ANNUAL DISCLOSURES

1. Privacy Policy Highlights
The firm understands your Privacy is important. We have posted this notice in accordance with applicable state and federal laws and because you are a current or potential customer of the firm. This notice will help you understand what types of nonpublic personal information - information about you that is not publicly available - we may collect, how we use it and how we protect your privacy.
·  We collect nonpublic personal information to process and administer our customers' business and to ensure that we are satisfying their financial needs. We have policies and procedures in place to protect nonpublic personal information about our customers. We do not sell nonpublic personal information about our customers to third parties, i.e., companies or individuals that are not affiliated with ACE Securities, Inc. We do not disclose any nonpublic personal information about our customers to anyone, except as permitted by law. We do not share or use personally identifiable health information for marketing purposes. Our Privacy Policy applies to both current and former customers.

Questions and Answers that detail the Firm's. Privacy Policy
·  Q: What types of nonpublic personal information does the firm collect?
·  A: The firm, its employees, representatives, agents and selected third parties may collect nonpublic personal information about our customers, including:
o Information provided to us, such as on applications or other forms.
o Information about transactions with us, our affiliates or third parties.
o Information from others, such as credit reporting agencies, employers and federal and state agencies.
The types of nonpublic personal information the firm collects vary according to the products or services provided and may include, for example: account balances, income, assets, insurance premiums, credit reports, marital status and payment history.
·  Q: What does the firm do to protect nonpublic personal information?
·  A: We restrict access to nonpublic personal information to those employees, agents representatives or third parties who need to know the information to provide products and services to our customers. We have policies and procedures that give direction to our employees, and agents and representatives acting on our behalf, regarding how to protect and use nonpublic personal information. We maintain physical information and procedural safeguards to protect nonpublic personal information.
·  Q: With whom does the firm share nonpublic personal information, and why?
·  A: We do not share nonpublic personal information about our customers with anyone, including other affiliated companies or third parties, except as permitted by law. We may disclose, as allowed by law, all types of nonpublic personal information we collect when needed, to affiliated companies, agents, employees, representatives and third parties that market our services and products and administer and service customer accounts on our behalf; or other financial institutions with whom we have joint marketing agreements. Examples of the types of companies and individuals to whom we may disclose nonpublic personal information include banks, attorneys, trustees, third-party administrators, insurance agents, insurance companies, insurance support organizations, credit reporting agencies, registered broker/dealers, auditors, regulators, transfer agents and reinsures. We do not share personally identifiable health information unless the customer or the applicable law authorizes further sharing.
·  Q: Does the Firm's. Privacy Policy apply to its agents and representatives?
·  A: The Firm's Privacy Policy applies, to the extent required by law, to its agents and representatives when they are acting on behalf of the firm. Please note: There may be instances when these same agents and representatives may not be acting on behalf of the firm, in which case they may collect nonpublic personal information on their own behalf or on behalf of another. In these instances, the Firm's Privacy Policy would not apply.
·  Q: Will the Firm's Privacy Policy change?
·  A: The firm reserves the right to change any of its privacy policies and related procedures at any time, in accordance with applicable federal and state laws. You will receive appropriate notice of our Privacy Policy changes.
·  Opt Out Policy. You may opt-out of the disclosure of non-public personal information to a non-affliated third party by giving us in writing.

2. Payment For Order Flow
This notice provides information about the order routing policies of the firm.
First and foremost, the firm's order routing decisions are based on overriding principle of best execution.  Currently the firm has deemed it appropriate not to accept compensation or non-cash remuneration credits towards expenses charged by market centers or reciprocal business arrangements involving the firm's stock layoff business and specialist units.
The firm routes most of its orders for listed equities and over-the-counter equities to established market participants and clears all trades through its clearing firm on fully disclosed basis. Trades executed through the firm, both on listed and unlisted stocks may have the opportunity for price improvements (execution at prices superior to the displayed national best bid or offer).

3. Rule 11ac1-6 (Report on Routing of Customer Orders), Rule 11ac1-5 (Report on order execution quality) Pursuant to SEC Rule 11ac1-6, the firm's. report can be found at the following URL: www.acediversifiedcapital.com.
Due to our firm is using Wedbush Morgan Securities as our clearing firm,you can also view their website in regard this
Information at the following website,www.wedbush.com.

4. NASD Rule 2341 - Margin Disclosure Statement
The 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 the firm. Consult the 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 the firm's clearing firm. If you choose to borrow funds from us, you will open a margin account with the firm. The securities purchased are the firm's collateral (along with its clearing firm) 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 or its clearing firm can take action, such as issue a margin call and/or sell in ANY of your accounts held with the firm, 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 additional funds to the firm and/or its clearing firm which has made the loan to avoid the forced sale of those securities or other securities in your account(s).
·  The firm and/or its clearing firm can force the sale of securities in your account(s). If the equity in your account falls below the maintenance margin requirements of the firm's higher "house" requirements, the firm can sell the securities in any of your accounts held at the firm to cover the margin deficiency. You will also be responsible for nay shortfall in the account after such a sale.
·  The firm and/or its clearing firm can sell your securities 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 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 interest, including immediately selling the securities without notice to the customer.
·  You are not entitled to choose which securities in your account(s) are liquidated or sold to meet a margin call. Because the securities are collateral for the margin loan, the firm and/or its clearing firm has the right to decide which security to sell in order to protect its interests.
·  The firm and/or its clearing 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 Brahman and/or its clearing firm to liquidate or sell securities in your accounts.
·  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.

THIS NOTICE IS PROVIDED TO YOU FOR INFORMATIONAL PURPOSES ONLY. YOU DO NOT NEED TO CALL OR TAKE ANY ACTION IN RESPONSE TO THIS NOTICE. WE RECOMMEND THAT YOU READ AND RETAIN THIS NOTICE FOR YOUR PERSONAL FILES.

 
 
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