FERRETTI GROUP, INC.

40 WALL STREET, SUITE 1704
NEW YORK, NY. 10005

NYSE Rule 108

Please consider this notification pursuant to New York Stock Exchange Rule 108.  It is the general policy of Ferretti Group, Inc. to allow specialists to trade on parity with a customer order for some or all of the executions entered into to fill the customer order, provided that our execution is consistent with the firm’s best execution obligations.  Unless we receive a duly executed letter from your firm objecting to this policy, executions on your behalf will be consistent with this policy.

SEC Rule 606

Industry regulations require that Ferretti disclose the identity of the market centers to which Ferretti routes orders for certain equity securities, as well as the nature of relationships to those market centers.  Ferretti executes only on exchanges that are Regulation NMS compliant.  If you would like a written copy of this information please contact Ferretti.  This report is available from Abel Noser.                                

SEC RULE 607

Pursuant to SEC Rule 607(a), we are making the following disclosure to each of our customers, “in writing, upon opening a new account and on an annual basis thereafter”:

Ferretti Group, Inc. does not receive payment for order flow to direct securities orders to a particular venue, absent specific instructions from the customers regarding where to route an order.  Ferretti Group, Inc. will use its brokerage judgment that includes but is not limited to price, the opportunity for price improvement, available liquidity, and the speed of execution to determine where to route a particular order.

While Ferretti Group, Inc. does not receive payment for order flow, the certain market centers provide rebates or other payments for providing liquidity and charge fees for taking liquidity.  Therefore, for any given order or any given time period Ferretti Group, Inc. may be either charged fees or receive rebates from a particular execution venue.