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Legal Information

Securities and Exchange Commission Order Disclosure

SEC Rule 606 (formerly Rule 11Ac1-6)

Anderson & Strudwick, Inc. (“A&S”) has contracted with a third party auditor to provide quarterly reports on its order routing practices pursuant to an U.S. Securities & Exchange Commission rule, Rule 606. These reports may be viewed at www.Brasscompliance.com . A&S recommends that you visit the U.S. Securities & Exchange Commission website (http://www.sec.gov/rules/final/34-43590.htm ) to learn more about SEC Rule 606.

A&S directs its New York Stock Exchange (“NYSE”), American Stock Exchange (“AMEX”), and options order flows to its clearing broker, Pershing LLC (“Pershing”) for routing and execution. A&S does not receive compensation for directing order flow to Pershing. Pershing and its affiliates, Pershing Trading Company, L.P., receive compensation for directing a percentage of NYSE, AMEX, over the counter, and listed options order flow to certain exchanges, selected market makers, or specialists. Pershing generally receives compensation 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. A&S makes markets in various over-the-counter (“OTC”) stocks and uses Pershing to settle these trades. A&S may direct its Nasdaq trades to Pershing for those securities in which Pershing, or its affiliate, are market makers. In certain instances, large or block orders also may routed to Pershing for processing. Anderson & Strudwick does not receive compensation for directing this order flow.

Anderson & Strudwick takes into consideration many factors when determining where to route customers' Nasdaq orders. These items include opportunities for price improvement, speed of execution, market depth and order size, cost of execution and the reputation of a particular venue. A&S actively monitors the execution quality provided by the different market makers and routes orders to venues that have provided consistent, high quality execution over time.

 

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