In opening and servicing customer accounts, Ladenburg Thalmann & Co. Inc., together with its investment adviser subsidiary Ladenburg Thalmann Asset Management Inc. (together referred to as “Ladenburg”), need to collect certain kinds of personal information -- identifying information (such as your name, address, telephone number, and Social Security number), application information (such as information about your assets, income, investment goals, and risk preferences), and transaction information (such as account activity information). Ladenburg will use personal information in ways that are in accord with the purposes for which we originally requested it.   For example, we will use the information you give us to process your requests and transactions, to provide you with additional information about products and services, or to evaluate your financial needs.  We may share this personal information with a Ladenburg agent or affiliate, or Ladenburg’s clearing firm.  We limit the collection and use of personal information to what is necessary to administer our business and to deliver superior service to you.  This may include advising you about our products or services, those of our affiliates, and other opportunities that we believe may interest you. 

Ladenburg will not share personal information with others except as stated in this policy, unless we give you additional notice or ask for your permission.  Ladenburg reserves the right to disclose or report the personal information in certain circumstances:  (1) to Ladenburg’s clearing firm, as Ladenburg deems 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. 

Ladenburg does not sell its customers’ or potential customers’ personal information.

Ladenburg will protect the confidentiality of any personal information you share with us.  Ladenburg 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.

Ladenburg strives to improve our efforts to protect personal information and makes every effort to keep your personal information accurate and up to date.  If you identify any error in your personal information or need to make a change to that information, please contact us and we will promptly update our records.  If you have any questions or concerns, please contact Colin Moors, Ladenburg’s VP of Operations, at 212-409-2030.

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Margin Disclosure (FINRA Rule2341)

Your brokerage firm is furnishing this information to you in order to provide with some basic facts about purchasing  securities on margin, as well as to alert you to the risks involved with trading securities in a margin account. Before trading stocks in a margin account, you should carefully review the margin agreement provided by your firm. Consult your firm regarding any questions or concerns you may have with your margin accounts.

When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your brokerage firm. If you choose to borrow funds from your firm, you will open a margin account with the firm. The securities purchased are the firms collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the firm can take action, such as issue a margin call and/or sell securities and other assets in any of your accounts held with the member, in order to maintain the required equity in the account.

It is important that you fully understand the risks involved in trading securities on margin. These risks include the
following:

• You can lose more funds than you deposit in the margin account. A decline in the value of securities that are purchased on margin may require you to provide additional funds to the firm that has made the loan to avoid the forced sale of those securities or other securities or assets in your account(s).

• The firm can force the sale of securities or other assets in your account(s). If the equity in your account falls below the maintenance margin requirements or the firms higher “house” requirements, the firm can sell the securities or other assets in any of your accounts held at the firm to cover the margin deficiency. You also will be responsible for any short fall in the account after such a sale.

• The firm can sell your securities or other assets without contacting you. Some investors mistakenly believe that a firm must contact them for a margin call to be valid, and that the firm cannot liquidate securities or other assets in their accounts to meet the call unless the firm has contacted them first. This is not the case. Most firms will attempt to notify their customers of margin calls, but they are not required to do so. However, even if a firm has contacted a customer and provided a specific date by which the customer can meet a margin call, the firm can still take necessary steps to protect its financial interests, including immediately selling the securities without notice to the customer.
   

• You are not entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call. Because the securities are collateral for the margin loan, the firm has the right to decide which security to sell in order to protect its interests.

• The firm can increase its “house” maintenance margin requirements at any time and is not required to provide you advance written notice. These changes in firm policy often take effect immediately and may result in the issuance of a maintenance margin call. Your failure to satisfy the call may cause the member to liquidate or sell securities in your account(s).

• Your are not entitled to an extension of time on a margin call. While an extension of time to meet margin requirements may be available to customers under certain conditions, a customer does not have a right to the extension.

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Customer Identification

Anti-Money Laundering
 
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.
 
 What this means for you: When you open 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 or other identifying documents.

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Remuneration Statement

In a manner consistent with Ladenburg Thalmann’s obligation to provide best execution of all customer orders, we may direct orders to an exchange or market maker that matches or improves the then-current national best bid or offer for the particular stock. Ladenburg Thalmann & Co. Inc. receives remuneration in the form of payments for directing orders to certain broker/dealers for execution.

Such remuneration is considered to be compensation to Ladenburg Thalmann & Co. Inc. The source and amount of any compensation received in connection with specific transaction and any additional information concerning order flow payment will be disclosed upon written request.

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Best Execution

Order Execution Information
SEC Rule 11Ac1-5 under the Securities Exchange Act of 1934 requires market centers that trade national market system securities to prepare and make publicly available monthly electronic reports relating to the execution quality of their orders. Monthly public disclosures that categorize Ladenburg’s order executions and statistical measures of customer execution quality can be viewed at: www.ladenburg.com/trading.asp and click on the SEC Rule 11Ac1-5 Statistic Lookup button located on that page. Specific information regarding a particular transaction can be provided upon request.

Order Routing Information
SEC Rule 11Ac1-6 under the Securities Exchange Act of 1934 requires every broker-dealer to make publicly available, on a quarterly basis, a report on its routing of non-directed orders in covered securities during that quarter. Quarterly reports that disclose the executing venues for routed orders can be viewed at: www.ladenburg.com/trading.asp and click on SEC Rule 11Ac1-6 Statistic Lookup button located on that page. Specific information regarding a particular transaction can be provided upon request. If you have any questions or concerns, please contact Ladenburg at 800.523.8425 and request to speak with a Compliance representative.

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Complaints Inquiries

Should you have any questions or concerns regarding your  account that you wish to discuss with someone other than your Financial Consultant, please contact the Branch Office Manager of the office that services your account at the address and phone number listed on your statement.  You may also contact the Compliance Department at 1-800-523-8425.

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