Welcome to BlueFin Research Partners

To: All New and Current Clients
From: Jay Battista, VP - Head of Trading & Compliance

Re: Payment for Order flow

Dear Client:

In compliance with SEC rule 11Ac1-3 and 11Ac1-6, BlueFin Research Partners, Inc. is required to disclose the following information regarding Payment for Order flow, Order Routing Decisions, and Execution Practices.

The Firm receives no remuneration for directing orders in Over-the-Counter (OTC) securities to particular OTC market makers for execution. All OTC orders taken by the firm and executed through OTC market makers are held to "best price “practices and are exposed to price improvement opportunities. The firm does direct orders to BATS and ARCA; in certain case when these orders add liquidity to BATS or ARCA the firm is rebated fees vs. charges incurred when removing liquidity. On occasions when the firm directs more orders that result in added liquidity than result in drained liquidity the firm maybe rebated the difference in the form of a check payment. Please call to discuss in further detail.

BlueFin Research Partners, Inc. is required to make publicly available electronic reports that include uniform statistical measures of execution quality, payment for order flow data and the venues to which customer orders are routed to all market centers. Market Centers are defined as "any exchange market maker, alternative trading system, national securities exchange, or national securities association." This information is available from our website, www.bluefinresearch.com, or in writing upon request. These execution reports will become available 30 days after quarter end. Upon customer request, we will also disclose where an individual order was routed. Click here for the most recent report.

Sincerely,

Jay Battista