The Securities and Exchange Commission requires all registered broker-dealers to disclose their policies
regarding their receipt of “payment for order flow.” The commission defines “payment for order flow” as “any monetary payments, services, property, or other benefits that result in remuneration, compensation, or consideration to a broker or dealer from any broker or dealer, national securities exchange, registered securities association or exchange member in return for the routing of customer orders by such broker or dealer to any broker or dealer, national securities exchange, registered securities association, or exchange member for execution, including but not limited to research, clearance, custody, products or services, reciprocal agreements for the provision of order flow adjustment of a broker or dealer’s unfavorable trading errors, effort to participate as underwriter in public offerings; stock loans or shared interest accrued thereon; discounts, rebates, or any other reductions of or credits against any fee to, or expense or other financial obligation of, the broker or dealer routing a customer order that exceeds that fee, expense or other financial obligation. Apex Clearing Corporation “APEX” and Alpine Securities Corporation “ALPINE” and/or, if APEX and, or ALPINE “The Clearing Firms” are acting as the clearing broker, Scottsdale Capital Advisors, receives payment for order flow from third party maker execution firms.
Typically, these payments may take the form of rebates, volume discounts, reciprocal agreements to provide order flow and monetary compensation based upon the profitability, if any, of such order flow, to the particular specialist or market maker. When such remuneration is received, it is considered compensation to the receiving firm. The source and amount of any compensation received will be disclosed upon request. APEX and, or ALPINE and/or Scottsdale Capital Advisors, if APEX and, or ALPINE are acting as the clearing broker, route orders to different marketplaces in a manner consistent with the obligation to try and provide the best execution of all customer orders. Toward this end, when a customer does not specify a particular marketplace in which an order must be executed, that order is routed to an exchange or market maker that matches or improves on the then-current national best bid or offer for that particular security or option contract.