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ACAP Financial Inc. & Co.
SEC-Required Report on Routing of Customer Orders
Rule 11Ac1-6 Disclosure Information - 3rd Qtr, 2005.


Rule 11Ac1-6, states a broker-dealer must disclose any payment to/from another broker-dealer for order flow. Also a quantitative description of order routing must include the percentage of total customer orders for a particular section that were non-directed orders, and the percentages of total non-directed orders for a section that were market orders, limit orders, and other orders.

In accordance with rule 11Ac1-6, ACAP Financial Inc is disclosing the following information to the general public via our website (www.acap-financial.com), upon request and will be included with statements once each year. ACAP Financial Inc. will also provide information upon request from individual customers regarding their specific orders.

1.  ACAP Financial Inc. DOES NOT receive payment for order flow on NYSE, NASDAQ, AMEX, Options or any other Exchanges.

2. ACAP Financial Inc. DOES NOT pay for order flow on NYSE, NASDAQ, AMEX, Options or any other Exchanges..

3. Securities List on the NYSE have been routed:

Total Orders and Route Venues All Non-Directed Orders Market Orders Limit Orders Other Orders
Total ACAP Financial Inc. Orders 100% 55% 44% 1%
Orders Routed To:
Tri-Mark (TRIM) 48% 41% 56% 100%
Bernard Madoff (MADF) 41% 48% 32% 0%
Southwest Securities (SWST) 10% 11% 9% 0%
BRUTT LLC (BRUT) 1% 0% 1% 0%
Southwest a/o ARCA (ARCA) 10% 11% 9% 0%
100% of total customer orders were non-directed orders.

4. NASDAQ Securities have been routed:

Total Orders and Route Venues All Non-Directed Orders Market Orders Limit Orders Other Orders
Total ACAP Financial Inc. Orders 100% 18% 81% 1%
Orders Routed To:
Principal 72% 41% 76% 82%
Southwest Securities (SWST) 8% 28% 6% 0%
Citigroup Global (SBSH) 5% 7% 5% 0%
ETrade Capital Markets (ETRD) 3% 0% 4% 4%
Raymond James & Assoc (RAJA) 3% 13% 2% 0%
BRUTT LLC (BRUT) 3% 0% 4% 0%
Morgan Stanley (MSCO) 1% 7% 0% 0%
Oppenheimer & Co. (OPCO) 1% 2% 1% 0%
Merrill Lynch a/o Nite (NITE) 1% 2% 1% 4%
Spear Leeds a/o TASL (TASL) 1% 0% 1% 0%
100% of total customer orders were non-directed orders.

5. AMEX/Other Stock Exchanges have been routed:

Total Orders and Route Venues All Non-Directed Orders Market Orders Limit Orders Other Orders
Total ACAP Financial Inc. Orders 100% 15% 84% 1%
Orders Routed To:
Tri-Mark (TRIM) 98% 93% 98% 100%
Southwest a/o ARCA (ARCA) 1% 0% 1% 0%
Bernard Madoff (MADF) 1% 7% 0% 0%
Citigroup Global (SBSH) 0% 0% 1% 0%
100% of total customer orders were non-directed orders.

6. OPTIONS Trades have been routed:

Total Orders and Route Venues All Non-Directed Orders Market Orders Limit Orders Other Orders
Total ACAP Financial Inc. Orders 100% 98% 2% 0%
Orders Routed To:
Advanced Clearing Inc. (FOMA) 99% 99% 100% 0%
Pershing 1% 1% 0% 0%
100% of total customer orders were non-directed orders.

 

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