SEC Rule 606 Disclosure

Rule 606(a) requires broker-dealers to publish quarterly reports regarding routing of certain non-directed "covered orders" in NMS stocks and listed options.

Based on a review of the Firm’s business activities and order handling practices, Meridian has determined it has no covered orders subject to Rule 606(a) reporting.

This determination is based on the following:

Equity Orders

• Meridian handles institutional equity orders which are handled on a not-held basis
• Consistent with NYSE order handling conventions, equity orders routed to the New York Stock Exchange are treated as not-held unless otherwise specifically designated
• Not-held orders are excluded from Rule 606(a) covered order reporting requirements

Options Orders

• Meridian options activity qualifies for the de minimis exception described in SEC Staff Legal Bulletin No. 13A
• The Firm routes fewer than 500 reportable customer options orders per month on average during applicable reporting periods

Customer Order Definition

• Meridian’s client base consists of only institutional clients
• Orders from broker-dealers and institutional counterparties are excluded from the Rule 606 definition of customer orders
• The Firm’s orders generally exceed the SEC size thresholds applicable to covered orders (generally $200,000 for equities and $50,000 for options)
• Meridian does not engage in retail order routing activity