Disclosures

B. Riley Securities Legal Disclosures

In accordance with the regulations set forth by the USA PATRIOT Act, the Bank Secrecy Act (BSA) and the rules of the Office of Foreign Assets Control (OFAC), the Financial Crimes Enforcement Network (FinCEN), the U.S. Securities Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA), B. Riley Securities has in place a program to identify and report suspicious activities that could be related to money laundering or other illegal activities and to monitor and verify the identities of our customers. What this means for you: When you open an account, we may ask for your corporate formation documents or other information that will allow us to positively identify you/your entity. We may also ask to see your driver's license or other identifying documents. B. Riley Securities reserves the right to refuse to open any account, or close an existing account, at any time if information requested pursuant to an AML inquiry is refused.

Subject to applicable regulatory requirements, B. Riley Securities may execute your order in more than one transaction over a period of time, or, in certain markets, aggregate your order with other orders. In such instances, B. Riley Securities will provide you with a confirmation noting the aggregate amount of securities purchased or sold in your account at a single "average price". B. Riley Securities will provide you with information about the individual executions at your request without charge. Please notify your sales representative at the time you place your order if you do not want your order to be reported to you at a single average price. Should you elect this option, you will receive a confirmation for each individual execution.

B. Riley Securities provides you with access to the Bank Deposit Sweep Program ("BDSP") which is a core account investment vehicle used to hold a cash balance that is awaiting initial investment or reinvestment. If you choose to participate, cash balances in your account will be automatically swept into interest-bearing deposit accounts at one or more federally insured banking institutions that participate in B. Riley Security's BDSP. All deposits held at each bank will be eligible to be insured by the Federal Deposit Insurance Corporation (the "FDIC") generally up to a total of $250,000 principal and accrued interest per depositor. For more information about this program and a complete list of disclosures, please contact the Compliance Department.

B. Riley Securities seeks to execute its customers' orders at the most favorable terms reasonably available under prevailing market conditions. B. Riley Securities is responsible for overseeing the selection of the best market for each trade and for ensuring that the customer receives the best price. Details regarding our routing of U.S. equity and option orders are made publicly available, at no cost to you, on a quarterly basis. Please refer to the section entitled "SEC Rule 606: Quarterly Report on Routing of Customer Orders" for more information. B. Riley Securities conducts regular reviews to ensure that clients are getting the best executions on trades.

B. Riley Securities, Inc. ("B. Riley Securities") has a business continuity plan to protect the interests of our clients, shareholders and employees, and to facilitate the recovery of our core businesses in the event of a significant business interruption. The plan outlines core functions and the resources required to conduct them. It also details what we plan to do to recover them in the event of a disaster that affects our ability to function at our main locations. Our business continuity plan addresses: data backup and recovery; mission critical systems; financial and operational assessments; alternative communications with customers, employees and regulators; alternate physical locations of employees; critical supplier, contractor, bank and counter-party impacts; regulatory reporting; and customer assurance of prompt access to funds and securities if B. Riley Securities becomes unable to continue its business. B. Riley Securities is an introducing firm and does not perform its own or others' clearing functions. We do not hold customer's securities or funds. B. Riley Securities employs National Financial Services LLC ("NFS") as the clearing agent for its broker-dealer operations. In this capacity, NFS compares, allocates, clears and settles all B. Riley Securities transactions. NFS maintains our customers' accounts, and in the event of disaster, can grant customers access to them to deliver securities and funds. NFS has implemented a business continuity plan whose primary objectives are to meet the needs of customers. Each NFS department has developed the capabilities to recover both operations and systems. All continuity plans are designed to account for disruptions of various lengths and scopes, and to ensure that critical functions are recovered to meet their business objectives. Critical business groups operate from multiple sites. Dedicated teams within our technology organizations ensure that critical applications and data have sufficient redundancy and availability to minimize the impact of an event. In the event of a significant business interruption that prevents us from remaining in business, we will assure our customers' prompt access to any funds and securities custodied by our clearing agent. In such a catastrophic event, clients are directed to call NFS at (800) 801-9942 to inquire about their holdings and/or place orders. We intend to communicate with customers about the status of our disruptions through our website or by means of telephonic recordings.

Personal checks and wire transfers are the only form of monetary deposits that will be accepted into your account. All incoming checks or wires from third parties must be confirmed with the client at the time of deposit to determine the business reason behind the third-party deposit. B. Riley Securities reserves the right to refuse any deposit.

If you have granted discretionary trading over your account to a third party, you can revoke such discretionary authority for any of your accounts at any time. Should you wish to cancel such discretionary handling of your account, please contact the Compliance Department as listed above.

By transacting with B. Riley Securities, you consent to a pre-dispute arbitration clause in which you agree as follows:

  1. All parties have given up the right to sue each other in court, including the right to a trial by jury, except as provided by the rules of the arbitration forum in which a claim is filed.
  2. Arbitration awards are generally final and binding; a party's ability to have a court reverse or modify an arbitration award is very limited.
  3. The ability of the parties to obtain documents, witness statements, and other discovery is generally more limited in arbitration than in court proceedings.
  4. The arbitrators do not have to explain the reason(s) for their award unless, in an eligible case, a joint request for an explained decision has been submitted by all parties to the panel at least 20 days prior to the first scheduled hearing date.
  5. The panel of arbitrators will typically include a minority of arbitrators who were or are affiliated with the securities industry.
  6. The rules of some arbitration forums may impose time limits for bringing a claim in arbitration. In some cases, a claim that is ineligible for arbitration may be brought in court.
  7. The rules of the arbitration forum in which the claim is filed, and any amendments thereto, have been incorporated into this agreement.

All controversies that may arise between you, B. Riley Securities and NFS, concerning any subject matter, issue or circumstance whatsoever (including, but not limited to, controversies concerning any account, order or transaction, or the continuation, performance, interpretation or breach of this or any other agreement between you, B. Riley Securities and NFS whether entered into or arising before, on or after the date this account is opened) shall be determined by arbitration in accordance with the rules then prevailing of FINRA or any United States securities self-regulatory organization or United States securities exchange of which the person, entity or entities against whom the claim is made is a member, as you may designate. If you designate the rules of a United States self-regulatory organization or United States securities exchange and those rules fail to be applied for any reason, then you shall designate the prevailing rules of any other United States securities self-regulatory organization or United States securities exchange of which the person, entity or entities against whom the claim is made is a member. If you do not notify B. Riley Securities in writing of your designation within five (5) days after such failure or after you receive from B. Riley Securities a written demand for arbitration, then you authorize B. Riley Securities and/or NFS to make such designation on your behalf. The designation of the rules of a United States self-regulatory organization or United States securities exchange is not integral to the underlying agreement to arbitrate. You understand that judgment upon any arbitration award may be entered in any court of competent jurisdiction. No person shall bring a putative or certified class action to arbitration, nor seek to enforce any pre-dispute arbitration agreement against any person who has initiated in court a putative class action; or who is a member of a putative class who has not opted out of the class with respect to any claims encompassed by the putative class action until: (i) the class certification is denied; or (ii) the class is decertified; or (iii) the customer is excluded from the class by the court. Such forbearance to enforce an agreement to arbitrate shall not constitute a waiver of any rights under this agreement except to the extent stated herein.


Monthly account statements and physical trade confirmations for DVP/RVP accounts or master/sub-accounts can be suppressed upon receipt of authorization by the account owner or authorized individual. In order to elect this option, an NFS DVP/RVP Account Statement Mailing Suspension Consent Form is required to be completed, signed and returned to Operations-brs@brileyfin.com. This suspension shall remain in effect until such a time as B. Riley FBR is notified to reinstate the delivery of statements. Any suppressed statements are available to the account owner promptly upon request. For more information or to receive the required form, please email your request to Operations-brs@brileyfin.com.

All trades should be affirmed by the contra firm no later than the settlement date. In the event that a trade is not affirmed or is unknown (commonly called "dk'd" or "don't know"), post-settlement interest charges may be incurred and passed along to you as the customer. In the event that you or your firm is short a position and cannot deliver in a timely fashion, please notify Operations-brs@brileyfin.com. Should a potential buy-in occur we will make every attempt to notify you, the customer, at least 24 hours in advance.

Pursuant to the Securities Exchange Act of 1934 Release No. 36345 (Oct. 1995) and Release No. 37182 (May 1996) and the terms of your customer agreement, you have consented to receive prospectus delivery electronically. Generally, a prospectus will be sent via email with a hyperlink to the actual prospectus included in the body of the email. If you do not consent to the electronic delivery of prospectuses, please notify Operations-brs@brileyfin.com.

