Disclosure

du Pasquier is regulated by the following authorities:
http://www.finra.org
http://www.sec.gov
http://www.msrb.org
http://www.sipc.org

Payment For Order Flow Disclosure

The Securities and Exchange Commission requires all registered broker-dealers to disclose their policies regarding their receipt of "payment for order flow." The commission defines "payment for order flow" as "any monetary payments, services, property, or other benefits that result in remuneration, compensation, or consideration to a broker or dealer from any broker or dealer, national securities exchange, registered securities association or exchange member in return for the routing of customer orders by such broker or dealer to any broker or dealer, national securities exchange, registered securities association, or exchange member for execution, including but not limited to research, clearance, custody, products or services, reciprocal agreements for the provision of order flow adjustment of a broker or dealer's unfavorable trading errors, effort to participate as underwriter in public offerings; stock loans or shared interest accrued thereon; discounts, rebates, or any other reductions of or credits against any fee to, or expense or other financial obligation of, the broker or dealer routing a customer order that exceeds that fee, expense or other financial obligation. Pershing LLC and/or, if Pershing is acting as the clearing broker, du Pasquier & Company ("du Pasquier"), receive payment for order flow from third party maker execution firms. Typically, these payments may take the form of rebates, volume discounts, reciprocal agreements to provide order flow and monetary compensation based upon the profitability, if any, of such order flow, to the particular specialist or market maker. When such remuneration is received, it is considered compensation to the receiving firm. The source and amount of any compensation received will be disclosed upon request.

Pershing and/or du Pasquier, if Pershing is acting as the clearing broker, route orders to different marketplaces in a manner consistent with the obligation to try and provide the best execution of all customer orders. Toward this end, when a customer does not specify a particular marketplace in which an order must be executed, that order is routed to an exchange or market maker that matches or improves on the then-current national best bid or offer for that particular security or option contract.

Order Routing

du Pasquier & Co. has prepared this report pursuant to SEC Rule 606 requiring all brokerage firms to make publicly available quarterly reports on their order routing practices. The report provides information on the routing of "non-directed orders"--any order that the customer has not specifically instructed to be routed to a particular venue for execution. For these non-directed orders, du Pasquier & Co. has deferred to its clearing firm, Pershing, to select the execution venue on behalf of its customers. Order routing determinations are set mainly using the following criteria: quality of execution, timeliness of execution, and service requirements of the firm. The quarterly report for Pershing is available through www.orderroutingdisclosure.com. A written copy of all reports will be furnished to you on request by contacting the Compliance Department. Customers are free to designate a different execution venue at any time. Du Pasquier does not provide any inducements for customers to retain the default execution venue (such as a lower commission rate). Therefore, the orders routed pursuant to the default setting are directed orders and would not be included in the above quarterly reports. Because customers of du Pasquier can readily choose a different default venue other than the initial default venue, and du Pasquier does not charge a higher commission if the customer chooses another venue, orders routed pursuant to the initial default venue are classified as directed orders. In addition, once an order is classified as a directed order, it need not subsequently be reclassified as a non-directed order if the venue to which the customer directed the order is unable to execute the order (for example, due to a systems problem) and the broker-dealer then routes the order elsewhere for execution. This does not relieve du Pasquier of its duty of best execution.

Breakpoint Disclosure Statement

Before investing in mutual funds, it is important that you understand the sales charges, expenses, and management fees that you will be charged, as well as the breakpoint discounts to which you may be entitled. Understanding these charges and breakpoint discounts will assist you in identifying the best investment for your particular needs and may help you reduce the cost of your investment. This disclosure document will give you general background information about these charges and discounts. However, sales charges, expenses, management fees, and breakpoint discounts vary from mutual fund to mutual fund. Therefore, you should discuss these issues with your financial advisor and review each mutual fund's prospectus and statement of additional information, which are available from your financial advisor, to get the specific information regarding the charges and breakpoint discounts associated with a particular mutual fund.

