| 
				 
				
				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.  
				
				
				
				Polar Investment Counsel, Inc. does not nor has 
				the ability to route orders, all orders are routed by our 
				clearing firm, Hilltop Securities, Inc.
				 
				
				
				 
				
				
				Disclosure of Order Handling Information (sec.gov) 
				
				
				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. 
   |