Disclosure of SEC- Required Order Execution and Routing Information

Sanders Morris Harris Inc. (“SMH”) is a NASDAQ market maker. SEC Rule 605 (formerly SEC Rule 11Ac1-5) requires OTC market makers, exchange market makers, national securities exchanges, and others to make available monthly reports of statistical data regarding order execution for “covered orders” as defined under the Rule.

Please refer to SEC Rule 606 Reports below.

SEC Rule 605 Reports

April 2013: SMHI had no covered orders under SEC Reg. NMS, Rule 605 for this month.

SEC Rule 606 Reports

Pursuant to Rule 606 adopted by the Securities and Exchange Commission, SMH is presenting certain information with respect to orders executed during the preceding quarter. You can obtain this information by accessing the link below.

Please refer to:
Pershing Order Routing Disclosure (type “Sanders Morris Harris” in the search box.)
Sanders Morris Harris Inc(SMHI) Routing Disclosure

Please note that the vast majority of SMH’s customer trading activity is institutional in nature. Due to the size and trading strategies employed by these customers, most institutional orders are not subject to or relevant for Rule 605 or 606 reporting.

The SEC requires that the disclosure of a market center’s order execution information be made available free and readily accessible to the public via a web site.

• The Firm only transacts business in states where it is properly registered, or excluded or exempted from registration requirements.
• Past performance may not be indicative of future results.  Therefore, no current or prospective client should assume that the future performance of any specific investment, investment strategy (including the investments and/or investment strategies recommended and/or purchased by adviser), or product made reference to directly or indirectly on this Website, or indirectly via link to any unaffiliated third-party Website, will be profitable or equal to corresponding indicated performance levels.
• Different types of investment involve varying degrees of risk, and there can be no assurance that any specific investment will either be suitable or profitable for a client’s investment portfolio.  No client or prospective client should assume that any information presented and/or made available on this Website serves as the receipt of, or a substitute for personalized individual advice from the adviser or any other investment professional.

Historical performance results for investment indexes and/or categories generally do not reflect the deduction of transaction and/or custodial charges or the deduction of an investment-management fee, the incurrence of which would have the effect of decreasing historical performance results.

Reimbursements for Training, Education, and Marketing

As representatives of Sanders Morris Harris Inc., our financial advisors have the ability to build investment portfolios based on the specific needs and goals of each individual client. Sanders Morris Harris Inc. offers a wide variety of approved products and programs including stocks, bonds, options, mutual funds, annuities, life insurance, alternative investments, college savings plans, and asset management programs. Because there are hundreds of investment choices within this universe of approved products, Sanders Morris Harris Inc. may focus on a select group of companies that meet SMH’s due diligence criteria and assist Sanders Morris Harris Inc. in training, education and marketing. These product sponsors may have greater access to our advisors, if they are invited to market to, train and educate them on their products and industry related topics with the intent to better serve their mutual clients.

It is important to know that although the product sponsors pay some additional compensation to Sanders Morris Harris Inc. and/or its affiliates, clients do not pay more to purchase these products through Sanders Morris Harris Inc. than they would normally pay to purchase them through another broker/dealer. The payment of this additional compensation to Sanders Morris Harris Inc. by these product sponsors may pose a financial incentive for us to promote certain products over other products, although we believe that these arrangements do not compromise the advice your advisor provides to you.

Sanders Morris Harris Inc. is providing the following information to help you better understand the potential conflicts of interests regarding compensation that Sanders Morris Harris Inc. receives from the product sponsors whose investments we offer to you.

The additional amounts that these product sponsors pay Sanders Morris Harris Inc. vary from one sponsor to another and from one product to another.

Companies may at times send Sanders Morris Harris Inc. payments in recognition of our sales and marketing efforts, and may have additional opportunities to provide marketing services to our advisors. In addition, companies may pay marketing allowances to Sanders Morris Harris Inc. in connection with the sale of certain products and for training and educational meetings for our advisors. Product sponsors and other companies may reimburse up to 100 percent of the cost of due diligence, training and education/joint marketing meetings for our advisors, as permitted by industry rules. Sales of any products by Sanders Morris Harris Inc. advisors may qualify them for additional cash and non-cash compensation that may include support for their business activities, attendance at seminars, conferences and entertainment. Additionally, some investments, whether they are issued by a product sponsor or not, may pay higher rates of compensation than others (for example, commissions on equities are usually greater than those on bonds, and private placement offerings generally carry higher commissions than investments in publicly traded securities).

Sanders Morris Harris Inc. has in the past received compensation from:

KBS Real Estate
Inland Real Estate
Jackson National Insurance
Kensington Real Estate
Mewbourne Oil
Pacific Life
Salient Partners
Behringer Harvard Real Estate
Hines Real Estate
Dunham Funds
Pershing
Man Investments
Dempsey & Associates
Oppenheimer
American Funds
Prudential
Dividend Capital
Inland Investments
DBSI Group
John Hancock
DWS Scudder
Fidelity
Argus Realty
AIG SunAmerica