Securities

Best Execution

Best execution is the obligation of broker-dealers to execute customer orders at the most favorable terms reasonably available under the circumstances, considering price, speed, and likelihood of execution.

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Exam Tip

Best execution = broker must get best OVERALL terms, not just price. Consider speed, size, likelihood. It's an obligation!

What is Best Execution?

Best execution is a regulatory requirement that broker-dealers must seek the most advantageous terms for customer orders. This doesn't necessarily mean the absolute best price, but rather the best overall execution considering multiple factors.

Best Execution Factors

FactorDescription
PriceThe execution price relative to market
SpeedHow quickly the order is filled
SizeAbility to fill the entire order
LikelihoodProbability of successful execution
CostCommission and other transaction costs

Regulatory Framework

RegulatorRequirement
SEC Rule 606Quarterly routing reports disclosure
FINRA Rule 5310Best execution obligation
NMS Rule 611Order protection rule

Order Routing Considerations

When routing orders, broker-dealers evaluate:

ConsiderationWhat It Means
Market CenterWhich exchange or venue to use
Rebates/FeesPayment for order flow considerations
Execution QualityHistorical fill rates and price improvement
Market ConditionsVolatility, liquidity, spread

Best Execution vs. Payment for Order Flow

AspectBest ExecutionPFOF
FocusCustomer benefitRevenue for broker
RequirementMandatory obligationPermitted practice
DisclosureRequiredRequired
Potential ConflictMust prioritize customerMay create conflicts

Documenting Best Execution

Broker-dealers must:

  • Conduct regular reviews of execution quality
  • Compare results across market venues
  • Document decision-making process
  • Update routing policies as needed

Common Violations

ViolationExample
PriceExecuting at worse price than available
DelayUnreasonable delay in execution
RoutingRouting based on rebates vs. quality
DocumentationFailure to review execution quality

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