Disclosures

Business Continuity

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

Contacting Us - As all clients are primarily served by their respective Representatives who are located in an office physically remote from the Firm’s Home Office/Headquarters, the Representative would continue to be the first point of contact in the event of any business disruption. If the business disruption is limited to the local area of your Representative, you may access your funds, accounts, information and enter transactions by calling the BBGC Home Office/Headquarters at 714-628-5200.

In the event that the business disruption is within our Home Office/Headquarters, we will post a notice on our website at www.bbgraham.com, if available, advising the public of operational status and providing instructions on how to access our operational staff.

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

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

Our clearing firm, RBC Correspondent Services, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within the same business day. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions - Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 24 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 72 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary,and notify you through our customer emergency number, (626) 451-0840 how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

For more information - If you have questions about our business continuity planning, you can contact us at (714) 628-5200

Privacy Policy

While information is the cornerstone of our ability to provide superior service, our most important asset is our clients trust. Keeping client information secure is a top priority for all of us at B.B. Graham & Co. In the operation of the investment services provided by B.B. Graham & Co., Graham & Co. collects and maintains certain information regarding its clients. In order to best service our clients and determine suitable investment and or insurance strategies, we must have certain information, such as income, net worth, risk tolerance, investment objectives and insurable interests.

This information is obtained primarily from the account paperwork and applications that you, the client are required to fill out, and from communication between the broker and the client, or between the administrative support staff and the client.

In an addition our tax reporting requirements require us to have certain information such as name, address, and social security numbers, or tax ID numbers.

To whom do we disclose information:

B.B. Graham & Co. discloses personal information only to the broker and/or brokers who are working with the account, as well as the administrative staff required to facilitate th processing of paperwork or other functions related to the account. In addition, managementand compliance officers as required to fulfill their respective obligations.

B.B. Graham & Co. has contracted with RBC Correspondent Services, a division of RBC Capital Markets Corporation, to clear trades. RBC Correspondent Services will be provided only that information that is necessary to establish, process and maintain the account. RBC Correspondent Services will use this information as necessary to service the account, and will not use it for marketing purposes.

B.B. Graham & Co. has numerous selling agreements with mutual funds and insurance carriers and will share only information necessary to establishing, processing and maintaining the account.

Categories of information that we disclose:

In order to open and maintain your account, held at our Clearing Firm, a Mutual Fund, or Insurance Company, B.B. Graham & Co. may be required to disclose certain types of information to such entities. This information may consist of the name of all persons or entities, having ownership, control, or beneficial interest in such account, social security numbers and/or tax ID numbers, date of birth, the address or addresses or such persons or entities, phone numbers, place of employment, income and net worth information, investment objectives, and in the case of corporate or trust accounts, we may need to provide documentation of such corporation, partnership, sole proprietorship, limited liability company, or any other type of corporate entity, or trust, as well as who is authorized to act on behalf of such corporate entity or trust, and what types of investments that they are permitted to make. In the case of Qualified Retirement Plans, and Insurance Plans, we may also be required to provide information on beneficiaries of such plans, with names, addresses, Social Security Numbers, and date of birth of beneficiaries, and may need to provide a spouse's signature in community property states. Any information provided to us on the forms that you fill out to open the account, may need to be provided to the Clearing Firm, Mutual Fund Company, or Insurance Company. In order to process wire transfers, the Clearing Firm, Mutual Fund Company or Insurance Company require information regarding the account from the money is being wired out, or the account which the money is being wired into.

B.B. Graham & Co. will also make such information available where it is required by law or regulation. This includes court orders,response to a subpoena, or regulatory demand.

B.B. Graham & Co. will also make such information available as authorized by the client, such as a request for duplicate statement or trade confirmations to a third party.

B.B. Graham & Co. may make certain account information available to lenders to verify credit worthiness, provided the client has provided written authorization to the lender to verify such information.

B.B. Graham & Co. does not provide any information to mailing lists or marketing organizations.

If you wish us to provide trade information or other information to a third party, such as an accountant at tax time, please notify your B.B. Graham representative ahead of time in writing that such a person will be calling.

In regards to former customers of B.B. Graham & Co., your information will not be provided to any outside organization, except by your request, or where it is required by law or regulation, including court orders, response to a subpoena, or regulatory demand.

B.B. Graham & Co. will at all times take whatever measures reasonable and necessary to protect the confidentiality, security, and integrity of your nonpublic personal information.None of your information will be disclosed to any outside sources, except as described as above, and only internally to the extent that such information is necessary to service your account, or review your account for regulatory compliance, and only to such brokers, compliance, or administrative staff involved in such servicing of the account, to the extent that such information is necessary to do so.

RULE 606

B. B. Graham & Co.'s clearing firm, RBC Correspondent Services, has provided information pursuant to a U.S. Securities and Exchange Commission rule (606) that requires firms to make publicly available, quarterly reports on the firm's order routing practices. The report provides information on the routing of "non-directed orders" which is generally defined as any order that the client has not specifically instructed to be routed to a particular venuefor execution. To view this report online please visit S3.com. To receive a hardcopy of the report please contact a B. B. Graham & Co. representative at (714) 628-5200.

Anti-Money Laundering

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. This notice answers some questions about our firm's Customer Identification Program (CIP).

WHAT TYPES OF INFORMATION WILL YOU NEED TO PROVIDE?

When you open an account, our firm is required to collect information such as the following:

• Name
• Address
• Date of birth
• Identification number:
  
  • US Citizen: taxpayer identification number (social security number or employee identification number)
  • Non-US Citizen: taxpayer identification number, passport number, and country of issuance, alien identification card number, or government- issued identification showing nationality, residence, and a photograph of you. You may also need to show your driver's license or other identifying documents.

A corporation, partnership, trust or other legal entity may need to provide other information such as its principal place of business, local office, employer identification number, certified articles of incorporation, government issued business license, a partnership agreement or a trust agreement.

US Department of the Treasury, Securities and Exchange Commission, FINRA and New York Stock Exchange rules already require you to provide additional information, such as net worth, annual income, occupation, employment information, investment experience and objectives, and risk tolerance.

WHAT HAPPENS IF I DON'T PROVIDE THE INFORMATION REQUESTED OR MY IDENTITY CAN'T BE VERIFIED?

Our firm may not be able to open an account or carry out transactions for you.