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Margin Disclosure Statement

Business Continuity Plan

Use of IP Addresses

Analyst Certification

Legal Disclaimer

Disclaimer of Warranty and Limitation of Liability

Copyright or Other Notices

Use of Links

Investor Information

Customer Identification Program

Order Routing Policies and Inducements for Order Flow

Executing Your Orders

Masschusetts Investment Advisory Disclosure

Annual Investment Advisory Disclosure




Margin Disclosure Statement

Your brokerage firm is furnishing this document to you to provide some basic facts about purchasing securities on margin, and 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 firm's 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 or 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:
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Business Continuity Plan

Detwiler Fenton & Co. (DFC) has prepared and implemented a Business Continuity Plan ("BCP") in accordance with the NASD's optional guide to small introducing firms regarding the requirement to create and maintain a business continuity plan and emergency contact person lists under FINRA Rules 3510 and 3520.

There are 10 critical elements of a BCP specified in FINRA Rule 3510. DFC has addressed each element and its applicability to its business. There are no elements which management has not included a specified response. The components to the response include the following sections:

The above-listed 10 elements are not exhaustive. DFC has addressed other key areas included in its BCP for it to be complete and thorough, based on DFC's business and operations.

The BCP of DFC anticipates two kinds of Significant Business Disruptions; internal significant business disruptions ("ISBDs") and external Significant Business Disruptions ("ESBDs"). ISBDs affect only DFC's ability to communicate and do business such as a fire in our building or a disruption in electricity or phone services in our building. In such cases, the San Diego office would handle all client requests and arrange communications between the client and their respective registered representatives. ESBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale regional disruption. DFC's response to an ESBD relies heavily on other organizations and systems, and primarily on the capabilities of our clearing firm, National Financial Services, and their BCP execution. DFC's policy is to respond to a Significant Business Disruption by safeguarding employees' lives and DFC property, making financial and operational assessments, quickly recovering and resuming operations, protecting all of DFC's books and records, and allowing its customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers' prompt access to their funds and securities.

DFC maintains backups of critical systems in its Boston office and redundant computer systems in a server hosting facility located in California. The San Diego office keeps electronic backups of its limited computer systems in the Boston office. All mission critical systems are internet accessible and any Significant Business Disruption should not disrupt the access to such systems through any connection to the internet. DFC also clears its securities transactions through National Financial Services ("NFS"). NFS is contractually obligated to maintain a business continuity plan and ensure the capacity to execute that plan. NFS represents that it backs up our records at a remote, out of region site and it operates other back-up operating facilities in a geographically separate area with the capability to conduct the same volume of business as its primary site. NFS has also confirmed the effectiveness of its back-up arrangements to recover from a wide scale disruption by testing, and NFS has confirmed that it tests its back-up arrangements on a regular basis twice yearly. NFS represents that it will advise us of any material changes to its plan that might affect our ability to maintain our business.

The entire Business Continuity Plan is kept at both the Boston and San Diego offices as well as at every branch office and at the private residences of all BCP Committee members. A copy of this summary will be presented to all clients upon the opening of a new account. If after a significant business disruption you cannot contact us as you usually do at (800)950-2400, you should call our alternative number (800)248-4580 (San Diego Office), our Meriden Branch Office at (800)766-6960, go to our website at http://www.detwilerfenton.com or contact us via Information.
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Use of IP Addresses

We do log user IP addresses. IP addresses are saved in the web server's site log and are used only for authentication.
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Analyst Certification

The authors of Detwiler Fenton & Co. research certify that the views expressed in research comments, reports, and emails accurately reflect their own personal views about the securities mentioned and are based on sources believed to be reliable. No part of an analyst's compensation was, is, or will be directly related to the specific views contained in research comments, reports, and/or emails. A portion of an analyst's compensation is from a deferred bonus pool, which is derived from transactional-based revenues.
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Legal Disclaimer

The information provided on this site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Detwiler Fenton & Co.(DMC) or its affiliates to any registration requirement within such jurisdiction or country. Neither the information nor any opinion contained in this site constitutes a solicitation or offer by DMC or its affiliates to buy or sell securities, futures, options, or other financial instruments or provide any investment advice or service.
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Disclaimer of Warranty and Limitation of Liability

The information on this site is provided "as is." Detwiler Fenton & Co. does not warrant the accuracy of the materials provided herein, either expressly or impliedly, for any particular purpose and expressly disclaims any warranties of merchantability or fitness for a particular purpose. Detwiler Fenton & Co. will not be responsible for any loss or damage that could result from interception by third parties of any information made available via this site. Although the information provided on this site is obtained or compiled from sources we believe to be reliable, Detwiler Fenton & Co. cannot and does not guarantee the accuracy, validity, timeliness, or completeness of any information or data made available for any particular purpose. Neither Detwiler Fenton & Co., nor any of its affiliates, directors, officers, or employees, nor any third-party vendor will be liable or have any responsibility of any kind for any loss or damage incurred in the event of any failure or interruption of this site, or resulting from the act or omission of any other party involved in making this site or the data contained therein available, or from any other cause relating to access to, inability to access, or use of the site or these materials, whether or not the circumstances giving rise to such cause may have been within the control of Detwiler Fenton & Co. or of any vendor providing software or services support. In no event will Detwiler Fenton & Co., its affiliates, or any such parties be liable for any direct, special, indirect, consequential, incidental damages, or any other damages of any kind even if Detwiler Fenton & Co. or any other party has been advised of the possibility thereof.
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Copyright or Other Notices

