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Disclosures

Important Information Regarding your Account

Korea Investment & Securities America, Inc. (“KISA” or the “Firm”) is a broker/dealer registered with the Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). KIS America, Inc. is a wholly owned subsidiary of Korea Investment & Securities US Inc. (“KISUS’) which is 100% owned by Korea Investment & Securities Co., Ltd. (“KIS”), a financial services institution based in Seoul, South Korea.

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Please read the following information carefully in connection with your account(s) with KISA.

 

Anti-Money Laundering and Customer Identification Program 

KISA is committed to complying with U.S. statutory and regulatory requirements designed to combat money laundering and terrorist financing. In particular, the USA Patriot Act of 2001 requires all financial institutions to obtain, verify, and record information that identifies each person or entity that opens an account or establishes a relationship with the Firm. What this means for you: when an entity opens an account with KISA, for certain employees or principals of the entity we will ask for the legal name, address, date of birth (for individuals), identification number (i.e., social security number (for individuals) or EIN (for entities)) and any other information that will allow us to identify such individuals. We may also ask to see other identifying documents as necessary to enable KISA to verify such identity. For example, we may require a legal entity to provide other information such as the address of its principal place of business and/or local office(s), employer identification number(s), certified articles of incorporation, government-issued business license(s), formational documents (such as a partnership agreement or a trust agreement), and other such information identifying the individuals or entities that exercise ownership or control over (directly or indirectly) of the legal entity. We may also ask for a copy of a driver’s license or government issued passport and/or seek additional personal documentation. Unless KISA is required to disclose this information pursuant to applicable laws, rules or regulations, KISA will otherwise retain this information and documentation in confidence according to our Privacy Policy. If all required documentation or information is not provided, KISA may be unable to open an account or establish a relationship with you.

 

Extended Hours Trading Risk Disclosure – FINRA Rule 2265 

KISA may execute a customer order outside of regular trading hours should the customer specifically request such facilitation. Clients should consider the following points before placing orders for execution during extended hours trading. “Extended hours trading” means trading outside of “regular trading hours.” “Regular trading hours” generally means the time between 9:30 a.m. and 4:00 p.m. Eastern Standard Time.

  • Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for customers to buy and sell securities, and as a result, customers are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular market hours. As a result, your order may only be partially executed, or not at all.

  • Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular market hours.  As a result, your order may only be partially executed, or not at all, or you may receive an inferior price in extended hours trading than you would during regular market hours.

  • Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of the regular market hours, or upon the opening the next morning. As a result, you may receive an inferior price in extended hours trading than you would during market hours.

  • Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system.

  • Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.

  • Risk of Larger Spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.

  • Risk of Lack of Calculation or Dissemination of Underlying Index Value or Intraday Indicative Value (“IIV”). For certain Derivative Securities Products, an updated underlying index value or IIV may not be calculated or publicly disseminated in extended trading hours. Since the underlying index value and IIV are not calculated or widely disseminated during the pre-market and post-market sessions an investor who is unable to calculate implied values for certain Derivative Securities Products in those sessions may be at a disadvantage to market professionals.

 

Held and Not Held Orders 

Absent specific instructions to the contrary, KISA understands that when an institutional customer places an order with us, it is directing that we handle the order on a “not held” basis. This means the client is giving us discretion to use our judgment on the time, price, and manner in which the order is executed, so that we may seek to obtain best execution that are reasonably available within market conditions. Institutional client orders transmitted via FIX or other protocol and not designated as “held” or “not held” will be handled as “not held.”

If the order is to be executed on a “held” basis, the client must identify it as such at the time of entry. We will immediately execute any market order at the then prevailing market price and any limit order at or better than your limit price if possible.

 

Investor Education and Protection Disclosure – FINRA Rule 2267 

The Financial Industry Regulatory Authority runs a public disclosure program known as BrokerCheck that provides information about brokerage firms and their registered persons. To obtain an investor brochure that includes information about BrokerCheck or to obtain additional information, contact the FINRA public disclosure hotline at (800) 289-9999 or visit the BrokerCheck website at http://brokercheck.finra.org/. FINRA’s general website is located at www.finra.org/.

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Disclosure of Control Relationship with Issuer – FINRA Rule 2262  

Under Rule 2262, a member controlled by, controlling, or under common control with, the issuer of any security, shall disclose to a customer the existence of such control.  KIS America, Inc. is under common control with Korea Investment & Securities Co., Ltd. a registered broker dealer in Korea.

