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Regulation Best Interest Disclosure

This disclosure summarizes important information concerning the scope and terms of the services we offer through our broker dealer and details the material conflicts of interest that arise through our delivery of these services. Please review this information carefully, along with any applicable account agreement(s), disclosure documentation and our Customer Relationship Summary (“Form CRS”).

Please carefully review and consider the information in each section below by scrolling through.

Brokerage Services, Products and their Related Fees

As a broker-dealer, we offer full-service and self-directed brokerage services that include buying and selling securities. We provide the ability to execute the purchase and sale of various types of securities and investments on your behalf. We also offer investment recommendations and strategy recommendations.

You will pay a fee whenever you buy or sell an investment, this is referred to as a commission. Fees for certain investments, such as bonds, may be part of the price you pay for the investment (called either a mark-up or mark-down). In addition to our principal fees and costs, there are other common fees and costs which may be applicable including: custodian fees, account maintenance fees, inactivity fees, transaction charges, product level fees. For detailed information about our fees and charges, refer to fee schedule on our website (www.alexandercapitallp.com/fee-schedule).

Cash Brokerage and Margin Brokerage Accounts

• Cash acct – purchases paid in full at time of purchase.
• Margin acct – refer to disclosure on our website (www.alexandercapitallp.com/disclosures)
• Brokerage Fees refer to fee schedule on our website (www.alexandercapitallp.com/fee-schedule).

Brokerage Account Types

Account types offered by the firm. Individual, joint, custodial, DVP, estate, trust, partnership, individual retirement accounts, and any others as applicable.

Incidental Brokerage Services, Recommendations and Account Monitoring

incidental services offered by the firm. May include recommendations to buy, sell or hold; securities or investment strategy recommendation, recommendation specific to IRA rollovers.

• Recommendations (that the client can accept or not) are made in client’s best interest, based on stated investment objective, risk tolerance, liquidity needs, time horizon, financial needs, and other financial info.
• Monitoring – We do not offer account monitoring.

Clearing Services

All clearing services offered through RBC Capital Markets.

Understanding Risk

Refer to Risk Disclosure on our website (www.alexandercapitallp.com/disclosures).

Cash Sweep Program Feature

Clients are offered, through our clearing firm, the ability to automatically sweep un-invested cash from their account into RBC Insured Deposits, offering FDIC protection on cash balances up to $5,000,000 (FDIC coverage up to $10 million for joint accounts.).

Account Minimums and Activity Requirements

We do not require a minimum dollar amount to open and maintain a brokerage account. However, some products, including Private Placement securities may have minimums, please refer to the investment prospectus for specific information

Equities

We offer access to all exchanges and Nasdaq securities.

Debt Securities

Corporate, US Gov’t and Municipal are part of our product offering. Each may be traded on agency (commission) or principal (mark up/down) basis.

Mutual Funds

Mutual funds offered by Alexander are made available through RBC Capital Markets.

• Clients should see the respective product’s prospectus for exact details of fees/costs.
• Class A shares charge upfront fees and have lower expense ratios, so they are better for long-term investors.
• Class A shares also reduce upfront fees for larger investments, so they are a better choice for wealthy investors.
• Class B shares charge high exit fees and have higher expense ratios, but they convert to A-shares if held for several years.
• Class C shares have higher expense ratios than A-shares and a small exit fee, which is usually waved after one year.
• Class C shares are popular with retail investors, and they are best for short-term investors.

Annuities

Variable Annuities are offered by Alexander Capital, LP. Commissions, trails and other compensation. Can be found through individual products prospectus.

Derivatives

Options- Options allows investors to hedge risk or to speculate by taking additional risk. Buying a call or put option obtains the right but not the obligation to buy (call options) or to sell (put options) shares or futures contracts at a set price before or on an expiration date. They are traded on exchanges and centrally cleared, providing liquidity and transparency, two critical factors when taking derivatives exposure.

Warrants- A stock warrant gives the holder the right to buy a stock at a certain price at a predetermined date. Similar to call options, investors can exercise stock warrants at a fixed price. When issued, the price of a warrant is always higher than the underlying stock but carry a long-term exercise period before they expire. When an investor exercises a stock warrant, the company issues new common shares to cover the transaction, as opposed to call options where the call writer must provide the shares if the buyer exercises the option.

Alternative Investments Information

Alexander offers a variety of alternative investments such as REITs, DST and closed end funds. Commission and/or fees vary per investment. Please consult the individual investment’s prospectus.

Unit Investment Trusts (UITs)
Equity and Fixed Income are the most common UITS offered. Details of all fees are disclosed in the prospectus issued by the UIT provider.

Private Placements
Clients are offered a variety of private placements either directly with the issuer or through our affiliate Alexander Capital Ventures, LLC.

Our Compensation and Conflicts of Interest

Compensation We Receive from Clients

• Transaction-based commissions
• Markups and markdowns for principal transactions
• Account maintenance and other administrative fees

Compensation We Receive from Third Parties

• Revenue Sharing – clearing firm, mutual fund companies, product sponsors, etc.
• Trail Compensation; 12b-1 fees
• Additional Compensation from Product Sponsors and Other Third Parties – like gifts, non-cash comp, reallowance, training/education support, etc.
• We receive margin and sweep/bank deposit/other float compensation from our clearing firm

Compensation and Conflicts of Interest Related to Our Affiliates

• Some Registered Representatives maintain ownership of affiliated companies and/or are board
members of entities. This presents a conflict of interest as these individuals may have incentive to
recommend investments in these entities.
• We receive placement fees from Alexander Capital Ventures, LLC

Compensation Received by Financial Professionals

• % of revenue generated from sales of products/services
• Upfront transaction-based compensation
• Trail payments
• Deferred compensation
• Recruitment compensation – may receive higher payouts, lowered transaction costs and override

Additional Resources

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