Disclosures

Important Information About Procedures for Opening a New Account

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. What this means for an individual: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. What this means for a corporation, partnership, trust or other legal entity: When your open an account, we will ask for your business address, tax identification number, domicile, date of incorporation or formation, articles of incorporation, government-issued business license, partnership agreement, or a trust agreement.

Summary of Business Continuity Plan

We are a member of FINRA and are required to create and maintain a business continuity plan pursuant to FINRA Rule 3510. In accordance with this rule, T&T Capital Management has developed a plan to ensure that we can continue to run our business during periods of business emergencies

Our plan addresses the following areas of concern:

• Books and records recovery
• All mission critical systems
• Financial and operational assessments
• Alternate communications between T&T Capital Management and its customers
• Alternate communications between T&T Capital Management and its employees
• Alternate physical location of employees
• Critical business constituents, banks and counter-party impact;
• Regulatory reporting
• Communications with regulators
• How T&T Capital Management will assure customers’ prompt access to their funds and securities in the event that T&T Capital Management determines it is unable to continue its business.

Events creating a disruption of business may vary in nature. They could affect only T&T Capital Management affect the building where T&T Capital Management is located, affect the entire business district where T&T Capital Management is located, or result in a regional disruption. T&T Capital Management fully intends to continue to conduct a securities business during these periods of disruption. To address disruptions affecting only T&T Capital Management, T&T Capital Management’s building, or the business district where T&T Capital Management is located, T&T Capital Management has arranged to conduct its business out of an alternate location that can accommodate its employees and critical information technology systems.

Please be advised that business continuity plans are subject to change and modification. T&T Capital Management intends to update and test its business continuity plans as business conditions and technology change. All changes to its business continuity plan will be communicated to our customers.

This website is a publication of T&T Capital Management. Information presented is believed to be factual and up-to-date, but we do not guarantee its accuracy and it should not be regarded as a complete analysis of the subjects discussed. All expressions of opinion reflect the judgment of the authors as of the date of publication and are subject to change. Content should not be viewed as personalized investment advice or as an offer to buy or sell, or a solicitation of any offer to buy or sell the securities mentioned herein.

T&T Capital Management is registered as an investment adviser and only transacts business in states where it is properly registered, or is excluded or exempted from registration requirements. Registration as an investment adviser does not constitute an endorsement of the firm by securities regulators nor does it indicate that the adviser has attained a particular level of skill or ability.

Hyperlinks on this website are provided as a convenience and we disclaim any responsibility for information, services or products found on websites linked hereto.

All investment strategies have the potential for profit or loss. Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment or strategy will be suitable or profitable for a client’s investment portfolio. Asset allocation and diversification do not ensure or guarantee better performance and cannot eliminate the risk of investment losses.

Historical performance results for investment indexes and/or categories, generally do not reflect the deduction of transaction and/or custodial charges or the deduction of an investment-management fee, the incurrence of which would have the effect of decreasing historical performance results. There are no assurances that a client’s portfolio will match or outperform any particular benchmark.

A list of all specific recommendations made by the firm for the past year is available upon written request.