RAM FINANCIAL LLC
ORDER ROUTING AND PAYMENT FOR ORDER FLOW DISCLOSURE
When you submit an order through Aries, Ram Financial LLC ("Ram Financial") works diligently to ensure your order is routed to the execution venue that will provide you with the best price reasonably available. How your order is routed depends on several factors, most notably the type of security that you are buying or selling.
As the introducing broker-dealer for your brokerage account, Ram Financial relays your orders to our fully disclosed clearing firm, Apex Clearing Corporation ("Apex Clearing"). Apex Clearing then routes your order to an execution venue, where your trade is filled. The execution venues that receive orders through Apex Clearing include national securities exchanges, alternative trading systems, and wholesalers (also known as market makers).
This disclosure describes how orders are routed once they are received by Apex Clearing, and the practices of Ram Financial with respect to payment for order flow. "Payment for order flow" or "PFOF" is any type of compensation or consideration that we receive from an execution venue in exchange for routing orders to that venue.
Order Routing by Type of Security
Exchange-Listed Stocks and ETFs
When you submit an order for exchange-listed stocks or ETFs through Aries, Ram Financial passes that order to Apex Clearing. Apex Clearing then routes your order using its systematic, automated routing algorithm to one of several wholesalers (also known as market makers) or other execution venues. Ram Financial receives payment for order flow from the wholesalers and other venues that execute your orders.
Stock and ETF Options
When you submit a trade for a stock or ETF options contract through Aries, Ram Financial passes that order to Apex Clearing. Apex Clearing then routes that order for execution to one of several wholesalers (also known as market makers) or options exchanges. Ram Financial receives payment for order flow in connection with the execution of your options orders.
Factors Considered When Determining an Execution Venue
Apex Clearing uses a systematic, automated routing algorithm to determine which particular venue will receive any particular order. That automated logic takes into consideration several factors, including, among other things:
- Trading characteristics of the security and character of the market for the security (e.g., price, volatility, and relative liquidity)
- Size and type of transaction
- Number of primary markets checked
- Transaction costs
- Opportunity for price improvement
- Accessibility of quotation sources including speed of execution
- Any special handling instructions guiding the execution of the order
Payment for Order Flow
Ram Financial receives payment for order flow on equity, ETF, and options transactions. Apex Clearing Corporation receives compensation from execution venues in the form of monetary and/or non-monetary payments for directing order flow. Ram Financial shares in such payments received by Apex Clearing. The amount of payment varies based on the type of security, the execution venue, and the characteristics of the order.
Payment for order flow creates a potential conflict of interest because it provides a financial incentive for Ram Financial and Apex Clearing to route orders to venues that pay for order flow rather than to venues that might provide the best execution absent such payments. However, Ram Financial and Apex Clearing are obligated to seek best execution for customer orders, and Apex Clearing's order routing decisions take into account the factors described above.
The source and nature of any compensation received in connection with a specific transaction will be furnished upon written request from the customer.
SEC Rule 606 Quarterly Reports
Pursuant to SEC Rule 606(a), broker-dealers that route equity and options orders on behalf of customers are required to prepare quarterly reports that disclose specific information about their order routing practices for non-directed orders. A "non-directed order" is any order that you have not specifically instructed to be routed to a particular venue for execution.
Ram Financial routes 100% of its orders to Apex Clearing Corporation for execution. Accordingly, Ram Financial adopts Apex Clearing's quarterly Rule 606 reports, which are prepared by S3 Matching Technologies LP, a third-party market surveillance and auditing firm. The most recent quarterly reports for Apex Clearing can be found at: Apex Clearing Quarterly Order Routing Reports.
These reports identify the venues most often selected by Apex Clearing, set forth the percentage of various types of orders routed to those venues, and discuss the material aspects of Apex Clearing's relationships with those venues.
SEC Rule 606(b) — Individual Order Routing Disclosure
Under SEC Rule 606(b)(1), Ram Financial is required to disclose to customers, upon request, the identity of the venue to which your orders were routed for execution in the six months prior to the request, whether the orders were directed or non-directed, and the time of the transactions, if any, that resulted from such orders.
Under SEC Rule 606(b)(3), customers who place "not held" orders may request an individualized report concerning how Ram Financial handled those orders for the prior six months. This report will be provided within seven business days of the customer's request.
To request an individualized order routing report, please contact us at support@aries.com.
SEC Rule 607 Disclosure
SEC Rule 607 of Regulation NMS requires broker-dealers to disclose at account opening, and annually thereafter, their policies regarding payment for order flow and order routing practices.
Ram Financial receives payment for order flow from Apex Clearing in connection with the routing of customer orders in equity securities and options. Payment for order flow is considered compensation to Ram Financial and may create a conflict of interest, as described above. Ram Financial's policy is to route all customer orders to Apex Clearing, which then routes orders to the execution venue where it believes the customer will receive the best execution, based on the factors described in this disclosure.
Apex Clearing sends equity and options orders to exchanges, electronic communication networks, and broker-dealers during normal business hours and during extended trading sessions. Some of those market centers provide payments to Apex Clearing, or charge access fees, depending upon the characteristics of the order and any subsequent execution. In addition, Apex Clearing may execute certain equity orders as principal. The details of these payments and fees are available upon written request.
Questions
If you have any questions about this disclosure, Ram Financial's order routing practices, or payment for order flow, please contact us at support@aries.com.