SEC Rules Regarding Disclosure of Order Execution and Routing Practices

Rule 605 (Monthly Report)

This rule requires "market centers" that trade national market system securities and exchange listed securities to make publicly available monthly statistical information about order executions as defined by the rule. Murphy & Durieu is a FINRA member firm and therefore considered a "market center."

Rule 605 is intended to promote visibility and competition in order executions which include factors such as effective spread, price improvement and disimprovement, fill rate and execution speed.

Each market center is required to prepare and make publicly available monthly reports in electronic form. Murphy & Durieu's report can be accessed, at no charge, from SunGard Valdi at http://www.sungard.com/valdicompliance.

Rule 606 (Quarterly Report)

This rule requires broker/dealers that route orders in equity and option securities to disclose the identifies of the execution venues to which they route orders on behalf of customers.

Each routing broker/dealer is required to provide information on the routing of "non-directed orders" - any order that the client has no specifically instructed to be routed to a particular venue or market center for execution. For these non-directed Murphy & Durieu has selected the execution venue on behalf of its clients.

This report can be accessed, at no charge, from SunGard Valdi at http://www.sungard.com/valdicompliance.

New York Stock Exchange Rule 108(a) Customer Disclosure

New York Stock Exchange Rule 108(a) permits the specialist on the Floor to trade at parity with orders in the Crowd when either establishing or increasing a stock position unless objected to at the time the order is entered.

This rule only applies to orders handled by the Firm's brokers on the New York Stock Exchange trading floor.

If you chose to object to permitting this, either in all instances or only on specific orders, you must notify your broker at Murphy & Durieu at the time the order is entered.

New York Stock Exchange Rule 446(d) Business Continuity Disclosure

Murphy & Durieu has developed a Business Continuity Plan 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.

Contacting Us — If after a significant business disruption you cannot contact us as you usually do at 212-618-0900, you should call our alternative number 732-741-1700 [or go to our web site at http://www.murphy.com/]. If you cannot access us through either of those means, you should contact our clearing firm, Penson Financial Services, Inc., at 888-836-6798.

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, Penson Financial Services, Inc., 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 four 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. 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 within 4 hours. 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 within 4 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site or our customer emergency number, how to contact us. 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 212-618-0900.


Valid HTML 4.01
  Transitional