RULE 11Ac1-6 REPORTS: ORDER EXECUTION AND ROUTING PRACTICES

On November 17, 2000, the Securities and Exchange Commission ("SEC") adopted two rules concerning disclosure of order-execution and routing practices. The second of those rules, Rule 11Ac1-6, requires all broker-dealers that route orders in equity and option securities to make available quarterly reports that present a general overview of their routing practices. The reports must identify the significant venues to which customer orders were routed for execution during the applicable quarter and disclose the material aspects of the broker-dealer's relationship with such venues. In addition, the Rule requires broker-dealers to provide customers on request, a written copy of the report of the venues to which the customer's individual orders were routed. The SEC adopted the rules to increase the visibility of execution quality of the U.S. securities markets for public investors.

Saperston Asset Management routes all non-directed NYSE and ASE trades and option trades to Knight Trading. All OTC trades are routed to our clearing firm First Clearing, LLC. “All non-directed” routing includes 99% of both NYSE and ASE “listed” trades and option trades. “All non-directed” routing also includes market and limit orders. As such, please hit either bar below to access the current quarterly report. Written copies are available (1-800-879-7541, X226). Saperston receives no payment for order flow.