Business Continuity Statement

The Buckingham Research Group Incorporated (“BRG”) has established a firm wide business continuity plan to assess and manage the effects of a significant emergency disruption on its business operations in an effort to provide continuity of critical business functions. Such critical business functions include entering of client orders, completing securities transactions. Consistent with regulatory requirements, BRG provides this disclosure statement to its clients summarizing the program. Due to the proprietary nature of some information, detailed plans for the program are not publicly disseminated. As part of our plans, BRG has identified the applications that are critical to each of our business divisions. These applications are implemented in separate production and recovery data centers using industry-standard practices to copy data from the production site to the recovery site in real time. In most cases, recovery times will range from nearly instantaneous to approximately four hours. For some business functions, next-day recovery is projected. The Plan is designed to account for the actions BRG will take in the event of disruptions of varying scope. This includes incidents involving the office building where BRG resides, city-wide or regional events of disruption. It also includes a plan for people loss, where staff members may be unable to work at their normal business location.

The Plan has been reasonably designed to allow BRG to continue its business, likely at a reduced capacity, and safeguard the interests of our clients. BRG expects to be able to meet its client obligations within the day of an incident. While BRG’s business continuity plan has been reasonably designed to allow the Firm to operate during emergency incidents of varying scope, such potential incidents are unpredictable. BRG has no control over certain infrastructure such as utilities, communication networks, transportation, and third party providers during an emergency. Because of the unpredictable and unknown nature of a potential future business disruption, BRG cannot guarantee that our systems will always be available or able to be recovered in the event of a serious emergency disruption. BRG’s business continuity plan is subject to change without notice. If the Plan is modified, an updated version will be made available to clients upon request. Nothing contained in this document amends or changes any of the terms set forth in any agreements between BRG and any of its clients.

2016 FINRA Annual Disclosure Statement

Buckingham Research Group Incorporated (“Buckingham”) is registered with the U.S. Securities and Exchange Commission (“SEC”) as a broker/dealer, and is a member of Financial Industry Regulatory Authority (“FINRA”).

FINRA makes available several services to all investors and can be contacted in the following ways:

1) FINRA’s Regulation Public Disclosure Program Hotline: (800) 289-9999

2) FINRA’s Regulation Web Site: (http//www.finra.org)

An investor brochure that includes information describing the Public Disclosure Program is available to you, by request to FINRA.

Order Routing Disclosures

Pursuant to SEC Rule 606, Buckingham provides relevant information regarding its order routing on a quarterly basis.

These reports are available to you at no charge, and can be found on “Vista One Solution’s” website (https://vrs.vista-one-solutions.com/sec606rule.aspx). Written copies are also available upon request. Further, additional order routing data relating to the identity of the venues to which your orders were routed for the prior six-month period is also available upon request.

Payment for Order Flow

In our capacity as a registered broker/dealer, we are required by the Securities and Exchange Commission to disclose to all new customers, and annually to all customers, our policies regarding the practice of receiving “payment for order flow”.

Buckingham routes equity orders to national securities exchanges, alternative trading systems, which may include electronic communications networks, and other market centers. In exchange for routing equity orders to certain market centers, Buckingham may receive monetary rebates per executed share for equity orders that add liquidity and/or rebates for exchange fees. The rebates may be considered payment for order flow although they may not necessarily offset Buckingham’s aggregate payments for removing liquidity. In any given period, the net of the “credits” received by Buckingham from a market center may exceed the “debits” charged to Buckingham for such period. Therefore, such excess credits paid to Buckingham may, according to regulatory interpretation, constitute payment for order flow.

Buckingham also may route certain orders for execution to Merrill Lynch, Pierce, Fenner & Smith, an affiliate of Buckingham’s clearing firm, the Broadcort Division of Merrill Lynch, Pierce, Fenner & Smith. The charges paid by Buckingham on such trades may be counted toward certain minimum quarterly fees due to the clearing firm from Buckingham.

Buckingham may route certain algorithmic trade orders for execution to Bloomberg Tradebook LLC and may receive an accommodation credit per executed share on such trades that Buckingham may apply toward the cost of its Bloomberg terminals.

However, Buckingham regularly reviews routing decisions, market centers and trade executions to ensure that your orders meet our duty of best execution.

Business Continuity Planning

Buckingham 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.

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 disruption.

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

Our clearing firm, Broadcort, 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 as quickly as possible. 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 local sites when needed and expect to recover and resume business within a 4 – 12 hour period. In a disruption affecting our business district, city, or region, we will transfer our operations to sites outside of the affected area, and recover and resume business within 4 – 12 hour period. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through email as to how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

For more information – If you have questions about our business continuity planning, you can contact us at (212) 922-5500 or email Peter Goldstein or Brian Crago.

Privacy Notice to our Customers and Clients

We consider it our great privilege to serve your financial needs. Buckingham Rhas always been committed to safeguarding customer information. We strongly believe in protecting the confidentiality and security of information we collect about you. This notice describes our privacy policy and practices for collecting, disclosing, and safeguarding “nonpublic personal information,” which may include financial and other customer information. We are committed to safeguarding your privacy. We take great care to protect the security of your customer information and to control how it may be used.

Information Collected: In the course of serving or administering our customer relationship with you, we collect a variety of nonpublic, personal information which is provided by you, as well as other sources, and may include:

Information we receive from you, such as your name, address, social security number, assets, and income, as provided, for example, on certain applications, investment advisory contracts, subscription agreement or other forms: and
Information about your transaction with us such as balances, payment history, parties to transactions, and account history.

The information we collect is based on services we may provide you. The information is used and shared as described in this notice.

Information Protected:

We treat your information in a confidential manner. Our employees are required to protect the confidentiality of information. Employees may access information only when there is an appropriate reason to do so, such as administer or offer products or services. We also maintain safeguards to protect information and have procedures in place to ensure your information is protected. Employees are required to comply with our
established procedures.

We use or share your information only in a limited and carefully controlled manner. For example, the information we collect is used for purposes such as:

To identify you in order to protect against fraud and guard against unauthorized access to your information;
To enable us to complete your transactions quickly and efficiently and to provide you with quality customer service; and
To better serve our relationship by understanding which products maybe suitable for your needs.

Information Disclosed: We do not sell your information to any third parties, nor do we disclose your information or information about you to anyone except as permitted by law. We do not share your information with any non affiliated third-parties, except i) as necessary to effect, administer, or enforce a transaction that your request or authorize; ii) in connection with processing or servicing a financial product or service you authorize; and/or iii) in connection with maintaining or servicing your account. Your information may also be disclosed and shared as permitted by law with Buckingham affiliates.

Except as described above, your information will not be shared with any third-parties. However, in the event that we are required by law or authorized by you to share your information with government agencies, courts, parties to lawsuits, or regulators, we will share only the information that we are required by law or authorized by you to share.

As always, please contact us with any questions you may have.

Sincerely,

The Buckingham Research Group