Rule 6151 filing guidance permits an introducing member that routes all customer orders to one or more clearing firms for further routing and execution to adopt the clearing firms’ Rule 606(a) reports by reference, subject to applicable SEC guidance. Since 12 December 2025 the member does this through the Adopt by Reference form on the FINRA Gateway, in place of the earlier CSV submission. The introducing member provides each clearing firm’s CRD number and a link to the introducing firm’s own webpage disclosing the relationship and adoption by reference, and updates that information when it changes. Staff FAQ 12.01, written for a customer-facing broker routing through another broker, keeps the reporting responsibility with the customer-facing broker and allows adoption by reference only if it has examined the report and has no reason to believe it materially misrepresents the routing practices.

A customer asks for a Rule 606(b)(3) report but trades about $800,000 a month in not held orders through us. Is a report owed?

Not if that figure is the monthly average over the prior six months. Rule 606(b)(5) removes the obligation for a customer below the $1,000,000 average. The customer can still request the lighter Rule 606(b)(1) disclosure, which covers not held NMS stock orders where no (b)(3) report is owed.

Do we have to host our Rule 605 files on our own website?

No. Staff FAQ Question 2 says a market center, broker or dealer need not make its detailed or summary reports available on its own internet site and may arrange for other entities, such as vendors or SROs, to do so; an SRO may also publish several entities’ detailed reports in a single file. The rule text still places the posting obligations and the one-month deadline on each market center, broker or dealer.

An execution was price-adjusted after the trade. Which terms go into the Rule 605 report?

Staff FAQ Question 32 turns on the settlement cycle. An adjustment or void made within a normal settlement cycle is reflected, and the order is reported on the terms of execution as finally received by the customer. A change made after the normal settlement cycle is ignored, and the order is reported as originally executed.

We had no covered orders in a quarter. What goes to FINRA under Rule 6151?

FINRA’s Rule 6151 guidance says the XML report must follow the SEC’s specification for indicating no covered orders, and points firms to a sample “empty” report that the SEC publishes as the model. The file still goes through the same schema check as any other, so a non-conforming empty report is rejected like a full one.

Where do complex options orders go in the Rule 606(a) options section?

Staff FAQ 13.02 places complex options orders in the “other orders” category, which puts them in the “other orders” percentages and payment columns of the options section.

Related Articles

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• Form PF Reporting: Thresholds, Deadlines and the July 2027 Form Switch: the SEC’s private fund return for registered investment advisers.
• EDGAR Filer Manual Version 78: Form 1, ANE Notices and the XBRL Move: the EDGAR technical rules that govern SEC filings outside the Rule 605 and 606 website model.
• MiFIR Transaction Reporting: Complete Guide to Article 26 Compliance: the EU regime that reports individual transactions in financial instruments to competent authorities.

Key Takeaways

• Record, for each broker-dealer, the month it first met the 100,000-account threshold, counting omnibus underlying accounts; that month fixes the start of its first Reporting Period.
• Budget for two Rule 605 builds: a pipe-delimited detailed file under the Plan and a comma-delimited OES summary file with its SEC-rendered PDF.
• Load SIP odd-lot data into the Rule 605 engine: the five best-available-displayed-price columns are required from 1 November 2026, starting with the November 2026 reports.
• Publish each Rule 606(a) report by the end of the following month. FINRA members must also satisfy Rule 6151 through the applicable upload or adoption-by-reference route.
• Convert per-share payment for order flow figures to cents per hundred shares before writing the 606 XML, and compute each net figure as amounts received less amounts paid.
• Keep a monthly log of not held share at broker-dealer level and of each customer’s six-month not held notional average, so a Rule 606(b)(3) request can be answered on time.

Sources and References

• Code of Federal Regulations, 17 CFR 242.605, Disclosure of order execution information: govinfo.gov (PDF)
• Code of Federal Regulations, 17 CFR 242.606, Disclosure of order routing information: govinfo.gov (PDF)
• Code of Federal Regulations, 17 CFR Part 242 (Regulation NMS, including Rules 600 and 607), 4-1-25 edition: govinfo.gov (PDF)
• SEC, Disclosure of Order Execution Information, Release No. 34-99679 (6 March 2024), 89 FR 26428 (15 April 2024): govinfo.gov (PDF)
• SEC, Extension of Compliance Date for Disclosure of Order Execution Information, Release No. 34-104147, 90 FR 47552 (2 October 2025): govinfo.gov (PDF)
• SEC, Order Granting Limited Exemptions Pursuant to Rule 605(b) of Regulation NMS, Release No. 34-105136 (1 April 2026): sec.gov (PDF)
• SEC, Order Approving an Amendment to the National Market System Plan Establishing Procedures Under Rule 605 of Regulation NMS, Release No. 34-103939 (10 September 2025): sec.gov (PDF)
• SEC, Order Approving a Proposed Rule Change to Adopt FINRA Rule 6152 (Disclosure of Order Execution Information for NMS Stocks), Release No. 34-103325 (25 June 2025): sec.gov (PDF)
• SEC, Disclosure of Order Handling Information, Release No. 34-84528 (2 November 2018), 83 FR 58338: sec.gov (PDF)
• SEC, The Trade-Through Rule and Locked and Crossed Markets Provisions of Regulation NMS, proposed rule, Release No. 34-105655 (11 June 2026): sec.gov (PDF)
• SEC rulemaking page, Disclosure of Order Execution Information (File No. S7-29-22): sec.gov
• SEC Division of Trading and Markets, staff Frequently Asked Questions on Rule 605 of Regulation NMS (1 April 2026, effective 1 August 2026): sec.gov
• SEC Division of Trading and Markets, Responses to Frequently Asked Questions Concerning Rule 606 of Regulation NMS: sec.gov
• SEC, Disclosure of Order Execution and Order Routing Information (Rules 605 and 606 resource page): sec.gov
• SEC, Technical Specifications and Schemas (Order Execution Summary Data Report; Order Handling Data Schema and Report Renderer): sec.gov
• SEC, Order Execution Summary Data Reports under Rule 605(a)(2), Technical Specification: sec.gov (PDF)
• SEC, Order Routing and Handling Data Technical Specification (21 May 2024): sec.gov (PDF)
• FINRA, SEC Rules 605 and 606 Reports: finra.org
• FINRA, Information Notice 6/17/26, New Rule 605 Designated Participant Authorization Form: finra.org
• FINRA, Regulatory Notice 24-05, FINRA Adopts Amendments to Improve the Accessibility of Order Routing Disclosures for NMS Securities (Rule 6151): finra.org
• FINRA, Rule 6151 Reporting Compliance guidance: finra.org

The entity map behind every Rule 605 and 606 file

The control that decides the rest is a register of every broker-dealer and market-center function in the group: its Rule 605 status and RIC, its monthly account count against the customer account threshold, its Rule 606(a) URL and FINRA submission route, and its not held share against the five percent test. Kept current each month, that register tells the reporting team which Rule 605 files, Rule 606(a) publications and applicable FINRA Rule 6151 actions each entity owes before the period closes, and under which code.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.