Downloading information or software from this site binds the user to agree not to copy it or to remove or obscure any copyright or other notices or legends contained in any such information.
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Use of Links

Users who leave this site via a link contained herein and view content that is not provided by DMC do so at their own risk. Such linked content will not have been developed, checked for accuracy, or otherwise reviewed by DMC. DMC is not responsible for damages or losses caused by any delays, defects, or omissions that may exist in the services, information, or other content provided in such site, whether actual, alleged, consequential, or punitive. DMC makes no guarantees or representations as to, and shall have no liability for, any electronic content delivered by any third party including, without limitation, the accuracy, subject matter, quality, or timeliness of any electronic content.
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Investor Information

FINRA sponsors an Investor Education and Protection Program. A brochure is available through FINRA that includes information describing the Public Disclosure Program. The program has been designed to make available to the public background information, including all reportable criminal convictions and dismissed indictments, final disciplinary actions taken by the FINRA or any other securities self-regulatory organization and state and federal regulators, pending FINRA and other SRO disciplinary actions, dismissed FINRA complaints, arbitration decisions, and civil judgments in securities or commodities disputes. Information is free to private investors for personal use; inquiries for professional purposes will be delivered for a fee.

For more information, please call FINRA at their toll-free number, 1-800-289-9999, or visit http://www.finra.org. The Securities and Exchange Commission (SEC) website ( http://www.sec.gov ) contains additional information for investors on numerous subjects.
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Customer Identification Program

To help the government fight the funding of terrorism and money-laundering activities, and to verify a client's identity, federal law requires National Financial Services (NFS) and DMC to obtain client name, date of birth, address, and a government-issued identification number before opening an account. In certain circumstances, NFS and/or DMC may obtain and verify this information with respect to any person(s) authorized to effect transactions in an account. For certain entities, such as trusts, estates, corporations, partnerships, or other organizations, identifying documentation is also required. An account may be restricted and/or closed if NFS or DMC cannot verify this information. NFS and/or DMC will not be responsible for any losses or damages (including, but not limited to, lost opportunities) resulting from any failure to provide this information, or from any restriction placed on, or closing of, an account.
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Order Routing Policies and Inducements for Order Flow

The Securities and Exchange Commission requires that we notify clients in writing of policies regarding inducements for order flow as well as policies for determining where orders subject to inducements for order flow are routed. Certain market centers offer inducements to brokerage firms to route customer orders to such markets centers for execution. Payment for order flow is defined as any monetary or nonmonetary compensation, remuneration, or consideration to a broker/dealer in return for routing customer orders to a particular market or dealer. Payments would include research, clearance, products or services, or reciprocal order swapping arrangements. Payments would also include credits, rebates, or discounts against execution fees that exceed the fees charged for executing the order.

Disclosure of Order-Routing Information (SEC) Rule 11Ac1-6

Current Order Routing information
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Executing Your Orders

We transmit client orders for execution to various exchanges or market centers based on a number of factors, including:
Certain market centers may execute orders at prices superior to the publicly quoted market, in accordance with their rules or practices. While clients may specify that an order be directed to a particular market center for execution, our order-routing policies take into consideration all of the above factors and are designed to result in favorable transaction processing for the client.
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Masschusetts Investment Advisory Disclosure

Detwiler Fenton & Co. also operates as an Investment Adviser in various states. Massachusetts law (Sec. 203A) requires disclosure that information on disciplinary history and the registration of the Adviser and its associated persons may be obtained by contacting the Public Reference Branch of the U.S. Securities and Exchange Commission at (202) 942-8090 or through its Public Disclosure Program website at http://www.adviserinfo.sec.gov or through FINRA at http://www.finra.org/InvestorInformation/InvestorProtection/p005882 (see BrokerCheck) or by contacting:

Massachusetts Securities Division
One Ashburton Place, 17th Floor
Boston, Massachusetts 02108
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Annual Investment Advisory Disclosure

Detwiler Fenton & Co. updates its Form ADV Part I & Part II no less than annually. The ADV Part I is available to the public online at http://www.adviserinfo.sec.gov. Part II and Schedule F of Part II of Form ADV are available to the public by sending an email to Information or by writing to:

Compliance Department
100 High Street, Suite 2800
Boston, MA 02110
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