Disclosure of SEC Required Order Execution and Order Routing Information

Report of Raymond James & Associates, Inc. with respect to orders in National Market System securities

Absent specific routing instructions from the client, the Raymond James & Associates, Inc. (RJA) policy is to route orders to the market center or designated broker-dealer intermediary where it believes that the client receives the best execution, based on a number of factors. Eligible orders (orders from non-managed and non-discretionary accounts, each an “eligible order”) will initially be directed to another broker-dealer to access a third-party Alternative Trading System (“ATS”) where the eligible order(s) will have an opportunity to trade with RJA institutional order flow, if such exists, using strategies targeting at or better than the national best bid or offer (often referred to as the NBBO) pricing. If no match occurs within that ATS between the eligible order(s) and the RJA institutional client order flow, the eligible order(s) will then be routed to other market centers for execution. Consistent with its obligation to provide best execution, RJA has implemented policies and procedures that continually review its order routing determinations and mitigate conflicts of interest relating to payment for order flow, trading profits and/or other forms of remuneration.

RJA trades National Market System securities as a market-maker in the over-the-counter market. Pursuant to Rule 605 adopted by the Securities and Exchange Commission, RJA is presenting certain information with respect to orders executed as market maker in the over-the-counter market during the preceding month. You can obtain this information by accessing the link below.

For information regarding RJA’s Nasdaq Principal Trading operation please refer to: https://www.fisglobal.com/ptc/rule-605 and select the downloadable Raymond James and Associates file.

The SEC requires that the disclosure of a market center’s order execution information be made available in an electronic data file, standard, pipe delimited, ASCII format and compressed using standard ZIP compression.

To effectively download and open RJA’s order execution information, installation of a zip utility program such as WinZip (www.winzip.com) will be required.

To help you understand this information, please refer to the sample data available on the SEC website at www.sec.gov/interps/legal/slbim12b.htm.

Raymond James & Associates, Inc. (RJA) also acts in an agency capacity for client orders in equity and option securities. Pursuant to Rule 606 adopted by the Securities and Exchange Commission, RJA is presenting certain information with respect to order routing practices by the firm during the preceding three months. You can obtain this information by accessing the link below.

If you have any questions regarding this information for listed (exchange-traded) or OTC-traded securities, you may contact John Cardinali at 212-856-4396.