Any recommendation contained in any email may not be suitable for all investors. Moreover, although the information contained herein has been obtained from sources believed to be reliable, its accuracy and completeness cannot be guaranteed. B. Riley Securities, Inc. may make markets and effect transactions, including transactions contrary to any recommendation herein, or have positions in the securities mentioned herein (or options with respect thereto) and may also have performed investment banking services for the issuers of such securities. In addition, employees of B. Riley Securities, Inc. may have positions and effect transactions in the securities or options of the issuers mentioned herein and may serve as directors of such issuers. For additional information, contact B. Riley Securities, Inc. at (888) 295-0155. All rights reserved by B. Riley Securities, Inc., Member FINRA & SIPC.

This disclosure is provided to customers who will engage in trading outside normal market hours. Such trading involves certain risks explained below.

  1. Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular market hours. As a result, your order may only be partially executed, or not at all.
  2. Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular market hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price in extended hours trading than you would during regular market hours.
  3. Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular market hours, or upon the opening of the next morning. As a result, you may receive an inferior price in extended hours trading than you would during regular market hours.
  4. Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended-hours system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended-hours trading system than you would in another extended-hours trading system.
  5. Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, it may cause an exaggerated and unsustainable effect on the price of a security.
  6. Risk of Wider Spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.

Risk of Lack of Calculation or Dissemination of Underlying Index Value or Intraday Indicative Value ("IIV"). For certain Derivative Securities Products (such as exchange-traded funds, ETFs), an updated underlying index value or IIV may not be calculated or publicly disseminated in extended trading hours. Since the underlying index value and IIV are not calculated or widely disseminated during the pre-market and post-market sessions, an investor who is unable to calculate implied values for certain Derivative Securities Products in those sessions may be at a disadvantage to market professionals.

Created by FINRA in 1988, and formerly known as the Public Disclosure Program, FINRA BrokerCheck provides investors with an easy, free way to learn about the professional background, business practices, and conduct of FINRA-registered firms and their brokers. To request information under this program, visit the FINRA Web site at http://brokercheck.finra.org, or call (800) 289-9999. Through this internet site or hotline, you can request a public report of background information on FINRA registered firms and their brokers. This report reflects information provided by the broker, the firms, and regulators as part of the securities industry's registration and licensing process. Should you have any complaints or disputes relating to your account please contact ControlRoom@brileyfin.com.

Customers with a minimum of $250,000 in assets in their B. Riley Securities accounts may be eligible to participate in a fully-paid lending program offered by our clearing firm. In a "fully paid" transaction you can lend a specific security to our clearing firm and in return you will receive collateral in the form of cash and securities held at a custodial bank. In addition, you receive an interest rate-based fee. Participation in this program is optional and requires the completion of additional paperwork. Please note that there are risks associated with participation in this program some of which include:

  • Fully-paid securities on loan are not covered under the provisions of the Securities Investor Protection Act of 1970.
  • Under the securities lending agreement you relinquish your ability to exercise voting rights.
  • Fully paid securities on loan are no longer eligible for margin treatment or buying power calculations.
  • Securities that pay dividends will be paid as "cash-in-lieu" which may have different taxable consequences than receipt of actual dividends.

For a full list of disclosures or for more information on this program please contact the Compliance Department as listed above.

Personal checks and wire transfers are the only form of monetary deposits that will be accepted into your retail brokerage account. All incoming checks or wires from 3rd parties must be confirmed with the client at the time of deposit to determine the business reason behind the 3rd party deposit. B. Riley Securities reserves the right to refuse any deposit.

When you place an order with your sales representative, you may specify that your order is handled on either a "not held" or "held" basis. A "not held" order means that you have given B. Riley Securities discretion as to the price and time of execution of your order. If given a "held" order, B. Riley Securities will not have discretion on handling your order and must execute it at the prevailing market price; or, if it's a "held" limit order, any execution will take place at the limit price or better, if available. As "not held" orders give B. Riley Securities the flexibility to work your order to seek to obtain the best execution reasonably available under the prevailing circumstances, your orders will be treated as "not held" unless we are specifically instructed to treat the order differently. Please note that, under FINRA Rules, a "not held" order does not have price protection. Consequently, there is no Limit Order Protection (i.e. no Manning obligation) for these orders and B. Riley Securities is not required to match incoming market orders with unexecuted better-priced limit orders. Nonetheless, any purchase and sale transactions must be consistent with our efforts to provide best execution of your orders. Please notify your sales representative at the time you place your order if you wish your order to be treated other than "not held".

High yield debt securities (also known as "junk bonds") generally involve a higher degree of risk and are typically rated BB or less by Standard and Poor's or Ba or below by Moody's. The following disclosures apply to these securities:

  • The bond may default resulting in loss of investment.
  • Markets for such bonds may be relatively illiquid, impacting the investor's ability to sell and the price of the bond.

In a low-interest, low-yield environment, there may be a compression of risk premium resulting from investors bidding up prices and driving down yields while default rates remain high.

You agree to indemnify B. Riley Securities from, and hold B. Riley Securities harmless for, any losses (meaning claims, damages, actions, demands, investment losses, or other losses, as well as any costs, charges, attorneys' fees, or other fees and expenses) resulting from your actions or failures to act, whether intentional or not, including losses resulting from actions taken by third parties, except to the extent that any losses described above result solely from the gross negligence or willful misconduct of B. Riley Securities. Beyond taking reasonable steps to verify the authenticity of instructions, B. Riley Securities has no obligation to inquire into purpose, wisdom, or propriety of any instructions we receive.

Information is an asset. The Firm has a duty and responsibility to protect. The confidentiality, integrity and availability of complete and accurate information is essential to the Firm functioning in an efficient manner and providing products and services to clients. The Firm holds and processes confidential and personal information on private individuals, employees, partners and suppliers, and information relating to its own operations. In processing information, the Firm has a responsibility to safeguard information and prevent its misuse. The purpose and objective of the Information Security Policy is to set out a framework for the protection of the Firm's information assets:

  • to protect the firm's information from threats, whether internal or external, deliberate or accidental,
  • to enable secure information sharing,
  • to encourage consistent and professional use of information,
  • to ensure that everyone is clear about their roles in using and protecting information,
  • to ensure business continuity and minimize business damage,
  • to protect the firm from legal liability and the inappropriate use of information.

The Information Security Policy covers the following areas:

  • Information Security Risk Management
  • Information Classification and Handling
  • Access Control
  • Password Policy
  • Hosted Services Security
  • Network Security
  • Server Security
  • Application Security
  • Database Security
  • Endpoint Security
  • Security Patching
  • Cryptographic Controls
  • Incident Response Management
  • Compliance

Pursuant to FINRA Rules 5130 & 5131 (the Rules), B. Riley Securities may not sell or cause to be sold a new issue (as defined in the Rules; generally, initial public offerings ("IPOs") of equity securities) to any account in which a restricted person holds a beneficial interest unless the account qualifies for a general exemption under the Rule. In addition, there is a restriction that applies to sales to executive officers or directors of a public company or covered non-public company. B. Riley Securities requires that you sign and return an IPO Certification annually indicating whether or not your account is eligible to purchase IPO shares in accordance with the Rule. In addition, in connection with any new issue, you hereby represent that you will not act as a finder (i.e., a person who receives compensation for identifying potential investors in an offering) or in a fiduciary capacity to any managing underwriter of any new issue and that you shall notify B. Riley Securities immediately in the event that such representation ceases to be true and correct. IPO Certifications can be returned to Operations-brs@brileyfin.com.

Please note that any instant message sent from or received by B. Riley Securities personnel is subject to archiving, monitoring and production to third parties as required by applicable rules, regulations and law. Instant messages and emails may be reviewed by someone other than the intended recipient.

Institutional Suitability Certification: Affirmative Indication of Exercise of Independent Judgment (Pursuant to FINRA Rule 2111) In connection with any recommended (as defined in FINRA rules), transaction or investment strategy by B. Riley Securities, you have acknowledged on behalf of your Institution that:

  1. It is an Institutional Account as defined in FINRA Rule 4512(c);
  2. It (1) is capable of evaluating investment risks independently, both in general and with regard to all transactions and investment strategies involving a security or securities; and (2) will exercise independent judgment in evaluating the recommendations of B. Riley FBR or its associated persons, unless it has otherwise notified B. Riley in writing;
  3. It will notify B. Riley Securities if anything in this Certification ceases to be true;

You have acknowledged that the above statements are accurate but do not waive any rights afforded under U.S. federal or state securities laws, including without limitation, any rights under Section 10(b) of the Securities Exchange Act of 1934, as amended, and the rules and regulations promulgated thereunder. This shall apply with respect to all recommended transactions and investment strategies involving securities that are entered into by your Institutional Account as named on the B. Riley Securities Institutional New Account Form, whether for the account of such Institutional Account or for the account of any beneficial owner that has delegated decision making authority to such Institutional Account.

