Important Information

Margin Disclosure Statement
Business Continuity Plan
Use of IP Addresses
Privacy Policy
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
Disclosure of Order Routing Information (SEC) Rule 11Ac1-6
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:

• 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 firm's higher "house" requirements, the firm can sell the securities or other assets in any of your account 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).
  
  
• You 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.

Business Continuity Plan

Detwiler Fenton & Company ("DMFG") 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. DMFG 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:

• Data back-up and recovery (hard copy and electronic)
• All mission critical systems
• Financial and operational assessments
• Alternate communications between customers and the member
• Alternate communications between the member and its employees
• Alternate physical location of employees
• Critical business constituents, banks, and counter-party impact
• Regulatory reporting
• Communications with regulators
• How the member will assure customers’ prompt access to their funds and securities in the event that the member determines that it is unable to continue its business

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

The BCP of DMFG anticipates two kinds of Significant Business Disruptions; internal significant business disruptions ("ISBDs") and external Significant Business Disruptions ("ESBDs"). ISBDs affect only DMFG’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. DMFG’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. DMFG’s policy is to respond to a Significant Business Disruption by safeguarding employees’ lives and DMFG property, making financial and operational assessments, quickly recovering and resuming operations, protecting all of DMFG’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.

DMFG 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. DMFG 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.dmcos.com or send an email to info@dmcos.com.

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.

Privacy Policy

When clients choose to invest their money with us, they not only entrust us with their investments, but also trust us with personal information and financial data. We are committed to protecting our clients’ privacy regarding the information disclosed to us.
In order to provide investment products and services that best suit our clients’ needs, we may collect nonpublic personal information in the following ways:

• Information provided by the client or his/her representative on applications, forms, letters, emails, or telephone
• Information arising from clients’ investments with us.

We do not disclose any nonpublic personal information about our clients to nonaffiliated third parties except as permitted by law. In order to service individual accounts and process transactions that are requested or authorized, we may provide a client’s nonpublic personal information to companies that perform administrative or other services for us on his or her behalf, such as a mutual fund company or a clearing firm. We require these outside companies to protect the confidentiality of all clients’ information and to use the information only for the purpose for which the disclosure is made.

We employ physical, electronic, and procedural controls in keeping with industry standards and practices. Our clients’ personal and account information is available only to authorized personnel who need that information in order to provide products or services to the clients. Our web server will log a client’s Internet Protocol (IP) address or the IP address of his or her proxy server. It will not systematically track a domain name or email address for any purpose. We currently do not use "cookie" technology on this site with the exception of our Client Login page.

When an account is closed, we will adhere to the privacy policies and practices as described in this notice and will secure an individual’s private information.

Analyst Certification

The authors of Detwiler Fenton & Company & Inc.’s 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.

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.

Disclaimer of Warranty and Limitation of Liability

The information on this site is provided "as is." Detwiler, Mitchell & Co., Inc. (DMC) 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. DMC 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, DMC cannot and does not guarantee the accuracy, validity, timeliness, or completeness of any information or data made available for any particular purpose. Neither DMC, 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 DMC or of any vendor providing software or services support. In no event will DMC, 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 DMC or any other party has been advised of the possibility thereof.

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.

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.

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 www.finra.org.

The Securities and Exchange Commission (SEC) website (www.sec.gov) contains additional information for investors on numerous subjects.

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.

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

Click here for the current order-routing information.

Executing Client Orders

We transmit client orders for execution to various exchanges or market centers based on a number of factors, including:
• Size of order
• Trading characteristics of the security
• Favorable execution price (including the opportunity for price improvement)
• Access to reliable market data
• Access to efficient automated transaction processing, and
• Reduced execution costs through price concessions from the market centers.

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.

Massachusetts Investment Adviser

DMFG 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 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.

Annual Investment Adviser Disclosure

DMFG updates its Form ADV Part I & Part II no less than annually. The ADV Part I is available to the public online at 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 info@dmcos.com or by writing to:

Compliance Department
150 Federal Street, 28th Floor
Boston, MA 02110