NYSE Equities

ING FINANCIAL PARTNERS INC

Top Venues Percentage of Non-Directed Orders Data as of 03/31/14
  Venue Total Total Market Orders Total Limit Orders Total Other Orders
1. BNY MELLON CAPITAL MARKETS, LLC 87.1 %   88.1 %   73.6 %   90.8 %  
2. KCG AMERICAS LLC 3.4 %   3.2 %   6.1 %   3.2 %  
 
  Summary Statistics 100.0 %   83.5 %   8.4 %   8.1 %  

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ING Financial Partners Inc. directs its New York Stock Exchange ("NYSE")
equity order flow to its clearing broker, Pershing Division of Donaldson, 
Lufkin & Jenrette Securities Corporation ("Pershing"), for routing and 
execution.  ING Financial Partners Inc. does not receive compensation for 
directing order flow to Pershing.  

Pershing and its affiliate, Pershing Trading Company, L.P., 
(collectively "Pershing") receive compensation for directing a percentage of 
NYSE equity flow to certain exchanges or specialists.  Pershing also routes 
certain NYSE equity order flow to affiliated specialists. 

Compensation is generally in the form of a per share cash payment.  
Additionally, certain exchanges reduce or eliminate execution fees on orders 
directed to them in dually listed securities. 

If an order for NYSE listed security is not immediately executable on the 
exchange to which is routed, such order may be represented in the national 
marketplace using the various means available for price discovery 

Pershing regularly reviews reports for quality of execution purposes.
 




Disclosure of Order Routing Practices web site supported by Pershing LLC