Investment Advisors may request the establishment of certain subaccounts with B. Riley Securities for the purpose of executing transactions that will clear or settle at another financial institution. The limited information that is provided to B. Riley Securities is to be used primarily to assist the Investment Advisor with its recordkeeping and to hold positions for a limited duration to facilitate the transfer of assets to another financial institution. All transactions in these subaccounts will be initiated by individuals authorized to transact on behalf of the Investment Advisor, there will be no interaction with the beneficial owners of the accounts, and in fact the beneficial owners shall have no direct control over subaccounts opened with B. Riley Securities. Investment Advisors that maintain subaccounts with B. Riley Securities attest that they have in their files client authorizations to direct orders to B. Riley Securities, in a fully discretionary manner, or otherwise, for all accounts for whom they may place orders through B. Riley Securities. Investment Advisors are authorized to place orders with B. Riley Securities to purchase and sell securities, to deliver and receive securities and to request and receive payment of funds on behalf of each account. In lieu of furnishing B. Riley Securities with specific evidence of authority in connection with each account in which an order with respect to securities is given to B. Riley, the Investment Advisor agrees to indemnify and hold B. Riley Securities harmless in the event that any such account should make claim against B. Riley Securities that its execution of any order, on the basis of the Investment Advisor's instructions, was without authority. Furthermore, B. Riley Securities may rely upon the Investment Advisor's assurance that it has examined any trust instruments, corporate resolutions or other authorizing documents, and is satisfied that the person or persons who signed such document(s) were themselves properly authorized by the entity they represent. Moreover, based upon the review of such documents and other relevant information regarding its clients, the Investment Advisor is satisfied that any investment or investment decision executed through B. Riley Securities is suitable for the relevant client. Investment Advisor agrees to indemnify B. Riley Securities and hold B. Riley Securities harmless in the event that any such account should make claim against B. Riley Securities that any investment or investment decision was not suitable.

If you or your account is a large trader as defined by Rule 13h-1 under the Securities Exchange Act of 1934, you agree to provide B. Riley Securities with your large trader identification number ("LTID"). Should you no longer qualify as a large trader you agree to notify Operations-brs@brileyfin.com.

The Limit Order Display Rule obligates the Firm to reflect the price and full size of a customer's limit order (whether the Firm's customer or the customer of another broker-dealer) in the Firm's quote, if the order would improve the Firm's quote. The Rule applies to common stock, preferred stock, and convertible preferred stock. In addition, if the Firm's bid or offer is equal to the National Best Bid or Offer, the size of any customer limit order that equals the bid or offer and represents more than a de minimis change in size must be displayed. One exception to this Rule allows for customers to request that their limit orders not be displayed, either at the time of the order or prior thereto, pursuant to agreements with our customers. B. Riley Securities will treat your limit order as "not displayed" unless specifically told to display the order. Please notify your sales representative at the time you place your order if you wish your limit order to be displayed.

B. Riley Securities is furnishing this disclosure 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 this Margin Disclosure and the margin agreement provided to you by B. Riley Securities.

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 in connection with your account, you will be required to open a margin account which will be carried by B. Riley Securities. Securities purchased on margin are collateral of B. Riley Securities and our clearing firm, NFS, for the loan to you. If the securities in your margin account decline in value, so does the value of the collateral supporting your loan. As a result, B. Riley Securities is required to take action, such as issue a margin call and/or sell securities or other assets in any of your accounts, in order to maintain the required level of equity in the account. It is important that you fully understand the risks involved in trading securities on margin. These risks include but are not limited to the following:

  • You can lose more funds than you deposit in the margin account.
  • The firm can force the sale of securities or other assets in your account(s).
  • The firm can sell your securities or assets without contacting you.
  • You are not entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call.
  • The firm can increase its "house" maintenance margin requirements at any time and is not required to provide you advance written notice.
  • You are not entitled to an extension of time on a margin call.
  • You can lose proxy voting rights for securities held in margin accounts.
  • You can risk receiving payments-in-lieu of dividends where shares are lent past the ex-dividend date.

B. Riley Securities has entered into a fully disclosed clearing agreement with NFS pursuant to which NFS may perform certain processing, clearing, custodial, and financing functions for your brokerage firm with respect to your account. NFS extends the margin credit to you and carries your margin loan. NFS is a beneficiary of your representations, warranties, acknowledgments, and covenants in the margin agreement (including, without limitation, your authorizations, indemnifications, waivers, and releases) to the same extent as if they were made directly by you to NFS. NFS, in its own name and for its own benefit, is entitled to exercise and enforce directly against you the margin agreement, all other rights granted to your brokerage firm, and the rights of the "firm" and "brokerage firm" described in this disclosure statement.

B. Riley Securities is a market maker in a number of NASDAQ and OTC Markets securities; as such we have the capability to execute orders on a "net" basis. A "net" transaction is defined as a principal transaction in which a market maker, after having received an order to buy (sell) an equity security, purchases (sells) the equity security at one price (to/from another broker-dealer or another customer) and then sells to (buys from) the customer at a different price. Unless instructed otherwise at the time the order has been placed, B. Riley Securities may treat your order as a "net" transaction. Trades will be confirmed on a net basis with the following understanding: The price per share or other unit of trading will reflect a net price which includes the addition of any mark-up for purchase transactions or the deduction of any mark-down for sale transactions, where mark-ups or mark-downs apply. In the event a transaction includes a commission, the net price will reflect any added commission for purchases or deducted commissions for sales. If the above is not consistent with your desire for confirming trades on a net basis, please notify your sales representative at the time you place your order that you do not want your order to be transacted on a "net" basis.

Options involve risk and are not suitable for all investors. Prior to buying or selling an option, investors must read a copy of the Characteristics & Risks of Standardized Options, also known as the options disclosure document (ODD). It explains the characteristics and risks of exchange traded options. Copies of this document can be viewed at https://www.theocc.com/about/publications/character-risks.jsp, or may be requested by contacting your B. Riley Securities representative for physical delivery.

Remuneration in the form of cash, liquidity rebates, order swapping or other reciprocal arrangements may be received by B. Riley Securities for directing orders to specific brokers and dealers or market centers for execution. When such remuneration is received it is considered compensation to the firm. The source and amount of such remuneration, if any, will be furnished to you upon written request. Absent specific instructions from customers, all orders received that are the subject of payment for order flow are directed to the source that offers customers the best execution. Notwithstanding the previous paragraph regarding payment for order flow, B. Riley Securities selects certain market centers to provide execution of over-the-counter and exchange-listed securities transactions which agree to accept orders, transmitted electronically up to a specified size, and to execute them at or better than the national best bid or offer (NBBO). On certain larger orders, or if the designated market centers do not make a market in the subject security, B. Riley Securities directly contacts market centers to obtain an execution. The designated market centers to which orders are automatically routed are selected based on the consistent high quality of their executions in one or more market segments and their ability to provide opportunities for executions at prices superior to the NBBO.

Penny stocks are low-priced shares of small companies. Penny stocks may trade infrequently which means that it may be difficult to sell penny stock shares once you have them. Because it may also be difficult to find quotations for penny stocks, they may be impossible to accurately price. While penny stocks generally trade over-the-counter, they may also trade on U.S. securities exchanges, facilities of U.S. exchanges, or foreign exchanges. You should learn about the market in which the penny stock trades to determine how much demand there is for this stock and how difficult it will be to sell. Investors in penny stock should be prepared for the possibility that they may lose their whole investment. Additional information about low-priced securities-including penny stocks-is available on the SEC's Web site at https://www.sec.gov/reportspubs/investor-publications/investorpubsmicrocapstockhtm.html. B. Riley Securities will send you a copy of this information upon request.

In addition to the privacy policies of our clearing firm, NFS, (http://fiiscontent.fidelity.com/769536.pdf) B. Riley Securities has in place policies and procedures to ensure that our client's privacy is protected. It is the policy of B. Riley Securities not to disclose our clients' nonpublic personal information except to our affiliates servicing your account, to non-affiliated third-party service providers as allowable by law, or in response to inquiries from regulators or government authorities. Information is shared with our affiliates and vendors servicing your account only in the ordinary course of business. In all other cases where information is shared, express written consent must be acquired from the client. Any party that receives this information will use it only for the services required and as allowable under law and is not permitted to share this information for any other purpose.

In the normal course of business, information pertaining to your account may be shared with non-affiliated third parties that perform various services for us such as clearing firms, custodians, auditors and attorneys, and other non-affiliated third parties as required or permitted by law, such as regulatory bodies. Non-public information that B. Riley Securities receives from you on your new account documents and/or other forms, includes, but is not limited to, your name, address, telephone number, occupation, social security number or tax identification number, and information pertaining to your financial status (i.e. net worth, annual income, etc.). Access to client information within B. Riley Securities will be limited to those employees and service providers who are involved in offering or administering the products and services that we offer. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic information. B. Riley Securities will adhere to these policies for both current and former clients and will notify customers of our policy at the time the relationship is established and annually thereafter. In the event that it becomes necessary to disclose any nonpublic information in a means inconsistent with this policy, we will provide you with advanced notice so that you will have the opportunity to opt out of such disclosure should you choose.