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Disclosure of Order Routing Information – Securities Exchange Act Rule 606  

KISA makes publicly available on its website a quarterly report on order routing statistics pursuant to and as described in SEA Rule 606(a)(1).  KISA will furnish, upon customer request, a written copy of the quarterly report.  KISA will also furnish, upon customer request and pursuant to SEA Rule 606(b)(2), a report on the order routing information described in SEA Rule 606(b)(1).

 

Statement of Policy Regarding Payment for Order Flow – Securities Exchange Act Rule 607

KISA is required by the SEC to disclose to new customers, and annually to all customers, its policies regarding the practice of receiving “payment for order flow,” the nature of order routing policies for orders subject to payment for order flow and the degree to which these orders can receive price improvement. The SEC generally defines “payment for order flow” to include any cash or non-cash compensation received by a broker or dealer from another broker or dealer, national securities exchange, registered securities association or exchange member in return for sending customer orders to such entities for execution.

Many venues offer cash credits or rebates for orders that provide liquidity to their books and charge explicit fees for orders that extract liquidity from their books, and some other “inverted venues” offer cash credits or rebates for orders that extract liquidity from their books and charge explicit fees for orders that provide liquidity to their books. Liquidity rebates are considered payments for order flow.  Although KISA does not receive outright payment for order flow, KISA may from time to time receive rebates for providing liquidity or extracting liquidity pursuant to agreements we have with certain executing brokers. KISA’s routing decisions are based on a number of factors, including but not limited to, price, liquidity, venue reliability, cost of execution, likelihood of execution and potential for price improvement.

 

Prohibition Against Trading Ahead of Customer Orders – FINRA Rule 5320  

In the section above entitled Held and Not Held Orders, we note that KISA presumes orders from our institutional customers are not held unless you specify otherwise. Please note that such not held orders are not subject to the protections of FINRA Rule 5320.

Rule 5320 generally prohibits KISA from trading for its own account in an NMS stock or OTC equity security at a price that is equal to or better than an unexecuted held customer order, unless KISA immediately thereafter executes the customer order up to the size and the price (or better) at which we executed our own order.

The Rule provides an exception for large-sized orders (orders of 10,000 shares or more with a total value of $100,000 or more) and/or orders for “institutional accounts.” For such orders, the Firm may trade a security on the same side of the market for its own account at a price that would satisfy the customer’s held order.

You may opt in to the protections of FINRA Rule 5320 with respect to all or any portion of your orders by notifying us of your objection to KISA trading along with your orders by mail to Korea Investment & Securities America, Inc. 1350 Avenue of the Americas, Suite 1602, New York, NY 10019. Attn: Compliance Department.

You may also notify us on a trade-by-trade basis that you object to our trading along with your order. If we do not receive any objection, we will presume that you consent to our trading activity.

 

Front Running of Block Transactions – FINRA Rule 5270

Rule 5270 prohibits a broker-dealer from trading for its own account while having material, non-public market information concerning an imminent block transaction in a security, a related financial instrument, or a security underlying the related financial instrument prior to the time information concerning the block transaction has been made publicly available or has otherwise become stale or obsolete. The Rule provides exceptions for certain transactions. For example, the Rule does not preclude a broker-dealer from trading for its own account for purpose of fulfilling or facilitating the execution of a client’s block transaction. A broker-dealer is also permitted to engage in hedging or pre-hedging when the purpose of the trading is to fulfill the client order and the broker-dealer has disclosed such trading activity to the client. This hedging or pre-hedging activity may materially impact the market prices of the securities or financial instruments a client is buying or selling. Of course, KISA conducts this trading in a manner designed to limit market impact and consistent with our best execution obligations to our clients.

 

Fractional Share Trading Disclosure

Fractional share trading is generally available for exchange-listed National Market System (“NMS”) securities.  Fractional share trading functionality allows you to buy and sell fractional share quantities and dollar amounts of certain securities (“Fractional Trading”). Fractional Trading presents unique risks and has certain limitations that you should understand before placing your first trade.

