SEC Rule 606 Disclosures

Order Routing Practices

Securities and Exchange Commission rules mandate the public disclosure of order routing practices (the "Disclosure Rules"). Under Rule 606 (formerly SEC Rule 11Ac1-6), broker-dealers that route customer orders in equity and option securities are required to make publicly available quarterly reports that, among other things, identify the venues to which customer orders are routed for execution.

SEC rule 606

The information required by SEC Rule 606 does not encompass all the factors that may be important to investors in evaluating the order execution and routing services of a broker-dealer. SEC Rule 606 statistics are intended to provide a general overview of a broker-dealer’s order routing practices. Accordingly, the statistical information required by SEC Rule 606 alone does not create a reliable basis to address whether any broker-dealer obtained the most favorable terms reasonably available under the circumstances for customer orders.

Rule 606 report

Each section of the report contains information regarding material aspects of SVB’s relationship, if any, with each venue. We have attempted to prepare these statistics in compliance with the SEC's rules. However, the statistics have not been audited and may contain errors. SVB Investment Services Inc. (“the Firm”) and its affiliates (collectively, "SVB") do not represent, warrant, or guarantee that the statistics are accurate. From time to time the Firm may become aware of systems or other errors that may affect the data or results reflected in its report, but which cannot be corrected before publication. The Firm may, in its discretion, revise and republish this Report and/or previous Reports for prior periods. SVB disclaims liability for any direct, indirect, punitive, special, consequential, or incidental damages related to the statistics or the use of such. The information provided in the reports may be impacted by market data system outages or errors, both internal and external, and it is dependent upon the integrity and accuracy of data provided by outside sources. Certain assumptions have been made in preparing the statistics, and changes to the assumptions may have a material impact on results. The statistics do not endorse or recommend any particular security or market participant.

Customers of SVB Investment Services Inc. may request information on any order executed within the prior six months from the time of the request. Specifically, you may request the identity of the venue to which the identified orders were routed for execution, whether the order was directed by you to that venue, and the time of the executions, if any, that resulted from such orders.