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.