KISA may facilitate the holding or trading of a fraction of a share of a security (“Fractional Shares”) in your Account. You acknowledge and understand that KISA rounds all trading of Fractional Shares to the sixth decimal place, the value of Fractional Shares to the nearest cent, and any dividends paid on Fractional Shares to the nearest cent. You understand that KISA will not accept U.S. dollar-based purchases or sales of less than $0.01 and that you will receive proceeds from the sale of any whole or Fractional Shares rounded to the nearest cent.

All orders with a fractional share component will be marked “Not Held,” which gives KISA the time and price discretion to execute the order without being held to the security’s current quote. In connection therewith, each time you submit an order to buy or sell a fractional share quantity or dollar amount of a particular security, you authorize KISA to “work the order.” If you do not wish your order to be handled on a Not Held basis, you should not engage in Fractional Trading. Due to rounding and price movements, the actual share amount received may differ from the estimated order quantity.

 

Trade Execution

 

For a variety of reasons, the actual amount of an executed dollar-value trade may be different from the requested amount. The actual amount of an executed order to buy or sell a dollar value of a security may also be lower than the amount requested due to the deduction of certain fees (e.g., the Additional Assessment) or taxes. Orders received in good form by KISA will be accepted and transmitted for execution. You may attempt to cancel an order, but there is no ability to request that an order be “cancelled and replaced” (i.e., you cannot modify an order once it has been submitted). Instead, you will need to cancel your order and then submit a new one.

Your ability to buy or sell a security using Fractional Trading may be more restricted than if you were to buy or sell traditional whole share quantities of the same security.   Certain securities are not eligible for fractional trading. KISA supports market and limit orders only for fractional share trading of a security that are good for that day’s trading session, or in the case of an order entered outside of market hours, that are good until the close of the next trading session.

You acknowledge that, subject to applicable requirements, KISA may report transactions in your Account in terms of either U.S. Dollars, shares, or both.

 

Trading Halts

 

Trading on a particular security, or in the market as a whole can be halted for a variety of reasons. In the event of a trading halt of a security, or if the market overall is experiencing a trading halt, Fractional Trading of that security will also be halted, and your order will be held until trading resumes. You will have the option to cancel pending fractional orders, but the cancel requests won’t be processed until the halt is lifted.  Your order is good only for that day’s trading session, or in the case of an order entered outside of market hours, good until the close of the next trading session. If trading does not resume or your order is not executed by the close of that day’s Fractional Trading window, it will be cancelled.

 

Risks

 

Fractional Trading presents unique risks and has certain limitations that you should understand before placing your first trade. You should review and understand these risks and limitations before engaging in Fractional Trading. More information about order types is available at:  https://www.sec.gov/oiea/investor-alerts-and-bulletins/ib_ordertypes.

 

Suitability and Appropriateness 

Certain securities or financial instruments may not be suitable or appropriate for all investors or in all geographical areas. Depending on the needs, investment objectives and financial situation of your institution, your institution must make its own independent decisions regarding any securities or financial instruments purchased and sold. Moreover, the institutional customer exception to the suitability requirements focuses on two factors: (1) whether a broker “has a reasonable basis to believe the institutional customer is capable of evaluating investment risks independently, both in general and with regard to particular transactions and investment strategies involving a security or securities”, and (2) whether “the institutional customer affirmatively indicates that it is exercising independent judgment”.

The fact that KISA has made available to you investment opinions and other information constitutes neither a recommendation that you enter into a particular transaction nor a representation that any financial instrument is suitable or appropriate for you. You should consider whether an investment strategy or the purchase or sale of any product is appropriate for your institution in the light of its particular investment needs, objectives and financial circumstances. You hereby acknowledge (i) that KISA has a reasonable basis to believe that your entity is capable of evaluating investment risks independently, both in general and with regard to particular transactions and investment strategies involving a security or securities, and (ii) that your institution is exercising independent judgement about the instruments it transacts in and that your institution is a sophisticated investor that has sufficient knowledge and experience in financial and business matters and is capable of evaluating the merits and risks of any prospective investment or transaction.

KISA may trade or make markets for its own account on a principal basis in any securities referenced herein. We may also engage in securities transactions that are inconsistent with this communication and may have long or short positions in such securities.

 

Margin Disclosure Statement – FINRA Rule 2264

Securities purchased on margin are the Firm’s collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the Firm can take action, such as issue a margin call and/or sell securities or other assets in any of your accounts, in order to maintain the required equity in the account. It is important that you fully understand the risks involved in trading securities on margin. These risks include the following:

  • You can lose more funds than you deposit in the margin account.

