Girard Securities, Inc.

Order Flow Routing

SEC Rule 11Ac1-3 and 11Ac1-6

Girard Securities, Inc. may route client orders for execution to market centers or through automated order entry systems on primary exchanges. These market centers may include dealers who make markets in these securities. Girard may be paid compensation for routing orders to dealers and does receive credits for exchange transaction fees through the use of automated order entry systems.

Girard makes order routing decisions based on a number of reasons including the size of the order, the opportunity for price improvement and the quality of order executions. All client orders are executed in a manner consistent with best execution.

Upon the written request of a customer, Girard will disclose the identity of the venue to which the customer’s orders were routed for execution in the six months prior to the request, whether the orders were directed orders or non-directed orders, and the time of the transactions, if any, that resulted from such orders.

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