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.
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