  • The Firm can force the sale of securities or other assets in your account(s).

  • The Firm can sell your securities or other assets without contacting you.

  • You are not entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call.

  • The Firm can increase its “house” maintenance margin requirements at any time and is not required to provide you advance written notice.

  • You are not entitled to an extension of time on a margin call.

 

Options

Options trading entails significant risk and is not appropriate for all investors. Options transactions are often complex and may involve the potential of losing your entire investment. Investors should consider their investment objectives and risks carefully before investing in options. To learn more about the risks associated with options, please read the Characteristics and Risks of Standardized Options, OCC - Options Disclosure Document (theocc.com), https://www.theocc.com/company-information/documents-and-archives/options-disclosure-document,  riskstoc.pdf (theocc.com), https://www.theocc.com/getmedia/a151a9ae-d784-4a15-bdeb-23a029f50b70/riskstoc.pdf,  before you begin trading options. Supporting documentation for any claims, if applicable, will be furnished upon request

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Special Statement for Uncovered Option Writers

There are special risks associated with uncovered option writing, which expose the investor to potentially significant loss. Therefore, this type of strategy may not be suitable for all customers approved for options transactions.

  • The potential loss of uncovered call writing is unlimited. The writer of an uncovered call is in an extremely risky position, and may incur large losses if the value of the underlying instrument increases above the exercise price.

  • As with writing uncovered calls, the risk of writing uncovered put options is substantial. The writer of an uncovered put option bears a risk of loss if the value of the underlying instrument declines below the exercise price. Such loss could be substantial if there is a significant decline in the value of the underlying instrument.

  • Uncovered option writing is thus suitable only for the knowledgeable investor who understands the risks, has the financial capacity and willingness to incur potentially substantial losses, and has sufficient liquid assets to meet applicable margin requirements. In this regard, if the value of the underlying instrument moves against an uncovered writer’s options position, the investor’s broker may request significant additional margin payments. If an investor does not make such margin payments, the broker may liquidate stock or options positions in the investor’s account, with little or no prior notice in accordance with the investor’s margin agreement.

  • For combination writing, where the investor writes both a put and a call on the same underlying instrument, the potential risk is unlimited.

  • If a secondary market in options were to become unavailable, investors could not engage in closing transactions, and an option writer would remain obligated until expiration or assignment.

  • The writer of an American-style option is subject to being assigned an exercise at any time after he has written the option until the option expires. By contrast, the writer of a European-style option is subject to exercise assignment only during the exercise period.

NOTE: This statement is not intended to enumerate all of the risks entailed in writing uncovered options.

 

Option Dividend Risk

It is important to remember if you are selling options (covered or uncovered), the risk of being assigned is always present. The likelihood of your option being assigned early increases when the underlying security announces an ex-dividend date.

When a dividend for a stock is declared an investor must own the stock before the ex-dividend date to receive the payment. Dividend risk may occur in this situation because short calls are exposed to early assignment. Investors who are looking to receive the dividend payment may exercise a long call option early so that they are eligible to collect the dividend payment. This can occur whether the contract is in the money or not. The investor who wrote (sold) the call option would be responsible to deliver the shares if the option is exercised against them which may put them in a short position. If a short position is held through the ex-dividend date, then the investor would be responsible for paying the dividend on the payable date. This risk exposure can be avoided if an investor closes out the short option the day before the ex-date to prevent them from being assigned early.

 

Voice Recording 

In accordance with applicable laws and regulations, KISA records certain telephone conversations with outside parties. By communicating with KISA you consent to the voice recording of conversations with personnel of KISA.

 

U.S. Treasury Circular 230 Tax Notice 

KISA does not render advice on tax and tax accounting matters to clients. This communication and any other communications between KISA and you are not intended or written to be used, and it cannot be used by any taxpayer, for the purpose of avoiding penalties that may be imposed on the taxpayer under U.S. federal income tax laws. Investors should consult their own legal, tax investment or other advisors, at both the onset of any transaction and on an ongoing basis to determine the laws and analyze applicable to their specific circumstances.

