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SEC Order Execution and Routing Disclosure

Churchill Financial, LLC. is an introducing broker dealer and has prepared this report pursuant to a U.S. Securities and Exchange Commission rule requiring all brokerage firms to make publicly available quarterly reports on their order routing practices. The report provides information on the routing of “non-directed orders” - any order that the customer has not specifically instructed to be routed to a particular venue for execution. For these non-directed orders, Churchill Financial, LLC’s clearing broker, National Financial Services, LLC, has selected the execution venue on behalf of its customers.

The report is divided into four sections: one for securities listed on the New York Stock Exchange, one for securities listed on The NASDAQ Stock Market, one for securities listed on the NYSE Market or regional exchanges, and one for exchange-listed options. For each section, this report identifies the venues most often selected by National Financial Services, LLC, discloses summary statistics, and sets forth the percentage of various types of orders routed to the venues.

Below are listed Churchill Financial’s quarterly reports, by year, on our order routing practices. Churchill Financial routes 100% of its orders to National Financial Services, LLC (NFS) our clearing agent. To view NFS’s SEC Rule 606 order disclosure, you can visit their website at

Department of Labor Fiduciary Rule Disclosure

Effective June 9, 2017, all individuals who provide advice to retirement plans including Individual Retirement Accounts (IRAs) must abide by the fiduciary standard. What does the fiduciary standard mean? This means that your representative must put your interests first before their own or that of the Firm, make prudent recommendations, charge reasonable compensation and make no misrepresentations to you regarding recommended investments. The recommendations made by your representative must be based upon your specific investment needs and objectives. The fiduciary standard is applicable to any recommendations that your representative makes to you, the client, for your retirement account(s).

Each representative has a set commission schedule, that is approved by the firm as reasonable, which is applicable to all their accounts.

Please note that the firm has policies and procedures in place to monitor this level of fiduciary responsibility for our retirement clients.