SEC Required

H.C. Denison


U.S. Securities and Exchange Commission ("SEC") Rules 605 and 606 (replacing Rules 11Ac105 and 11Ac1-6) requires all brokerage firms to publicly disclose their order routing practices. This rule was adopted to make visible the execution quality of the securities markets and order routing performance.

This disclosure is to describe routing of "non-directed orders," that is, orders that customers have not specifically asked to have sent to a particular venue for execution. For these non-directed orders, we select the venue on behalf of our customers. With respect to H. C. Denison's relationships with trading venues, our firm directs all trades in over-the-counter (OTC) and listed stocks to our clearing firm, Hilltop Securities, for execution.

H. C. Denison does not receive compensation for directing this order flow to Hilltop Securities. The designated market makers to whom orders are automatically routed are selected based on the consistently high quality of their executions in one or more market segments and their history of seeking price improvements. Hilltop Securities regularly reviews reports for quality of execution purposes. The most recent quarterly report prepared by Hilltop Securitiesis accessible here.

618 North 7th Street | Sheboygan, WI 53083 | 920-457-9451 | 800-247-8025