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Patriot Act Disclosure

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT OR ESTABLISHING A NEW CUSTOMER RELATIONSHIP

To help the U.S. government fight the funding of terrorism and money laundering activities, Federal law requires all U.S. financial institutions to obtain, verify, and record information that identifies each individual or institution that opens an account or establishes a customer relationship with Pickwick Capital Partners, LLC.

What this means for you: If you enter into a new customer relationship with PICKWICK CAPITAL PARTNERS, LLC we will ask for the following information.

Accredited Investors / Individuals

Unexpired government-issued ID evidencing nationality or residency and bearing a photograph or similar safeguard (e.g., driver’s license, passport, etc.) Other documents as may be required by our policies and procedures that allow us to establish a reasonable belief that we know the true identity of the customer.

Non-Individuals

Documents showing the existence of the entity, such as certified Articles of Incorporation, government-issued business license, Partnership Agreement, trust instrument, etc.

This information will be used to verify your identity. As appropriate, we may, in our discretion, ask for additional documentation or information. If all required documentation or information is not provided, PICKWICK CAPITAL PARTNERS, LLC may be unable to open an account or establish a relationship with you.

Privacy Notice

Pursuant to Federal regulations, we are providing this Privacy Notice to all of the individual clients of our brokerage firm and its affiliated entities. Further, the USA PATRIOT Act, which imposes Anti-Money Laundering Requirements on brokerage firms and financial institutions, requires that we ask you to provide us with various identification documents or other information in order for us to be permitted to open or maintain an account for you or to effect transactions for you. In addition, we may make inquiries of other organizations for information about you in order to fulfill our responsibilities under Federal regulations. The Information We Collect About You. The non-public personal information we collect about you (your “information”) comes primarily from the account applications or other forms you submit to us. We may also collect information about your transactions and experiences with us or our affiliates relating to the products or services we provide. In addition, depending upon the products or services you require, we may obtain information from consumer reporting agencies.

Our Disclosure Policies

We do not disclose your information to anyone, except as permitted by law and as required by clearing firms, transfer agents and issuers, as necessary to perform such clearing services in connection with your account. This may include sharing your information with non-affiliated companies that perform support services for your account or process your transactions with us. Additionally, it may include disclosing your information pursuant to your express consent, to fulfill your instructions, or to comply with applicable laws and regulations.

Our Information Security Policies

We limit access to your information to those of our employees and service providers who are involved in offering or administering the products or services that we offer. We maintain physical, electronic, and procedural safeguards that are designed to protect your information. If our relationship ends, we will continue to treat the information as described in this Privacy Notice. If you require further information please contact our Compliance Officer.

Customer Disclosure Statement
Pickwick Capital Partners, LLC

Pickwick Capital Partners, LLC plans to quickly recover and resume business operations after a significant business disruption (SBD) 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 company's business continuity plan (BCP) is designed to permit us to resume operations as quickly as possible, given the scope and severity of the SBD.

The BCP 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.

The product sponsor or issuer maintains all records related to your investments and account holdings and backs up important records in accordance with their business continuity plan. For more information on their contingency plan, please contact the sponsor or issuer directly at the telephone number provided on your offering documents or through their website.

Significant Business Disruptions: The Company's plan takes into account two kinds Significant Business Disruptions, internal and external. Internal SBDs affect only the Company's ability to communicate and do business, such as a fire or loss electrical power in the office or building.

External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a natural disaster, or another event that causes a wide-scale, regional disruption in essential services.

Internal SBDs: In the event of a disruption in the Company's business operations due an internal SBD, the Company will attempt to continue to conduct business as usual by utilizing alternate communications methods (if available), such as the internet, cell phones, etc., or by moving its operations to an alternative location.

If personnel or operations must be moved to an alternate location, the Company anticipates that it will resume regular operations within 2-4 hours.

External SBDs: In the event of a disruption in the Company's business operations due to an external SBD, the Company will attempt to continue to conduct business as usual by moving its operations to an alternative location outside the effected area, if possible, or by providing customers with alternative communication arrangements, as indicated below, to conduct business or to access their funds and securities.

The Company will attempt to resume business within 24-48 hours and to keep its customers informed regarding relevant events to the best of its ability based on the circumstances.

In all cases, the Company will resume normal business operations as soon as it is able to do so, based on the type and the extent of the disrupting event.

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.

Communications:

Primary Contact
Name: Douglas Greenwood
Address: 445 Hamilton Ave., Suite 1102, White Plains, NY 10601
Telephone: 914-220-5881
Email: greenwoodd@pickwickcapital.com

Secondary Contact
Name: David Danovitch
Address: 875 Third Avenue, 9th Fl., New York, NY 10022
Telephone: 212-603-6391
Email: ded@robinsonbrog.com

In the event you are unable to reach the Company at our main number or one of the contacts indicated above, please proceed as follows:

1. Contact the Company at the following alternate telephone number: 914-220-8334.

2. Access the Company's website at www.pickwickcapital.com

3. Contact the private placement issuer directly at the number listed on applicable offering documents.

4. Access the product sponsor or issuer website for more information on contacting this entity and their business continuity plans. The website address can generally be found on your statement or offering documents.

5. Contact the FINRA's District office at the following telephone number for more information on the company's status and additional instructions: 732-596-2000.

Contact information: Any questions regarding the Company's Business Continuity Plans should be addressed to: (Dawn Prommas, 445 Hamilton Ave., Suite 1102, White Plains, NY 10601, 914-220-5882).

 
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