If you reside in California, you can make the following requests with respect to your personal information:

  • Access - You can request that we disclose to you the categories of personal information collected about you, the categories of sources from which the personal information is collected, the categories of personal information sold (if applicable) or disclosed, the business or commercial purpose for collecting and selling (if applicable) the personal information, the categories of third parties with whom we share the personal information, and/or the specific pieces of personal information collected about you over the past 12 months.
  • Deletion - You can request that we delete your personal information that we maintain about you, subject to certain exceptions.
  • Opt-out - For purposes of this privacy policy, "sell" means the sale, rental, release, disclosure, dissemination, availability, transfer, or other oral, written, or electronic communication of your personal information to an outside party for monetary or other valuable consideration. Based on our understanding of California law, we do not sell your personal information, so we do not offer the opt-out right.

We will not discriminate against you because you made any of these requests. California residents can make these requests by emailing us at ControlRoom@brileyfin.com or by calling us toll-free (833) 774-0208. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us. California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent. For purposes of these requests, please note the following regarding how we collect and use your personal information as described in this policy:

  • We collect and use the following categories of personal information as set forth in the California Consumer Privacy Act of 2018: identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); commercial information; internet or other electronic network activity information; and professional or employment-related information.
  • We collect these categories of personal information from you, your devices, publicly available sources, our affiliates, our service providers, and our business partners.
  • We use these categories of personal information for our business and commercial purposes described above of this Policy.
  • We disclose these categories of personal information to our affiliates, service providers, business and advertising partners, law enforcement, and potential acquirers of our business, as described above in this policy.
Monthly statements and trade confirmations generally reflect a code or group name about the registered representative assigned to your account. To inquire as to the specific sales representative within B. Riley Securities that is responsible for servicing your account please email your request to Operations-brs@brileyfin.com.

Pursuant to Securities Exchange Act Rule 15c3-5, broker-dealers with market access are obligated to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage financial, regulatory, and other risks of this business activity. This includes: preventing the entry of orders that exceed appropriate pre-set credit or capital thresholds in the aggregate for each customer. In order to set appropriate customer trading threshold, we may require certain information about your Firm's trading activities and Assets Under Management ("AUM"). This information may be requested at the time of account opening and annually thereafter.

As a market maker, B. Riley Securities is required to make publicly available reports that categorize order executions and include statistical data about execution quality for orders covered under Rule 605.

2020: August - B. Riley Securities has no covered orders for this month. July - B. Riley Securities has no covered orders for this month. June - B. Riley Securities has no covered orders for this month. May - B. Riley Securities has no covered orders for this month. April - B. Riley Securities has no covered orders for this month. March - B. Riley Securities has no covered orders for this month. February - B. Riley Securities has no covered orders for this month. January - B. Riley Securities has no covered orders for this month.

2019: December - B. Riley Securities has no covered orders for this month. November - B. Riley Securities has no covered orders for this month. October - B. Riley Securities has no covered orders for this month. September - B. Riley Securities has no covered orders for this month. August - B. Riley Securities has no covered orders for this month. July - B. Riley Securities has no covered orders for this month. June - B. Riley Securities has no covered orders for this month. May - B. Riley Securities has no covered orders for this month. April - B. Riley Securities has no covered orders for this month. March - B. Riley Securities has no covered orders for this month. February - B. Riley Securities has no covered orders for this month. January - B. Riley Securities has no covered orders for this month.

2018: December - B. Riley Securities has no covered orders for this month. November - B. Riley Securities has no covered orders for this month. October - B. Riley Securities has no covered orders for this month. September - B. Riley Securities has no covered orders for this month. August - B. Riley Securities has no covered orders for this month. July - B. Riley Securities has no covered orders for this month. June - B. Riley Securities has no covered orders for this month. May - B. Riley Securities has no covered orders for this month. April - B. Riley Securities has no covered orders for this month. March - B. Riley Securities has no covered orders for this month. February - B. Riley Securities has no covered orders for this month. January - B. Riley Securities has no covered orders for this month.

Rule 606 of SEC Regulation NMS requires broker-dealers receiving non-directed client orders to publicly disclose, on a quarterly basis, the top execution venues to which such orders are routed for execution. Non-directed orders are any order that the client has not specifically instructed to be routed to a particular venue for execution and that B. Riley Securities will select the execution venue on your behalf. The Rule 606 report is divided into four sections: one for securities listed on the New York Stock Exchange, one for securities listed on the NASDAQ Stock Market, one for securities listed on the American Stock Exchange or regional exchanges, and one for exchange-listed options. For each section, this report identifies the venues most often selected by B. Riley Securities, sets forth the percentage of various types of orders routed to the venues, and discusses the material aspects of B. Riley Security's relationship with the identified execution venues. SEC Rule 606 - Order Routing Disclosure Report for MPID: RILY since Q2 2018 SEC Rule 606 - Order Routing Disclosure Report for MPID: RILY prior to Q2 2018

THIS MESSAGE CONTAINS INSUFFICIENT INFORMATION TO MAKE AN INVESTMENT DECISION. This material is a product of the B. Riley Securities, Inc. ("B. Riley Securities") Equity Sales and Trading department. It is not a product of B. Riley's Research Department, and is not to be regarded as research or a research report. Unless otherwise specifically stated, any views or opinions expressed herein are solely those of the individual author and may differ from the views and opinions expressed by B. Riley's Research Department or other B. Riley Securities departments, divisions and affiliates. B. Riley Securities and/or its affiliates may trade or make markets for its own account on a principal basis in the securities referenced in this communication. B. Riley and/or its affiliates may engage is securities transactions that are inconsistent with this communication and may have long or short positions in such securities. The information and any opinions contained herein are as of the date of this material and B. Riley Securities does not undertake any obligation to update them. All market prices, data and other information are not warranted as to the completeness or accuracy and are subject to change without notice. Past performance is not indicative of future results, and no representation or warranty, express or implied, is made regarding any matter including future performance. This material does not constitute investment advice, does not take into account individual client circumstances, objectives, or needs, and is not intended as a recommendation to any particular clients. Information conveyed in this material, including references to strategies, securities or other financial instruments, may not be suitable for all investors. In reaching a determination as to the appropriateness of any proposed transaction or strategy, clients should undertake a thorough independent review of the legal, regulatory, credit, accounting and economic consequences of such transaction in relation to their particular circumstances and make their own independent decisions. B. Riley Securities does not provide tax advice. As such, any information contained in Equity Sales and Trading department communications relating to tax matters were neither written nor intended by B. Riley Securities to be used for tax reporting purposes. Recipients should seek tax advice based on their particular circumstances from an independent tax advisor.

Subject to certain limited exemptions, before placing a short sale, you are required to borrow, arrange to borrow, or otherwise have reasonable grounds to believe that the security sold short can be borrowed for delivery by settlement date. Prior to executing a short sale order on your behalf B. Riley Securities will require confirmation from you that a borrow has been secured and from whom. This process is commonly referred to as "obtaining a locate." A locate is an indication that, as of the time the locate is obtained, B. Riley Securities has reasonable grounds to believe that securities will be available for borrowing on the settlement date. A locate is not a guarantee that securities will actually be available for lending and delivery on the settlement date or that the lender will not thereafter require the return of the borrowed securities at any time. If a sufficient quantity of securities is not available from our clearing firm's inventory, B. Riley Securities or our clearing firm may, among other things, contact third-party lenders to ascertain whether they have securities available for lending. If B. Riley Securities or our clearing firm determines that there are reasonable grounds to believe that a sufficient quantity of securities is borrowable, B. Riley Securities may proceed to execute the short sale on behalf of your account. If B. Riley Securities or its clearing firm is unable to determine that the shares can be borrowed, the order will not proceed at that time. If the order is executed and the securities are not available for borrowing for any reason by the settlement date, you as the seller will "fail to deliver" to the purchaser. A purchaser or securities lender may, in addition to other remedies and at any time after the giving of any required notice, buy-in the securities that were not timely delivered, and you will be responsible for all losses and costs of the buy-in.

