IMPORTANT LEGAL INFORMATION

Business Continuity Plan

Rockefeller Capital Management has developed a Business Continuity Plan to manage and mitigate the impact of events that have the potential to cause significant business disruption. Since the timing and impact of disasters and disruptions is unpredictable, the Business Continuity Plan needs to be flexible in responding to actual events as they transpire. Consequently, the Business Continuity Plan is designed to enable us to recover and return to business operations as quickly as possible.

 

We believe that we have implemented reasonable measures to quickly resume business operations after a significant business disruption and safeguard our employees, property, and books and records. The Business Continuity Plan addresses data backup and recovery, all mission critical systems, financial and operational assessments, alternative communications with customers, employees, and regulators, alternate physical locations for our employees, critical supplier, bank, and counter-party impact, and regulatory reporting requirements. 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 clearing firm, National Financial Services, LLC, 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 as soon as practicable. Your orders and requests for funds and securities could be delayed during this period.

 

Significant business disruptions can vary in their scope, such as affecting 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. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area and recover and resume business as soon as practicable. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our website (www.rockco.com), or our main number, (212) 549-5100. 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.

 

For more information – If you have questions about our business continuity planning, you can contact us at (212) 549-5100 or e-mail us at info@rockco.com.

 

Legal Entity Disclosure

Rockefeller Capital Management is the marketing name for Rockefeller Capital Management L.P. and its affiliates. Investment advisory and fiduciary activities are performed by the following affiliates of Rockefeller Capital Management: Rockefeller & Co. LLC, Rockefeller Trust Company, N.A. and The Rockefeller Trust Company (Delaware). Rockefeller Asset Management and Rockefeller Global Family Office are divisions of Rockefeller & Co. LLC. Rockefeller Financial LLC is dually registered as a broker dealer and registered investment adviser with the US Securities Exchange Commission, Member FINRA and SIPC.

You may find information on the background of Rockefeller Financial LLC and its financial professionals on FINRA’s BrokerCheck website: http://brokercheck.finra.org/.

Investing involves risk, including the possible loss of principal. Past performance is no guarantee of future results and no investment or financial planning strategy can guarantee profit or protection.

Neither Rockefeller Capital Management or its financial advisors provide legal, tax nor accounting advice to clients. Please consult your own legal and/or tax advisors in connection with financial decisions.

Notice to Canadian Clients

Routing and Execution Disclosures Made Pursuant to Rule of SEC Regulation NMS

Rule 606 of SEC Regulation NMS requires broker-dealers receiving non-directed client orders to publicly disclose, on a quarterly basis, the top execution venues to which such orders are routed for execution. In addition, broker-dealers must disclose material aspects of the relationships they maintain with the identified execution venues.   Rockefeller Financial LLC client orders in NMS securities are executed by and through its fully disclosed clearing and custodial firm, National Financial LLC (member NYSE\SIPC).

The Rule 606 statistics for Rockefeller Financial LLC is available for public review by clicking here.

Disclaimer.  Rockefeller Financial LLC and its affiliates do not represent, warrant, or guarantee that the Reports are accurate. Rockefeller disclaims liability for any direct, indirect, punitive, special, consequential, or incidental damages related to the Reports or the use of the Reports. The information provided in the Reports may be impacted by market data system outages or errors, both internal and external, and it is dependent upon the integrity and accuracy of data provided by outside sources. Certain assumptions have been made in preparing the Reports, and changes to the assumptions may have a material impact on results. The Reports do not endorse or recommend any particular security or market participant.

This disclaimer applies to the Reports in their entirety, irrespective of whether the Reports are used or viewed in whole or in part, and may be reviewed at any time by accessing the “Disclaimer” posted on the web page where the Reports are made available.

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