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PRIVACY POLICY

We are a FINRA (Financial Industry Regulatory Authority) registered fixed income Broker/Dealer specializing in the distribution of financial services primarily to institutional investors; and, from time to time, trades are transacted with retail investors.  We want you to know that, as a customer of ours, we believe that protecting your privacy is extremely important; and, we want to be sure that we maintain your confidence and trust.  We collect nonpublic information from you on the account application and related account documentation as well as from trade records.  We may share this information about you with our clearing agent(s) in order to deliver or receive the securities you have transacted with us.  We do not otherwise disclose any nonpublic personal information about our customers or former customers to anyone, except as required by law.  We may share information on your transactions if we are required to disclose it by law, regulation, or court order.  We restrict access to nonpublic information about you to those employees who need to know that information in order to provide products or services to you as you have instructed us.  We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

DISCLOSURE POLICY

The Board of Governors of FINRA, our primary regulator, has adopted a public disclosure policy (rule 2280) that provides certain types of disciplinary information on FINRA Member Firms and their Associated Persons.  Inquires can be made via the FINRA web site at www.finra.org  or via the FINRA toll free telephone listing 1-800-289-9999.  The FINRA Public Disclosure Policy provides you access to information that may help you determine whether to conduct business with a FINRA Member Firm or with it's Associated Persons and for other uses consistent with the FINRA Public Disclosure Policy.  A brochure describing the Public Disclosure Program is available to you upon request by contacting FINRA.