Is it permissible for a broker-dealer to prepare two or more reports that correspond to functional differences in the firms order routing practices?
A single firm may prepare two or more reports that correspond to functional differences in the firm’s order routing practices, but only if the separate reports will provide a clearer picture of the firm’s practices and the basis for the separate reports is fully disclosed to customers and the public. Each report should clearly explain the orders to which it applies, as well as identify the other reports for the firm and the orders to which they apply. Customers must be able to determine which report applies to their type of orders. For example, a broker-dealer with two divisions, each with its own customers and order routing practices, may generate a separate report for each division. Each report should explain that it applies only to orders submitted by customers of that division, and that another report has been issued that applies to orders submitted by customers of the other division. Similarly, an introducing broker whose customer accounts are carried by two different clearing fir
