SEC Rule 605 and 606    FINRA Rule 2124    Customer Identification Program    Business Continuity Planning

FINRA Rule 2124 (Net Trading)

At Puma Capital, LLC (“PUMA” or “Firm”), we give the highest priority to seeking the best quality execution of customer orders, taking into consideration all of our customer’s specific needs. This letter is being provided to you to clarify certain terms and conditions governing the execution of your orders in equity securities that are handled by PUMA.

Orders received by Puma Capital that are “not held” are not subject to the SEC Order Handling Rules. PUMA may execute certain “not held” orders on a net basis. Additionally, trades may be confirmed at an average price when multiple executions are required to complete the “not held” order. Trades will be executed on a net basis with the following understanding:

A “net” transaction is one in which we, after having received your order to buy (sell) a security, buy (sell) the security at one price from (to) another party and then sell to (buy from) you at a different price, with the difference representing the firm’s compensation for executing the transaction.

If the preceding statement is not consistent with your desire for PUMA executing certain orders on a net basis, please notify PUMA Sales/Traders at the time you place your order that you do not wish for your order to be transacted on a “net” basis, or you may email If you do not object, PUMA may reasonably conclude that you have consented to trading on a “net” basis pursuant to FINRA Rule 2124.

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