On November 15, 2000, the Securities and Exchange Commission adopted new rules mandating the public disclosure of order execution and routing practices.
SEC 605 - Disclosure of Order Execution Information
SEC Rule 605 requires that Janney Montgomery Scott LLC ("Janney") publicly disclose, on a monthly basis, basic standardized information concerning its handling and execution of orders. Please direct any questions you may have to your Financial Advisor.
To view Janney's current 605 disclosure. please click https://www.fisglobal.com/ptc
SEC 606 - Disclosure of Order Routing Information
Under SEC Rule 606, Janney is required to disclose, on a quarterly basis, the identity of the market centers to which it routes a significant percentage of its orders. Janney is also required to disclose the nature of its relationships with such market
centers, including any internalization or payment for order flow and reciprocal business arrangements. Please direct any questions you may have to your Financial Advisor.
To view Janney's current 606 disclosure, please click https://www.fisglobal.com/ptc
FINRA Rule 5320 Disclosure
Rule 5320 generally prohibits a member firm that accepts and holds a customer order from trading for its own account at terms that would satisfy the customer order, unless the member immediately thereafter executes the customer order at the same or better
price than it traded for its own account.
There are certain exceptions to the Rule. Not-held orders are outside the scope of the Rule. Large Orders and Institutional Account Exceptions Large orders (orders of 10,000 or more shares with
a total value of $100,000 or more) and/or orders by institutional accounts are excepted from the requirements of Rule 5320, provided that notice is provided to the customer and the customer is provided a meaningful opportunity to opt in to the Rule
5320 protections with respect to all or any portion of its order. Institutional accounts and persons placing orders for 10,000 shares or more not otherwise subject to the protections afforded by Rule 5320 may “opt in” to the Rule 5320
protections by providing written notice (i) with respect to any particular order, at the time of placing an order to the Janney representative taking your order, and (ii) with respect to all orders for your account, to Janney Montgomery Scott, Attn.
Capital Markets Compliance, 1717 Arch Street, Philadelphia, PA 19103.
Janney will generally work such orders in accordance with customer instructions. While working such orders, Janney may trade for its own account at prices that would
satisfy the customer order. “No-Knowledge” Exception Where a firm implements and utilizes an effective system of internal controls, Rule 5320 permits the respective separate units to trade independent of one another for purposes of the
Rule. Janney maintains Rule 5320 internal controls between its trading units. The controls are designed to prevent one trading unit from having knowledge of customer orders held by a different trading unit. With these controls in place, one trading
unit may hold a customer order while another trading unit, including the market making trading unit, executes an order for a Firm account that would satisfy the customer order.
Weighted Average Pricing
Janney has implemented Weighted Average Pricing to simplify the appearance of securities transactions on client confirmations, statements, Online Access and tax reporting to clients. Weighted Average Pricing is the process of averaging the price of a
single transaction using a volume-weighted calculation. For example, when several trade executions are used to complete a single client trade order for eligible securities, a volume-weighted average price is calculated for those trade executions.
Weighted Average Pricing is FINRA-approved, and is currently being used by other financial services firms. If you have any questions regarding Weighted Average Pricing, or if you do not wish to have Weighted Average Pricing applied to your account,
please contact your Financial Advisor.
Janney Montgomery Scott LLC makes two-sided markets for more than 700 stocks. The Janney agency and principal desks have phone and electronic connections to market makers and markets throughout the country. This enables us to insure prompt execution for client orders.