CONSUMER IDENTIFICATION PROGRAM NOTICE

USA Patriot Act

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license and/or other identifying documents.

Securities and Exchange Commission Rule 605/606

Securities and Exchange Commission Rule (“SEC”) 605 requires market centers that trade National Market System securities to make available to the public monthly electronic reports that include uniform statistical measures of execution quality. These reports are available as electronic data files downloadable in a raw form appropriate for advanced analytics. Please be aware that the majority of the order flow executed by Vertical Group is not covered by NMS Rule 605 due to special handling requests by clients. The execution results from this order flow will not appear in the data and may differ substantially from the results.

Securities and Exchange Commission Rule (“SEC”) 606 requires broker dealers that route client orders in certain equity and option securities to make available to the public quarterly reports that represent a general overview of their routing practices. Please be aware that the majority of the order flow executed by Vertical Group is not covered by NMS Rule 606 due to special handling requests by clients. The execution results from this order flow will not appear in the data and may differ substantially from the results.

Upon written request, Vertical Group will provide the market center location to which your specific equity and/or option order was routed for execution, and/or a copy of our website information.

FINRA BrokerCheck Hotline

The Financial Industry Regulatory Authority, Inc. offers investors information and education through the FINRA BrokerCheck Hotline at 800-289-9999 and FINRA website at www.finra.org. Available is an investor brochure that includes information describing FINRA BrokerCheck.

Privacy Statement

At Vertical Group, protection of your privacy has been a long-standing policy. We do not sell our current or former customer’s personal information to third parties. We collect certain “non-public personal information” about you from:

• Information we receive from you on applications or other forms;
• Information about your transactions; and
• Information we receive from non-affiliated third parties, including consumer and industry reporting agencies.

Vertical Group does not disclose your non-public personal information to anyone except as described as hereinafter. On a confidential basis, we may share the information we collect with companies that perform services to maintain your account information on our behalf. For example, we share information with third parties that assist us with data processing, preparing monthly statements, or companies that help us service our products. With your approval, we may share information within the affiliated Vertical companies to improve your experience with us and better serve your financial needs.

Vertical Group restricts access to your personal and account information to those employees who need to know that information to provide services to you. We maintain physical and electronic safeguards to protect your non-public personal information.

Important Disclosures For Investors Using Margin

Vertical Group (“Vertical”) is a registered broker-dealer; consequently, Vertical must adhere to margin rules and rules promulgated by the Securities & Exchange Commission (“SEC”). Margin represents the equity in your accounts. Account equity generally is the difference between the current market value of the securities in your account less the amount you owe. While it is not our practice to change our minimum margin requirements without prior notice, Vertical can, at any given time and without advanced warning, increase the amount of equity a margin account must maintain.

The minimum equity requirements vary depending on different factors, such as liquidity and price stability of the collateral. If the equity in an account falls or is falling, Vertical generally will issue a margin call for additional funds or collateral. In the event that you receive a margin call and are unable to meet it within the required timeframe, Vertical will decide whether an extension of time can be granted. Failure to satisfy a demand for additional margin could result in the involuntary liquidation of collateral held in your account. The consequences of a forced liquidation may be a loss greater than the initial deposit you made into your margin account. In addition, if liquidation doesn’t provide the funds necessary to meet the firm maintenance margin requirement, you must meet the deficiency. If your account holdings include SEC Rule 144 restricted or affiliate securities, such securities can be sold by Vertical under the provisions of SEC Rule 144 and related SEC interpretations governing our rights as pledgee in the event of default.

Accordingly, we want to take this opportunity to help you better understand the liquidation provision of the Margin Agreement. This provision covers the liquidation rights Vertical has over all assets held in your account as collateral for amounts due Vertical for loans, short positions, losses, or other charges in your account.

Generally before liquidating assets held as collateral, it is our practice (but not our obligation) to attempt to give prior notification whenever additional funds are required in order to protect the loans or other amounts due us. However, prior notification is not always a viable option because of adverse conditions in the market. Consequently, we might take action to sell positions (or buy in short positions) in your accounts without any prior notification to you, or we might elect not to sell or buy in positions to avoid aggravating an unfavorable market situation. Frequently, concentrated positions or positions causing the margin call could be sold before the liquidation of other securities held in your accounts. Vertical chooses which securities that serve as collateral for a margin account will be liquidated.

Please be aware that your margin agreement gives Vertical unlimited discretion to take action to protect itself against losses. Involuntary liquidation of assets is a significant risk factor which you should seriously reconsider and reevaluate from time to time, because it might result in material losses to you or other unforeseen negative consequences. We suggest you monitor your accounts frequently and be alert to prevailing market conditions, especially respecting concentrated positions, so that you can take preventive action in avoiding involuntary liquidations.

While it is not our intention to discourage you from using margin for buying and selling securities or for borrowing to satisfy your other business and personal needs, we believe that it is in your self-interest to focus on the market risks associated with all margin loans in order for you to make an informed decision.

Interest on Cash Balances in Securities Accounts

Vertical Group pays interest on free credit balances left on deposit with us for investment or reinvestment purposes, unless you advise us otherwise. The interest paid by us is a floating rate with periodic adjustments. Interest amounts of less than $1.00 per month will not be credited.