Order Execution and Routing Practices (SEC Rule 606)

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Copper Financial (“CuFi”) routes 100% of its orders to Apex Clearing Corporation (“Apex”). Pursuant to Securities and Exchange Commission Rule 606, Apex is required to make publicly available a quarterly report with information on its routing of non-directed orders. Apex pays CuFi for order flow payments and rebates received by Apex for CuFi’s orders.

The most recent quarterly report for Apex can be found here.