B. Riley Securities and NFS are members of the Securities Investor Protection Corporation (SIPC), a nonprofit, congressionally chartered, membership corporation created in 1970. SIPC plays an important role in the overall system of investor protection in the United States by, in certain specified situations, restoring funds to investors with assets in the hands of bankrupt and otherwise financially troubled brokerage firms. As a member of the SIPC, funds are available to meet customer claims up to a ceiling of $500,000, including a maximum of $250,000 for cash claims. Additionally, securities in accounts carried by NFS, a Fidelity Investments company, are protected in accordance with the SIPC up to $500,000 (including up to $250,000 for cash awaiting reinvestment). NFS also has arranged for coverage above these limits. Neither coverage protects against a decline in the market value of securities, nor does either coverage extend to certain securities that are considered ineligible for coverage. Note that SIPC coverage is not the same as, nor is it a substitute for, FDIC deposit insurance. Securities purchased through our brokerage firm are not FDIC-insured; however, cash in some account types may be covered by FDIC insurance and not by SIPC coverage. For more details on SIPC, or to request a SIPC brochure, visit http://www.sipc.org or call 1-202-371-8300. You may visit www.fdic.gov for additional FDIC insurance information.

While our internal policies generally prohibit B. Riley Securities from executing principal orders when there is customer order on the same side of the market, there may be circumstances where this activity would be allowable. As such we are required to disclose that as permissible under FINRA Rule 5320 B. Riley Securities may trade a security on the same side of the market for its own account at a price that would satisfy a customer order for an "institutional account" or for orders of 10,000 shares or more (unless such orders are less than $100,000 in value). Should you choose to opt in to the protections afforded in Rule 5320 for all or any portion of your order(s) please notify your sales representative at the time you place your order.

The material located on the B. Riley Securities website is for informational purposes only and is not intended as a solicitation to buy or sell any securities or other financial instrument or to provide any investment advice or service. Information included on our website is subject to change at any time. The firm does not guarantee the timeliness, sequence, accuracy or completeness of information included on this website. Past performance should not be taken as an indication of guarantee of future performance and no representation, express or implied, is made regarding future performance. The firm can only conduct business if registered in states where registration is required or if business is exempt under State requirements. Check with your representative or contact our Compliance Department to get a list of states we are currently registered in. B. Riley Securities is a member of Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). B. Riley Securities does not provide tax advice; clients should contact their attorney, accountant, or other tax adviser regarding tax matters. B. Riley Securities does not take responsibility for content contained at hyperlinked sites. B. Riley Securities may make markets and effect transactions, including transactions contrary to any recommendations herein, or have positions in the securities mentioned herein (or options with respect thereto) and may also have performed investment banking services for the issuers of such securities. In addition, employees of B. Riley Securities may have positions and effect transactions in the securities or options of the issuers mentioned herein and may serve as directors of such issuers. For additional information, please contact B. Riley Securities at (310) 966-1444.

B. Riley Securities Research Disclosures

B. Riley Wealth Management Regulatory & Legal Disclosures; Notices to Investors


B. Riley Wealth Management, Inc. is a full-service investment firm registered with the Securities and Exchange Commission as both a broker-dealer and an investment adviser. Brokerage and investment advisory services offered to retail investors include, but are not limited to, buying and selling of securities, traditional investment accounts, retirement accounts, insurance products, securities based lending, syndicate offerings, research from third-parties and financial planning and consulting services.

Fees for these services differ, and B. Riley Wealth Management is committed to providing a clear understanding of the costs for these services and to helping investors make an informed decision about whether to invest with our firm. More information can be found in our Customer Relationship Summary. A copy of our complete Regulation Best Interest disclosures is available through your B. Riley Wealth Management financial advisor or by sending a request to Contact Us. Find more information about our Fees and Commissions here.

B. Riley Wealth Management brokerage accounts are assessed an annual fee that varies based upon account type. Additional fees apply to certain services which you may request from time to time. Review the current account fee schedule here. A Commission Schedule is available through your B. Riley Wealth Management financial advisor or by sending a request to Contact Us.

Review B. Riley Wealth Management's Privacy Notice to Clients.

B. Riley Wealth Management, Inc. has selected First Clearing‡ to hold client brokerage account assets. First Clearing is a trade name used by Wells Fargo Clearing Services, LLC, a registered broker-dealer and non-bank affiliate of Wells Fargo & Company. First Clearing is a leading provider of clearing and custody services to financial institutions. First Clearing's services include transaction execution, operational support, and the production of account statements and tax reporting documents.

B. Riley Wealth Management, Inc. and First Clearing are members of the Securities Investor Protection Corporation (SIPC), a nonprofit, congressionally chartered, membership corporation created in 1970. SIPC protects clients against the custodial risk of a member brokerage firm becoming insolvent by replacing missing securities and cash up to $500,000, including up to $250,000 in cash, per client, in accordance with SIPC rules. (Note that SIPC coverage is not the same as, nor is it a substitute for, FDIC deposit insurance. Securities purchased through our brokerage firm are not FDIC-insured; however cash in some account types may be covered by FDIC insurance and not by SIPC coverage.) For more information about SIPC, please visit www.sipc.org. You may visit www.fdic.gov for additional FDIC insurance information.

Above and beyond SIPC coverage, First Clearing maintains additional insurance coverage provided through London Underwriters (led by Lloyd's of London Syndicates, the world's specialist insurance market). For clients who have received the full SIPC payout limit, First Clearing's policy with London Underwriters provides additional coverage above the SIPC limits for any missing securities and cash in client brokerage accounts up to a clearing-firm aggregate limit of $1 billion (including up to $1.9 million for cash per client). SIPC and the additional protection from London Underwriters do not protect against losses from the failure of a security, insure the quality of investments or protect against losses from fluctuating market value. All coverage is subject to the specific policy terms and conditions.

B. Riley Wealth Management financial advisors may only conduct business with residents of the states and/or jurisdictions for which they are properly registered. Therefore, a response to a request for information may be delayed. Please note that not all of the investments and services mentioned are available in every state. Investors outside of the United States are subject to securities and tax regulations within their applicable jurisdictions that are not addressed on this site. Contact your local B. Riley Wealth Management office for information and availability.

Social media networks are independent organizations and are not affiliated with B. Riley Wealth Management.

Any links to third-party websites or content are provided for information purposes only. B. Riley Wealth Management does not endorse, authorize or sponsor the content or its respective sponsors. B. Riley Wealth Management is not responsible for the content of the website or the collection or use of information regarding the website's users and/or members.

For Twitter Retweets and Facebook or LinkedIn Shares: Views expressed in these posts are the current opinion of the author, but not necessarily those of B. Riley Wealth Management or your financial advisor. The author's opinions are subject to change without notice. The information shared was received from sources believed to be reliable, but accuracy is not guaranteed.

Our financial advisors may also be involved in other business entities, including their own registered investment advisor firms and/or independent insurance relationships, unrelated to their association with B. Riley Wealth Management. These entities are completely independent of B. Riley Wealth Management. Brokerage and investment advisory services are offered through B. Riley Wealth Management, Inc.

The following disclosure statement is applicable if the email you have received contains a third party (non-B. Riley Wealth Management) research report as an attachment:

Please direct any questions regarding this information to the author of the email sent to you and not to the Investment Research Provider, its analysts or other representatives.

Investment Research Providers prepare research reports. The information in these reports is not personalized investment advice and is not intended as an offer or solicitation for the purchase or sale of any financial instrument. Securities, financial instruments, or strategies mentioned in these reports may not be suitable for all investors. Information and opinions regarding specific securities do not take into account individual circumstances, objectives, or needs and are not intended as recommendations of particular securities, financial instruments, or strategies. You should evaluate this report in light of your own circumstances. Opinions and estimates constitute the Investment Research Provider's judgment as of the date of these reports and are subject to change without notice. These reports may have been made available to us before being made available to you (our client). We are solely responsible for the distribution and use of these reports.

Research Reports from Third Party Affiliated Companies

B. Riley Wealth Management, Inc. ("BRWM" or the "Firm") is a wholly owned subsidiary of B. Riley Financial. B. Riley Securities, Inc. (f/k/a B. Riley FBR) is also a subsidiary of B. Riley Financial and an affiliate of BRWM. Through its affiliation as part of the B. Riley Financial family of companies, BRWM has made arrangements to receive and distribute research reports prepared by B. Riley Securities, Inc. BRWM is pleased to provide you with the attached third-party research report, which has been prepared by an affiliated company. Important information about the report and its preparation is provided at the end of the report, or in an appendix to the report, including information relating to activities involving, or relationships between, the company(ies) covered in the report and the affiliate preparing the report, as well as BRWM and other B. Riley Financial affiliates. You should read that information carefully. The report reflects the personal views of the analyst(s) preparing the report as of the time it was prepared. The Firm believes the report is objective and reliable and is based on data from sources the author(s) of the report believe to be reliable. We note, however, that the report is not guaranteed as to accuracy and does not purport to be complete.

For important disclosures related to the relationship between BRWM and certain companies that are subject to these third-party research reports please review the disclosure section titled Third Party Research Disclosure.

For up-to-date B. Riley Securities, Inc. covered company disclosures, please refer to section above titled B. Riley Securities, Inc. Research Disclosures for additional information.