 

SIPC Disclosure 

KISA, as a member of SIPC and pursuant to FINRA Rule 2266, discloses to new customers, and annually to all customers, that they may obtain information about SIPC, including the SIPC brochure, by contacting SIPC at the following address or visiting their web site at WWW.SIPC.ORG.

 

Securities Investor Protection Corporation
805 Fifteenth Street NW, Suite 800
Washington, DC 20005-2215
Tel. (202) 371-8300

 

Customer Complaints – In accordance with SEA Rule 17a-3(a)(18)(ii), please be advised that any complaints may be directed to the following:

 

Korea Investment & Securities America, Inc.
1350 Avenue of the Americas, Suite 1602
New York, NY 10019
ATTN: Chief Compliance Officer
(212) 314-0687

 

Your California Privacy Rights 

California Civil Code Section 1798.83 permits users of the client website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Under California law, California residents are entitled to ask us for a notice identifying the categories of personal customer information that we share with our affiliates and/or third parties for marketing purposes, and provide contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to:

 

Korea Investment & Securities America, Inc.
1350 Avenue of the Americas, Suite 1602
New York, NY 10019
ATTN: Chief Compliance Officer
(212) 314-0687

compliance@kisamerica.com

 

Do Not Track 

While many current browsers permit you to send a signal to us about your Do Not Track (“DNT”) preferences, we do not respond to DNT signals sent from your browser.

 

International Users 

KISA makes no claims that your content uploaded may be appropriately protected pursuant to privacy and data protection laws outside of the United States. Users from outside the United States, including the European Union, are advised that KISA stores personal information on servers within the United States, and they are further advised that personal information uploaded to the website may not be protected in accordance with their local laws and regulations. If you upload personal information to the client website from outside the United States, you do so at your own risk. (co.) is not responsible for compliance with the laws of your jurisdiction and makes no representations, warranties or guarantees that it complies with privacy, data protection or cyber security laws or similar laws or regulations outside the United States.

 

YOU ARE ADVISED TO PROMPTLY REPORT ANY INACCURACY OR DISCREPANCY IN YOUR ACCOUNT (INCLUDING UNAUTHORIZED TRADING) TO KISA. PLEASE BE ADVISED THAT ANY ORAL COMMUNICATION SHOULD BE RECONFIRMED IN WRITING TO FURTHER PROTECT YOUR RIGHTS, INCLUDING YOUR RIGHTS UNDER THE SECURITIES INVESTOR PROTECTION ACT. KISA’S CONTACT INFORMATION IS AS FOLLOWS:

 

KOREA INVESTMENT & SECURITIES AMERICA,INC.
1350 Avenue of the Americas, Suite 1602
New York, NY 10019
(212) 314-0687

 

Disclaimers

By accessing, browsing, and/or using this Website or linked websites and any pages hereof, you are indicating that you have read, acknowledged and agreed to be bound by this Disclaimers section and the Terms of Use section at (hyperlink). All persons and entities accessing the Website agree to do so on their own initiative and are responsible for compliance with applicable local laws and regulations.

This Website is for information purposes only and is not intended to be relied upon as a forecast, research or investment advice. The information on this Website does not constitute a recommendation, offer or solicitation to buy or sell any securities or to adopt any investment strategy. Although this material is based upon information that KISA considers reliable and endeavors to keep current, KISA does not assure that this material is accurate, current or complete, and it should not be relied upon as such. Any opinions expressed on this Website may change as subsequent conditions vary. Past performance is no guarantee of future results.

 

Nothing contained on this Website constitutes tax, accounting, regulatory, legal, insurance or investment advice. Neither the information, nor any opinion, contained on this Website constitutes a solicitation or offer by KISA or its affiliates to buy or sell any securities, futures, options or other financial instruments, nor shall any such security be offered or sold to any person in any jurisdiction in which such offer, solicitation, purchase, or sale would be unlawful under the securities laws of such jurisdiction. Decisions to act or not act that may be based on information contained on this Website are the sole responsibility of the visitor.

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The investments and strategies discussed in the Website may not be suitable for all investors and are not obligations of KISA or its affiliates or guaranteed by KISA or its affiliates. KISA makes no representations that the contents are appropriate for use in all locations, or that the transactions, securities, products, instruments, or services discussed on this site are available or appropriate for sale or use in all jurisdictions or countries, or by all investors or counterparties. By making available information on the Website, KISA does not represent that any investment vehicle is available or suitable for any particular user.

