NASD Rule 3050 Transactions for Associated Persons

In accordance with NASD Conduct Rule 3050, all associated persons shall be required to notify the member firm of the existence of any and all securities accounts maintained by the associated person with any foreign or domestic brokerage firm, bank, investment adviser or other financial institution. Further, all associated persons shall be required to notify *the member firm and the executing firm in writing, prior to opening a securities account or placing an initial order for the purchase or sale of securities with another firm, any foreign or domestic brokerage firm, bank, investment adviser or other financial institution. This written notice shall advise the executing firm, foreign or domestic brokerage firm, bank, investment adviser or other financial institution of: (i) the person’s association with the Company; (ii) the Company’s membership with FINRA; and (iii) the fact that such person is a restricted person in accordance with FINRA Conduct Rule 5130. However, if the account was established prior to the association of the person with the Company, the associated person shall notify both the Company and the executing firm in writing after becoming associated. Finally, for purposes of this section, notification shall not be required for transactions and/or accounts dealing exclusively in unit investment trusts, variable contracts, and/or redeemable securities of companies registered under the Investment Company Act of 1940, as amended.

The firm should complete the review of the outside brokerage accounts of all associated persons for the month of November.