Privacy Policy and Other Important Disclosures - For Our Customers.

Portsmouth Financial is pleased to welcome you as a new customer. We look forward to working with you and would like to take this opportunity to provide you with some information about the account you are opening.

Anti-Money Laundering and the Patriot Act. To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for our customers...when you open an account with Portsmouth, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. Failure to disclose all information requested may result in a delay or denial in opening your new account. Please be advised that our request for information is required under Federal Law.

Portsmouth Financial Privacy Policy. Portsmouth recognizes the importance of protecting your privacy and has established policies designed to safeguard your confidential information. These have been established in addition to the policies of Pershing, our clearing corporation, as outlined annually on the September account statements. You will be provided with a copy of our privacy policy and other important disclosures upon opening your account with Portsmouth Financial. Additional information regarding these disclosures can also be found on the account statements and on our website www.portsmouthfinancial.com. Portsmouth does not sell your personal information to anyone. Access to your personal information is restricted to those employees and agents who need the information to provide the products and services you have selected. We collect personal information about our customers from applications or other forms, such as name, address, social security number, assets and income. We do not share your information with anyone except as required or permitted by law or as implicitly authorized by you. We will not release information about our customers or former customers to anyone, except as permitted by law. We will not release information about our customers or former customers unless we receive your prior written consent, we believe the recipient to be you or your authorized representative or we are required by law to release the information. Your securities account is carried by our clearing firm, Pershing LLC, pursuant to a clearing agreement. We may disclose all the information we collect regarding your account to Pershing in accordance with our clearing arrangement. Pershing is contractually obligated to keep the information that we provide them confidential and use the information only for the services required and as allowed by applicable law or regulation as outlined in their Privacy Policy. Pershing carries your account and acts as your custodian for funds and securities deposited with us directly by you or as a result of transactions we process for your account. Inquiries concerning the position and balances in your account may be directed to Pershing Client Services Department at 201-413-2000. All other inquiries regarding your account or the activity therein should be directed to Portsmouth at any of our office phone numbers listed in this brochure. Please contact Portsmouth Financial or your representative if you identify any error with your accounts or if you have any questions concerning the use and maintenance of your confidential information at 415-543-8500 or 800-443-2227. Portsmouth Financial also publishes its privacy policy on each monthly customer account statement. If your account has a zero balance during the year and no quarterly statement is provided to you, we may provide you our privacy policy under separate cover. Please contact Portsmouth or your representative if you identify any error with your accounts or if you have any questions concerning the use and maintenance of your confidential information.

Margin Accounts. Securities purchased on margin are Portsmouth’s and Pershing’s collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan. As a result, Portsmouth or Pershing can take action, such as issue a margin call and/or sell securities or other assets in any of your accounts held with Pershing in order to maintain the required equity in your account. It is important that you fully understand the risks involved in trading securities on margin. Please be aware of the following facts about margin accounts. You can lose more funds than you deposit in your margin account. Portsmouth Financial or Pershing can force the sale of securities or other assets in you account(s) and can do so without contacting you. You are not entitled to choose which securities or other assets in you account(s) are liquidated or sold to meet a margin account. The “house” maintenance margin requirements can increase at anytime without prior advance written notice and you are not entitled to an extension of time on a margin call.

Payment for Order Flow Sec Rule 11Ac1-3 and SEC Rule 606. Portsmouth does not receive compensation for directing order flow. For additional information regarding our order routing practices and the venues to which orders are routed, you may visit www.orderroutingdisclosure.com. Enter our full name in the box when prompted, Portsmouth Financial Services. Upon written request you may obtain the identity of the venue to which your orders are routed for the six months prior to your request and the time of transactions that may have resulted from such orders. You may see the TERMS AND CONDITIONS section of your account statements for a description of Pershing’s payment for order flow practices.

FINRA Public Disclosure Rule 2267. The Financial Industry Regulatory Authority (FINRA) requires Portsmouth Financial, as a FINRA member, to provide to you the following information concerning the FINRA Public Disclosure Program. The FINRA Public Disclosure Hotline is 800-289-9999. The FINRA Regulation Web Site address is www.finra.org. An Investor brochure that includes information describing the public disclosure program may be obtained from FINRA.