Sales Charges
Investors that purchase mutual funds must make certain choices, including which funds to purchase and which class share is most advantageous. Each mutual fund has a specified investment strategy. You need to consider whether the mutual fund's investment strategy is compatible with your investment objectives. Additionally, most mutual funds offer different share classes. Although each share class represents a similar interest in the mutual fund's portfolio, the mutual fund will charge you different fees and expenses depending upon your choice of share class. As a general rule, Class A shares carry a "front-end" sales charge or "load" that is deducted from your investment at the time you buy fund shares. This sales charge is a percentage of your total purchase. As explained below, many mutual funds offer volume discounts to the front-end sales charge assessed on Class A shares at certain pre-determined levels of investment, which are called "breakpoint discounts." In contrast, Class B and C shares usually do not carry any front-end sales charges. Instead, investors that purchase Class B or C shares pay asset-based sales charges, which may be higher than the charges associated with Class A shares. Investors that purchase Class B and C shares may also be required to pay a sales charge known as a contingent deferred sales charge when they sell their shares, depending upon the rules of the particular mutual fund.

Breakpoint Discounts
Most mutual funds offer investors a variety of ways to qualify for breakpoint discounts on the sales charge associated with the purchase of Class A shares. In general, most mutual funds provide breakpoint discounts to investors who make large purchases at one time. The extent of the discount depends upon the size of the purchase. Generally, as the amount of the purchase increases, the percentage used to determine the sales load decreases. In fact, the entire sales charge may be waived for investors that make very large purchases of Class A shares. Mutual fund prospectuses contain tables that illustrate the available breakpoint discounts and the investment levels at which breakpoint discounts apply. Additionally, most mutual funds allow investors to qualify for breakpoint discounts based upon current holdings from prior purchases through "Rights of Accumulation," and future purchases, based upon "Letters of Intent." This document provides general information regarding Rights of Accumulation and Letters of Intent. However, mutual funds have different rules regarding the availability of Rights of Accumulation and Letters of Intent. Therefore, you should discuss these issues with your financial advisor and review the mutual fund prospectus to determine the specific terms upon which a mutual fund offers Rights of Accumulation or Letters of Intent.

Rights of Accumulation - Many mutual funds allow investors to count the value of previous purchases of the same fund, or another fund within the same fund family, with the value of the current purchase, to qualify for breakpoint discounts. Moreover, mutual funds allow investors to count existing holdings in multiple accounts, such as IRAs or accounts at other broker-dealers, to qualify for breakpoint discounts. Therefore, if you have accounts at other broker-dealers and wish to take advantage of the balances in these accounts to qualify for a breakpoint discount, you must advise your financial advisor about those balances. You may need to provide documentation establishing the holdings in those other accounts to your financial advisor if you wish to rely upon balances in accounts at another firm.

In addition, many mutual funds allows investors to count the value of holdings in accounts of certain related parties, such as spouses or children, to qualify for breakpoint discounts. Each mutual fund has different rules that govern when relatives may rely upon each other's holdings to qualify for breakpoint discounts. You should consult with your financial advisor or review the mutual fund's prospectus or statement of additional information to determine what these rules are for the fund family in which you are investing. If you wish to rely upon the holdings of related parties to qualify for a breakpoint discount, you should advise your financial advisor about these accounts. You may need to provide documentation to your financial advisor if you wish to rely upon balances in accounts at another firm.

Mutual funds also follow different rules to determine the value of existing holdings. Some funds use the current net asset value (NAV) of existing investments in determining whether an investor qualifies for a breakpoint discount. However, a small number of funds use the historical cost, which is the cost of the initial purchase, to determine eligibility for breakpoint discounts. If the mutual fund uses historical costs, you may need to provide account records, such as confirmation statements or monthly statements, to qualify for a breakpoint discount based upon previous purchases. You should consult with your financial advisor and review the mutual fund's prospectus to determine whether the mutual fund uses either NAV or historical costs to determine breakpoint eligibility.

