Payment for Order Flow

Securities and Exchange Commission (SEC) Rule 11Ac1-3 requires that all broker/dealers notify their customers of their payment for order flow (POF) practices on an annual basis. All registered broker/dealer firms, including those firms that do not participate in POF practices, must make an annual disclosure to their customers. Nationwide Planning Associates, Inc. does not receive compensation for order flow. Pershing sends certain equity orders to exchanges, Electronic Communication Networks, or broker/dealers during normal business hours and during extended trading sessions. Certain of these venues provide payments to Pershing or charge access fees to Pershing depending upon the characteristics of the order and any subsequent execution. These include size of order; trading characteristics of the security; favorable execution prices (including the opportunity for price improvement); access to reliable market data; availability of efficient, automated transaction processing; and reduced execution costs through price concessions from the market centers. The details of these payments and fees are available upon written request. Certain of the market centers may execute orders at prices superior to the publicly quoted market in accordance with their rules or practices. While a client may specify that an order be directed to a particular market center for execution, the order routing policies, taking into consideration all of the factors listed above, are designed to result in favorable transaction processing for clients.

Note: Trades placed through telephone, electronic, or online trading systems cannot specify a particular market center for execution.