SEC Required Order Disclosures

Quarterly reports regarding Pacific American Securities, LLC's Order Routing information in accordance with SEC rule 606 can be obtained in writing by contacting our offices or via the internet at www.marketsystems.com . Currently, Pacific American Securities, LLC is exempt from SEC rule 605, Order Execution.




Business Continuity - Disaster Recovery Plan


Pacific American Securities, LLC will forward a copy of our Business Continuity - Disaster Recovery Plan to our clients upon written request.

Please forward your request to:

Pacific American Securities, LLC
9191 Towne Centre Drive,Suite 406
San Diego, CA 92122

Attention: Compliance Department



Bank Disclosures


Products are not insured by the FDIC.

Products are not bank deposits or other obligations of the Bank and are not guaranteed by the Bank.

Products are subject to investment risks, including possible loss of principal invested.



Pacific American Securities, LLC Investment Protection Principles


On July 30, 2002, Pacific American Securities, LLC adopted the Investment Protection Principals set forth by the State Treasurer of California, the State Treasurer of North Carolina, and the Comptroller of New York State.

Our principles are as follows:

  • While PAS provides research on the Tech industry, we are not engaged in Investment Banking.

  • The President and Chief Compliance Officer review and approve all research recommendations.

  • Upon discontinuation of research coverage of a company, we will disclose the coverage termination and the rationale for such termination.

  • We will disclose, in research reports, whether the firm has received or is entitled to receive any compensation from a coverage company over the past 12 months.

  • PAS has established a monitoring process to ensure compliance with the principles.

If you have any questions or require additional information, please contact our offices at (858) 320-2850.



Pacific American Securities Research Disclosures

Analyst Certification:
I, Michael D. Cohen, hereby certify (1) that the views and opinions expressed in PAS research reports accurately reflect my personal views and opinions about any or all of the subject securities or issuers referred to in our reports, and (2) no part of my compensation was, is, or will be directly or indirectly related to the specific recommendations, views, or opinions expressed in our reports outside of any personal investments made in the securities of companies that are the subjects of our research.

Important Disclosures:
The information and opinions in PAS reports were prepared by the research department of Pacific American Securities, LLC (PAS). These reports are based upon information available to the public. The information in our reports is believed to be reliable and has been obtained from sources we believe to be reliable. PAS makes no representation as to the accuracy or completeness of such information and independent verification of information is encouraged.

PAS has no current investment banking interests in companies subject to its research. However, the officers, directors and/or employees of PAS may directly hold long or short positions in the securities, options thereon or other related financial products of companies discussed in any PAS research report. PAS maintains ethical procedures and blackout periods to prevent its employees, officers, directors or other related parties from trading ahead of research. The Director of Research for PAS does directly own common shares of many companies covered in PAS research reports; however, positions are entered into at least 30 days prior to the planned publication of any related report. For more detailed and timely disclosures of relevant holding information, please refer to the disclosure page on any individual PAS Coverage Report.

Companies covered by the research of Pacific American Securities are not chosen randomly. So readers should not necessarily expect an even distribution of recommendations across Buy, Hold and Sell categories. PAS chooses its coverage companies to provide investment ideas among companies that its research department believes would be interesting to its client base. These companies are chosen to provide representation among small-, mid- and large-cap companies, and also to provide variety among the various sub-sectors within the information technology industry. For the purpose of compliance with NASD rule #2711, PAS considers its Buy and Accumulate ratings to fall within the "Buy" category. PAS does not issue any "Hold" ratings, and PAS considers its Sell and Decrease ratings to fall within the "Sell" category. For a timely and accurate breakdown of the percentages of PAS ratings falling into these three categories, please refer to the disclosure page on any individual PAS Coverage Report.

Opinions, estimates and projections in PAS research reports constitute the judgment of PAS and are subject to change without notice. Prices and availability of financial instruments also are subject to change without notice. PAS reports are provided for informational purposes only. They are not to be construed as an offer to buy or sell or a solicitation of an offer to buy or sell any financial instruments or to participate in any particular trading strategy in any jurisdiction in which such an offer or solicitation would violate applicable laws or regulations.

The financial instruments discussed in PAS research reports may not be suitable for all investors, and investors must make their own investment decisions using their own independent judgment or advisors as they believe necessary and based upon their specific financial situations and investment objectives. Securities of information technology companies can be extremely risky. Security prices in this sector tend to be much more volatile than those in other industries. Accordingly, the price or value of financial instruments described in PAS reports, either directly or indirectly, may rise or fall. Furthermore, past performance is not necessarily indicative of future results.

PAS reports are only authorized for distribution to institutional investors in the United States of America. In the U.S., PAS reports are approved and/or distributed by Pacific American Securities, LLC.

Pacific American Securities, LLC is a member of FINRA, SIPC, MSRB and SIA.

No part of any PAS research material may be copied or duplicated in any form or by any means, or redistributed, without the prior written consent of Pacific American Securities, LLC.
Copyright 2003, Pacific American Securities, LLC., All Rights Reserved.

Copyright © 2008, Pacific American Securities, LLC., All Rights Reserved