 

All investments involve risk and may lose value.

The value of your investment can go down depending upon market conditions. BEFORE ACQUIRING THE SHARES OF ANY INVESTMENT FUND BY PURCHASE OR EXCHANGE, IT IS YOUR RESPONSIBILITY TO READ THE FUND’S PROSPECTUS OR OFFERING MATERIALS.

You expressly acknowledge that you have checked and confirm that you; (i) are over eighteen (18) years of age and, are legally entitled to view this website; (ii) understand that any products mentioned on the website may no longer be available for investment or may not be available to you; and (iii) understand that the information on the website is not a promotion and that you will not treat it as such and that any information on the website is not addressed specifically to you.

Indemnification: As consideration for the provision of this website by KISA, the visitor agrees to indemnify, defend and hold KISA, its officers, directors, employees, affiliates, agents, licensors and suppliers harmless against any and all claims, losses, liability, costs and expenses (including but not limited to attorneys’ fees) arising from your use of this Website, from your violation of this Section or from any decisions that the visitor makes based on such information.​

 

Disclosure of Order Routing Information

Disclosure Statement made Pursuant to Rule 606 of the Securities Exchange Act of 1934

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KISA has prepared the following reports pursuant to Rule 606 of the Securities Exchange Act of 1934 and any other applicable rules (the “Rule” or the “Rules”). KISA has made every reasonable attempt to prepare these reports in compliance with Rules. Although the information herein has been obtained from sources believed to be reliable, these reports have not been audited and may contain errors, inadvertent omissions, or the like. Accordingly, KISA does not guarantee its accuracy, completeness, or fairness. From time to time, KISA may become aware of systems or other errors that may affect the information provided in the reports but that cannot be corrected before publication. KISA may, in its discretion, revise and republish this report and/or previous reports for prior periods. All reports, original and amended, are available upon request.

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Further, KISA disclaims all liability, including without limitation direct, indirect, punitive, special, consequential, or incidental damages on behalf of ourselves and our affiliates with regard to financial results or damages that may arise from the use of the information and data herein, any errors contained in the reports or any inability to access or use these reports. The information provided in the report may be impacted by market data system outages or errors, both internal and external, and it is dependent upon the integrity and accuracy of the data provided by outside sources. This information, including these disclaimers, applies to the current reports, previously published reports, and any revised reports in their entirety, irrespective of whether the reports are used or viewed collectively or individually, in whole or in part. The information and data provided in the reports is not intended to and do not reflect all factors relevant to an analysis of a broker-dealer’s best execution and order routing practices. These statistics capture only a small part of KISA’s total order flow. The order routing decisions reflected by the statistics in the Report should not be construed as an endorsement of any particular security or market participant. Any decision about whether to open an account or to direct orders to KISA should be based on analysis of the Firm’s full range of services and not solely based on these statistics.

 

KISA does not route orders directly to any execution venues and relies instead on executing brokers to route orders to exchanges and third-party trading centers. Certain equities exchanges and third-party trading centers to which executing brokers route equities orders have implemented fee structures under which broker-dealer participants may receive rebates on certain orders. Under these fee structures, participants generally are charged a fee for orders that take liquidity from the venue and provided a rebate for orders that add liquidity to the venue. Some venues charge a fee for orders that add liquidity to the venue and provide a rebate for orders that remove liquidity from the venue. In either or both cases, rebates received from a venue by execution brokers and passed on to KISA during any time period may or may not exceed the fees paid by KISA to the executing brokers during that time period. This does not alter KISA’s policy to route customer orders to the executing broker and via strategies where it believes clients will receive the best execution, taking into account, among other factors, price, transaction cost, volatility, market depth, quality of service, speed, and efficiency.

 

KISA also may or may not enter into a routing arrangement with an executing broker whereby commissions may be reduced or rebates may be increased based on the volume of shares that KISA routes to an executing broker. This does not alter KISA’s policy to route customer orders to the executing broker where it believes clients will receive the best execution, taking into account, among other factors, price, transaction cost, volatility, market depth, quality of service, speed, and efficiency.

 

Fee rates and rebate amounts on any given venue or with any given broker may change periodically. We will provide you additional information regarding fees and rebates on your written request, including the amount per order or per share received by KISA.    KISA's SEC Rule 606 Report

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