IMPORTANT NOTICES: The information contained in this electronic message (including any attachments) is privileged and confidential information intended only for the use of the recipient(s) named above. Please notify the sender by email if you are not the intended recipient. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. B. Riley Wealth Management, Inc. ("BRWM") does not accept time sensitive, action-oriented messages or transaction orders, including orders to purchase or sell securities, via email or by any other electronic means. BRWM reserves the right to monitor and review the content of all messages sent to or from this email address. Messages sent to or from this email address are stored by a third-party vendor and may be provided to regulators upon request. Neither the sender nor BRWM accepts any liability for any errors or omissions arising as a result of transmission. Any information contained in this electronic message is not an offer or solicitation to buy or sell any security, and while such information has been obtained from sources believed to be reliable, its accuracy is not guaranteed. Any references to the terms of executed transactions should be treated as preliminary only and subject to our formal written confirmation.

The Federal Deposit Insurance Corporation (FDIC) insurance coverage in our Bank Deposit Sweep utilizes four Wells Fargo & Company banks ("Program Banks"). If the Bank Deposit Sweep is the cash sweep vehicle for your brokerage account, uninvested cash balances in your account are automatically deposited into the Bank Deposit Sweep. To view the Cash Sweep Program Disclosure Statement visit: https://www.wellsfargoclearingservicesllc.com/index.htm.

B. Riley Wealth Management, Inc. ("BRWM" or the "Firm") is a wholly owned subsidiary of B. Riley Financial. B. Riley Securities, Inc. is also a subsidiary of B. Riley Financial and an affiliate of BRWM. Through its affiliation as part of the B. Riley Financial family of companies, BRWM has made arrangements to receive and distribute research reports prepared by B Riley Securities, Inc. BRWM is pleased to provide you with the attached third-party research report, which has been prepared by an affiliated company. Important information about the report and its preparation is provided at the end of the report, or in an appendix to the report, including information relating to activities involving, or relationships between, the company(ies) covered in the report and the affiliate preparing the report, as well as BRWM and other B. Riley Financial affiliates. You should read that information carefully. The report reflects the personal views of the analyst(s) preparing the report as of the time it was prepared. The Firm believes the report is objective and reliable, and is based on data from sources the author(s) of the report believe to be reliable. We note, however, that the report is not guaranteed as to accuracy and does not purport to be complete.

Refer to section above titled B. Riley Securities, Inc. Research Disclosures for additional information.

B. Riley Wealth Management, Inc. ("BRWM") is furnishing this information 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 BRWM. Please contact your broker regarding any questions or concerns you may have with your margin account(s).

When you purchase securities through BRWM, you may pay for the securities in full or you may borrow part of the purchase price from BRWM's clearing firm, First Clearing‡. If you choose to borrow funds, you will need to open a margin account with BRWM. The securities purchased are First Clearing'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, First Clearing or BRWM 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 First Clearing, the firm that has made the loan, to avoid the forced sale of those securities or other securities or assets in your accounts).

First Clearing or BRWM 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 First Clearing's higher "house" requirements, First Clearing can sell the securities or other assets in any of your accounts held at the firm to cover the margin deficiency. You also will be responsible for any shortfall in the account after such a sale.

First Clearing or BRWM 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 brokerage firm cannot liquidate securities or other assets in their accounts to meet the call unless the brokerage 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 you.

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, First Clearing or BRWM has the right to decide which security to sell in order to protect its interests.

First Clearing or BRWM 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 First Clearing or BRWM 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.

Securities in your margin account may be loaned to or by First Clearing. To the extent First Clearing determines, in accordance with Federal tax regulations, that your securities have been loaned, payments received by you with respect to such securities (including payments in lieu of dividends) may be reclassified as substitute payments. Substitute payments may be reported on different tax reporting forms than payments received on the underlying securities and may be subject to different tax consequences and rates. You are advised to contact your tax advisor to discuss the tax treatment of substitute payments.

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 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.

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.

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.

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 allow 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.

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.

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 website. See www.finra.org or visit the public website of the applicable mutual fund company.

The largest source of IRA contributions comes from individuals who move their money from their employer-sponsored retirement plans such as 401(k) and 403(b) plans when they leave a job. If you are considering rolling over money from an employer plan into an IRA, please read the FINRA Investor Alert titled "10 Tips to Making a Sound Decision," which can be found on the FINRA Investor website at http://www.finra.org/investors/alerts/ira-rollover-10-tips-making-sound-decision.

FINRA is the Financial Industry Regulatory Authority, a self-regulatory organization that oversees securities firms and stockbrokers. FINRA offers unbiased information on a full range of issues that affect your money and investments. On FINRA's website, www.finra.org, you can find facts and tools as well as background information on both firms and brokers.

In accordance with FINRA Rule 2267, B. Riley Wealth Management, Inc. is providing the following information in the event you wish to contact FINRA. You may contact FINRA at 301-590-6500 or by mail at 1735 K Street NW, Washington, DC 20006-1500. In addition, investors may utilize the BrokerCheck hotline (800-289-9999) or the FINRA Seniors Helpline (844-574-3577). For more information on FINRA, see the document titled "Putting Investors First" at http://www.finra.org/sites/default/files/InvestorDocument/p014341.pdf.

To satisfy the requirements of MSRB rule G-10, you are hereby notified that B. Riley Wealth Management is registered with the U.S. Securities and Exchange Commission and the Municipal Securities Rulemaking Board. For more information about the Municipal Securities Rulemaking Board please visit their website at www.msrb.org. Additionally, customers may access the MSRB Investor Brochure, which describes the protections that may be provided by the Municipal Securities Rulemaking Board rules and how to file a complaint with an appropriate regulatory authority, by accessing the following web page: http://msrb.org/msrb1/pdfs/MSRB-Investor-Brochure.pdf

Prior to the sale of a CMO to any person other than an institutional investor, B. Riley Wealth Management offers educational material that includes a discussion of the characteristics and risks of CMOs including credit quality, prepayment rates and average lives, interest rates (including their effect on value and prepayment rates), tax considerations, minimum investments, transaction costs and liquidity. Additionally, the educational material discusses the structure of a CMO, including the various types of tranches that may be issued and the rights and risks pertaining to each (including the fact that two CMOs with the same underlying collateral may be prepaid at different rates and may have different price volatility), the relationship between mortgage loans and mortgage securities, questions an investor should ask before investing, and finally a glossary of terms related to CMOs.

You can obtain a copy of the educational material, the Investors Guide: Mortgage-Backed Securities (MBS) and Collateralized Mortgage Obligations (CMOS), from your Financial Advisor or access it online at www.investinginbonds.com or directly here: http://www.investinginbonds.com/learnmore.asp?catid=5&subcatid=23

The Chicago Board Options Exchange regularly publishes educational materials for investors regarding options. Prior to buying or selling an option, investors must read a copy of this disclosure document. It explains the characteristics and risks of exchange traded options.

The latest "Characteristics and Risks of Standardized Options," as well as all supplements to the original 1994 pamphlet, can be viewed at https://www.theocc.com/about/publications/character-risks.jsp or may be requested from your Financial Advisor for physical delivery.

B. Riley Wealth Management is required by the U.S. Securities and Exchange Commission ("SEC") to provide the following disclosure statement: http://www.sec.gov/investor/schedule15g.htm. It explains some of the risks of investing in penny stocks. Please read it carefully before you agree to purchase or sell a penny stock.

B. Riley Wealth Management follows the allocation procedures for callable securities established by our clearing firm, First Clearing‡. For an explanation of this allocation process, review the First Clearing Callable Securities Disclosure.

To request a written copy of the Callable Securities Disclosure, please contact your Financial Advisor.

B. Riley Wealth Management seeks to execute its customers' orders at the most favorable terms reasonably available under prevailing market conditions. B. Riley Wealth Management is responsible for overseeing the selection of the best market for each trade and for ensuring that the customer receives the best price. Details regarding B. Riley Wealth Management routing of U.S. equity and option orders are updated quarterly and may be found below in the section entitled Routing Disclosures Made Pursuant to SEC Rule 606. B. Riley Wealth Management conducts regular reviews to ensure that clients are getting the best executions on trades.

Rule 605 of SEC Regulation NMS requires "market centers" to publicly disclose, on a monthly basis, certain statistical information relating to the quality of executions provided to eligible client orders. The information generally depicts how orders of various sizes are executed relative to public quotes existing at the time of order receipt, and also attempts to measure speed of execution. Effective April 18, 2018, B. Riley Wealth Management ceased acting as a market center as defined by Rule 605 of SEC Regulation NMS and no longer has a Rule 605 reporting obligation.

