Compliance

Under Rule 11Ac1-6 as adopted, broker-dealers that route orders on behalf of customers are required to prepare quarterly reports that disclose the identity of the venues to which orders are routed for execution. The reports also disclose the nature of the broker-dealer’s relationship with those venues, including the existence of any internalization or payment for order flow arrangements. Finally, broker-dealers are required to disclose, on customer request, where they routed a customer’s individual orders for execution.

Business Continuity Plan

In the event of a Significant Business Disruption (SBD) that is internal (only relates to Garrett Nagle & Co., Inc.’s office) or external (an event that could be regional, national and prevents the operation of securities markets, affects a number of firms…like a terrorist attack, flooding, etc..) we will attempt to contact our customers as quickly as possible. We will utilize whatever communication vehicles are available to us depending upon the severity of the SBD. Our clearing firm, National Financial Services LLC also has a BCP in place to facilitate the operations of its customers, like Garrett Nagle & Co., Inc.

Garrett Nagle & Co., Inc. will continue to be the conduit between our clients and the clearing firm for communications, trades and check requests. The facilitating process may change but the client will still have access to their securities and funds in their accounts.
In the event that we are unable to process orders from our office or our relocated site the client will be directed on how we will proceed with the clearing firm.

We should be able to set-up at the new temporary location and be fully operational within 48 hours for trading and processing check requests. These items can also be expedited by us by phone to our clearing firm as we get up to speed. During that time frame we will be attempting to contact all clients to keep them informed of our status and how to stay in contact with us.
This BCP will be reviewed annually or more frequently if deemed necessary. It will be updated when changes occur as a result of these reviews. All clients will receive a copy of this summary at the time of account opening and annually coupled with our privacy statement. It can also be obtained by mail upon request.

Our BCP will be reviewed annually by our executive representative and updated as needed. The review will encompass any changes in our operations, business structure, business niche and location and any changes with our clearing firm relationship.

I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD.

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Founded in 1976, Garrett Nagle & Company is a boutique investment management firm specializing in managing portfolios for high net worth individuals and institutions. Based in Woburn, Massachusetts, our portfolios are separately managed and customized according to each client’s individual risk tolerance and return objectives. The firm is a Registered Investment Advisor with the SEC.

Founded in 1976, Garrett Nagle & Company is a boutique investment management firm specializing in managing portfolios for high net worth individuals and institutions.

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