Rule 606(a) Reports (Order Routing Practices)
The SEC and FINRA require that all broker-dealers inform their customers when a new account is opened, and on an annual basis thereafter, of payment for order flow practices (compensation received for placing orders through specialists on national securities exchanges, over-the-counter market makers, and alternative trading systems).
Valley Financial Management, Inc. (VFM) does not receive payment for order flow regarding equity and option orders. To review VFM’s most recent “Held NMS Stocks and Options Order Routing Public Report,” go to www.orderroutingdisclosure.com (broker-dealer full name “Leumi Investment Services Inc” (n/k/a Valley Financial Management, Inc.)).
VFM routes equity orders to Pershing, LLC (its clearing firm) and Pershing then sends these equity orders to exchanges or broker-dealers during normal business hours and during extended trading sessions. Some of these market centers provide payments to Pershing or charge access fees depending upon the characteristics of the order and any subsequent execution. In addition, Pershing may execute certain equity orders as principal. For the details relating to Pershing’s payment for order flow practices, please see Pershing’s SEC rule 606 disclosures at www.orderroutingdisclosure.com (broker-dealer full name “Pershing LLC”).
In addition, VFM routes listed option orders to Pershing, which may receive payments for directing listed options order flow to certain options exchanges. Compensation is generally in the form of a per option contract cash payment. For the details relating to Pershing’s payment for order flow practices, please see Pershing’s SEC rule 606 disclosures at www.orderroutingdisclosure.com (broker-dealer full name “Pershing LLC”).
Equity, option and mutual fund transactions routed through the clearing broker will be executed with VFM acting in the capacity of “Agent.” It is intended that the commission on each transaction will be the only remuneration VFM receives for each transaction. The commission for each “agency” transaction shall be disclosed on the customer’s trade confirmation. VFM does not anticipate receipt of any additional revenue as a payment for order flow.