Business Continuity Plan. Portsmouth Financial has developed a Business Continuity Plan (BCP) on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan. We plan to quickly recover and resume business operations after a significant business disruption 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 business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan 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.

Our clearing firm, Pershing LLC, a subsidiary of The Bank of New York Mellon Corporation, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within 4 hours. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions. Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. if there is a significant disruption to our main office, we will transfer our operations to another location. If there is a disruption affecting our main San Francisco office, we will post instructions at our voicemail emergency number, 877-841-4436. 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 through Pershing LLC.
Detailed instructions can be found at
http://www.pershing.com/business_continuity.html#business.

Contacting Us – If after a significant business disruption you cannot contact us as you usually do at 415-543-8500/800-443-2227 in our San Francisco office, you should call our alternative number 877-841-4436 where you can hear a message from our firm and be able to also leave a message. If you cannot access us through any of these phone numbers, you should contact our clearing firm, Pershing LLC at 201-413-3635 for recorded instructions or visit www.pershing.com. If you cannot access the instructions from the website or previously noted telephone number, Pershing may be contacted at 213-624-6100 extension 500 as an alternate telephone number for recorded instructions. All Pershing operational facilities are equipped for resumption of business and are tested several times per year. Pershing's recovery time objective for business resumption, including those involving a relocation of personnel or technology, is four (4) hours. This recovery objective may be negatively affected by the unavailability of external resources and circumstances beyond our control. In the event that Portsmouth experiences a significant business interruption, you may contact Pershing directly to process limited trade-related transactions, cash disbursements, and security transfers. Instructions to Pershing must be in writing and transmitted via facsimile at (201) 413-5368 or by postal service as follows: Pershing LLC, P.O. Box 2065, Jersey City, New Jersey 07303-2065. For detailed instructions in the event of a significant business disruption, go to www.pershing.com to view details on prompt access to funds and securities, instructions to enter orders and process other trade-related, cash, and security transfer transactions. If you have questions about our business continuity plan, you can contact us at 800-443-2227. Our Business Continuity Plan will be reviewed annually and updated to include any changes when necessary.

SIPC - Information regarding the Securities Investor Protection Corporation (SIPC), including a SIPC brochure, may be obtained by contacting SIPC via its website at www.sipc.org or by calling 202-371-8300.

Compliance Department. At Portsmouth Financial, we strive to provide quality service to our customers at all times. In the event you may wish to contact us for any reason our phone numbers are 415-543-8500 or 800-443-2227. Complaints of any nature may be forwarded to: PORTSMOUTH FINANCIAL SERVICES, ATTN: COMPLIANCE DEPARTMENT, 625 MARKET ST., 7TH FLOOR, SAN FRANCISCO, CA 94105 OR CALL 415-543-8500. If you wish to contact us by email, our address is: operations@portsmouthfinancial.com

This site has been designed for informational purposes only and does not constitute an offer to sell or a solicitation of an offer to buy any security that may be referenced on this site. Such offers can only be made where lawful under applicable law. The accuracy, completeness and timeliness of the information contained on this site cannot be guaranteed. Portsmouth Financial does not warranty, guarantee or make any representations or make any implied or express warranty or assume any liability with regard to the use of any information on this site. Portsmouth Financial is not liable for any harm caused by the transmission through accessing the services or information on this site, of a computer virus, or other computer code or programming device that might be used to access, delete, damage, disable, disrupt, or otherwise impede in any manner, the operation of the site or of any users software, hardware, data or property. This use of this site is at your own risk. Portsmouth will attempt to ensure that the information contained on our website is updated but does not guarantee nor have the duty or obligation to update or correct information on this site. Except as may be expressly authorized, all information on this website may not be reproduced, transmitted, displayed, distributed, copied, or otherwise commercially exploited without the written consent of Portsmouth Financial.