Rule 606 of SEC Regulation NMS requires broker-dealers receiving non-directed client orders to publicly disclose, on a quarterly basis, the top execution venues to which such orders are routed for execution. Broker-dealers also must disclose material aspects of the relationships they maintain with the identified execution venues. Effective April 18, 2018, B. Riley Wealth Management transmits all customer orders to its clearing firm, First Clearing‡. For customer orders transmitted to First Clearing, First Clearing makes the routing decisions concerning these orders without regard to the identity of the introducing broker and routes orders to selected market makers and exchanges for execution. As such, B. Riley Wealth Management has adopted by reference First Clearing's Rule 606 disclosure report with respect to customer orders transmitted to First Clearing. B. Riley Wealth Management has reviewed First Clearing's 606 disclosure report and believes it accurately represents, in all material respects, the order routing practices for B. Riley Wealth Management's customer orders transmitted to First Clearing. B. Riley Wealth Management does not receive any payment for order flow from First Clearing. First Clearing's 606 disclosure report is available for public review online here.

Prior to April 18, 2018, B. Riley Wealth Management operated internal trading desks. For customer orders transmitted to B. Riley Wealth Management's internal trading desks, the Rule 606 disclosure data was prepared based on all qualifying routes to execution venues, including customer orders that were routed to multiple execution venues. B. Riley Wealth Management was not compensated directly for customer orders handled by its internal trading desks which were routed to market makers or exchanges. However, we may have received standard rebates for providing liquidity to certain exchanges which were credited against the fees charged by those exchanges. The Rule 606 disclosure reports for B. Riley Wealth Management's internal trading desks are available for public review online here.

Prior to January 1, 2016, B. Riley Wealth Management prepared its Rule 606 disclosure data by consolidating the customer order flow transmitted to First Clearing and to its internal trading desks. Additionally, for orders routed to multiple execution venues, the report was prepared using a single venue, generally the venue that received the largest quantity of shares, and excluded all other venues the order was routed to. B. Riley Wealth Management did not receive any payment for order flow for customer orders prior to January 1, 2016.

This disclosure is provided to customers who will engage in trading outside normal market hours. Such trading involves certain risks explained below.

  1. Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities and, as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular market hours. As a result, your order may only be partially executed, or not at all.
  2. Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular market hours. As a result, your order may only be partially executed or not at all, or you may receive an inferior price in extended hours trading than you would during regular market hours.
  3. Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular market hours or upon the opening of the next morning. As a result, you may receive an inferior price in extended hours trading than you would during regular market hours.
  4. Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours trading system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system.
  5. Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
  6. Risk of Wider Spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.
  7. Risk of Lack of Calculation or Dissemination of Underlying Index Value or Intraday Indicative Value ("IIV"). For certain Derivative Securities Products (such as exchange-traded funds, or ETFs), an updated underlying index value or IIV may not be calculated or publicly disseminated in extended trading hours. Since the underlying index value and IIV are not calculated or widely disseminated during the pre-market and post-market sessions, an investor who is unable to calculate implied values for certain Derivative Securities Products in those sessions may be at a disadvantage to market professionals.

In accordance with the regulations set forth by the USA Patriot Act, the Bank Secrecy Act and the rules of the Office of Foreign Assets Control (OFAC), the Financial Crimes Enforcement Network (FinCEN), the SEC and FINRA, B. Riley Wealth Management has in place a program to identify and report suspicious activities that could be related to money laundering or other illegal activities and to monitor and verify the identities of our customers. What this means for you: When you open an account or otherwise establish a business relationship with B. Riley Wealth Management, we may ask for your name, address, date of birth, social security number or taxpayer ID and other information that will allow us to positively identify you. We may also ask to see your driver's license, corporate formation documents or other identifying documents as applicable.

B. Riley Wealth Management reserves the right to refuse to open any account, or to close an existing account, at any time if information requested pursuant to an AML inquiry is not provided.

The paragraphs below provide a general overview of the Business Continuity Plan ("BCP") for B. Riley Wealth Management, Inc. ("B. Riley Wealth Management"). A BCP is a program designed to help ensure that we can continue to do business even if we experience an unplanned business interruption such as a loss of utility service, a building evacuation, or a catastrophic event.

B. Riley Wealth Management's BCP addresses the action that we will take in the event a significant business disruption ("SBD") affects a single building, a business district, a citywide area, or an entire region. We have different planned recovery times depending on the severity of the SBD. In the event of a branch outage, the telephones to the branch office experiencing the SBD will be re-routed within a few hours to the main office or another branch office facility with the ability to service the needs of the clients. In the event of a short term SBD at the main office, the telephones would be re-routed to a branch office location within several hours. In the case of a major business disruption at the main office, the firm has a plan to relocate the mission-critical employees and systems to an alternate location, which would result in a disruption of several hours to several days.

B. Riley Wealth Management's BCP is subject to annual review and update. In addition, the firm's regulators will periodically review the BCP for compliance. As our BCP is materially updated, the changes will be reflected here on our website. You may also contact us to request a copy of our most recent BCP by calling 1-800-726-0557 and requesting to speak with the Operations Department.

For retail accounts held at First Clearing‡:

In regard to retail client assets carried by First Clearing, we have received and reviewed First Clearing's Business Continuity Plan. We are committed to providing continued service to our clients and, to that end, during a significant business disruption B. Riley Wealth Management, Inc. will re-establish telephone service with our clients as soon as possible. Our clients should check here on our website for our latest information.

We recognize that as a client of B. Riley Wealth Management Securities, Inc. you many need access to your account to sell a position or request a check before we re-establish telephone service with our clients. During this time First Clearing will assist you with sell/liquidation orders and provide check disbursements, if needed. If you cannot contact our firm, please call First Clearing for assistance at 877-496-3223 or visit their website at https://www.wellsfargoclearingservicesllc.com/index.htm.

The information on this site is provided 'AS IS'. B. Riley Wealth Management, Inc. ("B. Riley Wealth Management") 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. This information is for informative purposes only and is not intended as an offer or solicitation with respect to the purchase or sale of any product. B. Riley Wealth Management will not be responsible for any loss or damage that could result from interception by third parties of any information made available to you via this site. Although the information provided to you on this site is obtained or compiled from sources we believe to be reliable, B. Riley Wealth Management cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose. Neither B. Riley Wealth Management, 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 that you incur 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 to you, or from any other cause relating to your 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 B. Riley Wealth Management or of any vendor providing software or services support. In no event will B. Riley Wealth Management, its affiliates or any such parties be liable to you for any direct, special, indirect, consequential, incidental damages or any other damages of any kind even if B. Riley Wealth Management or any other party have been advised of the possibility thereof.

If you have any questions or complaints regarding your account, please call 901-251-1330.

COMPLIANCE CONTACT:

Michael Markunas, General Counsel & Chief Compliance Officer
B. Riley Wealth Management Compliance Department
40 S. Main, Suite 1800
Memphis, TN 38103

Order Execution Disputes Must Be Submitted in Writing

Please note that reports of execution of orders shall be conclusive if you do not object to them in writing within the shorter of (i) the applicable settlement cycle of the subject transactions or (ii) three business days after such documents have been transmitted to you by mail or otherwise. Your statements of account(s) shall be conclusive if you do not object to them in writing within 10 days after transmission to you by mail or otherwise.

B. Riley Wealth Management, Inc.
Attn: Compliance Department
40 S. Main, Suite 1800
Memphis, TN 38103

Privacy Policies

In addition to the privacy policies of our clearing firm, NFS, (http://fiiscontent.fidelity.com/769536.pdf) B. Riley Securities has in place policies and procedures to ensure that our client's privacy is protected. It is the policy of B. Riley Securities not to disclose our clients' nonpublic personal information except to our affiliates servicing your account, to non-affiliated third-party service providers as allowable by law, or in response to inquiries from regulators or government authorities. Information is shared with our affiliates and vendors servicing your account only in the ordinary course of business. In all other cases where information is shared, express written consent must be acquired from the client. Any party that receives this information will use it only for the services required and as allowable under law and is not permitted to share this information for any other purpose.

In the normal course of business, information pertaining to your account may be shared with non-affiliated third parties that perform various services for us such as clearing firms, custodians, auditors and attorneys, and other non-affiliated third parties as required or permitted by law, such as regulatory bodies. Non-public information that B. Riley Securities receives from you on your new account documents and/or other forms, includes, but is not limited to, your name, address, telephone number, occupation, social security number or tax identification number, and information pertaining to your financial status (i.e. net worth, annual income, etc.). Access to client information within B. Riley Securities will be limited to those employees and service providers who are involved in offering or administering the products and services that we offer. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic information. B. Riley Securities will adhere to these policies for both current and former clients and will notify customers of our policy at the time the relationship is established and annually thereafter. In the event that it becomes necessary to disclose any nonpublic information in a means inconsistent with this policy, we will provide you with advanced notice so that you will have the opportunity to opt out of such disclosure should you choose.