Letters of Intent - Most mutual funds allow investors to qualify for breakpoint discounts by signing a Letter of Intent, which commits the investor to purchasing a specified amount of Class A shares within a defined period of time, usually 13 months. For example, if an investor plans to purchase $50,000 worth of Class A shares over a period of 13 months, but each individual purchase would not qualify for a breakpoint discount, the investor could sign a Letter of Intent at the time of the first purchase and receive the breakpoint discount associated with $50,000 investments on the first and all subsequent purchases. Additionally, some funds offer retroactive Letters of Intent that allow investors to rely upon purchases in the recent past to qualify for a breakpoint discount. However, if an investor fails to invest the amount required by the Letter of Intent, the fund is entitled to retroactively deduct the correct sales charges based upon the amount that the investor actually invested. If you intend to make several purchases within a 13 month period, you should consult your financial advisor and the mutual fund prospectus to determine if it would be beneficial for you to sign a Letter of Intent.

As you can see, understanding the availability of breakpoint discounts is important because it may allow you to purchase Class A shares at a lower price. The availability of breakpoint discounts may save you money and may also affect your decision regarding the appropriate share class in which to invest. Therefore, you should discuss the availability of breakpoint discounts with your financial advisor and carefully review the mutual fund prospectus and its statement of additional information, which you can get from your financial advisor, when choosing among the share classes offered by a mutual fund. If you wish to learn more about mutual fund share classes or mutual fund breakpoints, you may wish to review the investor alerts available on the FINRA Web site, and or visit the many mutual fund Web sites available to the public.

du Pasquier & Co., Inc Business Continuity Plan (BCP) - Disclosure

du Pasquier & Co, Inc. has developed a Business Continuity Plan (BCP) on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our BCP.

Contacting Us - If after a significant business disruption you cannot contact us as you usually do at (212) 624-4100 or (646) 367-6384 / dupasquier@dupasco.com, you should call our alternative number, (800) 443-4342 (Pershing Disaster Recovery), or go to our web site at www.dupasco.com . If you cannot access us through either of those means, you should contact our clearing firm, Pershing at (201) 413-2000 and www.pershing.com for instructions on how it may provide assistance.

Our Business Continuity Plan - We plan to quickly recover and resume business operations after a significant disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firm, Pershing, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, our clearing firm has advised us that its objective is to restore its own operations and be able to complete existing transactions and payments within the quickest time possible. Your orders and requests for funds and securities could be delayed during this time period.

Varying Disruptions - Significant business disruptions can vary in their own scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within the quickest time possible. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within the quickest time possible. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site, www.dupasco.com or our customer emergency number, (800) 443-4342, how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer's prompt access to their funds and securities.

For more information - If you have questions about our business continuity planning, you can contact us at (212) 624-4100 or dupasquier@dupasco.com.

MARGIN DISCLOSURE STATEMENT

Your securities brokerage firm (your introducing securities broker dealer and/or your introducing securities broker dealer's clearing 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 introducing securities broker dealer and/or your introducing securities broker dealer's clearing firm. Consult your introducing securities broker dealer 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 introducing securities broker dealer's clearing firm (the lender of margin funds is the clearing firm rather than the introducing firm). If you choose to borrow funds, you will open a margin account. The securities purchased are collateral for the loan to you (the collateral is for the benefit of your introducing securities broker dealer and your introducing securities broker dealer's clearing firm). If the securities in your account decline in value, so does the value of the collateral supporting your loan and, as a result, your introducing securities broker dealer and/or your introducing securities broker dealer's clearing 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 introducing securities broker dealer and/or your introducing securities broker dealer's clearing 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 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).
  • Your introducing securities broker dealer and/or your introducing securities broker dealer's clearing 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 either firm's higher "house" requirements, either firm can sell the securities or other assets in any of your accounts held at either firm to cover the margin deficiency. You also will be responsible for any short fall in the account after such a sale.
  • Your introducing securities broker dealer and/or your introducing securities broker dealer's clearing 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 introducing and clearing firms will attempt to notify 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, either the introducing or the clearing firm has the right to decide which security or securities to sell in order to protect its interests.
  • Your introducing securities broker dealer and/or your introducing securities broker dealer's 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 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.