Legal

Privacy Statement

Stuart Frankel & Co., Incorporated (“STFC”) protects your privacy and treats as confidential any personal or financial information we receive in the course of providing our financial services to you. We are providing you with our Privacy Policy in accordance with Title V of the Gramm-Leach-Bliley Act and its implementing regulations.

STFC will not share personal information with others except as stated in this policy, unless we give you additional notice or ask for your permission. STFC reserves the right to disclose or report the personal information in certain circumstances: (1) to STFC’s clearing firm, as we deem necessary or appropriate, to handle, process and clear transactions in accounts; (2) where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, (3) to perform necessary credit checks or collect or report debts owed to us, (4) to protect our rights or property, or (5) upon reasonable request by a mutual fund or relating to other investments in your account.

STFC does not sell its customers’ or potential customers’ personal information. STFC will protect the confidentiality of any personal information you share with us. STFC corporate policies require that employees with access to confidential customer information may not use or disclose the information except for business use. All employees are required to safeguard such information.

It is the policy of STFC to protect the privacy of our clients who share personal and financial information with us in the course of receiving financial services from STFC. We treat your information as confidential and recognize the importance of protecting access to it.

Payment for Order Flow

The rules of the Securities and Exchange Commission require that Stuart Frankel & Co., Incorporated (“STFC”) advise of our policy regarding payment for order flow. STFC hereby informs you that we do not receive payment for order flow now. However, the firm does receive a minimal rebate from certain NASDAQ market centers for some of the orders executed there on behalf of our clients.