If you reside in California, you can make the following requests with respect to your personal information:

  • Access - You can request that we disclose to you the categories of personal information collected about you, the categories of sources from which the personal information is collected, the categories of personal information sold (if applicable) or disclosed, the business or commercial purpose for collecting and selling (if applicable) the personal information, the categories of third parties with whom we share the personal information, and/or the specific pieces of personal information collected about you over the past 12 months.
  • Deletion - You can request that we delete your personal information that we maintain about you, subject to certain exceptions.
  • Opt-out - For purposes of this privacy policy, "sell" means the sale, rental, release, disclosure, dissemination, availability, transfer, or other oral, written, or electronic communication of your personal information to an outside party for monetary or other valuable consideration. Based on our understanding of California law, we do not sell your personal information, so we do not offer the opt-out right.

We will not discriminate against you because you made any of these requests. California residents can make these requests by emailing us at ControlRoom@brileyfin.com or by calling us toll-free (833) 774-0208. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us. California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent. For purposes of these requests, please note the following regarding how we collect and use your personal information as described in this policy:

  • We collect and use the following categories of personal information as set forth in the California Consumer Privacy Act of 2018: identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); commercial information; internet or other electronic network activity information; and professional or employment-related information.
  • We collect these categories of personal information from you, your devices, publicly available sources, our affiliates, our service providers, and our business partners.
  • We use these categories of personal information for our business and commercial purposes described above of this Policy.
  • We disclose these categories of personal information to our affiliates, service providers, business and advertising partners, law enforcement, and potential acquirers of our business, as described above in this policy.

Review B. Riley Wealth Management's Privacy Notice to Clients.

Last Updated: September 11, 2020

Introduction: What This Privacy Policy Covers

GlassRatner Advisory & Capital Group, LLC, Great American Group Advisory & Valuation Services, LLC, Great American Group Intellectual Property, LLC, and Great American Group Machinery & Equipment, LLC, collectively dba B. Riley Advisory Services ("BRAS", "we" or "our") are committed to protecting your privacy. This privacy policy ("Policy") applies to your interactions with BRAS online and offline, including this website (the "Site") and BRAS services (the "Services"). The purpose of this Policy is to disclose BRAS practices related to information we collect from you and have about you. Please read this Policy carefully.

1. Collection of Your Information

2. Use, Sharing & Disclosure of Your Information

3. California Privacy Rights

4. Minors' Use of the Services

5. Changes to the Privacy Policy

6. International Users

7. Legal Basis for Processing Personal Information

This Policy applies to our Site and Services only. When you visit websites to which we link, you will be interacting with another party that operates under its own privacy and security policies. Personal information you give to another party will be subject to that party's own terms, conditions, and policies - not this Policy. You should review the other party's privacy policy and terms of service before providing your information or using their services. We encourage you to review the privacy policies of any other website or application from which you request products or services.

1. Collection of Your Information

A. Information you provide to us:

We and our service providers may collect information about you when you ask us to contact you, such as:

  • your name;
  • your address;
  • your telephone number;
  • your company affiliation, job title, and related information;
  • the nature of your request; and/or
  • your email address

In addition, if you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses.

We and our service providers may also collect information that you provide to us when you apply for a job, such as:

  • your work history;
  • your resume; and/or
  • your academic background

Please see Section II of this Policy to see how we use, share and disclose information you have provided to us.

B. Information we collect through your interaction with our Site:

We and our service providers may automatically collect information from your access device and browser, including:

  • what type of browser you use;
  • processor type;
  • operating system; and
  • IP address

As you browse and interact with our Site, we and our service providers may automatically collect information related to your use of the Site, including:

  • how often you visit the Site; and
  • how you navigate and conduct searches on our Site

Please see Section II of this Policy to see how we may use, share and disclose information we collect through your interaction with our Site or Services.

C. Information we receive from other parties:

We may collect information about you from other sources, including publicly available sources and our Affiliates or our partners, service providers or others, in order to update or supplement information we have collected directly from you. For example, we may use Google Analytics to measure and report statistics about your device, interests, location and interactions on the Site. An "Affiliate" is a company that controls, is controlled by or is under common control with BRAS.

D. Information collected through technological methods:

In addition, we may use, and may allow our service providers to use, technological methods such as cookies or web beacons to collect information about you. Cookies are small pieces of data that may be stored on your computer, mobile device, or other similar device and are used to make the Site easier to use and to analyze use of the site.

E. Retention of Information:

BRAS retains the information we collect for as long as necessary to (i) provide our services to you, (ii) comply with legal obligations, (iii) resolve disputes, and (iv) enforce our agreements.

Please see Sections II and III of this Policy to see how we use, share and disclose information collected through technological methods.

2. Use, Sharing & Disclosure of Your Information

A. How we use your information:

We use the information we collect in a variety of ways, including:

  • to operate and improve the Site;
  • to understand your use of the Site;
  • to communicate with you;
  • to notify you about important changes to our website, new services and special opportunities we think you will find valuable; and
  • to develop research reporting for us, our Affiliates and third party market research partners.

B. How we share your information:

We may share your information, including in some cases information that specifically identifies, relates to, or could be associated with you, directly or indirectly, ("personal information") such as your name, your email address, your physical address or telephone number, with Affiliates and trusted partners and service providers in ways including the following:

  • to help operate the Site and Services;
  • to facilitate fulfillment of a transaction or request; and
  • to provide research reporting for us, our Affiliates and our service providers.

Examples of service providers may include providers who compile and analyze data collected by us (e.g., Google Analytics), service providers who supplement or match information we have collected with information from other parties, market research companies, website hosts, and email support vendors.

In addition, we may share information in the following circumstances:

  • without notice, to law enforcement or government agencies in response to subpoenas, court orders, or other legal process (including civil and criminal) or otherwise as required by law;
  • in connection with the actual or potential sale of our business.

Please see Section I of this Policy to see the types of information we collect.

3. California Privacy Rights

If you reside in California, you can make the following requests with respect to your personal information:

  • Access - You can request that we disclose to you the categories of personal information collected about you, the categories of sources from which the personal information is collected, the categories of personal information sold (if applicable) or disclosed, the business or commercial purpose for collecting and selling (if applicable) the personal information, the categories of third parties with whom we share the personal information, and/or the specific pieces of personal information collected about you over the past 12 months.
  • Deletion - You can request that we delete your personal information that we maintain about you, subject to certain exceptions.
  • Opt-out - For purposes of this privacy policy, "sell" means the sale, rental, release, disclosure, dissemination, availability, transfer, or other oral, written, or electronic communication of your personal information to an outside party for monetary or other valuable consideration. Based on our understanding of California law, we do not sell your personal information, so we do not offer the opt-out right.

BRAS will not discriminate against you because you made any of these requests. California residents can make these requests online by emailing us at emailing us at ccpa@brileyadvisoryservices.com or by calling us toll-free at 310-966-1444.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.

California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.

For purposes of these requests, please note the following regarding how we collect and use your personal information as described in this Policy:

  • We collect and use the following categories of personal information as set forth in the California Consumer Privacy Act of 2018: identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); commercial information; internet or other electronic network activity information; and professional or employment-related information.
  • We collect these categories of personal information from you, your devices, publicly available sources, our Affiliates, our service providers, and our business partners.
  • We use these categories of personal information for our business and commercial purposes described in Section II of this Policy.
  • We disclose these categories of personal information to our Affiliates, service providers, business and advertising partners, law enforcement, and potential acquirers of our business, as described in Section II of this Policy.

4. Minors' Use of the Services

BRAS offers a general audience Site. This Site is not intended for children under the age of 16.

5. Changes to the Privacy Policy

By using the Site or Services, you signify your acceptance to this Policy. If you do not agree to this Policy, please do not use any of the Site or Services. We reserve the right to make changes in this Policy at any time. Please check the Policy each time you use our Site or Services to ensure you are aware of any changes in our privacy practices. Your continued use of our Site or Services will signify your acceptance of the changes to this Policy. Notification of any material changes to this Policy will be posted on the BRAS home page.

If you have any questions about this Policy please contact us at:

B. Riley Advisory Services

11100 Santa Monica Blvd.

Suite 800

Los Angeles, CA 90025

6. International Users

The information we collect from users is processed and maintained in the United States, where privacy laws may not be as protective as in your home country. If you are using our Site or Services from outside of the United States, by providing information to us you are consenting to the transfer of the information to the United States for processing in a manner consistent with this Policy. If you are accessing this website from a European Union member state, you have the right to object to the collection and processing of your personal data as set forth in this Privacy Policy, and if you wish to do so please notify us at the address above. Please bear in mind that if you object this may affect our ability to provide you with the Services.

7. Legal Basis for Processing Personal Information

If you are a visitor from the European Union member state, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you. If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), such legitimate interests include: (i) improving our Site and Services; (ii) responding to inquiries from you; (iii) measuring and improving the effectiveness of our marketing activities; and (iv) transmitting data internally within our company for administrative purposes.